There is evidence that the company has a publicly stated commitment to high ethical standards and integrity as part of its Code of Conduct, which details the company's stance against any form of bribery or corruption. This commitment, and the Code of Conduct itself, is clearly authorised and endorsed by the company's President and Chief Executive Officer.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company publishes a clear anti-bribery and corruption policy and Code of Conduct, both of which specifically prohibit bribery, payments to public officials, commercial bribery, and facilitation payments. The company\u2019s policies clearly apply to all employees and board members as described in (a) and (b) in the question.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a designated board committee \u2013 the Audit Committee \u2013 is ultimately responsible for oversight of the company's anti-bribery and corruption programme. There is evidence indicating that this includes reviewing reports from management on the programme\u2019s performance along with the results of audits, and there is evidence that it has the authority to require that any necessary changes to the programme are made. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that that a designated senior executive \u2013 the General Counsel \u2013 has ultimate responsibility for the company\u2019s anti-corruption programme. There is evidence that the General Counsel has a direct reporting line to the Audit Committee, which provides oversight of the anti-bribery and corruption programme. There is evidence of reporting and feedback activities between this person and the Audit Committee as part of the company\u2019s reporting structure.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
There is evidence that the company has a formal bribery and corruption risk assessment procedure in place that informs the design of its anti-bribery and corruption programme. The results of risk assessments are reviewed by the board on at least an annual basis. There is evidence 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":"2","comments":"
There is evidence that the company\u2019s entire anti-bribery and corruption programme is subject to a regular audit process on at least an annual basis to ensure the programme is consistent with best practice and the business risks facing the company. This process includes provisions for continuous improvement, supplemented by internal and external audits. There is also evidence that audit findings are presented to the Audit Committee, and that the General Counsel or head of ethics and compliance is responsible for implementing any changes as a result of these findings, alongside the Legal Department.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents, and there is a specific procedure in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken at each step. The company provides whistleblowers with updates on the outcome of the investigation if they so wish, and there is evidence that whistleblowing reports are handled by an independent team. There is evidence to indicate that the Ethics and Compliance Review Board reviews summary information and oversees all investigations.<\/p>\n
The company receives a score of \u20181\u2019 because in publicly available evidence the company does not provide full details on the investigation process from receipt to final outcome. There is also no publicly available evidence that the company Ethics and Compliance Review Board meets regularly or at least on an annual basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"2","comments":"
There is evidence that the company assures itself of the quality of its internal and whistleblowing investigations and that staff conducting investigations are properly training and qualified. There is evidence that the Ethics and Compliance Review Board (ECRB) receives and handles any complaints about the investigative process. The company indicates that it reviews its investigations procedure on at least an annual basis.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence the company commits to report material findings of bribery and corruption from investigations to the Ethics and Compliance Review Board. This body includes the company\u2019s General Counsel who has a direct reporting line to the board-level Audit Committee. The company states that the Legal Department holds responsibility for disclosing material findings of corruption to the relevant authorities. <\/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 reports, investigations or disciplinary actions involving its employees.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training for employees that outlines the principles of its anti-bribery and corruption policy, including the whistleblowing options available. There is evidence the company provides this training to all employees annually, across all divisions and countries of operation, and in all appropriate languages. <\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides tailored anti-bribery and corruption training based on the different levels of risk facing employees in different roles. The company states that it provides dedicated training to board members, employees in high-risk roles and middle management. There is evidence that employees in these categories must refresh their training on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is evidence that the company measures and reviews the effectiveness of its anti-corruption training programme on an annual basis. The company indicates that it does this through anonymous employee surveys, the results of which are used to update specific elements of the training programme.<\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company\u2019s incentive or reward schemes for employees incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company commits to support and protect employees who refuse to act unethically. The company indicates that it supports its employees to make ethical decisions and maintain honesty and integrity in all business dealings, even when pressured by internal or external third parties to act unethically. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that it assures itself of its employees' confidence in this commitment through anonymised surveys or other clearly stated means.<\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company promotes a policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents, as outlined in the company\u2019s Code of Conduct. There is evidence the Code of Conduct applies to business partners of the company, including suppliers and joint venture partners. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that it commits to assure itself of its employees\u2019 confidence in this commitment through surveys or other clearly stated means. This could include monitoring the usage statistics of whistleblowing channels across different parts of the organisation or conducting independent anonymised employee surveys.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides multiple channels for its employees report instances of suspected corrupt activity and seek advice on the company's anti-bribery and corruption programme. There is evidence that the company\u2019s channels are sufficiently varied to allow the employee to raise concerns across the management chain and to an external helpline operated by an independent third party. These channels allow for confidential and, wherever possible, anonymous reporting. <\/p>\n
In addition, the company indicates that its channels are available and accessible to all employees in all jurisdictions where the company operates, including those employed by the group as third parties, suppliers and joint venture partners. The company publishes copies of its Code of Conduct in various languages and there is evidence indicating that reports to its external helpline can be made in multiple languages.<\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence the company addresses conflicts of interest as a corruption risk, and has a policy and procedure that define conflicts of interest, including actual, potential and perceived conflicts. The company\u2019s policy clearly covers possible conflicts arising from concerning employee relationships, government relationships, financial interests and outside employment. There is evidence that this policy applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
There is evidence the company has procedures to identify, declare and manage conflicts of interest, including those actual, potential and perceived. There is evidence that employee and board member declarations of actual and potential conflicts of interest are recorded in a central depository that is accessible to those responsible for oversight of the process. <\/p>\n
In addition, the company states that potential or actual conflict of interest declarations are reviewed and overseen by the Chief Human Resources Officer and the Chief Legal Officer, and there is evidence that they are accountable for the implementation of the policy and handling of individual cases. The company also provides examples of criteria for recusals and there is evidence that disciplinary measures apply to employees who violate the policy. <\/p>\n"},{"question":73,"commitment_area":10,"score":"1","comments":"
There is evidence the company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagement to current and recently departed public officials. According to the policy, employment discussions with current and former state officials require approval from the company\u2019s human resources and legal departments. There is also evidence the company assesses potential conflicts of interest around appointments of current or former public officials.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available evidence that the company may proactively require a cooling-off period of at least 12 months before public officials are permitted to have any form of contact or relationship with their former organisation on the company\u2019s behalf. <\/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 on its website.<\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
The company publishes a clear statement that it does not make corporate political contributions. The company prohibits any donations to political parties, candidates or for other political purposes, and indicates that this policy applies to all employees, agents or third parties acting on its behalf. <\/p>\n
There is also evidence that the company has a policy to adhere to all relevant laws governing the operation of Political Action Committees (PAC) in the United States; however there is no readily available evidence in the public domain to indicate that the company is associated with a PAC or that it has been associated with a PAC in the most recently reported financial year.<\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company states that it does not make political contributions 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 on both charitable donations and sponsorships. The company\u2019s policy specifies measures to ensure that such expenses are not used as vehicles for bribery and corruption, including criteria for donations, procedures for senior sign-off and due diligence requirements on recipients. In addition, the company indicates that it did not make any donations over $10,000 during 2019. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it publishes full details of all charitable donations made in the most recently reported financial year, such as details of the recipient, amount, country of recipient and which corporate entity made the payment.<\/p>\n"},{"question":78,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has a policy and procedures to regulate its lobbying activities. The company also refers to standards of conduct that apply to lobbyists working on its behalf.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the company\u2019s policies on lobbying apply company-wide to all employees, board members and third parties engaged in lobbying activities on the company\u2019s behalf. There is no publicly available evidence concerning specific controls or guidelines for lobbying behaviour; the company states that it has an internal lobbying policy, which outlines the values and behaviours that constitute responsible lobbying, but this does not appear to be publicly available.<\/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 on its website. The company states that its federal lobbying disclosures are available on the United States House of Representatives website and provides a direct link; however disclosures from the company itself, which include all of its lobbying activities, could not be identified through a public search. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes information on its global lobbying expenditure on its website. The company states that its federal lobbying disclosures are available on the United States House of Representatives website and provides a direct link; however disclosures from the company itself, which include all of its lobbying activities, could not be identified through a public search. <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with procedures designed to ensure that such promotional expenses are bona fide and not used for bribery. This policy establishes financial limits, along with a specific approval procedure, for the different types of promotional expense. The company\u2019s policy also clearly addresses the risks associated with gifts and hospitality given to and\/or received from domestic and foreign public officials, and provides different financial thresholds for gifts given and received from such parties. <\/p>\n
In addition, there is evidence that all gift and hospitality disclosures are required to be logged in a register 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 requires the involvement of its procurement department in the establishment of new suppliers and that this department is responsible for providing oversight of its supplier base. <\/p>\n
However, there is no clear publicly available evidence that the company assures itself of the procurement department\u2019s proper involvement in the procurement process through clearly stated means, such as an audit of its internal systems, at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based due diligence when engaging and re-engaging with any suppliers. There is evidence that the highest risk suppliers are subject to enhanced due diligence and that all suppliers are screened on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that the due diligence process includes establishing the beneficial ownership of all suppliers. In addition, the company states in its Code of Conduct that it reserves the right to terminate third party contracts but makes no clear statement that it would do so in circumstances when a red flag highlighted in due diligence cannot be mitigated.<\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company requires suppliers to have adequate anti-bribery and corruption policies and procedures in place. The company clearly states that all suppliers must have policies that prohibit foreign and domestic bribery and facilitation payments, as well as policies and procedures to address conflicts of interest, gifts and hospitality, and whistleblowing. The company takes active steps to ensure this by requiring that all suppliers follow its Supplier Code of Conduct. There is evidence that the company screens suppliers annually to ensure compliance with these policies.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is 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. This evidence is in the form of contractual commitments for all sub-contractors to maintain a code of conduct and ethics and compliance programme. It is noted that this contractual commitment relates to contracts with the United States government, the company\u2019s primary customer. There is evidence the company also commits to flowing down the principles of its Supplier Code of Conduct.<\/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 reports, investigations or disciplinary actions involving its suppliers.<\/p>\n"},{"question":87,"commitment_area":13,"score":"N\/A","comments":"
The company publishes a statement to indicate that it only has contracts with the United States government and as such there is evidence to indicate that it cannot engage or employ agents or intermediaries as brokers in the conduct of business. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":89,"commitment_area":13,"score":"N\/A","comments":"
The company publishes a statement to indicate that it only has contracts with the United States government and as such there is evidence to indicate that it cannot engage or employ agents or intermediaries as brokers in the conduct of business. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":90,"commitment_area":13,"score":"N\/A","comments":"
The company publishes a statement to indicate that it only has contracts with the United States government and as such there is evidence to indicate that it cannot engage or employ agents or intermediaries as brokers in the conduct of business. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":91,"commitment_area":13,"score":"N\/A","comments":"
The company publishes a statement to indicate that it only has contracts with the United States government and as such there is evidence to indicate that it cannot engage or employ agents or intermediaries as brokers in the conduct of business. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":92,"commitment_area":13,"score":"N\/A","comments":"
The company publishes a statement to indicate that it only has contracts with the United States government and as such there is evidence to indicate that it cannot engage or employ agents or intermediaries as brokers in the conduct of business. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":98,"commitment_area":13,"score":"N\/A","comments":"
The company publishes a statement to indicate that it only has contracts with the United States government and as such there is evidence to indicate that it cannot engage or employ agents or intermediaries as brokers in the conduct of business. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":99,"commitment_area":13,"score":"N\/A","comments":"
The company publishes a statement to indicate that it only has contracts with the United States government and as such there is evidence to indicate that it cannot engage or employ agents or intermediaries as brokers in the conduct of business. The company is therefore exempt from scoring on this question. <\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all of its joint venture partnerships. The company indicates that it conducts such checks prior to entering into the business relationship and on a continuing basis throughout the relationship. <\/p>\n
However, there is no clear evidence that the company\u2019s due diligence process includes establishing the ultimate beneficial ownership of the partner entity, nor that it conducts enhanced due diligence on joint ventures operating in high risk countries or with high risk partners. <\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies and procedures in its joint ventures. The company requires joint venture partners to adhere to its anti-corruption policies. There is also evidence that the company includes anti-corruption clauses and termination rights in contracts with all third parties, including joint venture partners. <\/p>\n
The company receives a score of \u20181\u2019 because there is no clear evidence that the company includes audit rights in its contracts with joint venture partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company makes an explicit commitment to take an active role in preventing bribery and corruption in all of its joint ventures. The company states that its managers are responsible for communicating to all business partners and third parties the expectation that they adhere to high standards of integrity and ethics. However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on the steps that it takes to ensure this in practice. <\/p>\n"},{"question":103,"commitment_area":14,"score":"N\/A","comments":"
The company publishes a clear statement that it does not engage in offset contracting and is therefore exempt from scoring on this question. <\/p>\n"},{"question":104,"commitment_area":14,"score":"N\/A","comments":"
The company publishes a clear statement that it does not engage in offset contracting and is therefore exempt from scoring on this question. <\/p>\n"},{"question":105,"commitment_area":14,"score":"N\/A","comments":"
The company publishes a clear statement that it does not engage in offset contracting and is therefore exempt from scoring on this question. <\/p>\n"},{"question":106,"commitment_area":14,"score":"N\/A","comments":"
The company publishes a clear statement that it does not engage in offset contracting and is therefore exempt from scoring on this question. <\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is some evidence that the company\u2019s acknowledges the possible corruption risks of operating in different markets, and there is evidence that its risk assessment process includes considerations of geographic location and interactions with various government officials. <\/p>\n
However, there is no clear publicly available evidence that the results of risk assessments have a direct impact on business decisions in certain locations or inform the development and implementation of additional controls to mitigate such risks. <\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company publishes a list of the holdings in its corporate group, alongside information on the jurisdictions in which they are registered. The company updates 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 its percentage ownership for each entity, nor does it publish the country or countries of operation for each entity. As there is no information on the percentage ownership, it is not clear whether the companies listed are major subsidiaries, affiliates or joint ventures and therefore it is not clear that the list published represents all of the company\u2019s holdings.<\/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 (NYSE) and therefore it is not required to disclose further information on its beneficial ownership to receive a score of \u20182\u2019. The company also publishes information on its major institutional shareholders on its website.<\/p>\n"},{"question":110,"commitment_area":15,"score":"2","comments":"
There is evidence that the company publishes information on its defence sales by customer, to indicate that all of its contracts are with different branches of the United States government. The company indicates that its primary customer is the United States Department of Defence (DoD) and that it provides products and services to all three branches of the military. There is evidence that this information is published and updated for the most recently reported financial year.<\/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\/891","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=891"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=891"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}