There is evidence that the company has a publicly stated commitment to anti-bribery and corruption, which details the company's stance against any form of bribery or corruption within the organisation. It is clear that this commitment is authorised and endorsed by the company's CEO and General Counsel. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes a formal and clearly stated anti-bribery and corruption policy, which specifically prohibits bribery, commercial bribery, payments to public officials, and facilitation payments. The policy clearly 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":"
There is evidence that the Audit Committee and Board of Directors are ultimately responsible for providing oversight of the company's anti-bribery and corruption programme. This includes reviewing reports from management on the programme\u2019s performance, along with the results of internal and external audits, and there is evidence that these bodies have the authority to required that changes to the programme are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior executive has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. It is clear that this person has a direct reporting line to the board and the Audit Committee, which jointly provide oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure in place that informs the design of its anti-bribery and corruption programme. The company indicates that the results of risk assessments are reviewed by the board on at least an annual basis, or when the results of the risk assessments reveal significant findings. There is evidence that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
There is some evidence that the company\u2019s anti-bribery and corruption programme is subject to regular review, including internal and external audits. The company indicates that the results of these audits are presented to the board and then used to ensure that the programme is consistent with best practice and the business risks facing the company. The company also states that it reviews and adapts all anti-corruption related processes and policies at least every three years, or as regulatory requirements demand, with the company\u2019s compliance department holding responsibility for implementing required changes. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a system for tracking, investigating and responding to bribery and corruption allegations or incidents, including those reported through whistleblowing channels. The company indicates that it takes steps to ensure the independence of its investigations and that it commits to ensure whistleblowers are informed of the outcome, if they so wish. For whistleblowing cases, there is evidence of a procedure in place that stipulates documentation and actions to be taken at every step of the case, from receipt to final outcome. There is evidence that the company\u2019s Board of Directors, Audit Committee and Group Executive Board receive summary information of all investigations on a quarterly basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company assures itself of the quality of its investigations. The company states that the Vice President Compliance & Risk Management and the responsible Compliance Officer conduct investigations, with support from the General Counsel. There is evidence that the company may involve external lawyers and specialised external audit or IT forensic service providers in complex investigations. In addition, the company indicates that it reviews its investigations procedure as part of a wider periodic review of its anti-corruption programme at least every three years or in response to changes in the regulatory environment. <\/p>\n
However, there is no evidence that the company has a procedure in place to receive or handle any complaints about the investigation process.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company commits to reporting material findings of bribery and corruption from investigations to the board. In addition, there is evidence that the Vice President Compliance & Risk Management and General Counsel are ultimately responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if found necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
The company publishes high-level information on its ethics and compliance-related incidents and investigations, involving company employees at all levels. The company provides details on the number of reports received, including those received through whistleblowing channels, the number of investigations launched, and the number of disciplinary actions as a result of investigation findings. There is evidence to suggest that this data is updated and published on an annual basis.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training for its employees that outlines the principles of the anti-bribery and corruption policy, including the whistleblowing options available. The company indicates that it provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. There is evidence that employees are required to undertake refresher courses or modules on the anti-bribery and corruption programme at least every three years.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides tailored anti-bribery and corruption training to its employees based on the different levels of risk facing those in different roles. The company makes specific reference to specialised training for employees in high risk positions, middle management and board members. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that employees in high risk positions are required to undertake tailored refresher training on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is some evidence that the company measures and reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme on a regular basis. The company indicates that it undertakes dedicated employee surveys and measures the number of compliance-related inquiries in a year, as well as measuring completion rates of its anti-bribery and corruption e-learning course. There is evidence that the results of these reviews and surveys are used to update specific parts of the training programme, with the entire programme subject to a comprehensive review at least every three years.<\/p>\n"},{"question":67,"commitment_area":9,"score":"2","comments":"
There is evidence that the company\u2019s incentive schemes for employees are designed in such a way that they promote ethical behaviour and do not undermine its commitment to anti-bribery and corruption. Where financial rewards are part of its incentive scheme, the company indicates that any performance-based incentives are proportionate to the employee\u2019s salary. In addition, the company indicates that its employee incentives are based on performance reviews and regular feedback sessions. Although the company does not explicitly mention employees in high risk roles, there is clear evidence that the company ensures that incentives are proportionate for employees in sales roles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company commits to support and protect employees who refuse to act unethically. The company states that employees must adhere to its code of conduct and indicates that neglecting this to secure business is against its values, but there is no clear evidence that it commits to support and protect its employees to do the right thing. <\/p>\n"},{"question":69,"commitment_area":9,"score":"2","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. The company\u2019s policy applies to all employees across the organisation, as well as external employees and third parties who use its whistleblower system. There is evidence that the company assures itself of its employees\u2018 confidence in this commitment through usage data. <\/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 its anti-bribery and corruption programme. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain and to external bodies through an independently operated hotline. The company indicates that these channels allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
In addition, there is evidence that the company\u2019s reporting channels are available and accessible to all employees in all jurisdictions where it operates, including to external parties such as employees of suppliers and joint venture partners, and in all relevant languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflicts of interest as a corruption risk, and that it has a clear policy that defines conflicts of interest, including those actual, potential and perceived. It is clear that the company\u2019s policy covers possible conflicts arising from employee relationships, government relationships, financial interests and other employment. The company indicates that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has procedures in place to identify, declare and manage conflicts of interest, including those actual, potential and perceived. This includes a statement that all employee and board member declarations of actual and potential conflicts of interest are recorded in a dedicated central register that is accessible to those responsible for oversight of the process. <\/p>\n
In addition, there is evidence that a designated body is responsible for monitoring all conflicts of interest, while relevant managers are accountable for the handling of individual cases. The company\u2019s description of this procedure includes examples of criteria for recusals and it states that disciplinary consequences may apply if the policy is breached.<\/p>\n"},{"question":73,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has a policy regulating the employment of current or former public officials. The company requires compliance officer approval before the initiation of any employment discussions with former or current public officials who pose an actual, potential or perceived conflict of interest. In addition, the company states that if employment is approved, that a further review will take place to determine whether a conflict of interest exists, and if so, what restrictions are appropriate to place on their activities. <\/p>\n
Although the company does not provide any information on cooling off periods, there is evidence to indicate that such a procedure would conflict with the Swiss political system and therefore the company is exempt from this requirement.<\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company publishes details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company publishes a clear statement that it does not make any contributions to political parties. It is noted that in the Swiss political system, it is only possible to make contributions to political parties and not to individuals. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not make any contributions to political parties and it 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 policy and procedure on both charitable donations and sponsorships. This policy includes measures to ensure that donations are not used as vehicles for bribery and corruption, by specifying criteria for donations and procedures for senior sign-off. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes details of its charitable donations and sponsorships on an annual basis, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on lobbying, nor does the company publish a statement that it does not engage in such activities.<\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any information on its lobbying aims, topics or activities.<\/p>\n"},{"question":81,"commitment_area":11,"score":"2","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. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy clearly addresses the risks associated with gifts and hospitality given to and received from domestic and foreign public officials by requiring a different approval procedure. <\/p>\n
In addition, the company indicates that all gifts and hospitality offerings 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":"0","comments":"
There is no publicly available evidence to indicate that the company requires the involvement of its procurement department in the establishment and oversight of its supplier base.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company conducts anti-bribery and corruption due diligence on its third parties, which includes suppliers. The company indicates that this is based on an assessment of risk, and states this due diligence process may include checks on the company\u2019s shareholders, other affiliated legal entities and natural persons. <\/p>\n
However, there is no publicly available evidence that this process applies to all suppliers, since the company simply refers specifically to third parties supporting sales activities. In addition, there is no evidence that it requires and conducts checks on ultimate beneficial ownership for all suppliers. There is also no publicly available evidence that the company might be willing to review and\/or terminate supplier relationships in circumstances where a red flag highlighted during the due diligence process cannot be mitigated.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company requires its suppliers to follow adequate anti-bribery and corruption policies and procedures. The company indicates that all suppliers must follow its \u2018Code of Conduct for Business Partners of RUAG\u2019 which clearly prohibits bribery and facilitation payments and outlines procedures for dealing with conflicts of interest, gifts and hospitality and whistleblowing. There is evidence that the company includes termination rights in its contracts with suppliers, and the company states that it reserves the right to monitor existing or new business partners for compliance with its code of conduct. <\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
There is evidence that the company takes steps to ensure that sub-contractors in its supply chain have adequate anti-bribery and corruption programmes in place. The company indicates that it expects suppliers to communicate the substance of its \u2018Code of Conduct for Business Partners of RUAG\u2019 in subcontracts throughout the supply chain. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no further publicly available evidence of steps that the company ensures this in practice.<\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or anti-bribery and corruption-related investigations or disciplinary actions relating to its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a clear policy to control the use of agents, which addresses the corruption risks associated with their use and provides details of specific controls to mitigate these risks. As part of this policy, the company commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. This policy applies across the group, including associated companies in which the company has a controlling interest. The company states that it will strive to establish a comparable policy in any affiliated companies.<\/p>\n"},{"question":89,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to engaging and re-engaging with its agents. The company states that high risk agents and intermediaries are subject to enhanced due diligence. The company commits to not engaging or terminating its engagement with agents or intermediaries where the risks identified in the due diligence process cannot be mitigated. In addition, the company indicates that it renews this due diligence at least every three years or whenever there is a change in the business relationship. <\/p>\n"},{"question":90,"commitment_area":13,"score":"2","comments":"
There is evidence that the company establishes the beneficial ownership of its agents and intermediaries as part of its due diligence process. The company indicates that its Compliance department conducts background checks on shareholders of any third parties involved in sales at the start of the contractual relationship and at least every three years or when there is a significant change in the business relationship. <\/p>\n
Where a third party is identified as high risk, the company states that it may require the individual or entity to complete an external questionnaire and indicates that it may require an in-depth background check on affiliated legal entities from an independent organisation. In addition, the company indicates that it will not proceed with the contractual relationship if such information about the third party cannot be verified or if significant red flags are identified.<\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policies apply to all agents and intermediaries. The company publishes a \u2018Code of Conduct for Business Partners of RUAG\u2019, which outlines the anti-bribery and corruption standards applicable to all third parties, and the company\u2019s information on contracts with third parties indicates that all third parties must adhere to its anti-corruption standards. In addition, there is evidence that it includes monitoring and termination rights in its contracts with these parties. <\/p>\n"},{"question":92,"commitment_area":13,"score":"2","comments":"
There is evidence that the company highlights and addresses remuneration to agents as a factor in bribery and corruption risk. The company indicates that it places a threshold on sales-based commissions to agents so that payments do not exceed a proportion of the net fee to the agent. In addition, there is evidence that agents are required to provide quarterly activity reports and payment is only released on submission of these reports. The company also 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":"
There is evidence that the company has formal procedures in place 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 identified as posing higher corruption risks, such as state-owned enterprises. There is evidence that the company conducts anti-bribery and corruption due diligence both prior to entering into a joint venture and on the entity and its activities once established, 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":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in all of its joint ventures, by developing a programme jointly with the relevant partner company. In addition, the company indicates that it will only enter into joint ventures if anti-bribery and corruption clauses are included in the contract, which prohibit foreign and domestic bribery and facilitation payments, as well as specifying audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":102,"commitment_area":13,"score":"2","comments":"
There is evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. The company provides examples of possible controls that it may implement to do so, dependent on the context, such as secondment schemes for compliance officers, veto rights on certain transactions and training for relevant employees and management. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company recognises the corruption risks associated with offset contracting, nor that it has a dedicated body, department or team responsible for monitoring of its offset activities. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is some evidence that the company conducts reviews of its offset partners. However, the company does not provide further publicly available information to indicate whether this includes anti-bribery and corruption due diligence on all aspects of the obligation. There is also no publicly available evidence that the company assesses whether there is a legitimate business rationale for its offset obligations. <\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes information about the beneficiaries of its indirect offset projects. The company publishes some information about its involvement in one offset project, however there is no evidence that it provides comprehensive information on all offset obligations nor that it distinguishes between direct or indirect projects. <\/p>\n"},{"question":107,"commitment_area":15,"score":"1","comments":"
There is some evidence that the company has a dedicated assessment process in place to assess the risks of operating in different markets. However, there is no evidence that the company provides further information on its risk management procedures, nor is it clear that the results of these assessments have an impact on business decisions or trigger the implementation of additional controls. <\/p>\n"},{"question":108,"commitment_area":15,"score":"2","comments":"
There is evidence that the company publishes a list of its fully and non-fully consolidated holdings, along with its percentage ownership for each entity. For each entity, the company publishes the location of its head office and country of incorporation. In addition, the company provides information in narrative form on the countries of operation for its major holdings. Since this information is published in the company\u2019s Annual Report, there is evidence that this list is current and updated on at least annual basis.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company publishes a clear statement that it is wholly owned by the Swiss Confederation, indicating that it is the sole shareholder.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is evidence that the company publishes some information about its defence sales, to indicate that the Swiss Federal Department of Defence is its largest customer. The company indicates that Switzerland accounts for 38% of its net sales, with customers in Europe accounting for 50% of its sales. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no clear evidence that it publishes a breakdown of defence sales per customer for at least 50% of its sales.<\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
There is evidence that the company is wholly owned by the Swiss Confederation, and the company states that this entity holds 100% of its voting rights. Since one single entity holds all of the company\u2019s voting rights, there is no requirement for the company to publish a percentage breakdown and therefore it is exempt from scoring on this question.<\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes information on its commercial and public policy objectives on its website. There is evidence that these objectives are updated on at least an annual basis or whenever there is a change in objectives.<\/p>\n"},{"question":113,"commitment_area":16,"score":"2","comments":"
There is evidence that the company publishes some information about the nomination and appointment process and composition of its board. The company indicates that none of its board members have a material business relationship with the group, and it discloses any other relevant mandates or interests that each member might have. In addition, the company provides publicly available information on how the board is elected and who manages the appointment process, in line with all national regulations. <\/p>\n"},{"question":114,"commitment_area":16,"score":"2","comments":"
There is evidence that the company\u2019s Audit Committee is composed entirely of independent directors. The company indicates this by stating that none of its board members have a material business relationship with the group.<\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
There is evidence that the company has a system in place to manage asset transactions. The company indicates that it has controls in place to ensure that asset transactions correspond with fair market value. The company also publishes the financial results from asset acquisitions in its annual corporate reporting documents. <\/p>\n
However, there is no clear publicly available evidence that responsibility for managing asset transactions is held at board level. It is also not clear whether asset transactions are subject to scrutiny by an audit body.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/876","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=876"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=876"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}