By public info, this company is placed in Band E

Ownership

PRIVATE

Defence revenue, USD

Unknown

Defence revenue, %

Unknown

Country

SPAIN

Internal information

NO

Leadership 0%
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, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

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 insufficient evidence that the company publishes a statement of values or principles representing high standards of business conduct. TI notes that the company website sets out a company mission statement with values that include an ethical commitment, and states that the company is governed by an ethical and transparency framework. However, no values are listed and no further information is provided on how this commitment and framework is implemented in practice.

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. TI notes that public information suggests that the responsibility for implementing the company’s anti-corruption agenda may be distributed across different departments and committees.

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 publicly available information suggests that the responsibility for implementing the company’s anti-corruption agenda may be distributed across different departments and committees. Further, it is not clear that any of these departments have a reporting line to the Board.

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, 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 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.

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 58%
15.
score
2

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

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms.

COMMENTS -+
16.
score
2

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

Based on public information, there is evidence of a zero-tolerance anti-corruption policy.

COMMENTS -+
17.
score
1

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 evidence that the company has an anti-corruption policy and an ethical code. However, the anti-corruption policy can only be found when doing a key word search on an internet search engine and the Ethical Code is only available in Spanish. The company therefore scores 1.

COMMENTS -+
17a.
score
2

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

Based on public information, there is evidence that the company has an anti-corruption policy and an Ethical Code that are easily understandable and clear to Board members, employees and third parties.

COMMENTS -+
18.
score
1

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

Based on public information, there is evidence that the company has an anti-corruption policy that applies to all personnel of the company. However, evidence does not suggest that this includes Board members. The company therefore scores 1.

COMMENTS -+
20.
score
2

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 evidence that the company has a policy on potential conflicts of interest, which includes a definition and examples. Evidence suggests that this policy applies to both employees and Board members.

COMMENTS -+
21.
score
2

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 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. It sets out under which circumstances gift exchange is accepted, as well as upper limits and value thresholds necessitating senior management authorisation.

COMMENTS -+
22.
score
2

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 evidence that the company has a policy for the giving and receipt of hospitality to ensure that such transactions are bona fide and not a subterfuge for bribery. It sets out under which circumstances hospitality exchange is accepted, as well as upper limits and value thresholds necessitating senior management authorisation.

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.

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 36%
31.
score
2

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

Based on public information, there is evidence that the company has a clear and formal process by which employees declare conflicts of interest. The policy on conflict of interests contains a declaration form, while conflicts of interest can also be declared via email.

COMMENTS -+
32.
score
1

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 evidence that the company has an explicit commitment to apply disciplinary procedures to employees. However, it is unclear if this also applies to Board members. The company therefore scores 1.

COMMENTS -+
33.
score
0

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 no readily available evidence that the company has 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.

COMMENTS -+
33a.
score
0

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

Based on public information, there is no readily available evidence that whistleblowing channels are available to all employees in all geographies.

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, or that whistleblowers are treated supportively.

COMMENTS -+
34.
score
2

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 evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. Specifically, the Department of Legal Advice is responsible for providing support and advice in regard to the Anti-Corruption Policy.

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 -+