The company publishes an Anti-Corruption Policy which demonstrates the company's commitment to anti-bribery and corruption, but there is evidence that this is authorised by senior figures other than the Company Leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an Anti-Corruption policy, which applies to all employees and managing directors, as well as the staff and leadership of all subsidiaries and other controlled entities. The company\u2019s policy explicitly prohibits bribery, commercial bribery and payments to public officials.<\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that the company specifically prohibits facilitation payments, nor is there evidence that its Anti-corruption policy explicitly applies to non-executive directors of the company. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
Based on publicly available evidence, the General Director, who is a member of the Board of Directors, oversees the company\u2019s anti-bribery and corruption programme. However, there is no evidence to suggest that the General Director engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
There is evidence that a managerial-level individual, the Head of the company\u2019s Department of Internal Control, has been assigned responsibility for implementing and managing the company's anti-bribery and corruption programme, but he is not a senior executive. There is some evidence that this individual has a reporting line to the General Director, who provides oversight of the anti-bribery and corruption programme.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-corruption and bribery programme. However, there is no evidence that corruption risk assessments are reviewed on at least an annual basis, or that the results of 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 a regular internal audit process to ensure the programme is consistent with best practice and the business risks facing the company. The evidence suggests that periodic external audits are also conducted. The company states that the General Director is provided with an analysis of audit findings, and that the Department of Internal Control is responsible for implementing required changes. However, it is not clear how frequently audits are conducted. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
The company publicly commits to investigating incidents, and there evidence that a procedure is in place to deal with reports. There is evidence that investigations are handled by the Department of Internal Control, which reports to the General Director. Publicly available information clearly stipulates the documentation which should be provided as part of the report and some of the actions that should be taken in response. <\/p>\n
However, the company\u2019s description in publicly available information of its investigative procedure does not cover the whole investigation process from receipt to final outcome and there is no evidence that the company commits to providing whistleblowers with updates on the outcome of investigations. It is also not clear whether summary information of investigations is reviewed by a central body, nor whether a central body reviews the status of investigations on at least an annual basis.<\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company assures itself of the quality of its internal investigations.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
The company makes a clear commitment to report material findings of bribery and corruption from investigations to the General Director, a member of the company\u2019s board. The company states that the General Director is 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":"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":"0","comments":"
There is insufficient evidence to suggest that the company provides anti-bribery and corruption training to all employees.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that 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":"1","comments":"
The company states that it takes into account whether employees have complied with the Anti-Corruption Policy when considering employees for promotion. However, information is lacking on the breadth of the scheme and how financial incentives in high risk departments are handled. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company commits to support employees even where such actions result in a loss to the company.<\/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, without making an explicit statement that this commitment also applies to individuals employed by the group as third parties, suppliers and joint venture partners. <\/p>\n
There is no evidence that the company assures itself of its employees\u2019 confidence in its non-retaliation commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is clear evidence that the company has multiple channels to report instances of suspected corrupt activity, which allow for confidential reporting. However, there is evidence that the company only offers internally operated channels, and it is not evident that the company offers advice channels alongside whistleblowing channels, or anonymous reporting channels. The company also does not state that its channels are explicitly available to all employees in any country of operation, or in multiple languages, or to any employees of third parties, suppliers or joint venture partners. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is evidence that the company formally addresses conflict of interest as a corruption risk and has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly makes reference to conflicts concerning personal relationships, financial interests and outside employment. <\/p>\n
However, there is no evidence that the company mentions potential conflicts concerning government relationships. Also, while the company states that its policy applies to all employees, it does not explicitly mention board members or employees of subsidiaries and joint venture partners. <\/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. There is evidence that employee declarations of actual and potential conflicts of interest are recorded and reviewed by a designated body, the company\u2019s Department of Internal Control, which has ultimate accountability for the implementation of this policy and the handling of individual cases. The company also describes, examples of criteria for recusals and potential punitive measures for breaches of the policy. <\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has a policy governing the appointment of 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 no evidence that the company has a policy covering political contributions. <\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes details of political contributions made by the company and its subsidiaries.<\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
The company states that it employs oversight and control mechanisms to ensure that its charitable donations are not used for corrupt purposes, without providing any further details in publicly available evidence. <\/p>\n
There is no evidence that the company maintains a policy regarding sponsorships to ensure that they too are not used for corrupt purposes. Furthermore, there is no evidence that the company publishes details of charitable donations made, such as the amount or details of the recipients. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy covering 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 publishes any details about its 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. As part of this, the company explicitly addresses the risks associated with gifts and hospitality given to and received from domestic or foreign public officials. <\/p>\n
However, the policy does not specify financial or proportional limits or different approval procedures for different types of promotional expenses. There is also no 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 Procurement Commission is involved, in some capacity, in the establishment and oversight of supplier relationships. There is evidence that this Commission is the main body responsible for oversight of the company\u2019s supplier base and that its involvement is required for establishing any new suppliers over a certain threshold.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company assures itself of the Procurement Commission\u2019s involvement at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company conducts anti-corruption based due diligence on its supply chain.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company requires its suppliers to comply with its own business ethics and it states that it conducts checks on the strength of suppliers\u2019 and other third parties\u2019 anti-corruption procedures and policies. <\/p>\n
However, the company does not explicitly state that all suppliers must have, at least, policies that prohibit foreign and domestic bribery, prohibit facilitation payments, and\/or policies that cover conflicts of interest, gifts & hospitality, or whistleblowing. In addition, there is no evidence that the company assures itself of this for all suppliers, or that this assurance is conducted when onboarding new suppliers and\/or when there is a significant change in the business relationship.<\/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":"
While the company acknowledges the corruption risks associated with having business relations with external consultants and other persons, there is no evidence of a clear policy which covers the use of agents. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
While the company states that it checks the willingness of third parties to comply with ethical business conduct, there is no evidence which suggests that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on its agents or intermediaries.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company aims to establish the ultimate beneficial ownership of its agents or intermediaries. <\/p>\n"},{"question":91,"commitment_area":13,"score":"1","comments":"
There is some evidence that the company requires third parties to comply with its own business ethics and that it conducts checks on the strength of third parties\u2019 anti-corruption procedures and policies. The company states that counterparties are subject to anti-corruption clauses in their contracts, however there is no evidence that it includes audit and termination rights in contracts with agents and intermediaries. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company acknowledges incentive structures as a risk factor in agent behaviour and there is no evidence that the company's incentive structures for agents are designed to minimise risks of anti-bribery and corruption.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes details of the agents contracted to work for 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":"
While the company states that it checks the willingness of third parties to comply with ethical business conduct, there is no evidence which suggests that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence on its joint ventures.<\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company requires third parties to comply with its own business ethics and that it conducts checks on the strength of third parties\u2019 anti-corruption procedures and policies. The company states that counterparties are subject to anti-corruption clauses in their contracts, however it is not clear whether this includes joint ventures. Overall, there is insufficient 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 all of its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no evidence that the corruption risks associated with offset contracting are addressed, and there is no evidence that a dedicated body, department or team is responsible for monitoring of the company's offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company\u2019s offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of its offset obligations or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company acknowledges the corruption risks of operating in different markets, or 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 Group Companies. However, it is not expressly clear if the list provided represents all of the company\u2019s holdings, rather than just the company\u2019s principal or significant subsidiaries, associates and joint ventures. In addition, there is no evidence that the company publishes the percentages owned, country of incorporation or countries of operation for each entity. There is also no evidence that the company makes a statement that it is complete at the time of publication to the best of the company\u2019s knowledge, and there is no publicly available information regarding when the list was last updated.<\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company\u2019s publicly available charter, which was written in 2002, states that the company was 100 percent state owned, and there is no evidence to suggest that this has changed. However, 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":"
The company states that a major area of its activities is servicing the Russian defence ministry. However, the company receives a score of \u20180\u2019 because there is no evidence that it discloses at least 50% of its defence sales by customer.<\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
The company states that shareholders are granted the same proportion of voting rights. The evidence also suggests that the company is 100% owned by the Russian Federation and therefore there are no other shareholders. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":112,"commitment_area":16,"score":"1","comments":"
The SOE's commercial and public policy objectives are made publicly available on its website. However there is no clear evidence that this information is updated on at least an annual basis or whenever there is a change in objectives.<\/p>\n"},{"question":113,"commitment_area":16,"score":"1","comments":"
The SOE publishes clear information about the composition of its board, identifying each director as either a state official or a company executive. It also discloses some details of its nomination process, however there is evidence that the selection criteria is given in a separate document entitled Regulations on the Board of Directors, which is not publicly available. <\/p>\n"},{"question":114,"commitment_area":16,"score":"0","comments":"
There is no evidence that the SOE has an audit committee.<\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
There is evidence that the SOE has a system in place to manage asset transactions, with responsibility held at board level. However, it is unclear whether asset transactions are subject to scrutiny by an audit body. Furthermore, the company does not clearly state that all transactions are documented, and there is no evidence that the company publishes the financial results from asset acquisitions in its reports.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/883","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=883"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=883"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}