Ball Aerospace & Technologies Corp

Based on public information, there is evidence that the company publishes a statement from the Chief Executive Officer and Chairman of the Group, John A. Hayes, supporting its ethics and anti-corruption agenda. This statement is included in the Code of Business Ethics and stresses the importance of the company’s values and compliance programme. The company therefore scores 1. To score higher the company would need to provide evidence of at least two more statements from the last two years, in which the CEO and Chairman supports the company’s whole ethics and anti-corruption agenda, or one statement from the last two years, in which the CEO and Chairman specifically supports the company’s strong stance against corruption.

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 Chief Executive Officer demonstrates a strong, personal, internal-facing commitment, to the company’s ethics and anti-corruption agenda.

Based on public information, there is limited evidence that the company publishes a statement of values representing high standards of business conduct, including integrity and honesty. These values are described briefly in the Code of Business Ethics. The company therefore scores 1. To score higher the company would need to provide evidence that it abides by more of the values sought in this question and shows that they are explained in detail.

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 Audit Committee has overall corporate responsibility for the company’s ethics and anti-corruption agenda. The Audit Committee’s responsibilities include examining with the Chair of the Corporate Compliance Committee, the General Counsel, and senior executive officers, the company’s ethical standards and the use of the hotline reporting system.

Based on public information, there is evidence that the company has appointed at least one person at a senior level with responsibility for implementing its ethics and anti-corruption agenda. Ball Corporation’s General Counsel, Charles Baker, may hold this function. Similarly, Ball Aerospace’s Vice President Finance, Alison Medbery, may have this role. To score higher the company would need to provide evidence that an individual has clearly been assigned the role of overseeing the ethics and anti-corruption agenda.

Based on public information, there is limited evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. Evidence suggests that the Audit Committee continually monitors compliance with the company’s ethical standards and use of the hotline reporting system. Specifically, the Code of Business Ethics has been reviewed and revised periodically since 1994. Evidence does not suggest that the Corporate Compliance function is at the Board level. To score higher the company would need to provide evidence of a periodic, heavyweight, Board level review of its ethics and anti-corruption agenda.

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 is based. Evidence suggests that the Audit Committee continually monitors compliance with the company’s ethical standards and use of the hotline reporting system, and that improvement plans are implemented, such as revisions to the Code of Business Ethics. However, it is unclear if this forms the basis of a formal, clear, written plan, as part of a heavyweight, periodic, Board level review of the company’s whole ethics and anti-corruption agenda. Evidence does not suggest that the Corporate Compliance function is at the Board level.

Based on public information, there is no readily available evidence that the company has a formal process for reviewing and updating its policies and practices in response to actual or alleged instances of corruption. TI notes that the Corporate Compliance Program is revised and enhanced on an ongoing basis, but there is no evidence this process specifically occurs 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. Evidence shows that the company has a risk management procedure, but it is unclear if corruption is an identified risk.

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 decision. Evidence shows that the company has a risk management procedure, but it is unclear if corruption is an identified risk.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimizes 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 communicates its ethics and anti-corruption agenda down the supply chain, and makes clear its requirement for suppliers to conform to its anti-corruption policies. The company ensures 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, including the giving and receiving of improper payments.

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 some evidence that the company’s ethics and anti-corruption policies are easily accessible to Board members, employees and third parties. The Code of Business Ethics, the Ball Corporation Executive Officers and Board of Directors Business Ethics Statement, and the Ball Corporation Supplier Guiding Principles, are available on the company’s website. The company therefore scores 1. To score higher the company would need to provide evidence that these ethics and anti-corruption policies are available in different languages.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily understandable to Board members, employees and third parties. The policies are written in clear, comprehensible language, using unambiguous terms.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies apply to all employees and Board members.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. It includes a definition of a conflict of interest and lists numerous examples. Board members have a separate policy on potential 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. All gifts must be associated with a business purpose, be of nominal value, be legal under applicable anti-corruption laws, and not be seen as a bribe. The Company’s Business Ethics handbook includes monetary limits.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. All hospitality must be associated with a business purpose, be of nominal value, be legal under applicable anti-corruption laws, and not be seen as a bribe. The Company’s Business Ethics handbook includes monetary limits.

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 or regulates political contributions in order to prevent undue influence or other corrupt intent. TI notes that the company prohibits bribes to any political party or party official. However, this question is seeking evidence of the existence of mechanisms to regulate political contributions.

Based on public information, there is no readily available evidence that the company has a policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, nor discloses the issues on which it lobbies.

Based on public information, there is evidence that the company has a policy that regulates charitable contributions, in order to prevent undue influence or other corrupt intent. All charitable contributions go through the Ball Foundation, which has guidelines and an application procedure. Recent grant recipients and the total annual amount of charitable contributions are listed on the company’s website.

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 company’s ethics and anti-corruption agenda. TI notes that the Code of Business Ethics refers to the Corporate Policy Manual and Corporate Policy Statements, but these are not publically accessible.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption. Managers and other targeted employees must perform an electronic compliance verification for business conduct, which includes anti-corruption policies. However, it is unclear if this is part of a training programme.

Based on public information, there is no readily available evidence that the company provides anti-corruption training in all countries where it operates or has sites. Managers and other targeted employees must perform an electronic compliance verification for business conduct, which includes anti-corruption policies. However, it is unclear if this is part of a training programme.

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. Managers and other targeted employees must perform an electronic compliance verification for business conduct, which includes anti-corruption policies. However, it is unclear if this is part of a training programme.

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. Employees are instructed to discuss any conflicts of interest with their supervisor, who will then contact the appropriate personnel. To score on this question the company would need to provide evidence that employees report conflicts of interest either to a manager in writing, or to an independent department.

Based on public information, there is evidence that the company has a policy to apply disciplinary procedures to violations of the Code of Business Ethics. However, it is not an explicit commitment. Also, the Ball Corporation Executive Officers and Board of Directors Business Ethics Statement does not include a commitment to apply disciplinary procedures to Directors and Board members found to have engaged in corrupt activities. The company therefore scores 1.

Based on public information, there is evidence that the company has multiple, well-publicised and secure channels, for employees to report concerns or instances of suspected corrupt activity. These channels include a department manager, a business unit compliance officer and a business unit executive. In particular, employees may contact authorised executives anonymously using telephone hotlines and email addresses. However, evidence does not suggest that the telephone hotlines and email addresses are externally operated. The company therefore scores 1. To score higher the company would need to provide evidence that at least one whistleblowing channel is externally operated.

Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. For example, employees can report to a business unit compliance officer, or an authorised executive either by telephone or email

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 evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. These resources include business unit compliance officers and authorised executives as part of the compliance hotline.

Based on public information, there is evidence that the company has a non-retaliation policy for bona fide reporting of corruption. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary measures are applied to employees who breach this policy.