Aerospace Industrial Development Corporation (AIDC)

Based on public information, there is evidence that the company has published a statement from the President outlining the company’s AIDC’s Anti-corruption Principles and a statement emphasizing AIDC’s ethical rules for procurement activities.

Based on public information, there is no readily available evidence that the President 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 evidence that the company publishes a statement of values, primarily including accountability, but with mention of honesty and openness. Although the company demonstrates that these are translated into policies and codes, TI assesses that these values do not focus on enough possible high standards of business conduct to merit a higher score here. The company therefore scores 1.

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. TI assesses that it is possible that the Audit Committee has this role, but it this not outlined in publicly available information.

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 reference is made to a ‘government ethics group leader’ but information pertaining to the responsibilities and reporting line relating to this role are not publicly available.

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 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.

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.

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.

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 some evidence that the company makes clear to suppliers, through policy terms, its stance on bribery and corruption. However, it is not clear that this is made clear in contractual terms or that they are informed of the consequences of breaching this stance.

The company has informed TI that it does not engage in offset contracting.

The company has informed TI that it does not engage in offset contracting.

Based on public information, there is evidence that the company has an anti-corruption policy that is explicit about all the forms corruption may take.

Based on public information, there is evidence that the anti-corruption policy is one of zero-tolerance. In addition, TI notes that it is prohibited to violate the Code of Ethics and Standards of Ethical Conduct.

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible. However, TI notes that the policy is only available in Chinese. The company therefore scores 1.

Based on public information, there is evidence that the company’s anti-corruption policy is understandable to Board members and employees.

Based on public information, the company’s anti-corruption policy applies to employees and members of the Board.

Based on public information, there is limited evidence that the company addresses the issue of potential conflicts of interest in its Code of Business Conduct. In addition, TI does note that the company mentions the requirement to avoid conflicts of interest in it’s Independent Policy. However, this is not assessed to be strong enough evidence of a policy on this issue.

Based on public information, there is evidence that the company has a policy for the receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. However, it is not clear that this also covers the giving of gifts.

Based on public information, there is evidence of a statement on the receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery. However, it is not clear that this also covers the offering of hospitality.

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 no readily available evidence that the company prohibits political contributions, or regulates 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 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.

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.

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. TI notes the Code of Ethics and Standards of Ethical Conduct but assesses these to be weak in terms of explanation or guidance.

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 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.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have violated the company’s ethical code and standards of conduct.

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.

Based on public information, there is no readily available evidence that the company has whistleblowing channels.

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 insufficient evidence that the company has 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 there is a commitment to non-retaliation for bona fide reporting of corruption.