There is evidence that the company has an anti-corruption policy, which was signed off by the company\u2019s General Director at the time. However, the company scores \u20181\u2019, because while there is evidence that the company\u2019s anti-corruption policy is approved by its leadership, there is no evidence that the company publishes a clear statement or message made by an appropriate senior figure either promoting its anti-corruption policy or against corruption in general.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company has an anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, commercial bribery and payments to public officials. However, the company receives a score of \u20181\u2019 because there is no clear evidence that the policy applies to board members or non-executive directors. Based on publicly available information, the company\u2019s policy also does not explicitly prohibit facilitation payments.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that the company\u2019s Audit Committee oversees the company\u2019s anti-bribery and corruption programme. However, based on publicly available information, there is insufficient evidence to suggest that it engages in formal oversight functions, such as reviewing reports from management on the programme\u2019s performance. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that a designated senior executive, the Deputy Chief Security Officer, has ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. However, the company receives a score of \u20181\u2019 because there is no clear evidence that this individual has a direct reporting line to the company\u2019s board of directors. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has a bribery and corruption risk assessment procedure that informs the design of the anti-bribery and corruption programme. However, the company receives a score of \u20181\u2019 because there is no evidence that the assessment is updated on an annual basis nor that the results are reviewed at board level. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is evidence that the company\u2019s Audit Committee reviews the company\u2019s anti-bribery and corruption programme. However, the company receives a score of \u20180\u2019 because there is no clear evidence that the results of such reviews are used to modify and update the anti-corruption programme. It is also unclear how frequently reviews take place.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
The company publicly commits to investigating incidents, and there is evidence that the company has procedures for dealing with whistleblowing cases, which stipulate documentation and actions to be taken at each step. The company indicates that its Security Directorate reviews summary data on investigations, although it is unclear how frequently such reviews are conducted.<\/p>\n
Based on publicly available information, the company receives a score of \u20181\u2019 because there is no evidence that investigations are handled by an independent team and\/or report to an independent board member. There is also no publicly available evidence that the company commits to providing whistleblowers with updates on the outcome of investigations.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company assures itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company makes a commitment to report material findings of bribery and corruption from investigations to its General Director. The company indicates that the General Director is responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if found necessary. However, the company scores \u20181\u2019 as there is no evidence that it commits to reporting findings to members of the wider board. <\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company publishes some data on the number of reports it receives via its reporting channels, including its whistleblowing line. There is evidence indicating that the company publishes this data every six months. <\/p>\n
However, the information that the company publishes does not cover all of the specific measures described in score \u20182\u2019, such as the number of investigations launched or the number of disciplinary actions taken as a result of investigation findings. Based on publicly available information, it is also not clear whether the data applies to employees at all levels, including board members or other executives.<\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company provides anti-bribery and corruption training to its employees. The company states that it carries out preventative measures to minimise the risk of corruption across the company without making any specific reference to training programmes. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company provides anti-bribery and corruption training to its employees.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company measures or reviews the efficacy of its anti-bribery and corruption communications or training programme. There is evidence that the company makes a general commitment to review the effectiveness of anti-corruption measures but it makes no specific reference to a communications and training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company commits to support or protect employees who refuse to act unethically, even when it might result in a loss of business. <\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
The company\u2019s parent company (Rostec) publishes a policy on its whistleblowing hotline which states that no employee in the corporation or third party who makes a corruption allegation using the service can be subject to sanction. This policy is published on the company\u2019s own website. <\/p>\n
However, the company scores \u20180\u2019 as there is no clear evidence that the policy on non-retaliation applies to both whistleblowers and employees who report bribery and corruption incidents by other means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company maintains several whistleblowing channels alongside policies which guarantee employees anonymity and confidentiality when making reports. There is some evidence that these channels are open to third parties, although the company does not explicitly refer to employees of suppliers or joint venture partners.<\/p>\n
The company receives a score of \u20181\u2019 because, based on publicly available information, the company only appears to offer internally operated whistleblowing channels and no advice channels. There is also no clear evidence that the channels are available to all employees in any country of operation, or in multiple languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy which addresses actual and potential conflicts of interest. There is evidence that this policy covers personal relationships and financial interests and applies to all employees of the company. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the policy covers conflicts of interest associated with government relationships or other employment. It also does not refer to perceived conflicts of interest and there is no clear evidence that the company\u2019s policy applies to board members. <\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has procedures to identify, declare and manage conflicts of interest. The company indicates that potential or actual conflict of interest declarations are reviewed and overseen by its Commission for the Regulation of Conflicts of Interest, a designated body which has ultimate accountability for handling individual cases. There is evidence that this body records all employee and board member declarations of actual and potential conflicts of interest. The description of this procedure also includes examples of criteria for recusals and a description of the disciplinary measures which apply for breaches of the policy.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
Based on publicly available information, there is no 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":"
In publicly available evidence the company states that it does not provide political donations with the aim of obtaining or maintaining a commercial advantage. However, the company receives a score of \u20180\u2019 because the company\u2019s statement does not make it explicitly clear that it prohibits all forms of political donations. In addition, based on publicly available information, there is no evidence of control or oversight mechanisms related to the company\u2019s political donations, such as a requirement for approval by an individual with legal expertise.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company discloses details of its political contributions. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company has a policy and\/or procedure covering both charitable donations and sponsorships.<\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, 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 publishes details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. There is evidence that this policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. There is evidence that all gifts and hospitality are recorded in a dedicated register that is accessible to those responsible for oversight of the process. <\/p>\n
However, there is no evidence that the company explicitly addresses the corruption risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials and therefore it does not fulfil the criteria to score \u20182\u2019.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s parent company (Rostec) maintains a policy stipulating the involvement of its procurement department in some capacity, in the establishment of supplier relationships throughout the corporation\u2019s holdings. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether this department is the main body responsible for oversight of the company\u2019s supplier base, nor is there evidence that the involvement of the procurement department is required for establishing any new suppliers over a certain threshold. In addition, there is no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company conducts risk-based anti-bribery and corruption due diligence on its suppliers.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is evidence that the company requires counterparties with which it has business relations to support its Anti-Corruption Policy, which covers prohibitions on bribery and conflicts of interest. It is assumed that these counterparties include suppliers. <\/p>\n
However, based on publicly available information, there is no evidence that counterparties or suppliers are expected to adopt the company\u2019s whistleblowing or gifts and hospitality procedures. There is also no evidence that the company takes active steps to ensure that its suppliers have adequate anti-bribery and corruption policies and procedures in place.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, 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":"
Based on publicly available information, there is no evidence that the company has a policy covering the use of agents.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that shows that the company aims to establish the beneficial ownership of its agents. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
In publicly available evidence the company states that all counterparties must adhere to its anti-corruption policy. However, the company receives a score of \u20180\u2019 because there is no evidence that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company\u2019s incentive structures for agents are designed to minimise risks of bribery and corruption.<\/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 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":"
Based on publicly available information, there is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures, or that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no evidence that the company commits to taking an active role in preventing bribery and corruption in all its joint ventures. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
Based on publicly available information, there is no evidence that the corruption risks associated with offset contracting are addressed, or that a dedicated body, department or team is responsible for monitoring the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
Based on publicly available information, 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 and contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company acknowledges the corruption risks of operating in different markets. However the company scores \u20180\u2019 as there is no clear 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":"2","comments":"
The company publishes a list of all of its consolidated subsidiaries and non-fully consolidated holdings in its Financial Statements and Annual Reports. The company provides the percentage of the share capital it holds in all its subsidiaries as well as the country of incorporation. There is evidence that this data is updated annually, and that the data provided represents all of the company\u2019s holdings and not just principal subsidiaries. According to the company\u2019s statements, all of its holdings operate in the Russian Federation. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company discloses 97.58% of its shareholding, including its sole major shareholder, which is listed as holding 95.83% of the company\u2019s share capital. This information is included in the company\u2019s financial statements. However, there is no evidence that the company\u2019s ownership information is available in a freely available central public register. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes information concerning any of the customers of its defence sales.<\/p>\n"},{"question":111,"commitment_area":16,"score":"0","comments":"
The company publishes some information about the rights of shareholders in its company statutes. There is evidence that the company is 95.83% state-owned by the government of Russia, however there is no indication from this statement that the government is the sole entity that holds shares or voting rights. There is no evidence that the company provides a breakdown of its shareholder voting rights of its shareholders, so it therefore receives a score of '0'.<\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
The SOE publishes information about its objectives. However, the company receives a score of \u20181\u2019 because it is not clear whether these objectives are updated on at least an annual basis.<\/p>\n"},{"question":113,"commitment_area":16,"score":"1","comments":"
The SOE publishes information about the composition of its board, stating the current and previous state and commercial affiliations of individual board members. In publicly available information, the company also states that three of its board of directors are independent, although it is unclear which directors this status applies to. <\/p>\n
The company scores \u20181\u2019 as there is no evidence that it publishes information on the nomination and appointment process for board members. <\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
In publicly available evidence the company states that where possible an independent member of the board will be elected as Chairman of the Audit Committee. However, there is no evidence that the company discloses any further information on the composition of its Audit Committee and there is no evidence that a majority of directors are independent. <\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
Based on publicly available evidence, there is no evidence that the SOE published any 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\/878","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=878"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=878"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}