Arsenal JSC

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the 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 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 no readily available evidence that the company publishes a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability. TI notes that the company refers to principles which do not include those sought in this question.

Based on public information, there is no readily available evidence that the company belongs to a national or international initiative that promotes anti-corruption, or business ethics with a significant focus on anti-corruption. TI notes that the company belongs to the Bulgarian Defense Industry Association, which is a member of ASD. However, there is no evidence that this results in the company adopting the ASD Common Industry Standards.

Based on public information, there is some evidence that the company has appointed an Ethics committee that has some responsibility over the Company’s anti-corruption policy. However, there is no evidence detailing what this responsibility entails or the regularity of meetings. The company therefore scores 1.

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 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, 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 limited evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. However, there is no evidence of the implementation of mitigation plans. The company therefore scores 1.

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 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 no readily available evidence that the company makes clear to contractors, sub-contractors and supplies 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 limited evidence that the company has an anti-corruption policy. However, the policy is not a clear statement and is not explicit on all the forms that such corruption may take. The company therefore scores 1.

Based on public information, there is no readily available evidence of a zero-tolerance anti-corruption policy.

Based on public information, there is limited evidence that the company’s anti-corruption policy is easily accessible. It is available only in English, while the Company operates only in Bulgaria. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is easily understandable to Board members, employees and third parties. It does not provide a comprehensive overview of the Company’s stance on anti-corruption and applicable employee regulations.

Based on public information, there is no readily available evidence that the company’s 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. However, the wording remains vague, and the policy does not provide either a definition or examples. The company therefore scores 1.

Based on public information, there is no readily available 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.

Based on public information, there is no readily available evidence of a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery.

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.

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 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 to the Ethics Committee. However, there is no evidence that the company allows anonymous reporting or offers an independent reporting channel. Therefore the company scores 1.

Based on public information, there is evidence that across geographies, all employees can report to the Ethics Committee. The company therefore scores 1. To score higher the company would need to provide evidence that across geographies, all employees have access to more than one reporting channel.

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, or that whistleblowers are treated supportively.

Based on public information, there is no readily available 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 no readily available evidence that there is a commitment to non-retaliation for bona fide reporting of corruption.