Babcock International Group Plc

Based on public information, there are multiple statements from the Chairman emphasizing the importance of good corporate governance and also of transparency, integrity and probity. These statements reference the company’s anti-corruption agenda.

Based on public information, including searches outside the company website, there is no readily available evidence that the company’s Chairman or CEO demonstrates a strong personal external facing commitment to the anti-corruption agenda of the company.

Based on public information, there is evidence that the Chief Executive Officer personally introduced the Code of Conduct to the company’s senior management across all the company divisions. The company therefore scores 1. To score higher the company would need to provide evidence of at least two other examples of such engagement.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including honesty and integrity. The company explains the importance of these values, along with openness, transparency and accountability, and demonstrates how they are translated into its policies.

Based on public information, there is evidence that the company subscribes to the Common Industry Standards for European Aerospace and Defence.

Based on public information, there is evidence that the company has assigned the Audit and Risk committee to oversee anti-bribery and anti-corruption policies and procedures. The committee is headed and comprised of members from the Board and has clear terms of reference.

Based on public information, there is evidence that at operational level, Divisional Chief Executives and Managing Directors are responsible for the Anti-Bribery and Corruption policy. They have a direct reporting line to the Board. Indeed, four out of five of the Divisional Chief Executives sit on the main Board and are named.

Based on public information, there is evidence that the company reviews its anti-corruption policies and regulations annually. Specifically, this falls under the remit of the Audit and Risk Committee when reviewing the company's internal controls.

Based on public information, there is some evidence that the company has a formal process of review and monitoring of its anti-corruption policy but there is insufficient information about the implementation of improvement plans. The company therefore scores 1.

Based on public information, there is evidence that the company reviews its anti-bribery policies, whistleblowing investigations and fraud cases on a regular basis. There is evidence to indicate that the company initiates updates based on alleged or actual instances of corruption.

Based on public information, there is evidence of a risk assessment and management procedure implemented through the Audit and Risk Committee that covers both anti-corruption and the entire organisation. Further, the company’s Anti-Bribery and Corruption policy contains extensive procedures to ensure that risk assessment is implemented enterprise-wide.

Based on public information, there is evidence of a documented detailed risk assessment procedure for business decisions with clear guidelines, red flags and circumstances to take into consideration.

Based on public information, there is evidence that the company has extensive anti-corruption due diligence arrangements when selecting business advisers. The due diligence is renewed every 2 years.

Based on public information, there is evidence that the company has contractual rights and monitoring processes in place for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.

Based on public information, there is evidence of the company passing on clear information to sub-contractors that they must comply at all times with the company's code of ethics. TI notes that the company is on the ADS SC21 initiative for better supply chains and also on its Steering committee initiative which has ethics as one of its seven commitments in all business dealings including suppliers, contractors in their supply chain. Further, the company’s Anti-bribery and corruption policy specifies the details of these arrangements. However, TI has not seen any evidence to confirm that contractual obligations make clear the consequences in the event of breach of this policy. The company therefore scores 1.

Based on public information, there is evidence that the company addresses the corruption risks associated with offset contracts. TI understands that when the company appoints an intermediary for the implementing of an offset contract, the regulations covering agents are enforced.

Based on public information, there is evidence in the company Anti-Bribery and Corruption policy that the offset intermediaries are subject to due diligence process that also applies to appointing business partners or agents altogether. As such, the arrangements are reviewed every 2 years.

Based on public information, there is evidence that the company has a policy prohibiting corruption in its various forms, including bribes, facilitation payments, gifts and hospitality.

Based on public information, the company’s anti-corruption policy explicitly states its stance of zero tolerance of corruption.

Based on public information, there is evidence of the code of conduct being available online, introduced and distributed and explained to the employees by a member of the senior management team and it is also in a readable format. Furthermore, the company’s Anti-Bribery and Corruption Policy is available online and provides detailed guidelines. However, TI notes that the Code of Conduct only appears to be available in English. The company therefore scores 1.

Based on public information, the company’s code of conduct is presented in a clear and an understandable format. Further, the company’s Anti-Bribery and Corruption Policy provides extensive guidelines on all company anti-corruption regulations in accessible and understandable language.

Based on public information, there is evidence that the Code of Conduct covers all employees but it does not explicitly mention whether Board members are included or if additional regulations apply. The company therefore scores 1.

Based on public information, there is evidence that the company has a conflicts of interest policy which applies to all employees and board members. However, the company does not provide examples of potential conflicts of interest. The company therefore scores 1.

Based on public information, there is evidence that the company has extensive regulations regarding giving and receiving of gifts in order to ensure these transactions are bona fide. TI understands that each Divisional Department sets its upper limits although it is unclear exactly what these are for each Division, they regulations are clearly outlined.

Based on public information, there is evidence that the company has extensive regulations regarding giving and receiving of hospitality in order to ensure these transactions are bona fide. TI understands that each Divisional Department sets its upper limits although it is unclear exactly what these are for each Division, they are clearly outlined.

Based on public information, there is evidence that the company clearly prohibits facilitation payments and also goes into detail to define facilitation payments to employees and business partners and to explain how they are regulated.

Based on public information, there is evidence that the company clearly regulates political contributions based on a set of guidelines. TI notes that the company has declared that under this process there were no political contributions in the year 2013.

Based on public information, there is evidence that the company regulates lobbying activities in order to prevent undue influence.

Based on public information, there is evidence that the company regulates charitable donations to prevent undue influence or other corrupt intent. TI notes that the company also declares the recipients of such donations.

Based on public information, there is evidence that the company’s Code of Business Conduct and Anti-Bribery and Corruption policy contain guidance and explanation of the company’s anti-corruption policies in a clear and readable format.

Based on public information, there is evidence that the company has a training programme covering anti-corruption and its scope and employee coverage is extended to employees who require it “appropriate” to their role. Also further training is extended in the form of divisions and group functions having designated members from its senior management responsible for ensuring that employees are trained in anti-corruption guidance.

Based on public information, there is evidence that the company requires all employees to complete an on-line training module or face-to-face when deemed necessary.

Based on public information, there is no readily available evidence of anti-corruption training being specifically provided to members of the Board. TI understands that the highest ethical conduct is expected of the senior management and the Board but has found no explicit information on anti-corruption training targeted to the Board. The company therefore scores 0.

Based on public information, there is evidence that the company recognises the need for more targeted training to employees in high risk roles and that this is provided.

Based on public information, there is evidence that the company has a clear policy for directors to disclose their conflicts of interest; however, the Code of Business Conduct for employees refers only to "proper disclosure" for employees and the process for this is not defined.

Based on public information, there is evidence that the company is committed to applying disciplinary action to employees for breaches of their policies and the applicable legislation. However, it is not clear that this commitment also applies to Board members. The company therefore scores 1.

Based on public information, there is evidence that the company has a well-publicised and confidential whistleblower hotline to report corruption. The hotline also has multiple channels for reporting corruption. TI also notes the good practice that “[a]ll calls, letters or emails received regarding whistleblowing cases are initially received by an external third party and logged into a whistle blowing database”.

Based on public information, there is evidence that several channels, including independent third party whistleblowing channels, are available to all employees in all geographies.

Based on public information, the whistleblowing channels are comprehensive and easily accessible; they are also introduced to all new employees on induction and are strongly promoted. Further, whistleblowing incidents are reviewed and investigated on annual basis and reported to the Audit and Risk Committee. However, TI found limited readily available evidence that whistleblowers are supported by follow up after serious incidents have been reported and investigated or by independent employee surveys to gauge employee feelings about the reporting process. The company therefore scores 1.

Based on public information, TI has found evidence that the company has resources available to employees where help and advice can be sought on corruption-related issues.

Based on public information, there is evidence that the company states that employees have the right to report violations of the Code without fear of unfavourable consequences. There is also evidence that employees who breach this commitment will be subject to disciplinary measures.