The company has a publicly stated anti-corruption commitment, within its Anti-Corruption Policy, which details the company's stance against any form of bribery or corruption within the organisation. There is evidence that this policy was authorised and endorsed by the Company's Leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company has an Anti-Corruption Policy, which clearly applies to employees of all levels of seniority and board members, including non-executive directors. There is evidence that the company\u2019s policy specifically prohibits bribery and commercial bribery.<\/p>\n
The company receives a score of \u20181\u2019 because neither this policy, nor any other publicly available evidence, makes specific reference to the prohibition of payments to public officials or facilitation payments.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that the General Director, who is a member of the Supervisory Board, is ultimately responsible for oversight of the company's anti-bribery and corruption programme, and that anti-corruption issues are discussed during board meetings. According to publicly available evidence, the General Director receives reports from the Commission for Corporate Conduct and Conflicts of Interest Resolution, which is chaired by the company\u2019s Deputy General Director. However, based on publicly available information, it is not clear whether responsibility for reviewing the results of internal and external audits, and ensuring that required changes are made, is held at the level of Supervisory Board. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive (the Deputy General Director) is responsible 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 General Director, who provides oversight of the anti-bribery and corruption programme, and that feedback activities take place. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a formal corruption risk assessment procedure that informs the design of the anti-corruption and bribery programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that risk assessments are reviewed at least annually, or that the results are reviewed at board level.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is evidence which indicates that the anti-bribery and corruption programme is subject to a regular audit process to ensure the programme is consistent with the requirements of anti-corruption legislation and the business risks facing the company, and that recommended updates and improvements are made based on audit findings. However, while there is some evidence that the Audit Committees of subsidiary companies review audit findings, it is not sufficiently clear based on publicly available information that audit findings are presented to the Supervisory Board, or an appropriate board-level committee. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigating incidents, and that there is a specific procedure in place to deal with whistleblowing cases, which stipulates documentation, actions to be taken at each step and a commitment to providing whistleblowers with updates on the outcome of investigations. There is evidence that information on each investigation is documented and that the company carries out a summary analysis of investigations annually and presents the results to the company\u2019s senior management. <\/p>\n
However, there is no evidence that investigations are handled by an independent team or report to an independent board member and there is no publicly available information indicating that a central body reviews the status of investigations on at least an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
There is evidence that the company reports criminal offences to the relevant authorities. However, there is no evidence of a clear commitment to report material findings of corruption to the board and it is not evident that an appropriate senior individual is ultimately responsible for evaluating whether to pass information to law enforcement agencies. <\/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":"1","comments":"
Publicly available evidence suggests that the company provides training on its anti-bribery and corruption programme, including the whistleblowing options available to employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company provides training systematically to all employees across all divisions, all countries and regions of operation and in all appropriate languages. It is also unclear, based on publicly available information, how frequently the company conducts anti-corruption training. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
The company states in publicly available information that some employees in certain positions receive different or tailored anti-bribery and corruption training, including senior managers and those in higher risk positions. <\/p>\n
However, there is no evidence as to how systematically this tailored training is conducted or whether it is refreshed on at least an annual basis. There is also no evidence that board members receive tailored training<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is evidence that the company publicly commits to continuously work to improve its educational and outreach programme in the area of anti-corruption. However, there is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
While there is some evidence that employees\u2019 conduct is taken into account when under consideration for promotion, there is insufficient evidence to suggest that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company commits to support or protect employees who refuse to act unethically. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this explicitly applies to all employees across the organisation, including those employed by the group as third parties, without making specific reference to suppliers and joint venture partners.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company assures itself of its employees\u2019 confidence in its non-retaliation commitment through surveys, analysis of usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company has whistleblowing and advice channels, which allow for confidential and anonymous reporting. It is stated in publicly available information that these channels are available to all employees and third parties, although there is no clear evidence as to whether this includes employees of suppliers and joint venture partners, or whether all employees in every country of operation can access these channels in all relevant languages. Based on publicly available information, there is evidence that the company only offers internally operated reporting and advice channels.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company formally addresses conflict of interest as a corruption risk, and has a clear policy that defines conflicts of interest, including actual and potential conflicts. There is evidence that the policy specifically covers conflicts involving personal and family relationships, outside employment and financial interests and explicitly applies to all employees and board members. There is evidence that the company makes some reference to the employment of former government officials; however, there is no evidence that this fully covers possible conflicts of interest that could arise from an employee also acting as an officer of any government or government department. <\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has clear procedures to identify, declare and manage conflicts of interest, actual, potential and perceived. This includes a publicly available statement that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process. There is evidence that potential or actual conflict of interest declarations are reviewed and overseen by a designated body or individual with ultimate accountability for its implementation and handling of individual cases. The publicly available description of this procedure also includes examples of criteria for recusals and potential punitive measures for breaches of the policy.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
The company states publicly that when hiring individuals previously employed in the public sector it is sometimes required by regulations to obtain written permission from state bodies to facilitate their appointment. The company, however, receives a score of \u20180\u2019, because there is no evidence that it has a clear policy regulating the hiring of former public sector employees with a view to mitigating corruption risks. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company reports details of the contracted services of serving politicians<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy or procedure covering political contributions.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company discloses details of its political contributions. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has policies covering both charitable donations and sponsorships, and that it has some procedures in place, such as a formal application process and sign-off by the Board of Directors, to ensure that such donations are not used as vehicles for bribery and corruption. The company publishes some information in its Annual Report in relation to the types of charitable causes it supports; however, there is no evidence that the company publishes details such as the amount donated to individual projects or which corporate entity made the payment. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy and\/or procedure on lobbying.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes 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 provides details on its global lobbying expenditure.<\/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 bona fide and not used for bribery. The company\u2019s publicly available policy establishes an approval procedure for the different types of promotional expense that employees may encounter and all gifts and hospitality must be recorded in a dedicated register accessible to those responsible for oversight of the process. The company states that employees should adhere to regulations governing gifts to state employees, however there is no evidence that it addresses the risks associated with gifts given to or received from foreign public officials. <\/p>\n
It is noted that the company states in its 2017 Annual Report that it now prohibits the giving and receiving of gifts and hospitality, however there is no evidence that this has been reflected in its publicly available policies.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
Based on publicly available evidence, there is no evidence that the company requires the involvement of a specialised procurement department in the establishment or oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
The company states that it conducts corruption-based due diligence on its partners, contractors and third parties and intermediaries, which is understood to include suppliers. However, there is insufficient publicly available evidence as to the content and consequences of due diligence. <\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
The company states that it \u2018strongly welcomes\u2019 third parties to adopt similar anti-corruption policies to its own. However, the company receives a score of \u20180\u2019 because there is no evidence that the company ensures that suppliers have anti-corruption policies in place which meet a high standard. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required throughout the supply chain.<\/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 investigations relating to its suppliers, or the associated disciplinary actions.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company has a clear published policy covering the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
The company states that it has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging third parties and agents. However it is not clear based on publicly available information whether agents and high-risk intermediaries are subject to enhanced due diligence and there is no evidence that the company conducts due diligence on its agents 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 no evidence that the company aims to establish the beneficial ownership of its agents.<\/p>\n"},{"question":91,"commitment_area":13,"score":"1","comments":"
The company states that it encourages third parties to adopt similar anti-corruption policies to its own; however, there is no evidence as to the contents and how it ensures this. There is also evidence to suggest that the company includes anti-corruption clauses in contracts with third parties, but there is no evidence that audit and termination rights are included. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company recognises incentive structures as a risk factor in agent behaviour and there is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes details of the agents currently contracted to act for or on behalf of the company.<\/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 the associated disciplinary actions involving agents.<\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is evidence that the company conducts due diligence on third parties, but there is no evidence that it makes specific reference to joint ventures. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. Furthermore, there is no publicly available evidence to show that the company requires anti-bribery and corruption clauses specifically in its contracts with joint venture partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company 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":"0","comments":"
There is no evidence that the corruption risks associated with offset contracting are addressed, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no 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 the company\u2019s 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":"0","comments":"
The company states that it has procedures to ensure that its activities in foreign countries do not infringe local anti-corruption laws. However, there is no evidence that this involves an assessment of the corruption risks prevalent in different markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes information regarding its main subsidiaries and joint ventures, alongside information on the location of each of these companies. However publicly available information about the company shows that this information is incomplete and does not include all of its holdings. Furthermore there is no evidence that the company provides information such as the countries of operation for each company, or the percentages owned. It is also not clear how frequently this information is published or updated. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company states that it is a state-owned entity, and although it is not explicitly stated, it is assumed that this means that the company is 100% owned by the state. However, the company only discloses its ownership on its website instead of a central public register and therefore a score of \u20181\u2019 applies.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes a percentage breakdown of its defence sales by customer.<\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
The company publishes a statement that it is 100% owned by the Russian Federation and is a State Corporation. Therefore, it can be inferred that the company only has one shareholder. It is therefore exempt from scoring on this question.<\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
The SOE publishes some information about its objectives but receives a score of \u20181\u2019 because there is no evidence that this information is updated on at least an annual basis. <\/p>\n"},{"question":113,"commitment_area":16,"score":"1","comments":"
There is evidence that the SOE publishes clear information about the composition of its Supervisory Board, including that each member is a state representative. However, there is no evidence that the company publishes information on the nomination and appointment process. <\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
While there is evidence that the company\u2019s subsidiaries have audit committees, it is unclear from publicly available information whether Rostec itself has an executive-level audit committee, or how this is composed.<\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
There is no evidence that the SOE publishes details about its management of asset transactions.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/872","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=872"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=872"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}