AAR Corp

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.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or Chair of the Board demonstrates 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 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.

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. TI notes that the Code of Business Ethics and Conduct states that employees must maintain integrity, but very little explanation is provided.

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.

Based on public information, there is limited evidence that the company has appointed the Audit Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Committee has responsibilities relating to legal and regulatory compliance, and receives reports concerning non-compliance with the Code of Business Ethics and Conduct. The company therefore scores 1. To score higher the company would need to provide evidence of what this responsibility specifically entails.

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, and who has a direct reporting line to the Board.

Based on public information, there is no readily available evidence of 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 of 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.

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.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The company identifies non-compliance with international anti-corruption legislation as a risk, but provides no evidence of a corresponding risk assessment procedure.

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, 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 conducts 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 has 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 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.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

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.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. This includes giving bribes, kickbacks and receiving corrupt gifts and hospitality.

Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. However, the company has a zero tolerance policy of violations of the Code of Business Ethics and Conduct, as shown by its explicit stance on disciplinary procedures in the event of a violation by any employee or director. The company therefore scores 1.

Based on public information, there is some evidence that the company’s ethics and anti-corruption policies are easily accessible to Board members, employees and third parties. The Code of Business Ethics and Conduct is available on the company website, but it is only available in English, despite the company operating in over 60 locations worldwide. The company therefore scores 1.

Based on public information, there is evidence that the company’s Code of Business Ethics and Conduct is written in accessible, comprehensive language.

Based on public information, there is evidence that the company’s Code of Business Ethics and Conduct explicitly applies to all employees and Board members.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. The policy contains a brief description of a conflict of interest but provides no examples. The company therefore scores 1. To score higher the company would need to provide examples of potential conflicts of interest.

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. Employees may not solicit or accept any gifts from a source that conducts or seeks to conduct business with the Company. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of a gift and/or has the requirement for senior management authorisation if a value threshold is exceeded.

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. Employees may not solicit or accept hospitality from a source that conducts or seeks to conduct business with the Company. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of hospitality and/or has the requirement for senior management authorisation if a value threshold is exceeded.

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

Based on public information, there is evidence that the company regulates political donations, in order to prevent undue influence or other corrupt intent. Written approval must be received from the General Counsel before making any political contributions using company funds or in the company’s name. The company therefore scores 1. To score higher the company would need to provide evidence that it publically declares recipients of its political contributions.

Based on public information, there is limited evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent. The company states that employees who deal with public officials must be familiar with and comply with applicable lobbying laws and regulations, particularly those that apply to registrations and filings. The company therefore scores 1. To score higher the company would need to provide evidence that it publically discloses the issues on which it lobbies.

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

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 company’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption.

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

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

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.

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. Employees are instructed to advise the company of any real or potential conflicts of interest. To score on this question the company would need to provide evidence that employees are instructed to either report conflicts of interest to a manager in writing, or to an independent department.

Based on public information, there is evidence that the company has an explicit commitment to apply disciplinary procedures to employees who violate the Code of Business Ethics and Conduct. The Code includes an anti-corruption policy and is applicable to Board members.

Based on public information, there is evidence that the company has multiple, accessible, secure channels, for employees to report concerns or instances of suspected corrupt activity. These channels include a Human Resources representative, the General Counsel, the Senior Counsel, or the Corporate Compliance Officer. In particular, employees may report anonymously to the independently operated Ethics Hotline.

Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. For example, employees can report to a Human Resources representative or the Ethics Hotline.

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.

Based on public information, there is evidence that the company has well-publicised resources available to all employees, such as the General Counsel, where help and advice can be sought on corruption-related issues.

Based on public information, there is evidence that the company has a non-retaliation policy for bona-fide reporting of corruption. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary measures are applied to employees who breach this policy.