Bharat Electronics

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. TI notes the Vigiliance Manual (2011) foreward by Chairman and Managing Director. However, this statement is assessed to be insufficiently strong, as it does not discuss the ethics and anti-corruption agenda specifically, and is not from the last two years.

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 some evidence that the company publishes a statement of values representing high standards of business conduct, including honesty, trust, transparency, and integrity. However, evidence was only found in the Code of Business Conduct and Ethics for Board Members and Senior Management. TI notes that the company’s Vigilance Manual is only a ready reference book for use by officers and staff involved in vigilance administration, and as such is not a guide for all employees. Therefore the company scores a 1. To score higher the company would need to provide evidence that its statement of values representing high standards of business conduct readily available to all employees.

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 Vigilance Committee with overall corporate responsibility for its anti-corruption agenda; its members include the Chairman and Managing Director. However, it is unclear what this responsibility specifically entails. The company therefore scores 1.

Based on public information, there is 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. However, the Chief Vigilance Officer is not identifiable by name, despite the fact that he has written a preface to the Vigilance Manual. The company therefore scores 1.

Based on public information, there is some evidence that there is regular monitoring and review of the performance of the company’s ethics and anti-corruption agenda. However, it is unclear how often there is a major formal review of the agenda or how often the Board is involved with the review process. The company therefore scores 1.

Based on public information, there is some 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. However, there is no readily available evidence of improvement plans being implemented when issues are identified. The company therefore scores 1.

Based on public information, there is 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 malpractice. The vigilance departments are responsible for analysing results of detective vigilance and finding solutions to prevent recurrence.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure. TI notes that the company has a ‘Risk Management Framework’ but it is unclear if it includes an anti-corruption risk assessment.

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. TI notes that there is a specific sub-contract procedure in place, but the approval process does not address corruption risk.

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 has an integrity pact which is signed by vendors and makes clear the company’s 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 evidence that the company has an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence that it explicitly prohibits many of the forms that corruption might take, for example the giving and receiving of bribes, and kickbacks, facilitation payments, and giving and receiving of gifts and hospitality.

Based on public information, there is evidence that the company has a zero-tolerance policy towards any form of corruption.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are publicly accessible. However, they seem to be available only in one language. The company therefore scores 1.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are understandable to some extent. However, evidence shows that the documents are written in dense language and are not fully clear on corruption related issues. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy applies to all employees. However, the Code of Business Conduct and Ethics for Board Members and Senior Management applies to Board members. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest that applies to Board members and senior management. However, no similar policy was found for employees and the information available is assessed to be limited in terms of definition and examples.

Based on public information, there is limited evidence that the company has a policy for the receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. Furthermore, this policy, which includes limits for senior authorisation, is only applicable for Board members and senior management, rather than employees.

Based on public information, there is limited evidence that the company has a policy for the receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. Furthermore, this policy is only applicable for Board members and senior management, rather than employees.

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. TI notes that the Vigilance Manual is only a reference book for officers and staff involved in vigilance administration, and as such is not a guide for all employees.

Based on public information, there is evidence that the company provides internal and external vigilance training programmes. However, it is unclear if this includes a specific anti-corruption training module. The company therefore scores 1.

Based on public information, there is evidence that vigilance training is provided to all employees.

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 some evidence that the company has a complaints handling policy, which includes an investigation and penalty decision-making process. However, the commitment remains vague and it is unclear if disciplinary procedures are taken in all instances. The company therefore scores 1.

Based on public information, there is evidence that the company has one independent whistleblowing channel, which is easily accessible and secure for employees to report concerns or instances of suspected corrupt activity. However, evidence suggests that this is the only channel and that employees are unable to report anonymously. The company therefore scores 1.

Based on public information, there is evidence that across geographies, all employees can report to more than one whistleblowing channel. This includes the Chief Vigilance Officer or the vigilance heads of specific units.

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. TI notes the complaint registration process, but there is no clear commitment to non-retaliation.