AM General LLC

Based on public information, there is evidence that the company publishes one statement from the CEO in support of the company’s ethics standards and values. The company therefore scores 1. To score higher, TI would need to see further evidence of statements from the CEO or 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 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 some evidence that the company publishes a statement of values representing high standards of business conduct, including integrity, honesty and accountability. However, these values fall short of the range sought by this question and the company does not demonstrate how they are translated into its policies. 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 some 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 has found evidence of the existence of a Government Contract Compliance Review Board, known as the Self-Governance Steering Committee. However, the degree to which this committee has corporate responsibility for the company’s overall ethics and anti-corruption agenda is unclear, and it is noted that the source document referring to this committee is now 18 years old.

Based on public information, there is evidence that the Chief Compliance Officer and the Vice President of Human Resources are the main points of contact on ethical and anti-corruption issues for the company. Furthermore, it is evident that the Company’s Executive Vice President, who is identifiable by name, is the person responsible for the ethics policy.

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. TI has found evidence of the existence of a Self-Governance Steering Committee with responsibility for reviewing compliance issues, but further details about this group are not available and the scope of this review, as well as the group’s reporting line, are unclear. It is also noted that the source document for this committee is 18 years old.

Based on public information, there is no readily available evidence of a formal, clear, written plan 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 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 makes clear to contractors, 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 some evidence that the company has an anti-corruption policy, but this is not assessed to be explicit on all the forms corruption can take. The company therefore scores 1.

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

Based on public information, there is evidence that the company’s Code of Conduct and Business Ethics is easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company.

Based on public information, there is evidence that the company’s Code of Conduct and Business Ethics is overall understandable. However, the language is dense and legalistic, and may be less understandable to third parties working with the company. The company therefore scores 1.

Based on public information, there is evidence that the Code of Conduct and Business Ethics applies to all employees, agents and partners. However, it is not explicitly clear whether it applies to the leadership and the executive managers. The company therefore scores 1.

Based on public information, there is some evidence that the company has a policy on potential conflicts of interest. However, few examples are provided and it is not clear whether the policy also applies to the executive management and the leadership of the company. The company therefore scores 1.

Based on public information, there is evidence that the Company regulates the giving and receiving of gifts, with set upper limits and authorisation procedures in place.

Based on public information, there is evidence that the company regulates the giving and receiving of gratuities and entertainment. However, there appear to be no upper limits when offering hospitality to non-government persons or when receiving hospitality. 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.

Based on public information, there is evidence that the company regulates political contributions. However, limited information is provided about this process and it is not clear that contributions are recorded and disclosed. The company therefore scores 1.

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.

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. TI notes that the employees may refer to the Chief Compliance Officer or the Human Resources or Law Department if they have any questions about material contained within the Code of Conduct and Business Ethics. However, there is no readily available procedure for disclosing conflicts of interest specifically.

Based on public information, there is evidence of a commitment to apply disciplinary procedures to employees found to have violated the company’s ethics and compliance policy and its Code of Conduct and Business Ethics. However, it is not explicitly clear that this also applies to the company’s leadership. The company therefore scores 1.

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 particular, the company’s hotline is hosted by an independent third party.

Based on public information, there is evidence that the whistleblowing channels are available to employees in all geographies. This includes the Human Resources, Law Department, Chief Compliance Officer, and the hotline.

Based on public information, there is evidence that the company seeks to foster an environment supportive of whistleblowing. However, there is no readily available evidence of mechanisms to ensure that whistleblowing is not deterred, or that whistleblowers are treated supportively.

Based on public information, there is some evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. However, it is not clear whether these resources are available in all locations where the company operates and that the supervisors are specifically trained for the 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, and evidence that those who breach this commitment are subject to disciplinary measures.