Alliant Techsystems Inc. (ATK)

Based on public information, there is evidence that the company publishes a statement from the Chief Executive Officer supporting the ethics agenda of the company. However, no specific mention of anti-corruption is made. The company therefore scores 1.

Based on public information, there is some evidence that the Chief Executive Officer demonstrates a personal, external facing commitment to the ethics and anti-corruption agenda of the company. The President and CEO, Mark DeYoung, was quoted in a press release on the company’s ethics policy when the Corporate Social Responsibility Report was published in May 2014. The company therefore scores 1.

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 representing high standards of business conduct, in particular integrity. The company demonstrates that integrity is translated into company policies and codes, but the scope of values falls short of those sought by the question. The company therefore scores 1.

Based on public information, there is evidence that the company is a member of the Defence Industry Initiative on Business Ethics and Conduct (DII).

Based on public information, there is evidence that the company has appointed the Audit Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Committee Charter states its responsibilities with respect to the company’s ethics and compliance.

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.

Based on public information, there is evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. The Audit Committe Charter sets out the company’s commitment to monitoring and review, but the precise scope of such review is not articulated, nor is there any indication of how often such review will take place. The company therefore scores 1. To score higher the company would need to indicate the exact scope of the review and how regularly such a review is carried out.

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 process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption. TI notes that the company investigates concerns, but it is not clear if this includes a review of the policies and practices.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise wide. The company therefore scores 1. To score higher the company would need to provide evidence of the development and application of mitigation plans.

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. TI notes that agents working with the company are required to abide by the Code of Conduct. However, there is no evidence to suggest that contractual rights are put in place.

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

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

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible. The company’s Business Ethics Code of Conduct is available in English and Spanish. However, TI notes that the old version of the Business Ethics Code of Conduct is still accessible via the Values page on the company website, and this could be confusing for those trying to access the Code.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear. TI notes that examples are provided in a Q and A format in the Business Ethics Code of Conduct to aid understanding.

Based on public information, there is evidence that the company’s anti-corruption policy 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 for employees and for Board members. The company provides examples of possible 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. However, no public reference is made to upper limits or the requirement for senior authorisation. These details may be included in the company’s Business Courtesies, Gifts and Gratuities Policy, but this is not publicly available. The company therefore scores 1.

Based on public information, there is no readily available evidence of a statement on the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. However, no public reference is made to upper limits or the requirement for senior authorisation. These details may be included in the company’s Business Courtesies, Gifts and Gratuities Policy, but this is not publicly available. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments. TI notes that the company prohibits such payments to low-level foreign government employees without the review and approval of an ATK Legal Advisor. As such, TI assesses that this is not a comprehensive policy and its wording implies that such payments may be permitted in certain circumstances.

Based on public information, there is evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent. There is evidence that such contributions are publicly disclosed.

Based on public information, there is evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent. There is evidence that the company discloses lobbying expenditures.

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. TI notes that the company provides significant details on its charitable activities in the Corporate Social Responsibility Report.

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. Specifically, the company’s Business Ethics Code of Conduct goes into some detail and provides examples in a Q and A format to aid understanding. The company therefore scores 2.

Based on public information, there is evidence that the company has a training programme on its Business Ethics Code of Conduct, which includes an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence of an explicit anti-corruption module.

Based on public information, there is evidence that the company has a mandatory training programme for all employees that covers the Business Ethics Code of Conduct, which includes an anti-corruption policy.

Based on public information, there is evidence that the company provides targeted compliance training to members of the Board. However, it is unclear if such training is refreshed at least every three years. The company therefore scores 1.

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. TI notes that the company affirms to train all employees on their Business Ethics Code of Conduct.

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. TI notes that employees are simply directed to discuss the issue with a Legal Advisor or the Corporate Ethics and Compliance Office.

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 Business Ethics Code of Conduct and related policies.

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. In paticular, the Ethics Helpline is operated externally and facilitates anonymous reporting.

Based on public information, there is evidence that the across geographies, all employees have access to more than one whistleblowing channel.

Based on public information, there is some evidence that whistleblowing by employees is not deterred. However, there is no readily available evidence of formal mechanisms to ensure that whistleblowers are treated supportively, for example through employee surveys, an analysis of whistleblowing data or followup with individual whistleblowers.

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 that the company has a commitment to non-retaliation for bona fide reporting of corruption, and disciplines individuals who breach this policy.