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- B
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- F
Ownership
PRIVATE
Defence revenue, USD
788.7m (2013)
Defence revenue, %
92.9% (2013)
Country
USA
Internal information
NO
Based on public information, there is no readily available evidence that the 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 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 but these fall short of the values covered by the question (honesty and integrity are included) and the company does not explain the importance or demonstrate the application of these values. 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 evidence that the Corporate Governance and Compliance Committee is responsible for providing overall guidance with regard to the Ethics Programme. The company therefore scores a 1. To score higher the company would need to provide evidence of terms of reference detailing what this responsibility entails.
Based on public information, there is evidence that the company has appointed a person at a senior level to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board. This is the Corporate Compliance Officer. The person is not publicly identifiable by name. The company therefore scores 1.
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.
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 evidence that contracted third parties are expected to comply with the Code of Ethics, Conduct and Responsibility (2013) or similar standard; however, 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 evidence that the company passes its ethics and anti-corruption standards down the supply chain. The Code of Ethics, Conduct and Responsibility (2013) states that contracted third parties are expected to comply with the Code of Ethics, Conduct and Responsibility (2013) or similar standard. The company therefore scores 1. To score higher the company would need to provide evidence that it has contractual rights to apply sanctions in the event of a breach of its contract.
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 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 that the company’s anti-corruption policy is explicitly one of zero-tolerance.
Based on public information, there is evidence that the company's anti-corruption policy is easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company. It is available on-line. However, it appears to be available in only one language. The company therefore scores 1.
Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear to Board members, employees and third parties.
Based on public information, there is evidence that the anti-corruption policy explicitly applies to all employees and members of the Board.
Based on public information, there is evidence that the company has a policy on potential conflicts of interest that applies to both employees and board members. The Code of Ethics, Conduct and Responsibility (2013) statement is extensive and covers both Personal and Organisational conflicts of interest. TI notes that there are additional policies referenced from the Code of Ethics, Conduct and Responsibility that are not publicly available.
Based on public information, there is evidence that the company has a comprehensive policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. Specific limits are stated. TI notes that there are additional policies referenced from the Code of Ethics, Conduct and Responsibility that are not publicly available.
Based on public information, there is evidence that the company has a comprehensive policy for the giving and receipt of hospitality to ensure that such transactions are bona fide and not a subterfuge for bribery. Specific limits are stated. TI notes that there are additional policies referenced from the Code of Ethics, Conduct and Responsibility that are not publicly available.
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 prohibits political contributions by employees. Political contributions on behalf of the company are made through the PAC, iaw federal law. However, it is not clear that recipients are publicly declared. The company therefore scores 1. TI notes that there are additional policies referenced from the Code of Ethics, Conduct and Responsibility that are not publicly available.
Based on public information, there is evidence that the company has a policy on engagement in lobbying activities. All such activities must be coordinated with the Director of Government Relations. There is also evidence that the company publically discloses the issues on which it lobbies. TI notes that there are additional policies referenced from the Code of Ethics, Conduct and Responsibility that are not publicly available.
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 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 Code of Ethics, Conduct and Responsibility contains an ethical decision making model and key do’s and don’ts. The Company therefore scores 1. To score higher the company would need to provide evidence of written guidance that contains numerous scenarios and case studies.
Based on public information, there is evidence that the company has an ethics training programme but it is not clear if this explicitly covers anti-corruption. The company therefore scores 1.
Based on public information, there is evidence that employees are required to participate in mandatory annual ethics training. However, it is unclear if this training is provided to all employees in all sites of operation. The company therefore scores 1.
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 of the formality of the process by which employees declare conflicts of interest.TI notes that there are additional policies referenced from the Code of Ethics, Conduct and Responsibility that are not publicly available.
Based on public information, there is evidence that the company ‘may’ apply disciplinary procedures to employees, Directors and Board members found to have violated the Code, company policies or procedures or law or regulation. The company therefore scores 1. To score higher, the company would need to provide evidence of a stronger commitment using ‘will’ rather than ‘may’.
Based on public information, there is 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, to report concerns or instances of suspected corrupt activity. 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 the whistleblowing channels are available to all employees in all geographies. Channels include several designated internal officers, the Law Department, Internal Audit, and 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 where help and advice can be sought on corruption-related issues.
Based on public information, there is evidence of a commitment to non-retaliation for bona fide reporting of corruption, including the application of disciplinary measures to those who breach this commitment.
Based on public information, there is limited evidence of a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company. TI notes the statement at the beginning of the Code of Ethics, Conduct and Responsibility (2013), but does not assess this to be strong enough evidence to score higher here.