Aerospace Corporation

Based on public information, there is some evidence that President and CEO Dr. Wanda M. Austin has made one strong statement in the past two years that promotes the company’s ethics agenda. However, statements in the Annual Reports and in regard to an award from Ethisphere are insufficiently strong. The company therefore scores 1. To score higher the company would need to provide evidence of at least two other such statements from the last two years, or one statement from the last two years that specifically supports the company’s strong stance against corruption.

Based on public information, there is insufficient 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, such as through public speeches or involvement with industry anti-corruption intiatives.

Based on public information, there is no readily available evidence that the CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. This engagement could for instance take the form of leading an anti-corruption workshop or chairing a review of the anti-corruption agenda.

Based on public information, there is some evidence that the company publishes a statement of values representing high standards of business conduct, including integrity. However, these values do not cover the range of values sought in the question, nor are these values linked to ethics and 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.

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.

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 that there is 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 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 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.

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 agents 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 engages in offset contracting.

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

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.

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

Based on public information, there is evidence that the company’s Standrads of Business Conduct are easily accessible to Board members, employees and third parties. It is available online in English, with evidence suggesting that the company only operates in the USA. The company therefore scores 2.

Based on public information, there is evidence that the company’s anti-corruption policy is understandable and clear to Board members and employees. The policy is written in accessible, comprehensible language.

Based on public information, there is evidence that the anti-corruption policy explicitly applies to all employees. The company therefore scores 1. To score higher, its application to members of the board must also be stated explicitly.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest, which applies to both employees and and board members. It provides several examples and differentiates between different forms of conflicts of interest.

Based on public information, there is evidence of a company policy for the giving and receipt of gifts. However, TI notes that it is extremely minimal, with the focus directed towards public officials. The company therefore scores 1. To score higher the company must indicate that there are set upper limits for gift exchange or senior authorisation.

Based on public information, there is evidence of a company policy for the giving and receipt of hospitality. However, TI notes it is extremely minimal and is only mentioned in relation to public officials. The company therefore scores 1. To score higher the company must indicate that there are set upper limits for hospitality exchange or senior authorisation.

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 some evidence that the company’s political contributions are regulated. The policy is extremely minimal with several general statements. The company therefore scores 1. To score higher, recipients must be publically declared and guidelines on the application of the regulations need to be clear.

Based on public information, there is evidence that the company has a clear policy on engagement in lobbying activities. Specifically, TI notes that the company states that it does not participate in lobbying activities.

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 evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. The Ethics: Standards of Business Conduct document is broad, provides several examples of conflicts of interest, and contains a brief summary of the key points. The company therefore scores 1. To score higher the company must provide written guidance that contains numerous scenarios or case studies to ensure that any areas of uncertainty are fully explained.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption. It is unclear if the Ethics Awareness and Anti-Fraud Programmes are training programmes. To score higher there would need to be evidence of an explicit anti-corruption module as part of the company’s ethics and compliance training programme.

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.

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

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. The Ethics: Standards of Business Conduct document states any employees with a question on a potential conflict of interest should talk to their supervisor, the Internal Audit Department or Office of the General Counsel. However, there is no evidence of how the conflict is recorded and resolved.

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.

Based on public information, there is evidence that employees can report concerns or instances of suspected corrupt activity using multiple channels. The Ethics: Standards of Business Conduct document directs employees who want to report concerns to the company's Fraud, Waste, and Abuse Hotline. Despite the hotline’s availability to any employee it is not confidential. Employees may also address questions to the Internal Audit Department or the Office of the General Counsel, in an unsigned letter or memo if preferred. However, it is not clear whether the hotline is an independent channel. The company therefore scores 1.

Based on public information, there is evidence that employees in all geographies have access to one whistleblowing channel, the hotline. It is unclear whether all employees have access to at least one other whistleblowing channel, as specific details are not provided for reporting using an unisgned letter or memo. The company therefore scores 1.

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 resources available to all employees where help and advice can be sought on corruption-related issues. This includes managers, the General Counsel’s Office, Human Resources, Security and Safety, or Internal Audit. However, it is not clear that these individuals have been specifically trained for this job. The company therefore scores 1.

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