The company states that it is committed to conducting business to high ethical standards and preventing corruption in all of its operations. However, there is no evidence that the company publishes an explicit anti-bribery and corruption statement which is clearly endorsed by a member of the company\u2019s senior leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes an Anti-Corruption Policy, as well as a Code of Ethics. Together these documents make specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. There is evidence that the company\u2019s anti-bribery and corruption policies apply to all employees and board members as described in (a) and (b) above, regardless of their seniority.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated board committee (the Ethics and Control Committee) is responsible for oversight of the company's anti-bribery and corruption programme. There is evidence that the committee\u2019s responsibilities include reviewing reports from management on the programme\u2019s performance, along with the results of internal and external audits, and recommending that required changes are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
The company states that its General Director is responsible for managing its anti-corruption programme. However, the company receives a score of \u20181\u2019 because there is no evidence as to how this individual interacts with the Ethics and Control Committee, which provides oversight of the company\u2019s anti-corruption programme. There is no clear evidence of reporting and feedback activities between the two parties.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
The company states that it periodically conducts formal bribery and corruption risk assessments that are used to inform 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 of these assessments are reviewed at board level. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
The company states that its anti-bribery and corruption programme is subject to regular audit and that its anti-corruption policies and procedures are updated according to best practice and when audits reveal weaknesses. There is also evidence that audit findings are presented to the company\u2019s Ethics and Control Committee. <\/p>\n
However, the company does not clearly state that the entire anti-corruption programme is regularly audited, nor does it provide details on how often audits are carried out. The ownership for implementing required changes as identified in audits is also unclear.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
The company publicly commits to investigating incidents, and there is evidence that there is a specific procedure in place to deal with whistleblowing cases, stipulating documentation and actions to be taken at each step. The company states that those submitting reports may be informed of the outcome of subsequent investigations, if they so wish. In addition to its own policies in relation to investigating reports of bribery and corruption, the company also includes information regarding its parent company\u2019s hotline and whistleblowing policy, which apply to the company\u2019s employees as well. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence as to whether investigations are handled by an independent team or report to an independent board member, or whether summary information on investigations is reviewed by a central body.<\/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":"
The company states that material findings of bribery and corruption from investigations may be reported to the board and if necessary to the appropriate external authorities. However, it does not clearly identify in publicly available information a senior individual responsible for evaluating whether to report material findings of corruption and bribery to the relevant authorities.<\/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":"
There is evidence that the company provides training that outlines the principles of the anti-bribery and corruption programme and that employees are required to undertake refresher courses or modules on the anti-bribery and corruption programme every two to three years.<\/p>\n
The company, however, receives a score of \u20181\u2019 because it makes no explicit statement that it provides anti-bribery and corruption training to all employees across all operations and in all appropriate languages. It is also not clear whether training covers the whistleblowing options available to employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
While the company states that it conducts annual ethical certification of middle and senior managers, the evidence is insufficiently clear to determine whether the company tailors its anti-bribery and corruption training to employees based on an assessment of their role and exposure to corruption risk. <\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
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 the company states that it takes into consideration employees\u2019 adherence to ethical principles when considering them for promotion to more senior positions, there is insufficient evidence to determine whether the company\u2019s incentive schemes specifically incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
The company clearly states that any employee who refuses to act unethically, in keeping with the company\u2019s anti-corruption commitments, will not be subject to sanctions, even where such actions result in a loss of business or another disadvantage to the company. <\/p>\n
However, there is no evidence that the company 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 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 policy applies to all employees across the organisation, including those engaged by the group as third parties and partners.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear 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":"1","comments":"
There is evidence that employees are able to access multiple channels to report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme, including channels provided by the parent company. There is evidence that channels are sufficiently varied to allow the employee to raise concerns across the management chain and they allow for confidential and, wherever possible, anonymous reporting. There is also evidence that it is clear that channels are available to all employees in any country of operation and to any employees of third parties, suppliers or joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because, based on publicly available information, employees only appear to have access to internally operated channels.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company formally addresses conflicts of interest as a corruption risk and has a clear policy and procedure that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers conflicts concerning financial interests, employee relationships, government relationships and outside employment opportunities. There is evidence that this policy applies to all employees, as well as to employees of subsidiaries and other controlled entities. <\/p>\n
However, it is not clear whether this policy applies to board members. <\/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 and there are examples of criteria for recusals. There is evidence that all employees and the Board are required to complete an annual declaration on conflicts of interest, and that these are submitted to the Internal Control and Audit department, although it is unclear whether they are held in a dedicated register or central depository. Nevertheless, there is evidence that this department compiles a report and recommendations for the final decision of the Board of Directors, which has ultimate accountability. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
The company states that it takes steps to avoid conflicts of interest when conducting activity with public officials or hiring relatives of public officials. However, there is no clear 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 reports details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
The company states that it is a group-wide policy that no political donations can be made in order to receive commercial gain. However, it is not sufficiently clear that the company completely prohibits political contributions in all circumstances, or what mechanisms are in place to ensure that no payments are used as vehicles for bribery and corruption. <\/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":"0","comments":"
The company states that it has a policy that does not permit charitable and sponsorship contributions to be used as vehicles for corruption or for illegitimate purposes. However, the company receives a score of \u20180\u2019 because there is evidence that the company does conduct charitable activity, but there is no evidence of measures to ensure that donations are not used as vehicles for bribery and corruption, for example, by specifying criteria for donations, procedures for senior sign-off, or due diligence on recipients. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy on responsible 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 provides any details about 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. The policy specifically addresses the risks associated with gifts and hospitality given to\/received from domestic or foreign public officials. <\/p>\n
However, there is no evidence that the company specifies financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no clear evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated register or central depository that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company's centralised procurement department is involved, in some capacity, in the establishment and oversight of supplier relationships. However, the company receives a score of \u20181\u2019 because there is no evidence that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold. There is also no clear evidence that the company assures itself of the involvement of its procurement department in supplier relationships at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
The company states that it has formal procedures to conduct due diligence on suppliers, however it is not clear whether this includes checks on ultimate beneficial ownership. There is no publicly available evidence which shows whether due diligence is only conducted before engaging with new suppliers or if it is repeated at least every two years. There is also no evidence that the company commits to review and possibly terminate supplier relationships in circumstances where a red flag highlighted in the due diligence cannot be mitigated. <\/p>\n
The company states that it has a separate policy entitled \"Verification of counterparties in JSC \"RTI\u201d, although this document is not publicly available.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company requires all suppliers to adhere to its Anti-Corruption Policy and that it includes anti-corruption clauses in contracts with suppliers. The Anti-Corruption Policy prohibits foreign and domestic bribery, facilitation payments, and contains information on whistleblowing channels open to third parties. <\/p>\n
However, there is no publicly available evidence of the practical measures it employs to assure itself of the strength of suppliers\u2019 anti-corruption programmes, neither at the onboarding stage of the business relationship or when there is a significant change in the business relationship. There is also no evidence that the company requires that suppliers have policies covering conflicts of interest and gifts and hospitality.<\/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 evidence that the company acknowledges the corruption risks associated with the use of agents. However, there is no evidence that it has a sufficiently clear policy covering the use of agents.<\/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 prior to engaging third parties, intermediaries and agents. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that agents and highest risk intermediaries are subject to enhanced due diligence, or that following onboarding 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":"0","comments":"
There is no evidence that the company aims to establish the beneficial ownership of its agents. There is also no evidence that the company makes a commitment to not engaging or terminating its engagement with agents or intermediaries if beneficial ownership cannot be established.<\/p>\n"},{"question":91,"commitment_area":13,"score":"1","comments":"
The company states that it includes anti-corruption clauses in its contracts with agents and intermediaries. However, there is no evidence that the company explicitly includes audit and termination rights in its contracts with these entities.<\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, the company makes no specific mention of 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":"
The company does not publish any details of the agents currently contracted to act for or and 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":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence into joint venture partners. However, there is no evidence that the company\u2019s due diligence procedures include checks on the ultimate beneficial ownership of the partner company. Also, 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, or that due diligence is conducted at least every two years throughout the business relationship following the onboarding process.<\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in all of its joint ventures and states that it will work alongside joint venture partners to implement an anti-corruption programme with policies equivalent to its own. There is evidence that the company includes anti-corruption clauses in counterparty contracts.<\/p>\n"},{"question":102,"commitment_area":13,"score":"1","comments":"
There is evidence that the company commits to take an active role in preventing bribery and corruption in its joint ventures but there is insufficient evidence with regards to the practical measures it has in place to achieve this.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the corruption risks associated with offset contracting are addressed, or that the company has a dedicated body, department or team that is responsible for monitoring of the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
The company states that it performs due diligence on all business partners and third parties, but there is no evidence of specific reference to offset obligations or contracts.<\/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 employees must adhere to anti-corruption legislation of the countries in which they do business. However, the company receives a score of \u20180\u2019 because there is no evidence that it acknowledges the corruption risks of operating in different markets. There is also no evidence that risk assessment procedures are used to inform the company\u2019s operations in high risk markets.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of subsidiaries and holdings, however, it is unclear if this represents all of the company\u2019s holdings. There is no evidence that the company publishes information on percentage ownership or countries of operation and incorporation for each entity. In addition, it is not clear how frequently the list of subsidiaries and holdings is updated.<\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses that it is part of another company, but there is no further evidence with regards to its ownership. Furthermore, the company does not disclose details of its ownership in an open data format and there is no ownership information published in a central public register.<\/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":"
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\/874","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=874"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=874"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}