There is evidence that the company has an anti-corruption statement authorised by its senior leadership. However, the company receives a score of \u20181\u2019 because this statement represents a general commitment to comply with anti-bribery laws and principles. The company\u2019s anti-bribery policy sits within its \u2018Standards of Conduct\u2019; however, there is no clear or direct evidence that the Standards of Conduct are endorsed by its leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company has an anti-bribery and corruption policy, which specifically prohibits bribery, illegitimate payments to public officials, commercial bribery and facilitation payments. There is evidence that this policy applies to all employees and directors across all of the Group\u2019s companies. <\/p>\n"},{"question":56,"commitment_area":7,"score":"0","comments":"
There is no publicly available evidence that the company has a designated board committee or individual board member responsible for its anti-bribery and corruption programme. The company indicates that it has a Risk Compliance Committee, which is chaired by the Chief Risk Compliance Management Officer, however it is not clear that this level sits at board-level or whether it is overseen by the board of directors.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that the company\u2019s Chief Risk Compliance Management Officer has ultimate responsibility for implementing and managing the company\u2019s compliance programme, which includes anti-bribery and corruption. There is evidence that this individual is a senior executive and that he\/she has a direct reporting line to the President and Chief Operating Officer. <\/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 that informs the design of its anti-bribery and corruption programme. The company provides some indication that its internal processes include risk management, however it is not clear that this includes anti-bribery and corruption risk nor that the results of specific risk assessments are used to update the programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company conducts audits of its compliance programme on an annual basis. The company indicates that the results of such audits are presented to the board, and there is evidence to indicate that the results of audits are used to review and update compliance measures. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear which committee, team or individual holds responsibility or ownership for planned updates and improvements to the anti-bribery and corruption programme. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company commits to investigate incidents and that it has a specific procedure in place to deal with whistleblowing cases. There is evidence that the company assures itself of the independence of its investigations and that in some instances the informants are informed of the status of the investigation. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available information on the investigation process from receipt to final outcome, nor that the company\u2019s procedure stipulates documentation and actions to be taken at each step. There is also no clear evidence that information from investigations is properly documented, nor that whistleblowers are informed of the outcome of the investigation in every situation. <\/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 by ensuring that staff are properly trained, implementing a system to handle complaints about the procedure, or reviewing its procedure at least every three years. The company indicates that its Audit Committee may engage attorneys or public accountants as part of investigations, but it is not clear that such expertise is present for all cases. <\/p>\n"},{"question":62,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company has an investigative procedure in place that includes a commitment to report material findings to the board or to the relevant authorities, if necessary. <\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company publishes some high-level information on its ethics and compliance-related incidents involving employees. The company publishes the number of reports received through its internal and external reporting channels, and there is evidence that it collects and publishes this information on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes further data on this subject, such as the number of investigations launched or disciplinary actions taken as a result. In addition, it is noted that there is no evidence that this data has been published annually since 2017. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company provides compliance training and awareness activities for employees. The company indicates that this training outlines the basic principles of its Standards of Conduct and clearly states that it covers the whistleblowing and reporting options available to employees. There is some evidence to indicate that the company provides this training to all employees in all group companies, and in all relevant languages. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that employees are required to undertake and refresh their training on anti-corruption on an annual basis. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides tailored anti-bribery and corruption training for employees based on their role and exposure to corruption risk. The company states that senior management and executive officers receive training, and there is some evidence that employees in certain functions receive training on accounting compliance. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the different training provided is tailored based on anti-bribery and corruption risk. There is also no evidence that employees in high risk positions must refresh their training in this area on an annual basis. <\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company reviews its anti-bribery and corruption communications and training programme. The company indicates that it does this through seminars and conversations with employees aimed at preventing compliance violations. <\/p>\n
However, there is no clear evidence that the company conducts such reviews on at least an annual basis, nor is there evidence that the results of such reviews are used to update specific parts of the company's anti-bribery and corruption communications and 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. The company provides some information on its compensation system for directors and executive officers, but there is no evidence that these incentives incorporate ethical principles and they do not apply to all employees. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company publicly commits to support or protect employees who refuse to act unethically. <\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company promotes a policy of non-retaliation against whistleblowers or employees who report bribery and corruption incidents.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides whistleblowing and advice channels for its employees to report concerns and seek advice on its anti-corruption programme. The company indicates that these channels allow for confidential and anonymous reporting. There is evidence that these channels are sufficiently varied to allow employees to raise concerns across the management chain, directly to the Audit Committee and to an external attorney\u2019s office. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that its channels are accessible and available to all employees in all countries of operation, or in multiple languages, or to employees of third parties or joint ventures. The company indicates that it provides a channel for suppliers, however it is not clear how this channel may be accessed.<\/p>\n"},{"question":71,"commitment_area":10,"score":"0","comments":"
There is no clear publicly available evidence that the company has a policy on conflicts of interest. Although the company addresses conflict of interest as a corruption risk, there is no evidence that it defines actual, potential and perceived conflicts. There is also no evidence that the company\u2019s policy applies to all employees and directors, nor that it covers employee relationships, financial interests, government relationships and other employment.<\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has procedures in place to identity, declare and manage conflicts of interest. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy that addresses the risks associated with the employment if public officials. The company commits to follow all applicable laws and regulations, and indicates that it may place restrictions on a former public official\u2019s activities when they join the company. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide any further information on the specific controls that it has in place to mitigate possible corruption risks. There is no evidence that the company requires senior approval before initiating employment discussions with current or former officials, nor that it conducts a full conflict of interest review or implements cooling-off periods. <\/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":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy on corporate political contributions. The company indicates that its employees must not make any direct or indirect contributions to politicians or political parties; however, there is some evidence that the company may make political contributions in some circumstances to support the political process. The company states that it follows applicable laws and there is evidence that it has internal procedures to regulate donations, but these do not appear to be publicly available. <\/p>\n
Since the company does not prohibit political donations, 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 any details of its corporate political contributions, nor does it publish a statement that it has not made any such donations in the most recently reported financial year. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is some evidence that the company has a policy covering both donations and sponsorships, which outlines some basic principles for its community engagement. The company states that its General Affairs Office, which reports into the CEO and COO, is responsible for authorising and overseeing all social contribution activities. In addition, the company provides some details of its charitable contributions made, including its total expenditure divided by category and information on some of its major activities. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes full details of its contributions made, such as details of the recipients, donation amount, country of recipient, and which corporate entity made the payment. It is also not clear that the company\u2019s policy stipulates specific controls such as due diligence on recipients, nor that it publishes data on contributions on an annual basis. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on lobbying. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any clear evidence 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 global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on gifts and hospitality, to ensure that such promotional expenses are not used as vehicles for bribery and corruption. The company indicates that directors and employees should not offer gifts or entertainment to government agencies that may be illegal or prohibited by law, but does not publish further information on the controls and measures that it has in place to reduce corruption risks in the giving or receipt of gifts and hospitality. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company\u2019s procurement department is involved in the management and oversight of its suppliers. However, the company receives a score of \u20181\u2019 because there is no clear evidence that its procurement department is the main body responsible for oversight of its supplier base. 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":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its supply chain. The company outlines its principles for selecting suppliers and indicates that an evaluation must be conducted prior to procurement, but it is not clear that this constitutes due diligence nor that such checks are regular and include anti-bribery and corruption considerations.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies in place. The company indicates that it takes active steps to ensure that all suppliers have adequate policies in place by including such considerations in its selection criteria and publishing details of the international standards that it expects suppliers to follow. In addition, there is evidence that the company makes its whistleblowing channel available to those employed by business partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it requires suppliers to specifically have policies in place that prohibit facilitation payments and procedures to cover risks arising from conflicts of interest or gifts and hospitality. It is also not clear whether the company assures itself of this both when onboarding new suppliers and when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. However, the company receives a score of \u20181\u2019 because it does not provide further details on the steps that it takes to ensure 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 investigations or disciplinary actions involving its suppliers. The company publishes some information on the number of suppliers that received additional guidance or were subject to the suspension of transactions on the basis of human rights and safety and environment, however there is no evidence that the company publishes data in relation to bribery and corruption concerns. <\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company has a policy on the use of agents that recognises the corruption risks associated with their use or provides details of specific controls to mitigate these risks. The company indicates that employees must ensure that agents and intermediaries observe all applicable laws and regulations, but it does not provide further information on the procedures that it has in place to ensure such compliance. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its agents and intermediaries.<\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the ultimate beneficial ownership of its agents and intermediaries. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is publicly available evidence that the company\u2019s anti-bribery and corruption policy applies to its agents and intermediaries. However, the company receives a score of \u20180\u2019 because there is no further information to indicate that it includes anti-bribery and corruption clauses in its contracts with agents and intermediaries, nor that such clauses stipulate audit and termination rights. <\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company considers incentive structures and compensation for agents as a factor in bribery and corruption risk. The company indicates that compensation must be reasonable, specified in advance and in compliance with all applicable laws and regulations. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it imposes a threshold on the payment of sales commissions to agents, nor that remuneration is paid in stage payments or 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":"0","comments":"
There is no publicly available 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":"
There is no evidence that the company publicly commits to establishing anti-bribery and corruption policies or procedures in its joint ventures, nor 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":"
There is no evidence that the company commits to taking 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 company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team is responsible for monitoring the company\u2019s offset activities.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company has a procedure in place to conduct 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 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 of 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 associated with operating in different markets, nor that it has a risk assessment procedure in place to account for these specific risks. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its consolidated subsidiaries and non-fully consolidated holdings. The company\u2019s list indicates whether each entity is domestic or overseas.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company publishes further information for each entity, such as its percentage ownership, or the country of incorporation and country or countries operation. There is also some indication that this list is not complete and therefore does not represent all of the company\u2019s subsidiaries and holdings.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is publicly listed on the Tokyo Stock Exchange (TYO) and Nagoya Stock Exchange (NSE) and therefore it is not required to disclose further information about its beneficial ownership in order to score \u20182\u2019. In addition, the company publishes information on its major shareholders in its Annual Report.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no publicly available evidence that the company publishes a breakdown of its defence sales by customer. The company provides some information to indicate that Japan accounts for more than 50% of its net sales, however it does not distinguish between commercial and defence revenues, nor is it clear that this data relates specifically to Toshiba Infrastructure Systems and Solutions rather than the group as a whole.<\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":""},{"question":112,"commitment_area":16,"score":"N\/A","comments":""},{"question":113,"commitment_area":16,"score":"N\/A","comments":""},{"question":114,"commitment_area":16,"score":"N\/A","comments":""},{"question":115,"commitment_area":16,"score":"N\/A","comments":""}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/886","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=886"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=886"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}