There is evidence that the company publishes a clear statement on its anti-bribery commitment, which details the company's stance against any form of bribery within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
The company publishes an anti-bribery and corruption policy, which specifically defines and prohibits bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that the company\u2019s policy applies to both employees and board members. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available evidence that the policy applies to those employed by subsidiaries and other controlled entities. <\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
Based on publicly available information, there is some evidence that a designated board committee \u2013 the Audit Committee \u2013 oversees the company's compliance programme, which is understood to incorporate the company\u2019s anti-corruption programme. There is evidence to suggest that this committee engages in formal oversight functions such as reviewing reports from management 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 a designated senior executive \u2013 the Compliance Officer \u2013 has ultimate responsibility for implementing and managing the company's compliance programme, which is understood to include the company\u2019s anti-corruption programme. There is evidence that this person has a direct reporting line to the board of directors and board committee that provides oversight of the programme. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a formal risk assessment procedure that informs the design of the compliance programme. The evidence suggests that the results of such reviews are used to develop tailored mitigation plans. <\/p>\n
However the company receives a score of \u20181\u2019 because there is no clear evidence to indicate the risk assessment goes beyond legal risks facing the company.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is some evidence that the company\u2019s anti-bribery and corruption programme, as part of its wider compliance programme, is subject to a regular audit process, which includes provisions for continuous improvement. There is also evidence that audit findings are reviewed by the board, with responsibility for implementing changes held by the Compliance Officer. <\/p>\n
However, the company receives a score of \u20180\u2019 because it is not clear from publicly available evidence how frequently audits or the efficacy testing take place, nor does the company specify that the entire programme is audited beyond financial accounts. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigating incidents, and there is a specific procedure in place to deal with whistleblowing cases, which stipulates actions to be taken at each step. There is evidence that the company takes steps to ensure the independence of its investigations. There is evidence that the company commits to put in place remediation plans and to report investigative findings to senior management and the board. <\/p>\n
However, the information provided does not cover the whole investigation process from receipt to final outcome and it is not clear whether information on each investigation is documented. Furthermore, there is no evidence of a commitment to providing whistleblowers with updates on the outcome of investigations. <\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company assures itself of the quality of its internal investigations, including those reported through whistleblowing channels. The company explicitly states that staff tasked with conducting investigations are properly qualified and\/or trained to perform the function. Any complaints about the handling of concerns and investigations are overseen by an appropriate senior management officer.<\/p>\n
However, there is no 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":"1","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 and relevant authorities. <\/p>\n
However, there is no evidence that an appropriate senior individual is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is evidence that indicates that the company publishes some information on its ethical, bribery or corruption-related incidents and investigations involving company employees, on its intranet. <\/p>\n
However, the company receives a score of \u20180\u2019 because this data is not made publicly available and therefore it is not clear whether this covers all of the specific measures as described in the guidance, including whether the information applies to company employees at all levels. It is also not stated how frequently this data is updated.<\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides a training module that outlines the basic principles of the anti-bribery and corruption policy. The evidence suggests that training is provided at least on an annual basis. <\/p>\n
However, there is no evidence to suggest that the training is systematically provided to all employees, in all countries or regions of operation and in all appropriate languages. It is also not clear whether training includes outlining the whistleblowing options available to employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides tailored anti-bribery and corruption training to employees in different roles, including employees working in high-risk positions. There is evidence which suggests that employees in high risk positions are required to undertake training in this area on at least an annual basis.<\/p>\n
However, there is no publicy available evidence that the company provides training to all three categories of employees referred to in the question. There is some evidence that refers to employees in decision making roles, but it is not clear whether they are expected to undertake training or deliver it to other employees. There is no evidence in relation to anti-bribery and corruption training for board members.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company measures the effectiveness of its anti-bribery and corruption communications and personnel training programme, although the frequency with which the company assures itself of this is not stated. Furthermore, it is unclear whether the results of evaluations are used to update specific parts of the company's anti-bribery and corruption communications and training programme. There is also no evidence that the company conducts a full review of its anti-bribery and corruption training programme at least every three years.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
Although the company states that its Compliance Officer may present rewards or promotions to employees who have demonstrated ethical conduct, the company\u2019s approach to incentives for employees across the company is unclear and so receives a score of \u20180\u2019. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
Although the company states that it cannot justify violations of its Code of Ethics in order to make a profit or reach targets, there is no publicly available evidence to indicate that the company commits to support or protect employees who refuse to act unethically, even where such actions result in a loss to the company.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. <\/p>\n
However, there is no evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys or usage data. Furthermore, the policy does not explicitly apply to all employees across the organisation, including those employed by the group as third parties, suppliers and joint venture partners.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has both whistleblowing and advice channels. There is evidence that channels are sufficiently varied to allow employees to raise concerns across the management chain, and that they allow for confidential and, wherever possible, anonymous reporting. The evidence states that any person can report a violation through its various channels and so it is understood that they are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that it offers an external channel operated by an independent party.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy for conflicts of interest that covers actual conflicts of interest. There is evidence that the policy defines financial interests, other employment and government relationships and applies to employees and directors. <\/p>\n
However, there is no evidence that the company\u2019s policy mentions potential or perceived conflicts of interest, or that it covers employee relationships as a possible conflict. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is evidence that the company requires its employees and board members to obtain approval before engaging in activities that may cause a conflict of interest. <\/p>\n
However, the company scores a score of \u20180\u2019 because no further information was found regarding the company\u2019s procedures to identify, declare and manage conflicts of interest. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagement to recently departed public officials and politicians. <\/p>\n
However, the company receives a score of \u20181\u2019 because the evidence does not indicate that senior approval is required for the initiation of employment discussions with former or current public officials, or that the company undertakes a conflict of interest review and imposing restrictions on activities if risks are identified.<\/p>\n"},{"question":74,"commitment_area":10,"score":"2","comments":"
The company publishes a clear statement that it does not contract advisory or consulting services from politicians. <\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, the company prohibits all corporate political contributions. There is evidence to indicate that this statement applies to all circumstances and clearly prohibits any contributions made in the company\u2019s name. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company clearly states that it does not make political contributions and is therefore exempt from scoring on this question.<\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a clear policy covering both charitable donations and sponsorships, to ensure that such donations are not used as vehicles for bribery and corruption. There is evidence this includes specifying criteria for donations and procedures for senior sign-off. <\/p>\n
However, the company receives a score of \u20181 because there is no evidence that the company publishes full details of all charitable donations made, such as details of the name, amount and country of the recipient entity. <\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a clear policy not to engage in any lobbying activities. There is evidence that this policy applies to all employees, board members and consultant lobbyists.<\/p>\n"},{"question":79,"commitment_area":11,"score":"N\/A","comments":"
The company clearly states that it does not engage in lobbying activities and is therefore exempt from scoring on this question.<\/p>\n"},{"question":80,"commitment_area":11,"score":"N\/A","comments":"
The company clearly states that it does not engage in lobbying activities and is therefore exempt from scoring on this question.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality with clear procedures designed to ensure that such promotional expenses are not used as vehicles for bribery and corruption. There is evidence that this policy establishes financial limits for the different types of promotional expense that employees may encounter. There is also evidence that the policy addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials.<\/p>\n
However, the company receives a score of \u20181\u2019 because the approval procedures for different types of promotional expenses are not clear from the available evidence. There is also no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company's procurement department is involved in the establishment and oversight of supplier relationships. It is clear that the procurement department is the main body responsible for oversight of the company\u2019s supplier base.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it assures itself of the procurement department\u2019s involvement at least every three years through clearly stated means, such as an audit or other assurance process.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company conducts due diligence on all of its suppliers. This includes evidence that third parties are required to complete a due diligence questionnaire before engaging with the company, which is understood to include suppliers. There is evidence that the questionnaire includes a question regarding ultimate beneficial ownership, and that the company might be willing to review or terminate its relationship with third parties where risks identified in the due diligence cannot be mitigated.<\/p>\n
However, there is no evidence to suggest that highest risk suppliers are subject to enhanced due diligence. Furthermore, there is no evidence that due diligence is repeated at least every two years or whenever there is a change in the business relationship. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. It is explicitly stated that all suppliers must have, at minimum, policies that prohibit bribery, and cover conflicts of interest and gifts and hospitality. There is evidence that the company ensures this by requiring that its suppliers adhere to the Poongsan Business Partner Code of Conduct. There is also evidence that the company asks for evidence of anti-bribery policies as part of its Third Party Due Diligence Questionnaire, which is required when engaging with third parties. It is understood that this includes suppliers.
\nHowever, the company does not explicitly state that all suppliers must address whistleblowing. Furthermore, it is unclear whether assurance is conducted when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company takes steps to ensure that the principles of the Poongsan Business Partner Code of Conduct is required of sub-contractors throughout the supply chain. However, this is in the form of a simple statement and it is unclear how the company does this in practice.<\/p>\n
Although there is also evidence that the company asks for details about subcontractors and their activities in its Third Party Due Diligence Questionnaire, it is not clear whether the company uses this information to ensure that they have adequate anti-bribery and corruption programmes in place.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence to indicate that the company publishes any data on ethical, bribery or corruption-related investigations or disciplinary actions involving its suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has a policy covering the use of agents, which addresses the corruption risks associated with their use and outlines a number of restrictions and controls to mitigate these risks. <\/p>\n
The company, however, receives a score of \u20181\u2019 because it does not commit to establishing and verifying that the use of agents, is in each case necessary to perform a legitimate business function. The company also does not specify that its policy applies to subsidiaries and joint ventures.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on its third parties and agents. There is also evidence that third parties are required to complete a due diligence questionnaire before engaging with the company, which is understood to apply to agents and intermediaries. There is some evidence that suggests that the company commits to not engaging with third parties where risks identified in the due diligence cannot be mitigated.<\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that agents and highest risk intermediaries are subject to enhanced due diligence. Furthermore, it is not clear from the available evidence that due diligence is repeated at least every two years and\/or when there is a significant change in the business relationship. <\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has formal procedures in place to establish the beneficial ownership of third parties prior to engaging them, which is understood to include agents and intermediaries. There is evidence that suggests that the company will not engage with third parties where beneficial ownership cannot be established.<\/p>\n
However, the company receives a score of \u20181 because there is no evidence that the company commits to independently verify the beneficial ownership information provided by high risk agents, nor that the company checks this information at least every two years and\/or when there is a significant change in the business relationship.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to agents and intermediaries acting for or on behalf of the company. The company states that agents and intermediaries who deal with public officials or employees of public corporations are subject to anti-bribery and corruption clauses in their contracts, which includes clear termination rights. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
Although there is evidence that the company conducts checks in relation to whether payments to agents are reasonable, there is no evidence that the company's incentive structures for agents include measures to mitigate potential bribery and corruption risks.<\/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, bribery or corruption-related investigations or the associated disciplinary actions involving its agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"1","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 prior to entering into a joint venture. It is clear that the company\u2019s due diligence includes checks on the ultimate beneficial ownership of the partner company.<\/p>\n
However, there is no evidence to suggest that joint ventures operating in high risk markets or with high risk partners, such as state-owned enterprises, are subject to enhanced due diligence. Furthermore, there is no evidence that due diligence is repeated at least every two years or when there is a significant change in the business relationship.<\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
Based on publicly available information, there is evidence that the company states that it accounts for anti-bribery and corruption considerations when entering into a joint venture. The company states that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract, at minimum prohibiting foreign and domestic bribery and facilitation payments. There is evidence that the company takes steps to detect, control and prevent breaches through auditing compliance with anti-bribery and corruption principles, and that it may terminate relationships with business partners found not to be compliant with these principles. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, it is unclear whether the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. The company does not discuss any practical measures that it has in place to counter bribery and corruption risks. <\/p>\n"},{"question":103,"commitment_area":14,"score":"1","comments":"
Based on publicly available information, there is evidence that the company recognises the corruption risks associated with offset contracting. The company\u2019s export department and its Compliance Officer are involved in the management of offset obligations.<\/p>\n
However, it is not clear that they are responsible for monitoring the company\u2019s offset activities throughout the lifecycle of each project and there is no evidence that all employees within the team receive tailored anti-bribery and corruption training. Furthermore, there is little evidence of other policies and processes to address the risks associated with offset contracting. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
Based on publicly available information, there is evidence that the company conducts risk-based anti-corruption due diligence on third parties engaged as part of its offset activities. However, there is no evidence that the company refreshes this due diligence continuously or when there is a significant change in the business relationship or nature of the partner.<\/p>\n
Furthermore, there is little evidence to indicate that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on other aspects of its offset obligations, such as checks on beneficial ownership and\/or conflict of interest associated with the beneficiaries. There is also no evidence that the company seeks to assure itself of the legitimacy of the investment. <\/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 indirect offset obligations and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence to indicate that the company acknowledges the corruption risks of operating in different markets, nor that it has a risk assessment procedure in place to identify such risks.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of its fully consolidated subsidiaries. For each entity, the company discloses its percentage ownership and the country of incorporation. This list is published alongside a statement that it is accurate to the best of the company\u2019s knowledge at the time of publication. There is evidence that this list is current and updated on at least an annual basis.<\/p>\n
The company receives a score of \u20181\u2019, however, because for each entity it does not include clear information on their countries of operation. Additionally, the list provides details of the company\u2019s subsidiaries but it is not clear that this represents all of the company\u2019s holdings, including joint ventures and non-fully consolidated holdings.<\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes information on the entities with significant holdings in the company, but this information is disclosed its corporate reports and not in a central public register. It is noted that the company is a publicly listed company on the Korea Stock Exchange, but it does not have voting shares admitted to a regulated market specified in the guidance.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information about its defence sales or 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\/870","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=870"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=870"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}