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Ownership
PUBLIC
Defence revenue, USD
2,401m (2013)
Defence revenue, %
18.5% (2013)
Country
US
Internal information
YES
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 evidence that the company publishes a statement of values representing high standards of business conduct, including honesty, integrity, transparency and accountability. The company clearly demonstrates that these are translated into policies and codes.
Based on public information there is evidence that the company is a member of the Defense Industry Initiative on Business Ethical Conduct (DII)
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. TI also notes the clear role of the Ethics and Compliance Office in this regard, which is chartered by the Board of Directors.
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. The Chief Ethics and Compliance Officer is Chris DePippo.
Based on public information, there is evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. There is also evidence that an ad-hoc Ethics Committee is convened to review the agenda in detail. However, it is not stated how often this takes place. The company therefore scores 1.
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. Evidence shows that the Audit Committee reviews the Code of Ethics and Standards of Conduct and recommends changes to the Board. However, evidence does not suggest that this process occurs in response to actual or alleged instances of corruption. The company therefore scores 0.
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 is understood to have a risk assessment and risk management process but it is not clear that this contains 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. TI notes that the company is understood to have a risk assessment and risk management process but it is not clear that this contains an anti-corruption risk assessment.
Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting its agents. However, it is not clear that this due diligence is refreshed at least every three years or when there is a significant change in the business relationship. The company therefore scores 1.
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 makes clear to contractors, sub-contractors, and suppliers, through policy terms, its stance on bribery and corruption. However, it is not clear that this is made clear in contractual terms and that the consequences of breaching this stance are outlined. The company therefore scores 1.
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 of a zero-tolerance anti-corruption policy.
Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible to Board members, employees, contracted staff and other organisations acting with or on behalf of the company. TI notes that key company documents are available in multiple languages.
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. Company documents are written in clear, non-legalistic language.
Based on public information, there is evidence that the company’s anti-corruption policy applies to all employees and members of the Board.
Based on public information, there is evidence that the company has a policy on potential conflicts of interest that applies to employees and Board members.
Based on public information, there is evidence that the company has a detailed policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. TI notes that the company has a process for recording all gifts and hospitality.
Based on public information, there is 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. TI notes that the company has a process for recording all gifts and hospitality.
Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments.
Based on public information, there is evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent.
Based on public information, there is 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 insufficient evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent.
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. TI notes that the Code of Business Conduct provides useful examples and that a number of other documents are available, including a summary of the company’s Business Conduct Policies.
Based on public information, there is evidence that the company has a training programme that explicitly covers anti-corruption.
Based on public information, there is evidence that anti-corruption training is provided to the company’s global workforce.
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 affirms to train ‘all staff’ but it is not clear that this includes Board members.
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 evidence that the company has a clear process by which employees declare conflicts of interest to their manager or to Human Resources; however, it is not clear that declarations must be made in writing. The company therefore scores 1.
Based on public information, there is evidence that the company is explicit in its commitment to apply the necessary corrective measures 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 easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee, to report concerns or instances of suspected corrupt activity. This includes a channel run by a third party.
Based on public information, there is evidence that the company has whistleblowing channels available to all employees in all geographies. Employees may report to the OpenLIne, a function head, a local HR manager, or the CSC Ethics and Compliance Office.
Based on public information, there is some evidence that the company makes efforts to ensure that whistleblowing is not deterred; however, there is limited evidence of formal and comprehensive mechanisms to ensure that whistleblowers are treated supportively, such as employee feedback surveys. The company therefore scores 1.
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, it is not clear that the consequences of breaching this commitment are outlined. The company therefore scores 1.
Based on public information, there is evidence that the Chief Executive Officer or the Chair of the Board publishes a statement supporting the ethics and anti-corruption agenda of the company. TI notes the message from the President and Chief Executive Officer on the company website and in the Code of Business Conduct.It is also noted that the Chief Compliance Officer publishes statements supporting the ethics and anti-corruption agenda of the company.