There is evidence that the company publishes a clear commitment to ethics and integrity, which is endorsed and authorised by its CEO and President. This commitment appears in the company\u2019s Standards of Business Conduct, which contains its anti-corruption policy, as well as on a dedicated webpage about anti-corruption compliance. <\/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 applies to all employees and board members as described 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 Audit Committee \u2013 is ultimately responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that its responsibilities include reviewing audits and reports from management on the programme\u2019s performance, and it is clear that this committee has authority to require that changes are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive \u2013 the Chief Compliance Officer \u2013 has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence that this person has a direct reporting line to the Audit Committee, which provides oversight of the anti-bribery and corruption programme. In addition, there is evidence of reporting and feedback activities between this person and the Audit Committee as part of the company\u2019s reporting structure. <\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a formal bribery and corruption risk assessment procedure in place that informs the design of its anti-corruption and bribery programme. The company indicates that these assessments are reviewed by the board-level Audit Committee on at least an annual basis, with the results used to develop tailored mitigation plans and to update specific parts of the company\u2019s anti-corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption programme is subject to annual review to ensure the programme is consistent with best practice and the business risks facing the company. It is clear that ownership for planned improvements to the anti-bribery and corruption policy sits with the Chief Compliance Officer and Office of the General Counsel. There is evidence that high-level audit findings are presented to the board-level Audit Committee, which is ultimately responsible for the company\u2019s programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company commits to investigating incidents and allegations. There is evidence that it has a specific procedure in place to deal with whistleblowing cases, which stipulates some actions to be taken as part of an investigation. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish information on the whole investigation process from receipt to final outcome. There is also no evidence that the company publicly commits to informing whistleblowers of the outcome of the investigation, nor that a central body reviews the status of all investigations on at least an annual basis. It is also unclear whether the company takes steps to ensure the independence of its investigations, for example by stipulating that investigations are handled by an independent team and\/or report to an independent board member.<\/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. The company states that a dedicated team of full-time professionals handles investigations and this team are trained in conducting interviews. <\/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 possible complaints about the investigation process. There is also no clear evidence that the company reviews its investigations procedure at least every three years or in response to any changes in the regulatory environment.<\/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 Audit 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 General Counsel, as part of the law department and in cooperation with the Audit Committee, is responsible for this process. <\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publishes high-level data from ethical or bribery and corruption-related incidents and investigations involving its employees. This data covers the number of reports received (including the number received through whistleblowing channels), the number of substantiated allegations and the number of disciplinary actions taken as a result of investigation findings. There is evidence to indicate that this data is updated and published on an annual basis.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company provides training for its employees that outlines the principles of its anti-bribery and corruption policy, including the whistleblowing options available. There is evidence that the company provides this training to all employees and in multiple languages. There is evidence that all employees must undertake annual ethics and compliance training.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides tailored anti-corruption training to its employees based on an assessment of their role and exposure to corruption risk. The company indicates that it provides such training to management, board members and employees in high risk positions, such as those in business development, programme management and finance.<\/p>\n
However, there is no clear publicly available evidence that the employees in high risk positions must refresh their role-specific training on an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a system for measuring and reviewing the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company\u2019s internal audit department audits the training programme, which also includes quizzes designed to test the effectiveness of materials. The company commits to assuring itself of this on an annual basis. It is clear that the results of these reviews are used to update specific parts of the company's anti-bribery and corruption communications and training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company\u2019s incentive schemes for employees incorporate ethical and anti-bribery and corruption principles. The company states that compensation schemes are designed to reward behaviour in line with the company\u2019s ethical values. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that these incentives apply to all employees or whether financial rewards must be proportionate to the employee\u2019s base salary in the case of high risk employees, such as sales roles. It is also unclear how the company incentivises ethical conduct in the workplace, such as through performance appraisals. <\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company will support any employee who refuses to act unethically, even if this might impact on the company\u2019s business. There is evidence that the company assures itself of its employees\u2019 confidence in this statement through annual anonymised surveys. <\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
Based on publicly available information, there is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that the company assures itself of its employees\u2019 confidence in this commitment through anonymised surveys. In addition, the company indicates that its whistleblowing line is open to third parties including suppliers and that its commitment on non-retaliation extends to these parties. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides multiple channels for its employees to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow the employee to raise concerns across the management chain and to a reporting hotline operated by an independent third party. These channels allow for confidential and, wherever possible, anonymous reporting. The company indicates that its channels are available and accessible to all employees, in all jurisdictions where the company operates, including those employed by the group as third parties such as suppliers, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy that addresses and defines conflicts of interest, including actual, potential and perceived conflicts. The company\u2019s policy clearly covers possible conflicts arising from employee and government relationships, as well as financial interests and other employment. The company\u2019s policy applies to all employees and board members.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual, potential and perceived conflicts. The company states that any actual or potential conflicts must be immediately disclosed and indicates that the relevant manager, ethics office, law department and the General Counsel may be involved in the handling of cases. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further details on its management of conflict of interest cases. There is no evidence that employee and board member declarations are held in a central register that is accessible by those responsible for oversight of the process, nor is it clear that disciplinary measures will apply if the policy is breached. In addition, the company lists several individuals or departments that may be able to advise on possible conflict of interest issues, but does not provide any clear evidence that a designated senior individual or central body is responsible for oversight and accountability of the process. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has a policy that addresses the risks associated with the employment of public officials. The company\u2019s policy includes pre-employment screening procedures, cooling off periods and activity restrictions once the individual has joined the company. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further details on the controls that it may implement to reduce risks. Although the company indicates that employees should be careful when engaging in pre-employment discussions with current or former public officials, there is no evidence that it requires senior sign-off before the initiation of such discussions. In addition, there is no indication that the company stipulates the duration of its cooling off periods, nor is it clear that such procedures would apply in all jurisdictions including those where such periods are not directly required by law.<\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
The company publishes a clear statement that it does not retain the services of serving politicians. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy on corporate political contributions, which indicates that such activities are restricted but permissible in certain circumstances. The company states that it has not made any political contributions since 2012, but indicates that any such donations would require board-level approval and follow all relevant laws and regulations. In addition, there is evidence that the company is associated with a Political Action Committee (PAC) in the United States, which is overseen by an executive-led committee. <\/p>\n
Since the company does not clearly prohibit political donations and is associated with a PAC, it receives a score of \u20180\u2019 in line with the scoring criteria.<\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
The company publishes a clear statement that it has not made any corporate political contributions since 2012. In addition, there is evidence that details of the contributions made by the company\u2019s Political Action Committee (ENGPAC), as well as payments made by the company to trade associations, are published on the company\u2019s website and disclosed as required to the U.S. Federal Election Commission (FEC). <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on charitable donations and sponsorships. There is evidence that these policies include measures to ensure that these payments are not used as vehicles for bribery and corruption, for example by stipulating criteria for donations and conflict of interest reviews. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes details of all charitable donations and sponsorships made, including 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 has a procedure on lobbying. The company states that any engagement in lobbying requires prior written approval from the company\u2019s management team, which includes its law department.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that its policy defines responsible lobbying, nor is there evidence that it stipulates certain standards of conduct or specific oversight mechanisms that apply to all types of lobbyists. In addition, it is not clear from publicly available information that its procedures apply to all employees, board members and third parties engaged in lobbying activities on the company\u2019s behalf.<\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes some information on its lobbying topics and activities in the United States by making its quarterly federal lobbying reports publicly available via a direct link on its website. <\/p>\n
However, the company does not provide further details about its broader public policy aims or positions. Although the company indicates that it does not generally engage in lobbying outside of the United States, there is no evidence that the company publishes any information on the activities that it has conducted in other jurisdictions nor does it clearly state that it has not engaged in lobbying elsewhere in the most recently reported financial period.<\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
There is evidence that the company publishes summary information of its lobbying expenditure in the United States by making its quarterly federal lobbying reports publicly available via a direct link on its website. <\/p>\n
However, the company receives a score of \u20181\u2019 because this expenditure data is not broken down into internal, external or association lobbyists and does not include an explanation of how these figures have been calculated. Furthermore, although the company indicates that it does not generally engage in lobbying outside of the United States, there is no evidence that the company publishes any information on any expenditure that relates to such activities nor does it clearly state that it has not engaged in lobbying elsewhere in the most recently reported financial period.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with procedures designed to ensure that such promotional expenses are not used as vehicles for bribery. There is evidence that the policy places proportional limits on different types of promotional expenses. The company also states that in general employees must not offer or accept gifts and hospitality from government officials.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that all gifts and hospitality above a certain threshold are held in a dedicated central register which is accessible to those responsible for oversight of the process. The company indicates that it maintains a central register of business courtesies for non-U.S. government officials that exceed a certain limit, but it is not clear that the same requirements apply for recipients in the U.S. or outside of government. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base. The company indicates that the procedures in place for its supply chain are integrated into its wider third party processes, however there is no clear evidence that a central procurement department is the main body responsible for establishing and monitoring supplier relationships. <\/p>\n"},{"question":83,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to conduct risk-based due diligence when engaging and re-engaging with any suppliers. The company\u2019s due diligence process clearly includes establishing the ultimate beneficial ownership of the supplying company, and there is evidence indicating that the highest risk suppliers are subject to enhanced due diligence. <\/p>\n
In addition, there is evidence that the company refreshes its due diligence periodically and when there is a change in the risk profile of the supplier. There is also some evidence to suggest that the company might be willing to review or terminate supplier relationships in circumstances where a red flag highlighted in the due diligence process cannot be mitigated.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
Based on publicly available information, there is evidence that the company requires that its suppliers have adequate anti-bribery and corruption policies and procedures in place. The company clearly states that all suppliers must comply with its Supplier Standards of Business Conduct, which prohibits bribery and facilitation payments, and outlines procedures on conflicts of interest, gifts and hospitality, and whistleblowing. The company takes active steps to ensure this at the start of the relationship by including these provisions in its contractual agreements, and through a review when there is a change in the relationship with the supplier.<\/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 its sub-contractors have adequate anti-bribery and corruption programmes in place. The company states that it conducts due diligence on lower tier subcontractors in high risk transactions and indicates that it may require the supplier to take steps to cascade anti-corruption compliance to lower tiers. In addition, the company\u2019s Supplier Standards of Business Conduct requires that such entities conduct anti-corruption due diligence on their own sub-contracts. <\/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 reports, investigations or disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is some publicly available evidence that the company has a policy on the use of agents, which includes enhanced due diligence procedures and restrictions on remuneration for such entities. There is evidence to indicate that this policy applies to all sales representatives and agents acting on behalf of the company.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that its policy addresses the specific corruption risks associated with the use of agents, nor is there evidence that its commit to establishing that the use of each agent is necessary to perform a legitimate business function.<\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its third parties and agents. There is evidence that agents and the highest risk intermediaries are subject to enhanced due diligence. The company states that it refreshes due diligence periodically and when there is a change in the risk profile of the third party. <\/p>\n
In addition, there is evidence that the company commits to not engage or review and potentially terminate its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.<\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company seeks to establish the ultimate beneficial ownership of agents and intermediaries as part of its due diligence processes. There is evidence that the company has enhanced screening procedures to examine the beneficial ownership of high risk agents. The company indicates that it conducts such checks periodically throughout the lifecycle of the business relationship, and indicates that all agents are contractually obliged to report any material changes in beneficial ownership information, which may trigger additional controls or a review of the relationship. <\/p>\n
In addition, there is evidence that the company commits to not engage or review and potentially terminate its engagement with agents or intermediaries where the risks identified in the due diligence cannot be mitigated.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company indicates that all agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"2","comments":"
There is evidence that the company highlights and addresses incentive structures for agents as a factor in bribery and corruption risk. The company states that commission fees are determined according to local market value and that both expenses and commissions are capped to ensure that the overall remuneration remains reasonable and proportionate. In addition, there is evidence that the company only pays remuneration to agents in staged payments over the course of their contract, based on clear milestones, and it commits to only paying agents 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 on its behalf.<\/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":"2","comments":"
Based on publicly available information, there is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. The company states that this includes establishing the ultimate beneficial ownership of the partner company, with enhanced due diligence for joint ventures operating in high risk markets. There is evidence that the company conducts anti-bribery and corruption due diligence prior to entering into a joint venture and when there is a change in the business relationship. <\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company considers anti-bribery and corruption issues when entering into a joint venture and that it requires all third parties to commit to anti-corruption undertakings. There is also evidence that the company includes anti-corruption clauses in its contracts with joint venture partners, with clear termination rights in the event of a compliance violation or after a review of any changes to its beneficial ownership. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it requires all joint ventures to adopt its own anti-bribery and corruption programme or that it works with partner companies to develop a programme. There is also no evidence that the company includes audit rights in its contracts with joint venture partners to detect, control and prevent breaches.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures, for example, by stipulating provisions for secondments of its senior management, providing specific anti-corruption training or establishing a separate internal audit function.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no clear evidence that the company addresses the possible corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for oversight of the company\u2019s offset activities. The company provides some information on its due diligence and review processes, but there is no further indication that it addresses the specific risks or provides dedicated training for staff involved in the company\u2019s offset activities. <\/p>\n"},{"question":104,"commitment_area":14,"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 on its offset obligations. The company indicates that this process includes checks on the beneficial ownership of any offset brokers or beneficiaries, as well as conflict of interest risks associated with the brokers or beneficiaries. <\/p>\n
In addition, there is evidence that the company refreshes this due diligence periodically or whenever there is a change in the business relationship or nature of the partner. There is evidence that the company has procedures in place to assess the business rationale of any proposed offset project prior to entering into binding agreements.<\/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":"1","comments":"
Based on publicly available information, there is evidence that the company acknowledges the corruption risks associated with operating in different markets and that it has a dedicated process in place to assess such risks. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence on the risk management procedures that it has in place, nor is there evidence to suggest that the results of these assessments have an impact on business decisions or trigger the implementation of additional anti-corruption controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a clear list of its fully consolidated subsidiaries and non-fully consolidated holdings, including details such as its percentage ownership, the country of incorporation and country or countries of operation of each entity. The company provides some information on a subsidiary and on its business divisions, however there is no evidence that this represents all of the company\u2019s holdings nor that it includes details of each entity. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is a publicly listed entity on the New York Stock Exchange (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. The company also publishes ownership information in annual its Proxy Statement, which is available on its website. <\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
There is evidence that the company publishes information on its defence sales by customer, to indicate that the United States government accounts for more than 80% of its sales. Although the company does not explicitly state that this figure relates to defence sales, there is sufficient evidence to indicate that the company\u2019s primary products and services relate to the defence and security sector. There is evidence that this information is published as part of the company\u2019s annual corporate reporting, which reflects the most recently reported financial year. <\/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\/868","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=868"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=868"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}