There is evidence that the company\u2019s Group Global Code of Conduct outlines the company's stance against bribery and corruption. There is evidence that this document was authorised and endorsed by the company's leadership in the form of an introductory message from the company\u2019s President and CEO. However, the company receives a score of \u20181\u2019 because there is no evidence that the senior leadership directly mentions or addresses the company\u2019s stance against all forms of bribery and corruption within the organisation. <\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
There is evidence that the company has a clear anti-bribery and corruption policy as part of its Group Global Code of Conduct, which specifically prohibits bribery, payments to public officials, commercial bribery and facilitation payments. There is evidence that this policy applies 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 the Board of Directors \u2013 through the Compliance Committee \u2013 is ultimately responsible for oversight of the company's compliance programme, which includes the anti-bribery and corruption programme. In addition, there is evidence that the board engages in formal oversight functions, such as reviewing reports and updated from management, and due to the seniority of the body there is evidence to indicate that it has the authority to require that any necessary changes to the programme are made.<\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company\u2019s General Counsel and Executive Vice President is responsible for implementing and managing the company\u2019s compliance programme in their role as Chair of the Compliance Committee. There is some evidence to indicate that this individual, through the Compliance Committee, has a reporting line to the President and CEO. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the individual has a direct reporting line to the body that provides oversight of the compliance programme, which according to publicly available evidence is the Board of Directors. There is also no clear publicly available evidence of reporting and feedback activities between this person and the board as part of the company\u2019s reporting structure; for example, attendance or participation at board-level committee meetings.<\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
Based on publicly available information, there is evidence that the company employed an expert individual to conduct a bribery risk assessment of its anti-bribery and corruption systems in 2017. The company indicates that the purpose of this evaluation was to monitor the systems and identify areas for improvement. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that the company has a procedure in place to conduct bribery and corruption risk assessments on a regular basis or that the results of risk assessments are reviewed at board level.<\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review. The company indicates that it conducted audits to identify fraud risks in certain operating sites, however it is not clear from publicly available information that the company conducts specific anti-corruption audits of its compliance programme on a regular basis, nor that the results are reviewed by the board or used to make improvements to the programme.<\/p>\n"},{"question":60,"commitment_area":8,"score":"1","comments":"
There is evidence that the company publicly commits to investigating incidents and that there is a procedure in place to deal with whistleblowing cases, which is overseen by external lawyers. There is evidence that the company\u2019s Compliance Committee Secretariat conducts investigations.<\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further publicly available information on the whole investigation process from receipt to final outcome. In addition, there is no clear evidence to indicate that the company takes steps to ensure the independence of investigations, nor that a central body reviews summary information on all investigations on at least an annual basis. There is also no clear publicly available evidence that the company commits to providing whistleblowers with updates on the outcome of investigations. <\/p>\n"},{"question":61,"commitment_area":8,"score":"0","comments":"
There is no publicly available evidence that the company 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":"0","comments":"
There is no publicly available evidence that the company publicly commits to report material findings from its investigations to the board or to relevant authorities if necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publishes high-level data on an annual basis regarding ethical or bribery and corruption-related incidents and investigations involving company employees at all levels. The company provides information on the number of reports received, including the number received through whistleblowing channels, the number of investigations launched, and the number of disciplinary actions as a result of investigation findings. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides training for its employees that outlines the basic principles of its anti-bribery and corruption policy. The company indicates that it provides this training to all employees worldwide. <\/p>\n
However, the company receives score \u20181\u2019 because there is no publicly available evidence to indicate that employees must undertake and refresh their training at least every three years, nor is it clear evidence that this training specifically covers the whistleblowing options available.<\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
There is some evidence that the company provides tailored anti-bribery and corruption training to employees based on an assessment of their role. The company indicates that it provides specific training and guidance for employees in technical and skilled jobs.<\/p>\n
However, there is no publicly available evidence that the company provides tailored anti-corruption training to employees in middle management positions and to board members. In addition, there is no evidence that employees in high risk positions must refresh their training on an annual basis and it is not clear that the training is tailored on the basis of exposure to corruption risk.<\/p>\n"},{"question":66,"commitment_area":9,"score":"1","comments":"
There is evidence that the company measures and reviews the effectiveness of its compliance communications and training programme through metrics such as completion rates and employee awareness surveys. There is evidence that the company undertakes these reviews on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear publicly available 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, nor that a review of the programme takes place at least every three years.<\/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 anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is some evidence that the company encourages all employees to act with integrity and to avoid unethical conduct in the pursuit of growth, or face potential termination. There is no publicly available evidence that the company commits to support and protect employees who refuse to act unethically, even where such actions may result in a disadvantage or loss of business. There is also no clear evidence that the company assures itself of its employees\u2019 commitment in this statement through clearly stated means such as anonymised surveys. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence the company promotes a policy of non-retaliation against whistleblowers and employees who report bribery and corruption issues. There is evidence to indicate that the company\u2019s policy on non-retaliation extends to external parties, who may use its whistleblowing line. <\/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 commitment through surveys, usage data, or other clearly stated means. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides several whistleblowing and advice channels that allow employees and third parties, including business partners, to raise concerns and seek advice on its compliance programme. There is evidence that these channels allow for confidential reporting and that they are available to all employees in all jurisdictions where the company operates, and in all relevant languages. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that it provides an external reporting mechanism for employees, such as a channel operated by an independent third party. In addition, it is not clear whether the company\u2019s channels allow for anonymous reporting where possible. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence the company has a formal policy on conflicts of interest, which refers to actual, potential and perceived conflicts of interests. There is evidence that the policy applies to all employees and board members across the company, including those employed by subsidiaries and controlled entities. In addition, there is evidence that the company\u2019s policy addresses possible conflicts of interest related to employee relationships, financial interests and other employment.<\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear from publicly available information that its policy addresses possible conflicts arising from government relationships. <\/p>\n"},{"question":72,"commitment_area":10,"score":"1","comments":"
Based on publicly available information, there is evidence the company has procedures in place to identify, declare and manage conflicts of interest. There is evidence that the company\u2019s Legal Department is responsible for the appropriate management and handling of conflicts of interest cases, and that disciplinary measures apply for breaches of the policy. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that all employee and director declarations are held in a dedicated central register that is accessible to the Legal Department. There is also evidence that the company provides examples of criteria for recusals.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no publicly available evidence that the company has a policy regulating the employment of current and 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":"0","comments":"
Based on publicly available information, there is evidence that the company has a policy on political contributions to ensure that these payments are not used as vehicles of bribery. There is evidence that the company\u2019s Legal Department must pre-approve political contributions and that the policy \u2013 which is a part of the Group Global Code of Conduct \u2013 applies to all employees, including board members and group companies. <\/p>\n
However, the company receives a score of \u20180\u2019 because it does not clearly prohibit corporate political contributions. In addition, there is evidence that the company is associated \u2013 through a local subsidiary \u2013 with a Political Action Committee (PAC) in the United States.<\/p>\n"},{"question":76,"commitment_area":11,"score":"0","comments":"
There is evidence that the company publishes some details of its political contributions on an annual basis. The company publishes a high-level figure of the total value of its political donations for the most recently reported financial year, and there is some evidence to indicate that there was only one major recipient, which the company names in its public reports. Although the company does not explicitly provide this information, the recipient is understood to be located in Japan. <\/p>\n
However, the company receives a score of \u20180\u2019 because there is no evidence that it publishes details further of the contributions made by its subsidiary\u2019s Political Action Committee (PAC) in the United States, nor does it provide a direct link to its official disclosures of this information. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
Based on publicly available information, there is evidence that the company acknowledges the risks associated with charitable donations and that it publishes some high-level information on its annual expenditure on such activities. <\/p>\n
However, there is no publicly available evidence that it has a clear policy or procedure in place with specific controls in place to reduce the possible bribery and corruption risks associated with charitable donations and sponsorships, such as due diligence on recipients. In addition, there is no evidence that the company publishes full details of its donations including 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":"
Based on publicly available information, there is some evidence that the company has a policy on lobbying. There is evidence that employees who plan to engage in lobbying activities must request approval from the Legal Department, and that the policy applies to all employees, including board members and third parties acting on the company\u2019s behalf. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that the company provides clear guidelines on what behaviours or standards of conduct are acceptable. There is also no evidence that the company has clear oversight mechanisms that apply to in-house, external and association lobbyists. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
Based on publicly available evidence, the company publishes some information on the topics on which it lobbies. However, there is no evidence that it publishes further details of its lobbying aims and the activities that were carried out in a relevant period. It is also not clear from publicly available information whether these aims apply to all jurisdictions in which the company lobbies, or primarily to the jurisdiction in which it is headquartered.<\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes information on its global lobbying expenditure. <\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on gifts and hospitality to prevent bribery and corruption. The company\u2019s policy indicates that gifts must be reasonable and states that employees should avoid gifts in cash or from third parties in connection with work activities. <\/p>\n
However, it is not clear form publicly available information that the company\u2019s policy specifies financial or proportional limits or different approval procedures for different types of promotional expenses, nor is there evidence that it addresses the risks associated with gifts and hospitality given to or received from a domestic or foreign public official. There is also no evidence that gifts and hospitality in a dedicated central register that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"0","comments":"
There is some evidence that the company has a procurement policy, however there is no clear publicly available evidence that the company requires and ensures the involvement of its procurement department in the establishment of new supplier relationships. There is also no evidence that the company assures itself that proper procedures regarding the onboarding of suppliers are followed through clearly stated means, such as an audit or other assurance process, at least every three years.<\/p>\n"},{"question":83,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is some evidence the company has formal procedures to conduct anti-corruption due diligence when engaging with third parties. However, there is no evidence that the company provides further details on its due diligence process and it is unclear whether suppliers specifically are subject to due diligence.<\/p>\n"},{"question":84,"commitment_area":12,"score":"0","comments":"
Based on publicly available information, there is no clear evidence that the company ensures that its suppliers have anti-bribery and corruption policies in place that meet a high standard. There is no clear evidence that the Group Global Code of Conduct applies to suppliers.<\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no publicly available 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 high-level results from ethics-related reports, investigations and disciplinary actions against suppliers. <\/p>\n"},{"question":87,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company has a policy covering the use of agents. There is evidence that the company\u2019s Group Global Code of Conduct applies to agents and lists some controls to address the corruption risks associated with the use of agents. There is also evidence that this policy applies to subsidiaries and the company\u2019s business partners.<\/p>\n
However, the company receives score of \u20181\u2019 because there is no clear evidence that the policy commits to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function.<\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company conducts due diligence on its third parties. However, there is no evidence that the company provides further publicly available details on this process so it is not clear whether such checks include anti-bribery and corruption provisions, nor that they are conducted on a regular basis and specifically on all agents.<\/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.<\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is evidence that the company\u2019s anti-bribery and corruption policy applies to agents and intermediaries acting for or on its behalf. The company indicates that it includes contractual provisions in its agreements with third parties to regulate their conduct.<\/p>\n
However, there is no publicly available evidence that the company\u2019s contracts with agents and intermediaries specifically include clear audit and termination rights to detect, control and prevent breaches. In addition, although the company indicates that its contracts with third parties include rules on conduct, it is not clear whether this includes following the standards outlined in its anti-bribery and corruption policy.<\/p>\n"},{"question":92,"commitment_area":13,"score":"1","comments":"
Based on publicly available information, there is some evidence that the company recognises incentive structures for agents as a risk factor in bribery and corruption. The company indicates that fees and expenses paid to third parties must represent appropriate and justifiable renumeration for the services rendered.<\/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. There is also no evidence that the company requires 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 and on its behalf. <\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes high-level results from ethical reports, investigations and associated disciplinary actions involving its agents. <\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company conducts due diligence on third parties. However, there is no evidence that the company provides further publicly available details on this process so it is not clear whether such checks include anti-bribery and corruption provisions, nor that they are conducted on a regular basis and specifically on all joint venture partners.<\/p>\n"},{"question":101,"commitment_area":13,"score":"1","comments":"
There is evidence that the company\u2019s Group Global Code of Conduct applies to business partners acting on its behalf, which can be understood to include joint venture partners. The company indicates that its agreements or contracts with third parties must include contractual provisions requiring them to act properly. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no publicly available evidence that the company\u2019s contracts with joint venture partners specifically include clear audit and termination rights to detect, control and prevent breaches. In addition, although the company indicates that its contracts with third parties include rules on conduct, it is not clear whether this includes following the standards outlined in its anti-bribery and corruption policy.<\/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 its joint ventures.<\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting, nor is there evidence that a dedicated body, department or team that is responsible for monitoring its offset activities. There is no evidence that the company publishes a statement to indicate that it does not engage in such practices.<\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company has a procedure in place to conduct 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 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 publicly available 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. There is evidence that the company has an overall risk management system in place, but it is not clear that this accounts for market risk or anti-bribery and corruption specifically.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
There is evidence that the company publishes a list of its subsidiaries in its annual report and on its website. The company provides details of the full names of each entity, as well as an indication of the country and region of incorporation. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it publishes further information such as its percentages ownership and the country or countries of incorporation and operation for each entity. The company publishes some details on its website, but it is not clear how frequently this list is updated or published.<\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
There is evidence that the company is a publicly listed entity on the Tokyo Stock Exchange (TYO) and therefore it does not need to disclose further information about its beneficial ownership to receive a score of \u20182\u2019. There is also evidence that the company discloses information on its major shareholders in its annual report.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is no evidence that the company publishes any information on its defence sales by customer.<\/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\/948","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=948"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=948"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}