Boeing

Based on public information, there is some evidence that the company publishes a statement from the CEO, supporting its anti-corruption and ethics agenda. In addition to the introductory CEO statement in the Ethical Business Conduct Guidelines, there are two other statements referencing ethics and integrity in the company’s Annual reports. The company therefore scores 1. To score higher the company would need to provide evidence of additional strong statements from the CEO in the last two years, which promote the company’s ethics and anti-corruption agenda, or one CEO statement from the last two years, specifically supporting the company’s strong stance against corruption.

Based on public information, there is no readily available evidence that the company’s CEO demonstrates a strong, personal, external facing commitment to the company’s anti-corruption agenda. However, evidence suggests that this engagement is delegated. For example, Christopher Chadwick, the President and CEO of the company’s Defence, Space and Security division, is on the DII steering committee. The company therefore scores 1. To score higher the company would need to provide evidence that the CEO has demonstrated active external engagement in anti-corruption matters on more than one occasion over the last two years.

Based on public information, there is no readily available evidence that the CEO demonstrates a strong personal internal-facing commitment to the company’s ethics and anti-corruption agenda. The company provided internal information for the 2012 CI which was openly published in the survey report with the company’s permission. However, the public assessment score remains 0 as this part of the survey is seeking to understand company transparency.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including integrity, openness, honesty and trust. The company demonstrates that these values are translated into company policies and codes.

Based on public information, there is evidence that the company is a member of DII and IFBEC.

Based on public information, there is evidence that the company has appointed the Audit Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Committee reports to the Board at least annually on the implementation of the company’s ethics and anti-corruption programmes, and receives reports in regard to risk management and internal audit.

Based on public information, there is evidence that the company has appointed the Senior Vice President, Office of Internal Governance (SVP-OIG), with responsibility for implementing the company’s ethics and anti-corruption agenda. The company identifies this person as Diana L. Sands.

Based on public information, there is evidence that the Audit Committee reports to the Board at least annually on the implementation and effectiveness of the company’s ethics and compliance programmes.

Based on public information, there is no readily available evidence of a formal, clear, written plan, on which the Board or senior management review of the company’s anti-corruption and ethics agenda is based.

Based on public information, there is no readily available evidence that the company has a formal process to review and update its policies, 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 process implemented enterprise-wide. TI notes that the company provided internal information for the CI 2012, which was openly published in the survey report with the company’s permission. However, the public assessment score remains 0 as this part of the survey is seeking to understand company transparency.

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. TI notes that the company provided internal information for the CI 2012, which was openly published in the survey report with the company’s permission. However, the public assessment score remains 0 as this part of the survey is seeking to understand company transparency.

Based on public information, there is no readily available evidence that the company conducts due diligence to minimise corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights to monitor, control and audit agents with respect to countering corruption.

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors and suppliers, its stance on corruption and the consequences of breaches to this stance. Supplier contracts contain terms relating to Business Conduct and there is the contractual right to terminate the contract in the event of a violation.

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 brokers.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms.

Based on public information, there is no readily available evidence that the company has a zero tolerance approach to corruption.

Based on public information, the company’s ethics and anti-corruption policies are accessible to Board members, employees and third parties. Both the Code of Conduct and the Ethical Business Conduct Guidelines are available on the company website. TI notes that the Code of Conduct is available in multiple languages.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily understandable and clear. The Ethical Business Conduct Guidelines contain multiple FAQs and do not use dense, legal terms.

Based on public information, the company’s Code of Conduct explicitly applies to all employees and Board members. The company also produces a Code of Ethical Business Conduct for Members of the Board of Directors.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. The policy clearly defines a conflict of interest and examples are provided. Board members have a separate conflicts of interest policy.

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. However, the policy requires employees to determine whether each exchange of gifts is acceptable. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of a gift, or has a requirement for senior management authorisation if a value threshold is exceeded.

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. However, the policy requires employees to determine whether each exchange of hospitality is acceptable. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of hospitality, or has a requirement for senior management authorisation if a value threshold is exceeded.

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, the company regulates political contributions in order to prevent undue influence or other corrupt intent. All political contributions are recommended by the Government Relations organisation, and are reviewed by the Vice President and Assistant General Counsel, Washington D.C. Operations, before they are approved by the Senior Vice President, Washington D.C. Operations. The company states that any corporate political contributions are publically disclosed on its website.

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.

Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent. While the company states that the FCPA applies to charitable contributions, there is no evidence of how the company specifically regulates charitable contributions, such as due diligence on potential recipients. Also, the company provides an overview of charitable contributions, but the corporate charitable contributions amount is assessed to be unclear and does not specify individual recipients.

Based on public information, there is evidence that the company provides written guidance, to help Board members and employees understand and implement its ethics and anti-corruption agenda. The Ethical Business Conduct Guidelines clearly describes key ethics policies and contains a series of FAQs after every section.

Based on public information, there is evidence that the company has a training programme on its ethics and compliance systems, which includes an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence of an explicit anti-corruption module as part of its ethics and compliance training programme.

Based on public information, there is some evidence that the company conducts three mandatory and educational activities annually and a Code of Conduct annual certification. However, it is not explicitly clear that these apply to all employees in all countries where the company operates. The company therefore scores 1.

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 anti-corruption training for employees in sensitive positions.

Based on public information, there is evidence that the company has a clear and formal process for employees to declare conflicts of interest, by which they must seek approval from an Ethics Advisor in writing.

Based on public information, there is some evidence that the company makes managers responsible for taking corrective action against conduct in violation of the company’s standards. The company therefore scores 1. To score higher the company would need to provide evidence of an explicit 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 multiple, well-publicised channels that are accessible, secure and confidential. Channels include Ethics Advisors in each business unit and the Ethics Line. The company therefore scores 1. To score higher the company would need to provide evidence that at least one of the channels is independent and allows anonymous reporting.

Based on public information, there is evidence that more than one whistleblowing channel is available to all employees, in all geographies. All business units have Ethics Advisors and the Ethics Line is available to all employees, from anywhere in the company, as well as external individuals.

Based on public information, there is some evidence of company efforts to ensure whistleblowing is not deterred. Multiple statements encourage employees to report ethical issues and state that retaliation will not be tolerated. The company therefore scores 1. To score higher the company would need to provide evidence of detailed analysis of whistleblowing data or independent employee surveys.

Based on public information, there is evidence that the company has well-publicised resources available to all employees, where advice can be sought on corruption-related issues. These resources include supervisors, managers, ethics advisors, and the Ethics Line.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. Evidence suggests that disciplinary measures are applied to employees who breach this policy.