There is evidence that the company publishes a Code of Conduct containing a public statement from its CEO emphasising the company\u2019s commitment to 'integrity' and high ethical standards. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the CEO\u2019s statement directly mentions or addresses its stance against bribery and corruption within the organisation. In addition, the Code of Conduct contains a general directive to avoid bribery and corruption and comply with anti-corruption laws, rather than a clear and proactive stance against corruption.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company\u2019s Code of Conduct prohibits involvement in corruption and that this applies to all employees and board members. <\/p>\n
The company receives a score of \u20181\u2019 because there is no publicly available evidence that the company clearly prohibits bribery, payments to public officials, commercial bribery and\/or facilitation payments. It is also not clear whether the company\u2019s stance applies to subsidiaries and other controlled entities.<\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that a designated board committee \u2013 the Risk Oversight Committee \u2013 is ultimately responsible for the oversight of the company's ethics and compliance programme, which includes anti-bribery and corruption. There is also evidence that the Committee has the authority to require that any necessary changes to the programme are made. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the committee\u2019s responsibilities include monitoring and reviewing reports from management on the programme\u2019s performance.<\/p>\n"},{"question":57,"commitment_area":7,"score":"0","comments":"
There is no clear evidence that a senior executive or managerial-level employee has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption policy or programme. There is evidence that the Chair of the Risk Oversight Committee is responsible for leading the group in monitoring and overseeing the company\u2019s ethics and compliance activities, but it is not clear who is responsible for the day-to-day implementation and management of the programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company has a formal risk assessment procedure in place which is used to inform the company\u2019s anti-corruption programme. The company provides some information to indicate that it conducts risk management activities, but there is no further evidence to indicate that such assessments account for bribery and corruption risks, nor that the results are used to inform and update the company\u2019s anti-corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company\u2019s anti-bribery and corruption programme is subject to regular audit or review to ensure the entire programme is consistent with best practice and the business risks facing the company. There is evidence that this includes receiving reports from management\u2019s reviews of compliance. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that its anti-bribery and corruption programme specifically is subject to a formal audit or review process, nor is it clear that such reviews take place at least every two years. There is no evidence that audit findings related to the programme are presented to the board, and ownership of the process is unclear. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, and that there is a specific procedure in place to deal with whistleblowing cases. In addition, there is evidence that the Risk Oversight Committee is responsible for overseeing and handling complaints involving executive officers and other senior individuals such as the General Counsel and independent directors. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not publish further information on its investigative procedures for complaints involving non-executive individuals, such as employees and management. In addition, there is no evidence that investigations are handled by an independent team, nor that evidence that information on each investigation is documented and summary information on cases shared with a central body. There is also no evidence that the company makes a commitment 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 takes steps to ensure the quality of its internal investigations. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s investigative procedure includes a commitment to report material findings from internal investigations to the board or to relevant authorities, if necessary. <\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical, bribery or corruption investigations or the disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"0","comments":"
There is no clear publicly available evidence that the company provides training on its anti-bribery and corruption policy or programme to all employees. The company indicates that directors and senior executives receive ethics training, however it is not clear that the company provides training to all employees at all levels. <\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company provides tailored anti-bribery and corruption training to different employees based on an assessment of their role and exposure to corruption risk. The company indicates that directors must undertake ethics training but it is not clear that this training is specifically tailored to their role, nor is there evidence that the company provides training to the other categories of employees listed in the question.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company measures or reviews the effectiveness of its anti-corruption communications or training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s incentive schemes for employees incorporate ethical or anti-bribery and corruption principles. Although the company publishes some information about its approach to executive compensation, there is no evidence that this involves promoting ethical behaviour and discouraging corrupt practices.<\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is some evidence that the company encourages employees to act with integrity and report alleged misconduct; however there is no clear evidence that the company commits to support and protect those who refuse to act unethically, nor that it assures itself of its employees\u2019 belief in this commitment. <\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is evidence that the company has a policy of non-retaliation against whistleblowers and employees who report bribery and corruption concerns. However, there is no evidence that this policy extends to third parties and joint venture partners, nor is there evidence that the company takes steps to assure itself of its employees\u2019 belief in this statement. <\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides multiple whistleblowing and advice channels for employees to report concerns and seek advice about its anti-corruption programme. The company indicates that these channels allow for anonymous and confidential reporting if necessary, and there is evidence that they are sufficiently varied to allow employees to raise concerns across the management chain and to an external reporting system run by an independent third party provider. <\/p>\n
Although the company does not explicitly state that these channels are available to employees of third parties, suppliers and joint ventures, there is evidence that the hotline and online reporting system may be accessed by any such individual. The online system also contains a function to change the language, making it accessible to employees in all relevant languages and jurisdictions. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company formally addresses conflict of interest risks. There is evidence that the company\u2019s Code of Conduct states that conflicts should be avoided if possible and makes specific reference to conflicts arising from other employment, and that this applies to all employees and board members. In its publicly available additional guidance for executive directors and board members, the company refers to both actual and perceived conflicts. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it addresses the potential corruption risks arising from other categories mentioned in the question guidance, such as employee relationships, government relationships and financial interests. There is also no evidence that actual, potential and perceived conflicts are considered for employees as well as board members, nor is there evidence that this policy applies to subsidiaries and other controlled entities. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is some evidence that the company has procedures to identify, declare and manage conflicts of interest, including actual and perceived conflicts. There is evidence that the company\u2019s Risk Oversight Committee is responsible for managing conflicts of interest involving the company\u2019s executive management and board, who may be subject to disciplinary measures for breaking the policy. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear whether this also applies to conflict of interest cases involving employees, or whether this is undertaken by a separate body. Additionally, there is no evidence that the company mentions examples of criteria for recusals from conflicts of interest, nor is there evidence that declarations are held in a dedicated register accessible by those with oversight of the process. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure to regulate the employment of current or former directors, employees or consultants from the public sector. <\/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 evidence that the company has a policy on political contributions, which allows for such expenditures relating to the United States political process and when they are in the interest of the company. There is evidence that corporate political contributions are overseen by the Board of Directors, the Government Affairs Office and senior company leaders, and are reviewed on an annual basis by the Risk Oversight Committee (formerly the Ethics and Corporate Responsibility Committee). Based on publicly available evidence, employees are permitted to make personal political donations with approval from Government Affairs, as well as through the company\u2019s voluntary Political Action Committee (VPAC). The company states that the VPAC is non-partisan, chaired by a senior executive with legal expertise and governed by a committee of senior business leaders.<\/p>\n
Since the company does not prohibit political donations and is associated with a PAC, it receives a score of \u20180\u2019 in line with the scoring criteria.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of its corporate political contributions on its website. In addition, the company states that VPAC, state and local political contributions are disclosed to the relevant bodies in the United States as required by law, but there is no evidence that the company provides a direct link to these disclosures.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy and\/or procedure covering charitable contributions or sponsorships, nor that it publishes details of such expenditure. The publicly available Risk Oversight Committee Charter indicates that the company makes (or can make) contributions to charitable and other tax-exempt organisations, but there is no evidence of controls in place to prevent these donations from being used as vehicles for bribery and corruption. <\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a policy on lobbying. However, the company receives a score of \u20181\u2019 because there is no evidence that it provides a clear definition of what it considers to be responsible lobbying practices, and the specific controls or guidelines to regulate lobbying are unclear. It is also not clear whether the policy on lobbying applies company-wide to all employees, board members and third parties engaged in lobbying activities on the company\u2019s behalf.<\/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. The company states that it submits reports on its lobbying activities as required under the Lobbying Disclosure Act, but there is no evidence that it provides any further information on these activities. The company\u2019s approach to lobbying in other jurisdictions is also unclear. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of its global lobbying expenditure. The company states that it discloses its lobbying expenses for the United States as required under the Lobbying Disclosure Act, but there is no evidence that this information is proactively disclosed on the company\u2019s website. Moreover, there is no evidence that the company provides details of its lobbying expenditure in other jurisdictions nor does it state that it does not engage in such activities outside of the United States.<\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on gifts and hospitality. The publicly available Code of Conduct makes reference to a policy on the giving and receiving of gifts and hospitality, and warns against gifts that may be perceived as favourable treatment, but further details on this policy do not appear to be publicly available. <\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is no publicly available evidence 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":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its supply chain. The company states that its Risk Oversight Committee monitors the company\u2019s policies and practices with regard to third-party risk, but no further information on these policies and practices is publicly available.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. There is evidence in its publicly available Supplier Code of Conduct that the company sets minimum anti-corruption standards and requires suppliers to have policies in place that prohibit bribery and facilitation payments, as well as procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. There is evidence that the company assures itself of this by requiring suppliers to sign the Supplier Code of Conduct at the start of the contractual relationship, and by noting that any violations could result in termination of the business relationship. <\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is evidence that the company takes steps to ensure that its suppliers\u2019 sub-contractors have adequate anti-bribery and corruption programmes in place, by detailing minimum standards expected 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. <\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company has a policy covering the use of agents. There is some indication that the Risk Oversight Committee monitors the company\u2019s policies and practices with regard to third-party risk but it does not provide further publicly available information on these policies. Although there is evidence that the Risk Oversight Committee Charter covers the retention of advisors, it is not clear whether this covers business agents and intermediaries as defined in this assessment.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its agents or intermediaries. The company states that its Risk Oversight Committee monitors the company\u2019s policies and practices with regard to third-party risk, but it does not provide further publicly available information on these policies and practices.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents and intermediaries. There is no evidence that the company commits to not engaging or terminate its engagement with agents or intermediaries if beneficial ownership cannot be established. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. The company provides some information on the standards of conduct that it expects from its suppliers, but it is not clear that this definition includes agents and intermediaries, nor does the company provide further information on contractual clauses with these entities. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption, nor that incentive structures are recognised as a risk factor in agent behaviour. The company\u2019s publicly available Risk Oversight Committee Charter includes some information on the retention of agents but it is not clear whether this covers business agents and intermediaries as defined in this assessment.<\/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 the associated disciplinary actions involving its agents. <\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures. The company indicates that its Risk Oversight Committee monitors its policies relating to third-party risk, however there is no further publicly available information regarding this policy or whether it includes joint ventures.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. <\/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 its joint ventures. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence to suggest that a dedicated body, department or team is responsible for the monitoring of the company's offset activities. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. There is evidence that the company expects its suppliers to conduct due diligence on offset agreements, however it is not clear whether the company has procedures in place to conduct checks on its own offset arrangements. <\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details on the offset agents, brokers or consultancy firms currently contracted to act with and\/or on its behalf. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details on its offset obligations or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company acknowledges the corruption risks of operating in different markets, beyond abiding with applicable laws and regulations. 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 direct link to its annual 10-K filing to the United States Securities and Exchange Commission, which includes a list of its subsidiaries. The list includes the jurisdiction of incorporation for each entity.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence to indicate that this represents a comprehensive list of all the company\u2019s fully and non-fully consolidated holdings. There is also no evidence that the company publishes its percentage ownership for each entity, nor the country or countries of operation. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the New York Stock Exchange (\u2018NYSE\u2019) and therefore it is not required to disclose further information on its beneficial ownership in order to receive a score of \u20182\u2019.<\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
There is evidence that the company publishes a breakdown of its sales by major customer, to indicate that the United States government accounted for 97% of its sales in the most recently reported financial year. The company discloses that the main agencies it supplies are the U.S. Army, U.S. Navy and \u201cother\u201d entities within the U.S. Department of Defence, thereby indicating that this figure includes defence sales. <\/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\/880","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=880"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=880"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}