CAE Inc.

Based on public information, there is evidence that the company has published a statement from the President and Chief Executive Offier supporting the ethics and anti-corruption agenda of the company, as a preface to the code of conduct within the last two years. The company therefore scores 1. To score higher the company would need to provide evidence of at least two other such statements from the last two years, or one statement from the last two years that specifically supports the company’s strong stance against corruption.

Based on public information, there is no readily available evidence that the company’s 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 insufficient evidence of a statement on the company’s values and standards within the Corporate Social Responsibility Report. No information is provided on what these values mean for the company and how they translate into company policies and codes.

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 company has appointed an audit committee and a governance committee with overall corporate responsibility for its ethics and anti-corruption agenda. Their responsibilities include annually updating the Code of Business Conduct and the company’s system to monitor compliance, as well as reviewing legal compliance issues.

Based on public information, there is evidence that the company has appointed a general counsel responsible for its ethics and anti-corruption agenda, who is identifiable by name.

Based on public information, there is evidence that the company has general Board level monitoring and review of the performance of the company’s governance, but it is not clear whether this is continuous review or a scheduled major review of the entire agenda. The company therefore scores 1.

Based on public information, there is no readily available evidence of 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, or evidence of improvement plans being implemented when issues are identified.

Based on public information, there is no readily available 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, with clear requirements on the circumstances under which such a procedure should be applied.

Based on public information, there is evidence that the company has formal procedures in place for selecting agents, and requires an annual review for multi-year contracts.

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

Based on public information, there is evidence that the company makes clear its ethics and anti-corruption agendas. However, the consequences of non-compliance are not explicit nor is there evidence of contractual rights or sanctions. The company therefore scores 1.

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 a policy that prohibits the giving and receiving of bribes, and is explicit on the various forms corruption can take.

Based on public information, there is evidence that the company has a zero tolerance policy of bribery.

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible to board members, employees, and all other affiliate organizations through their website, and is also available in several languages.

Based on public information, there ie evidence that the company’s code of conduct and references to anti-corruption measures are written in clear, comprehensible language.

Based on public information, there is evidence that the company’s anti-corruption policies apply to all employees. Additionally, there is a Board Member Code of Conduct that applies to the Board.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest, which includes a definition and examples.

Based on public information, there is evidence that the company has a policy on the giving and receiving of gifts, sets an upper limit for senior authorisation and recommends public disclosure. Furthermore, it also provides scenarios and cases as guidance to better understand the policy.

Based on public information, there is evidence that the company has a policy on the giving and receipt of hospitality under their gifts and entertainment policy that sets a specific threshold for senior authorisation.

Based on public information, there is no readily available evidence that the company has an explicit policy prohibiting facilitation payments. TI does note that there is evidence of a policy on improper payments in the Board Member Code of Conduct.

Based on public information, there is evidence that the company prohibits political contributions.

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, and discloses the issues on which the company lobbies.

Based on public information, there is evidence that the company has a policy to regulate charitable contributions to prevent corruption or other undue influence. As part of this, procedures for donations are clear, but there is no guidance for public declaration of recipients. The company therefore scores 1.

Based on public information, there is evidence that the company has a separate Board code of conduct, along with designated ethics officers, to provide guidance to help board members and employees understand and implement the firm’s code of conduct. However, there is no evidence of written guidance beyond the codes of conduct.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption.

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 employees are only directed to inform their supervisors about any potential conflicts of interest.

Based on public information, there is evidence that the company has clearly stated it will apply disciplinary procedures to employees and directors who have violated its anti-corruption policies.

Based on public information, there is evidence that the company has multiple internal and independent channels to report instances of corruption that are well-publicised and allow for anonymity.

Based on public information, there is evidence that across geographies all employees have access to more than one reporting channel. This includes the Human Resources and Legal Departments, as well as the EthicsPoint hotline. The company therefore scores 2.

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 employees have access to supervisors and legal representatives, but there is no evidence that they are trained for the advisory job. The company therefore scores 1.

Based on public information, there is evidence that the company has a clear, legally enforceable, non-retaliation policy for bona-fide reporting of corruption and commits to disciplinary measures when this is breached.