There is no publicly available evidence that the company publishes an anti-bribery and corruption commitment that is endorsed by its senior leadership. The company has an anti-corruption policy which is approved by its President, however there is no evidence that this individual makes a direct statement endorsing the company\u2019s commitment to anti-corruption within the organisation. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes an Anti-Corruption Policy and Code of Conduct, both of which prohibit bribery, payments to public officials and commercial bribery. There is evidence that these policies apply to all employees in the company.<\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that either of the policies address and prohibit facilitation payments, nor is it clear that they apply to all directors, including non-executive directors. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is some evidence that the company\u2019s Anti-Corruption Commission provides oversight of the company's anti-bribery and corruption programme. However, the status of the Commission in relation to the rest of the company\u2019s corporate structure is not clear, and there is no clear evidence that it engages in formal oversight functions or that it has the authority to require that changes to the programme are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated senior-executive \u2013 the Vice President for Security \u2013 has been assigned ultimate responsibility for implementing and managing the company's anti-bribery and corruption programme. There is evidence to indicate that this individual is also the Chairperson of the Anti-Corruption Commission, and this committee has a direct reporting line to the company\u2019s President.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company has a formal bribery and corruption risk assessment procedure in place that informs the design of the anti-corruption and bribery programme. The company indicates that the results of major risk assessments and recommendations for updates are presented to the company\u2019s President. There is evidence to suggest that the results of corruption-risk assessments are reviewed at board level.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that such risk assessments are conducted or reviewed on an annual basis. It is also not clear that the results of such reviews are used to develop tailored mitigation plans and to update specific parts of the company's anti-bribery and corruption programme.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is some evidence that the company has formal procedures in place to conduct internal audits. However, it is not clear from publicly available information that the company has specific procedures in place to conduct audits or reviews of its anti-bribery and corruption programme on a regular basis, with oversight from the board. <\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, and there is some information available regarding procedures to deal with whistleblowing cases. There is evidence that the company provides those who report offenses with updates on the outcome of investigations. <\/p>\n
However, there is no evidence that the company provides publicly available details on its investigative procedure from receipt to final outcome. In addition, there is no evidence that investigations are handled by an independent team or report to an independent board member, nor is there publicly available information to indicate that information on each investigation is documented or that a central body reviews summary information on cases on a regular basis.<\/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 investigations, for example by indicating that staff conducting investigations are properly trained, by implementing a policy to handle complaints about the process or by reviewing the investigation process every three years. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a system in place to inform the Board of Directors of any violations of law or breaches of the Code of Conduct, which contains rules prohibiting bribery and corruption. In addition, there is evidence that the company commits to report material findings of corruption and criminality to law enforcement and the company indicates that the Vice President of the Security Department is responsible for interacting with law enforcement in such cases. <\/p>\n"},{"question":63,"commitment_area":8,"score":"1","comments":"
There is some evidence that the company provides some high-level data on the number of corruption-related criminal investigations initiated in a recently reported financial year. <\/p>\n
However, there is no publicly available evidence that the company publishes further information on the number of reports received, number of investigations launched or number of disciplinary actions taken as a result. It is not clear that the criminal investigations mentioned in publicly available information include all internal investigations, nor that this includes incidents reported through both direct and whistleblowing channels. It is also not clear from publicly available information that the company publishes this information regularly or on an annual basis. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the the company provides training for its employees which outlines the principles of its anti-bribery and corruption policies. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that all employees must undertake this training, nor is it clear that such training covers the whistleblowing options available. It is also not clear that all employees must undertake and refresh their training in this area every three years.<\/p>\n"},{"question":65,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company provides tailored 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 publicly available evidence that the company measures or reviews the effectiveness of its anti-bribery and 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.<\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
The company publishes a statement to indicate that no employee will suffer financial or career progression consequences for refusing to act unethically, even where such actions result in a loss of business or another disadvantage to the company.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company assures itself of its employees\u2019 confidence in this statement through anonymised surveys or other clearly stated means. In addition, the company does not clearly indicate in its published statement that it will support and protect employees who raise concerns or report incidents. <\/p>\n"},{"question":69,"commitment_area":9,"score":"0","comments":"
There is some evidence that the company has a publicly available policy of non-retaliation against employees who report bribery and corruption incidents which applies company wide. <\/p>\n
However, it is not clear from publicly available information that this policy extends to whistleblowers. In addition, there is no evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data, or other clearly stated means.<\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
There is evidence that the company provides internal whistleblowing and advice channels for its employees to raise concerns and report allegations or incidents of bribery and corruption. There is evidence that these channels allow for confidential and anonymous reporting. <\/p>\n
However, there is no publicly available evidence that the company provides an external reporting channel for its employees, for example an ethics line operated by an independent third party. In addition, there is no clear evidence that these channels are available to all employees in any country of operation, 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 conflicts of interest as a corruption risk and that it has a clear policy in place that defines conflicts of interest, including actual, potential and perceived conflicts. There is evidence that the company\u2019s policy addresses possible conflicts arising from employee relationships, government relationships, financial interests and other employment. This policy applies to all company employees. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that this policy applies to all board members or employees of subsidiaries and other controlled entities.<\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
There is evidence that the company has clear procedures in place to identify, declare and manage conflicts of interest. The company indicates that potential and actual conflict of interest declarations are reviewed and overseen by a designated body \u2013 the Commission for Corporate Ethics and Conflicts of Interest Resolution \u2013 which has ultimate accountability for the handling of individual cases. In addition, there is evidence to suggest that all employee conflicts of interest declarations are held by the Human Resources Department and inspected by the above named commission. <\/p>\n
However, it is not clear from publicly available information that the company provides descriptions of possible criteria for recusals nor that breaches of its policy in this area will result in disciplinary measures.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
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 publishes details of the contracted services of serving politicians.<\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
The company publishes a clear statement that it does not provide any form of contribution to political parties, candidates or campaigns. There is evidence that this policy applies company-wide to all employees. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not make political contribtions and therefore it is exempt from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy covering charitable donations and sponsorships. The company\u2019s policy includes a list of the types of projects that it prioritises. The company also publishes some details of charitable donations made and there is some evidence it indicate that it updates data on an annual basis, including details of the recipients of its contributions and data outlining general spending on broad areas of charitable activity and sponsorships. There is evidence that this includes spending made by both the company and the wider group. <\/p>\n
However, it clear from publicly available information that the company\u2019s policies on charitable donations and sponsorships include specific measures to ensure that such expenses are not used as vehicles for bribery and corruption, such as senior sign-off or conducting due diligence on recipients. In addition, there is no evidence that the company publishes the amount donated to each recipient.<\/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 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 global 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, with clear anti-bribery and corruption procedures. The company\u2019s policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees encounter. There is evidence to indicate that gifts and hospitality above certain thresholds are recorded in a dedicated central system that is accessible to those responsible for oversight of the process.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it addresses the risks associated with gifts and hospitality given to, or received from, domestic and foreign public officials, for example by specifying a different financial threshold or approval procedure.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company's Procurement Commission is involved in the establishment and oversight of all supplier relationships. However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it assures itself of this department\u2019s proper involvement in the procurement process through clearly stated means, such as an audit, at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence to suggest that the company performs checks on contractors to ensure that they have a good reputation and adequate anti-corruption programmes in placeThe company also indicates that it maintains a policy of not doing business with individuals and organisations implicated in corruption offenses. <\/p>\n
However, it is not clear from publicly available information that the company\u2019s due diligence processes include checks on ultimate beneficial ownership, or that high risk suppliers are subject to enhanced due diligence. It is also not clear how frequency the company conducts or refreshes this due diligence, nor is there evidence that it may review or terminate a supplier relationship where a red flag highlighted in the due diligence cannot be mitigated.<\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company takes steps to ensure that its contractors have adequate anti-bribery and corruption policies and procedures in place. The company indicates that it monitors counterparties\u2019 adherence to anti-corruption policies throughout the business relationship and that it focuses on establishing business relationships with contractors who support the company\u2019s own anti-corruption policy. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that all suppliers must have policies that prohibit foreign and domestic bribery, prohibit facilitation payments, and implement procedures to address conflicts of interest, gifts and hospitality, or whistleblowing. It is also not clear from publicly available information whether the company assures itself of this for all suppliers or whether this assurance is conducted 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 corruption-related reports, investigations or the associated disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company has a policy on the use of agents or intermediaries.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging with contractors. The company also provides information to indicate that it monitors contractors\u2019 compliance with anti-corruption policies throughout the duration of the business relationship. <\/p>\n
However, it is not clear from publicly avaialbel information that this process for contractors includes or applies to agents and intermediaries. In addition, there is also no clear evidence that high risk intermediaries are subject to enhanced due diligence or that it conducts due diligence checks at least every two years and when there is a significant change in the business relationship.<\/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 as part of the due diligence process.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company includes clauses to adhere to Russian anti-corruption laws in contracts with contractors, however it is not clear from publicly available information that the process for contractors includes or applies to agents and intermediaries. In addition, there is no clear evidence that the company includes audit and termination rights as part of its contracts with such entities. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company addresses or considers incentive structures as a risk factor in agent behaviour.<\/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 corruption-related reports, 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":"
The company publishes a statement that it only does business with third parties that have a clean reputation and their own anti-corruption policies, and indicates that all such parties must adhere to Russian anti-corruption laws in contracts.<\/p>\n
However, it is not clear from publicly available information that this applies to joint venture partners, nor is there evidence that the company commits to establishing or implementing anti-bribery and corruption procedures in its joint ventures.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. The company provides some information to indicate that it informs third parties and suppliers of its expected standards of behaviour in the area of anti-corruption, however it is not clear from publicly available evidence that this applies to joint venture partners. <\/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'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.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme.<\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is no evidence that the company publishes 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":"2","comments":"
There is evidence that the company publishes a list of its fully consolidated subsidiaries and non-fully consolidated holdings, including any associates, joint ventures and other related entities. For each entity, the company discloses its percentage ownership and the country of incorporation. There is evidence that this list is current and updated on at least an annual basis, as part of the company\u2019s Annual Report. <\/p>\n
Although the company does not publish details of the country of operation for each entity, there is sufficient evidence from publicly available information that the entities are based in Russia and operate in this jurisdiction as part of the function of the state-owned enterprise. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is 100% owned by the Russian Federation, through an agency referred to as the Federal Property Management Agency. The company provides a clear indication that it does not have any other shareholders. There is evidence that information on the company\u2019s ownership is available on its website and in annual reporting documents. <\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is evidence that the company\u2019s main purpose is to provide products and services for the Ministry of Defence of the Russian Federation. However, it is not clear from publicly available information that the Russian government is the company\u2019s only customer or that it accounts for all of its defence sales.<\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":"
There is evidence that the company is 100% owned by the Russian Federation, through an agency referred to as the Federal Property Management Agency. Since there is no evidence that any other entity holds shares or voting rights in the company, it is exempt from scoring on this question. <\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
There is evidence that the company\u2019s commercial and public policy objectives are made publicly available on its website. There is evidence that these objectives are updated on an annual basis or whenever there is a change in objectives.<\/p>\n"},{"question":113,"commitment_area":16,"score":"1","comments":"
The company publishes information about the composition of its board and provides details to indicate whether each board member is a financial beneficiary, executive or state representative. The company also provides publicly available information regarding the nomination and appointment process for board members, including how the final election decision is made. <\/p>\n
The company indicates in its 2018 Annual Report that each board committee is chaired by an independent director, however it is not clear from publicly available information which board members (if any) are independent.<\/p>\n"},{"question":114,"commitment_area":16,"score":"1","comments":"
There is no clear evidence that the company\u2019s audit committee is composed of a majority of independent directors. The company publishes information on the identity of those on the Audit Committee and publishes a statement that all board committees are chaired by independent directors, however it does not provide any further details on which members are independent so it is not clear that the committee is composed of a majority independent directors. <\/p>\n"},{"question":115,"commitment_area":16,"score":"1","comments":"
There is evidence that the company has a system in place, with responsibility assigned at board level, for managing asset transactions. The company provides information to indicate that all such transactions are documented, including those between the company and government departments or military, or if any of the latter make asset transactions on the company\u2019s behalf. In addition, there is some evidence that financial results from asset acquisitions or disposals may be made available in the company\u2019s financial reports, though the company notes that it has not conducted major transactions in the last two reporting years.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that its system for managing asset transactions includes oversight measures, for example through an audit body.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/889","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=889"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=889"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}