By public info, this company is placed in Band F

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Ownership

PRIVATE

Defence revenue, USD

614m (2013)

Defence revenue, %

11% (2013)

Country

USA

Internal information

NO

Leadership 5%
1.
score
0

Does the company publish a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company?

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company.

COMMENTS -+
2.
score
0

Does the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company?

Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

COMMENTS -+
3.
score
0

Does the company’s Chief Executive Officer demonstrate a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure?

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure. TI notes that the Leadership section of the company website states that all Management participate in upholding the company’s commitment to civic and social responsibility. However, there is no further detail on the specific actions of individuals, including the CEO.

COMMENTS -+
4.
score
1

Does the company publish a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability?

Based on public information, there is evidence that the company publishes a statement of values on its website, which includes honesty, integrity and accountability. However, it does not go into sufficient depth by explaining what the company means by such values and why they matter to the organisation.

COMMENTS -+
5.
score
0

Does the company belong to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption?

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

COMMENTS -+
6.
score
0

Has the company appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda?

Based on public information, there is no readily available evidence that the company has appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda.

COMMENTS -+
7.
score
0

Has the company appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board?

Based on public information, there is no readily available evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda. TI notes that the company website states that all members of management participate in setting an example of civic and social responsibility. However, no further information was found pertaining to specific actions by individuals and what is implemented within the company.

COMMENTS -+
8.
score
0

Is there regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda?

Based on public information, there is no readily available evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda.

COMMENTS -+
8a.
score
0

Is there a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and evidence of improvement plans being implemented when issues are identified?

Based on public information, there is no readily available evidence that there is a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and no evidence of improvement plans being implemented when issues are identified.

COMMENTS -+
9.
score
0

Does the company have a formal process for review and where appropriate update its policies and practices in response to actual or alleged instances of corruption?

Based on public information, there is no readily available evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

COMMENTS -+
Risk management 0%
9a.
score
0

Does the company have a formal anti-corruption risk assessment procedure implemented enterprise-wide?

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide.

COMMENTS -+
10.
score
0

Does the company have a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied?

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions.

COMMENTS -+
11.
score
0

Does the company conduct due diligence that minimises corruption risk when selecting or reappointing its agents?

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

COMMENTS -+
12.
score
0

Does the company have contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption?

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.

COMMENTS -+
13.
score
0

Does the company make clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance?

Based on public information, there is no readily available evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance. TI notes that the company has a policy of ensuring full regulatory compliance in its business with suppliers. However, there are no further details on what this entails and how it is put into practice.

COMMENTS -+
13a.
score
N/A

Does the company explicitly address the corruption risks associated with offset contracting?

Based on public information, there is no readily available evidence that the company engages in offset contracting.

COMMENTS -+
13b.
score
N/A

Does the company conduct due diligence that minimises corruption risk when selecting its offset partners and offset brokers?

Based on public information, there is no readily available evidence that the company engages in offset contracting.

COMMENTS -+
Policies & codes 0%
15.
score
0

Does the company have an anti-corruption policy that prohibits corruption in its various forms?

Based on public information, there is no readily available evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. TI notes that evidence suggests that the company has a code of conduct. However, it is not published on the company website and is only mentioned in the company’s Tax Returns Exemption Form.

COMMENTS -+
16.
score
0

Is the anti-corruption policy explicitly one of zero tolerance?

Based on public information, there is no readily available evidence of a zero-tolerance anti-corruption policy.

COMMENTS -+
17.
score
0

Is the company's anti-corruption policy easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company?

Based on public information, there is no readily available evidence that the company has an anti-corruption policy that is easily accessible. TI notes that there is evidence that the company has a code of conduct. However, it is not published on the company website and is only mentioned in the company’s Tax Returns Exemption Form.

COMMENTS -+
17a.
score
0

Is the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties?

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is easily understandable to Board members, employees and third parties.

COMMENTS -+
18.
score
0

Does the anti-corruption policy explicitly apply to all employees and members of the Board?

Based on public information, there is no readily available evidence that the company’s anti-corruption policy explicitly applies to all employees and members of the Board.

COMMENTS -+
20.
score
0

Does the company have a policy on potential conflicts of interest, and does it apply to both employees and board members?

Based on public information, there is some evidence that the company has a policy on potential conflicts of interest within the Code of Conduct. However, the Code is not available publicly and therefore no specific information on the policy is accessible.

COMMENTS -+
21.
score
0

Does the company have a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery?

Based on public information, there is some evidence that the company may have a policy prohibiting ‘improper private benefit’. However, bribery or the giving or receiving of gifts are not mentioned explicitly. TI notes that the company’s Code of Conduct is not publicly available.

COMMENTS -+
22.
score
0

Does the company’s anti-corruption policy include a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery?

Based on public information, there is no readily available evidence of a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery.

COMMENTS -+
23.
score
0

Does the company have a policy that explicitly prohibits facilitation payments?

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

COMMENTS -+
24.
score
0

Does the company prohibit political contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent? Does the company record and publicly disclose all political contributions?

Based on public information, there is no readily available evidence that the company prohibits political contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

COMMENTS -+
25.
score
0

Does the company have a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies?

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which the company lobbies.

COMMENTS -+
25a.
score
0

Does the company prohibit charitable contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent?

Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

COMMENTS -+
Training 0%
26.
score
0

Does the company provide written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda?

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda.

COMMENTS -+
27.
score
0

Does the company have a training programme that explicitly covers anti-corruption?

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption. TI notes that evidence suggests that the company provides training on its Code of Conduct, but limited information is provided and as a result it is unclear if it includes a specific anti-corruption module.

COMMENTS -+
28.
score
0

Is anti-corruption training provided in all countries where the company operates or has company sites?

Based on public information, there is no readily available evidence that anti-corruption training is provided in all countries where the company operates or has company sites.

COMMENTS -+
29.
score
0

Does the company provide targeted anti-corruption training to members of the Board?

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

COMMENTS -+
30.
score
0

Does the company provide tailored ethics and anti-corruption training for employees in sensitive positions?

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

COMMENTS -+
Personnel 14%
31.
score
0

Does the company have a clear and formal process by which employees declare conflicts of interest?

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest. TI notes that directors, officers and key employees complete annual conflicts of interest certificates. However, there is no evidence detailing the disclosure procedure for all employees.

COMMENTS -+
32.
score
0

Is the company explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities?

Based on public information, there is no readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

COMMENTS -+
33.
score
1

Does the company have multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity?

Based on public information, there is evidence that the company has a hotline that is open to report concerns surrounding ethics. However, it is not clear whether employees would be guaranteed anonymity or confidentiality when using this. Therefore the company scores 1. It is unclear if a dedicated email for 501(c)(3) related matters can be used to report instances of corrupt activity.

COMMENTS -+
33a.
score
1

Are the whistleblowing channels available to all employees in all geographies?

Based on public information, there is evidence that across geographies employees have access to the Battelle Business Ethics and Employee Concerns Hotline. It is unclear if a dedicated email for 501(c)(3) related matters can be used to report instances of corrupt activity. The company therefore scores 1. To score higher the company would need to provide evidence that across geographies, all employees have access to more than one reporting channel.

COMMENTS -+
33b.
score
0

Does the company have formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively?

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively.

COMMENTS -+
34.
score
0

Does the company have well-publicised resources available to all employees where help and advice can be sought on corruption-related issues?

Based on public information, there is no readily available evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues.

COMMENTS -+
35.
score
0

Is there a commitment to non-retaliation for bona fide reporting of corruption?

Based on public information, there is no readily available evidence that there is a commitment to non-retaliation for bona fide reporting of corruption.

COMMENTS -+