Battelle Memorial Institute

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. TI notes that the Leadership section of the company website states that all Management participate in upholding the company’s commitment to civic and social responsibility. However, there is no further detail on the specific actions of individuals, including the CEO.

Based on public information, there is evidence that the company publishes a statement of values on its website, which includes honesty, integrity and accountability. However, it does not go into sufficient depth by explaining what the company means by such values and why they matter to the organisation.

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 no readily available evidence that the company has appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda.

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. TI notes that the company website states that all members of management participate in setting an example of civic and social responsibility. However, no further information was found pertaining to specific actions by individuals and what is implemented within the company.

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, 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 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.

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 suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance. TI notes that the company has a policy of ensuring full regulatory compliance in its business with suppliers. However, there are no further details on what this entails and how it is put into practice.

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 no readily available evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. TI notes that evidence suggests that the company has a code of conduct. However, it is not published on the company website and is only mentioned in the company’s Tax Returns Exemption Form.

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

Based on public information, there is no readily available evidence that the company has an anti-corruption policy that is easily accessible. TI notes that there is evidence that the company has a code of conduct. However, it is not published on the company website and is only mentioned in the company’s Tax Returns Exemption Form.

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.

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 some evidence that the company has a policy on potential conflicts of interest within the Code of Conduct. However, the Code is not available publicly and therefore no specific information on the policy is accessible.

Based on public information, there is some evidence that the company may have a policy prohibiting ‘improper private benefit’. However, bribery or the giving or receiving of gifts are not mentioned explicitly. TI notes that the company’s Code of Conduct is not publicly available.

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. TI notes that evidence suggests that the company provides training on its Code of Conduct, but limited information is provided and as a result it is unclear if it includes a specific anti-corruption module.

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 directors, officers and key employees complete annual conflicts of interest certificates. However, there is no evidence detailing the disclosure procedure for all employees.

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 the company has a hotline that is open to report concerns surrounding ethics. However, it is not clear whether employees would be guaranteed anonymity or confidentiality when using this. Therefore the company scores 1. It is unclear if a dedicated email for 501(c)(3) related matters can be used to report instances of corrupt activity.

Based on public information, there is evidence that across geographies employees have access to the Battelle Business Ethics and Employee Concerns Hotline. It is unclear if a dedicated email for 501(c)(3) related matters can be used to report instances of corrupt activity. 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, and 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.