Cubic

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.

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 an 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. TI notes that principal executive and financial officers are expected to promote ethical behaviour within the company, but there is no evidence showing the Chief Executive Officer’s direct involvement.

Based on public information, there is insufficient evidence that the company publishes a statement of values and principles representing high standards of business conduct. TI notes that the company refers to integrity and openness in its Standards of Conduct and Compliance. However, this is not comparable to a published statement of values representing high standards of business conduct.

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, the company has appointed the Audit and Compliance Committee with overall corporate responsibility for its ethics and anti-corruption agenda.

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.

Based on public information, there is evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. The Audit and Compliance Committee receives reports from the Chief Ethics and Compliance Officer regarding the status of the corporate ethics and compliance programme. The company therefore scores 1. To score higher the company would need to provide evidence of a periodic, heavyweight review of the entire ethics and compliance programme.

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 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 evidence that the company addresses corruption risk in some areas, but this seems to be confined to international trade, and there is no readily available evidence of 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 conducts due diligence that minimises corruption risk when selecting or reappointing its agents. Consultants and representatives are retained only after prior review by the company’s Law Department. However, there is no evidence that this review is renewed at least every three 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 procedures in place for the behaviour and control of agents with respect to countering corruption. The company therefore scores 1. To score higher the company would need to provide evidence of its right to monitor and audit agents to ensure compliance.

Based on public information, there is some evidence that the company makes clear to contractors, sub-contractors, and suppliers through policy, its stance on bribery and corruption. The company therefore scores 1. To score higher the company would have to provide more evidence that the company’s anti-corruption stance is made clear in contractual terms, and that the consequences of breaches are clearly communicated.

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 a policy on the illegal use of funds and bribes, and covers corruption in its various forms.

Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. However, the company has a zero tolerance policy of violations of the Code of Business Ethics and Conduct, as shown by its explicit stance on disciplinary procedures in the event of a violation by any employee or director. The company therefore scores 1.

Based on public information, there is evidence that the company’s policy is easily accessible to board members, employees, and affiliated organizations through its website. However, TI notes that the company’s Code of Ethics is only available in English and the company is understood to operate internationally. The company therefore scores 1.

Based on public information, there is evidence that the company’s policy is written in clear, comprehensible language.

Based on public information, there is evidence that the company’s Code of Ethics applies to all employees and Board members.

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

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, there is no evidence of clear upper limits being set or a threshold for senior authorisation. TI notes that reference is made to a corporate policy on ‘Gifts and Hospitality’, available on the company’s intranet, but this does not appear to be publicly available. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy on the giving and receipt of hospitality, that ensures that such transactions are bona fide and not a subterfuge for bribery. However, there is no evidence of clear upper limits being set or a threshold for senior authorisation. TI notes that reference is made to a corporate policy on ‘Gifts and Hospitality’, available on the company’s intranet, but this does not appear to be publicly available. The company therefore scores 1.

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 evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent. All political contributions must be pre-approved by the Cubic Corporation Law Department. The company therefore scores 1. To score higher the company would need to provide evidence that it publically discloses 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, 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.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption. TI notes that new employees are required to certify in writing that they understand the company’s Code of Conduct, but this does not amount to a training programme.

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 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 and formal process by which employees declare conflicts of interest, either to their managers or to the human resources department.

Based on public information, there is evidence that the company clearly states that it will apply disciplinary measures to employees and Directors who have violated its Code of Ethics, which includes their anti-corruption policy.

Based on public information, there is evidence that the company has an Ethics Hotline for employees to report concerns or instances of suspected corrupt activity. However, there is no evidence of an independent reporting channel. The company therefore scores 1.

Based on public information, there is evidence that across geographies all employees have access to one whistleblowing channel, the Ethics Hotline. The company therefore scores 1. To score higher the company would need to provide evidence that across geographies, all employees have access to more than one whistleblowing channel.

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. Such formal mechanisms could include analysing whisteblowing data or conducting independent employee surveys.

Based on public information, there is evidence that employees can receive advice on the Code of Ethics from the Law Department.

Based on public information, there is evidence that the company has a policy that prohibits adverse action against any employee that makes a report. However, there is no evidence that disciplinary measures are applied to those who breach this policy. The company therefore scores 1.