By public info, this company is placed in Band F

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Ownership

PRIVATE

Defence revenue, USD

Unknown

Defence revenue, %

Unknown

Country

INDIA

Internal information

NO

Leadership 10%
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 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.

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.

COMMENTS -+
4.
score
0

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 no readily available evidence that the company publishes a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability. TI notes a brief statement on the company’s mission and vision. However, this does not reflect the standards of business conduct sought in the question.

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
2

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 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. This person is the Chief Vigilance Officer, S. Rangarajan.

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 the company has a process of a regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. TI notes that the Central Vigilance Commission's website states that the duties of the Chief Vigilance Officer include reviewing a company's ethics and anti-corruption agenda. However, no information about this review was found on the company website.

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 the company has 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, or 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 14%
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. TI notes the company’s consultancy agreement template, but has found no explicit evidence of monitoring processes or anti-corruption contractual rights.

COMMENTS -+
13.
score
2

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 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. For major procurements the company makes its suppliers and contractors sign an integrity pact. Also, as a general rule it is made clear that on discovery of corrupt or fraudulent practices the contract will be terminated.

COMMENTS -+
13a.
score
0

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 explicitly addresses the corruption risks associated with offset contracting.

COMMENTS -+
13b.
score
0

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 conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.

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.

COMMENTS -+
16.
score
0

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

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is explicitly one of zero tolerance.

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’s anti-corruption policy is easily accessible to Board members, employees, contracted staff and any other organisations.

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 and clear 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 no readily available evidence that the company has a policy on potential conflicts of interest, which applies to both employees and Board members.

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 no readily available evidence that the company has a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery.

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 that the company’s anti-corruption policy includes 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.

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.

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 the company provides anti-corruption training 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 36%
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.

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 some evidence that the company has channels that are easily accessible and secure, for employees to report concerns or instances of suspected corrupt activity. According to the Central Vigilance Commission's website the Chief Vigilance officer is required to provide an independent channel for complaints. However, it is unclear whether the complaints that are made via the channel mentioned in the OFB whistle blower policy are to be received by the Chief Vigilance officer. Employees can also report concerns directly to the Central Vigilance Commission. However, it is not clear that any of the available channels guarantee anonymity when required. The company therefore scores 1.

COMMENTS -+
33a.
score
2

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

Based on public information, there is evidence that across geographies, all employees have access to more than one whistleblowing channel. The whisteblower policy directs employees to the company’s website and to the intranet portal for contact details of competent authorities to whom they can make a disclosure.

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. TI notes that the company takes measures to minimize difficulties for whistleblowers, including help in any judicial processes associated with the same. However, it is unclear if this includes mechanisms such as independent employee surveys or the monitoring of whistleblowing channel usage statistics.

COMMENTS -+
34.
score
1

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 some evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. In particular, the contact details of vigilance officers are available on the company website. However, it is unclear if they provide guidance on anti-corruption issues or only handle complaints. The company therefore scores 1.

COMMENTS -+
35.
score
1

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

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. However, there is no readily available evidence that disciplinary measures are applied to employees who breach this policy. The company therefore scores 1.

COMMENTS -+