There is evidence that the company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's CEO.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes a clear anti-bribery and corruption policy, which specifically prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that this policy clearly applies to all employees and board members as listed in (a) and (b) in the question.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that a designated board committee \u2013 the Corporate Responsibility Committee \u2013 is responsible for oversight of the company\u00b4s anti-bribery and corruption programme. There is evidence to indicate that the committee\u2019s role includes reviewing reports from management on the programme\u2019s performance, and that it has the authority to require that any necessary changes to the programme are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is evidence that the Group Company Secretary has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. There is evidence of reporting activity between this individual and the board as part of the company\u00b4s reporting structure. The company indicates that the Group Company Secretary acts as the secretary of the Corporate Responsibility Committee, which reports on its activities to the Board after each meeting. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has an enterprise risk management process in place that includes reviews of bribery and corruption risk. There is evidence that the results of these assessments are reviewed by the board on an annual basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption programme. The company indicates that it updated its approach to commercial intermediaries as part of a risk management plan, however it is not clear that the results of risk assessments are used to update the company\u2019s anti-corruption initiatives as a whole. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption programme is subject to a regular audit process. This includes provisions for continuous improvement, supplemented by internal and external audits. There is also evidence that all findings are presented to the Audit Committee, with ownership assigned to units for planned updates and improvements to the anti-bribery and corruption programme. In addition, the company indicates that it conducts internal and external audits on a rolling basis based on an assessment of risk. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company commits to investigating incidents and that it has a specific procedure in place to deal with whistleblowing cases. There is evidence indicating that investigations are handled by an independent team and that the company publicly commits to providing whistleblowers with updates on the outcomes of investigations. There is also evidence that the Corporate Responsibility Committee receives all information on significant ethics violations and that this information is communicated to the board after each meeting, at least twice a year. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide any further publicly available information on the whole investigation process from receipt to final outcome, including documentation and actions to be taken at each step. <\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company assures itself of the quality of its internal investigations. There is evidence that the Corporate Responsibility Committee reviews the company\u2019s investigations procedure and that the Company Secretariat conducts a continuous review of the quality of investigations.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it has a procedure in place to receive and handle complaints about the investigation process. There is also no clear evidence that staff conducting investigations are properly trained and qualified to perform their function. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company commits to report material findings of bribery and corruption from investigations to the board-level Corporate Responsibility Committee. There is evidence that the company commits to report material findings of bribery and corruption from investigations to the relevant authorities, where necessary, and indicates that the chair of the Corporate Responsibility Committee, with oversight from the board, would be responsible for this process.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption investigations or disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training for its employees that outlines the basic principles of its anti-bribery and corruption policy, including the whistleblowing options available. There is also evidence that it provides this training on an annual basis to all employees across all divisions and countries of operation. In addition, the company indicates that it provides training in multiple languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides tailored anti-corruption training to employees based on their role or exposure to corruption risk. The company states that all board members and directors must undertake anti-corruption training, and indicates that employees working with third parties receive training on preventing corruption. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it provides tailored anti-corruption training to middle management. The company indicates that tailored training is delivered at specific sites, but it is not clear which employees this applies to or whether the selection is based on an assessment of corruption risk. There is also no evidence that employees in high risk positions must refresh their training on an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company indicates that it has a system in place to conduct employee engagement surveys on an annual basis, which include questions on ethics, communications and training. In addition, there is evidence to indicate that the results are used to update specific parts of the company's anti-bribery and corruption initiatives. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company\u2019s incentive schemes for employees incorporate ethical principles. The company indicates that annual salary evaluations take into account personal performance and that all employees set annual objectives in line with the company\u2019s values and culture. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on how its incentives are designed or how they reward ethical behavior while discouraging corrupt practices. There is no evidence that the company ensures such rewards are proportionate to base salary, nor is there evidence that it addresses employees in high risk positions or departments. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
The company publishes a clear statement that it will support and protect employees who choose to \u201cdo the right thing\u201d and indicates that this approach informs all areas of the business. However, the company receives a score of \u20181\u2019 because there is no evidence that it assures itself of its employees\u2019 confidence in this statement through anonymised surveys or other clearly stated means.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence the company promotes a policy of non-retaliation against whistleblowers and employees who report bribery and corruption incidents. The company indicates that this applies to all employees, and since this commitment appears in global policies it is understood to apply to employees of suppliers and third parties. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides whistleblowing and advice channels for its employees to report instances of suspected corrupt activity and seek advice on its anti-bribery and corruption programme. The company indicates that these channels are sufficiently varied to allow the employee to raise concerns across the management chain, as well as externally to an independent third party. These chanels allow for anonymous and confidential reporting, and they are available to all employees in all relevant countries and in multiple languages. The company indicates that this applies to all employees, and since this commitment appears in global policies it is understood to apply to employees of suppliers and third parties.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a formal policy which defines conflicts of interest, including actual, potential and perceived conflicts. The company\u2019s policy clearly addresses possible conflicts arising from employee relationships, financial interests and other employment. The policy applies to all employees and board members.<\/p>\n
However, there is no clear evidence that the company\u2019s policy addresses possible conflicts arising from government relationships. It is noted that the company references a document with specific standards of business conduct for those working on United States government contracts; but this does not appear to be available in the public domain and it is not clear that this would apply Group-wide.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is some evidence the company has procedures to identify, declare and manage conflicts of interest. The company states that it conducts an annual conflict of interest survey to identify any actual or potential conflicts, and there is evidence that it maintains a conflict of interest register for board members. The company indicates that disciplinary measures will apply if the company\u2019s policy is breached.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it has a conflict of interest register in place for employee declarations; the company\u2019s publicly available information indicates that its register is specifically for conflicts relating to the board. In addition, it is not clear from publicly available information which individual or body holds oversight and accountability for handling all conflict of interest cases.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a policy regulating the employment of current or former public officials.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company publishes details of the contracted services of serving politicians. <\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publishes a clear statement that it does not make corporate political contributions. The company states that it does not make financial or in kind contributions to political parties, campaigns or organisations, and indicates that this applies to all businesses worldwide.<\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company states that it does not make political contributions under any circumstances and therefore it is exempt from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on charitable donations and sponsorships to ensure that such contributions are not used as vehicles for bribery and corruption. In addition, the company\u2019s policy includes criteria for donations and sign-off from the Group Communications Director or Group Company Secretary. The company indicates that Corporate Responsibility Committee provdies overisght of this policy. <\/p>\n
However, the company receives a score of \u20191\u2019 because there is no evidence that it publishes full details of all charitable contribtions made, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company that the company has a policy on lobbying, which applies to all employees, board members and third parties engaged in lobbying activities on the company\u2019s behalf. The company states that all lobbying activities are overseen by its legal department. <\/p>\n
However, there is no evidence that the company publishes further information such as guidelines or standards of conduct for all types of lobbyists which would constitute a responsible approach to lobbying. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality. This policy recognises the possible corruption and bribery risks associated with gifts and hospitality, and stipulates that employees may only accept such promotional expenses when they are of nominal value. There is evidence that all gifts and hospitality given or received are recorded in a dedicated central register that is regularly audited and accessible to those responsible for oversight of the process. Although the company does not provide financial limits for gifts and hospitality, there is sufficient evidence that only nominal gifts may be accepted, so the company receives a score of \u20182\u2019.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s procurement department is the main body responsible for oversight of the company\u2019s supplier base. It is clear that this function is responsible for onboarding, managing and ensuring compliance of all suppliers.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that the company assures itself that its procurement department is appropriately functioning and involved in all supplier management at least every three years. <\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company conducts anti-bribery and corruption due diligence on all suppliers. The company indicates that it conducts due diligence on commercial arrangements, but it does not provide any further publicly available information on its procedures. For example, there is no evidence that such checks include establishing the beneficial ownership of the supplier, nor that high risk suppliers are subject to enhanced due diligence or that such checks are undertaken frequently. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company requires suppliers to follow its Code of Conduct, Anti-Corruption Policy and other Group policies, all of which prohibit bribery and facilitation payments and address conflicts of interest, gifts & hospitality and whistleblowing. The company also indicates that suppliers may implement their own equivalent standards. There is evidence that the company conducts audits of its suppliers. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company conducts assurance when onboarding new suppliers and when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. The company has procedures in place to ensure this, in the form of a contractual commitment.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption related investigations or the disciplinary actions involving its suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a policy on the use of agents, which address the corruption risks associated with their use and provide details of specific controls to mitigate these risks. The company states that it has decided not to appoint any new sales representatives nor to renew existing agreements other than in exceptional circumstances. There is evidence the policy applies to all divisions within the organisation which might employ agents or intermediaries.<\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging with its third parties and agents. There is evidence that agents and the highest risk intermediaries are subject to enhanced due diligence, and the company indicates such checks are repeated at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company seeks to establish the ownership of agents and intermediaries. However, there is no clear evidence that the company commits to independently verify beneficial ownership information of high risk agents, nor that it commits to not engage or terminate its engagement with intermediaries if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on its behalf. The company indicates that all sales representatives receive and must follow its Code of Conduct and Anti-Corruption Policy. In addition, there is evidence that the company has provisions to conduct audits on intermediaries. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that its contracts with agents and intermediaries include clear anti-bribery and corruption clauses, which include termination rights. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that incentive structures for agents are highlighted as a factor in bribery and corruption risk. The company indicates that its remuneration usually accords to a percentage of sales, and there is some evidence that it requires further review if a sales representative requests a commission payment. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information o its specific controls to mitigate bribery and corruption risks in agent incentives. There is no clear evidence that the company imposes a threshold on the payment of sales commissions to agents, nor that remuneration is paid in stage payments or into local bank accounts.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any details of the agents currently contracted to act for or and on behalf of the company. It is noted that the company states that it is taking steps to reduce its number of intermediaries and indicates that it will not enter into new agreements.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption-related investigations, incidents or disciplinary actions involving its agents. <\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into joint ventures. <\/p>\n
However, there is no further publicly available evidence to suggest that its due diligence includes establishing the beneficial ownership of the partner company, nor that joint ventures operating in high risk markets or with high risk partners are subject to enhanced due diligence. It is also not clear how frequently this due diligence is conducted or repeated.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publicly commits to establishing anti-bribery and corruption policies or procedures in its joint ventures, nor that it requires anti- corruption clauses in its contracts with such partners. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publicly commits to take an active role in preventing bribery and corruption in all of its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
Based on publicly avaialble information, there is some evidence that the company recognises corruption risks associated with offset contracting. The company states that its Commercial function is responsible for managing its offset activities, and indicates that any requests for offsets are subject to Group approval. <\/p>\n
However, the company receives a score of \u20191\u2019 because there is no evidnece that employees within the Commercial function receive tailored anti-bribery and corruption training on the risks associated with offsets. There is also no indication that the company publishes further details about its specific processes or controls to mitigate risks when engaged in offsets.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. <\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations or contracts. <\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
There is evidence that the company acknowledges the corruption risks associated with operating in different markets and there is evidence that it has a dedicated assessment process in place to assess such risks. There is evidence that the results of these assessments have an impact on business decisions and trigger the implementation of additional controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings, including joint ventures. For each entity, the list shows the company\u2019s percentage ownership and country of incorporation. There is evidence to indicate that this list is updated on an annual basis.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes the country or countries of operation for each entity.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed, with voting shares admitted to trading on the London Stock Exchange (LSE), and therefore it is not required to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information on its defence sales by customer. The company states that its defence business accounts for 36% of its total revenue, and indicates that it has a diverse portfolio of customers around the world. However, there is no evidence that the company publishes any further details regarding these customers. <\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":112,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":113,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":114,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"},{"question":115,"commitment_area":16,"score":"N\/A","comments":"
N\/A<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/865","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies"}],"about":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/types\/companies"}],"wp:attachment":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/media?parent=865"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=865"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}