Chemring Group PLC

Based on public information, there is some evidence that the company publishes a statement from the CEO supporting the ethics and anti-corruption agenda of the company. The CEO delivers a message in the Code of Conduct, in which he encourages transparency and openness. 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 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 ethics and anti-corruption agenda of the company. This engagement could for instance take the form of leading an anti-corruption workshop or chairing a review of the company’s anti-corruption agenda.

Based on public information, there is evidence that the company publishes a statement of values including transparency, openness, honesty, and integrity. However, the values mentioned fall short of those sought in this question and only short descriptions are provided of what they mean for the company. The company therefore scores 1.

Based on public information, there is evidence that the company belongs to ASD and subscribes to the Common Industry Standards that promote anti-corruption and business ethics.

Based on public information, there is evidence that the company has appointed a Board committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Audit Committee has this responsibility and full Terms of Reference are published on-line.

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, and who has a direct reporting line to the Board. TI notes that the Ethics Committee has responsibility for ensuring proper implementation of the Code of Business Principles by the Executive Committee. However, no named individual has been found on the company website as leading the implementation of the ethics and anti-corruption agenda, and the relationship between Ethics Committee, Executive Committee and Audit Committee is unclear.

Based on public information, there is some evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. The Code of Conduct is reviewed on an annual basis, but not the whole ethics and anti-corruption agenda, which evidence suggests is more of a continuous monitoring. 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, 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 update its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The company has a risk assessment system of which anti-corruption is part. The company has a Risk Management Committee that has clear timelines and clear ownership over the risk assessment procedure. The company has also implemented assessments to mitigate the risks.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for business decisions ‘to be carried out as part of normal operating procedures’. However, the circumstances under which it is carried out are not detailed. The company therefore scores 1.

Based on public information, there is some evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing agents. The company has formal procedures, but there is no evidence that the company refreshes the due diligence at least every 3 years and/or when there is a significant change in the business relationship. The company therefore scores 1.

Based on public information, there is some evidence that the company has contractual rights and processes for the behaviour, monitoring, control and audit of agents with respect to countering corruption. The agents are expected to commit to compliance of the company’s Code of Business Principles and all applicable laws. There is some evidence that there is ongoing review and monitoring of agents, however, there is no evidence of formal processes to prevent or deal with the occurrence of any violations. The company therefore scores 1.

Based on public information, there is no readily available evidence that contractors, sub-contractors, and suppliers must commit themselves to take all measures to prevent corruption. The company states that it requires all of its employees and third parties acting on their behalf to conduct business honestly and with integrity. However, the company does not mention contractors, sub-contractors or suppliers in relation to its ethics and anti-corruption agenda.

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.

Based on public information, there is evidence that the anti-corruption policy is explicitly one of zero tolerance. The company states that it will not engage in bribery or corruption, nor will they permit anyone acting on their behalf to engage in such activities.

Based on public information, there is evidence that the company has an anti-corruption policy that is easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company. The Code of Business Principles is given to all employees and it is easily accessible online.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear to Board members, employees and third parties. The company’s policy is easily understood by a non-legal audience. TI notes it provides examples of possible violations of the company’s anti-corruption policy.

Based on public information, there is evidence that the anti-corruption policy explicitly applies to all employees and Board directors.

Based on public information, there is evidence that the company has a detailed policy on potential conflicts of interest, which applies to both employees and Board members. The policy contains a definition and examples of potential conflicts of interest.

Based on public information, there is some evidence of a company policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. The giving and receiving gifts is regulated, but the company does not appear to set clear upper limits or a specific threshold for gifts. The company therefore scores 1.

Based on public information, there is some evidence of a company policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. The company makes a statement on the giving and receipt of hospitality, but does not appear to set clear upper limits or a specific threshold for the giving and receipt of hospitality. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. However, the company provides no guidance or supplementary information on how the policy is to be implemented in practice. The company therefore scores 1.

Based on public information, there is readily available evidence that the company prohibits political 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 evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent. The company encourages its employees to support charitable organisations, but the company regulates the contributions. Each business has its own locally held charity budget, and at a Group level, charitable donations are considered on a monthly basis by the Executive Committee. Individuals are asked to seek prior approval before undertaking any community or charitable work, which might be dependent on the company equipment or time. The company declares its charitable contributions on its webpage.

Based on public information, there is evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. The Code of Business Principles includes scenarios to explain particular policies. Also, detailed guidance is available on the company intranet

Based on public information, there is evidence that the company has a training programme that explicitly covers anti-corruption. The company states that it provides regular anti-corruption training for management and employees working with commercial, sales and marketing, finance and human resource functions.

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. TI notes that the company states that it gives training to its Committees, but it is unclear whether this training covers the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. The company provides anti-corruption training to employees working within commercial, sales and marketing, finance, and human resource functions.

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 encouraged to inform their managers verbally of any potential conflicts. To score higher the company would need to provide evidence that employees declare conflicts of interest either in writing to a manager or to an independent department.

Based on public information, there is evidence that the company will apply disciplinary procedures to employees, found to have violated the Code of Conduct. However, it is not clear that this also applies to Board members. The company therefore scores 1.

Based on public information, there is some evidence that employees can report concerns or instances of suspected corrupt activity using multiple, well-publicised channels. The company states that employees are able to report concerns to a line manager or HR manager. In particular, the company provides an external Ethics Reporting Line for employees to report their concerns confidentially, which is available 24h a day, 7 days a week.

Based on public information, there is evidence that whistleblowing channels are available to all employees, in all geographies. The company provides a reporting line number for each of the countries in which it operates, as well as suggesting that whistleblowers contact their HR manager or the Group Legal Director to make a disclosure.

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. TI notes that the company states that it provides a mechanism by which employees can report violations without fear of reprisal. However, there is no evidence that the company tries to reduce or eliminate the fear to report concerns through visible, credible efforts to ensure that employees are comfortable doing so, for example by monitoring the whistleblowing channel usage statistics, issuing independent employee surveys, or initiating follow ups with a whistleblower after serious incidents have been reported and investigated.

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.

Based on public information, there is evidence that there is a commitment to non-retaliation for bona fide reporting of corruption. However, there is no evidence to indicate that those breaching this commitment are disciplined. The company therefore scores 1.