Curtiss-Wright Corporation

Based on public information, there is no readily available evidence that the company publishes a statement from the CEO or 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 CEO 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 CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is some evidence that the company publishes a statement of values representing high standards of business conduct, including integrity, openness and honesty. The company therefore scores 1. To score higher the company would need to provide evidence of other such values and display that they are explained in detail.

Based on public information, there is evidence that the company is a signatory to the Defense Industry Initative (DII).

Based on public information, there is no readily available evidence that the company has appointed a Board committee or individual Board member 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.

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 Board reviews the Corporate Governance Guidelines annually. However, there is no evidence that a major review of the entire agenda is conducted at least annually. 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 no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. TI notes that the company undertakes risk management, which is overseen by the Committee on Directors and Governance, but evidence does not suggest this relates specifically to anti-corruption.

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

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. TI notes that agents are responsible for complying with all applicable laws, regulations and the Code of Conduct. However, there is no evidence of procedures and contractual rights in place that are monitored and audited to counter corruption.

Based on public information, there is evidence the company makes it clear that contractors, sub-contractors, and suppliers must comply with all the applicable laws and show high ethical standards. The company has a zero tolerance for bribery, kickbacks and other improper payments. However, it is not clear whether sanctions are applied in the event of breach of contract. 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 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.

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 company provides information about the anti-bribery policy on its intranet. However, evidence does not suggest that the policy is available in any other language except English. The company therefore scores 1.

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 clearly written in a comprehensible language, and is easily understood by a non-legal audience.

Based on public information, there is evidence that the anti-corruption policy explicitly applies to all employees and members of the Board. The company states that the Code of Conduct, which includes an anti-corruption policy, applies to all employees. The Corporate Governance Guidelines indicate that the anti-corruption policy applies explicitly to the members of the Board.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest, which applies to both employees and for Directors. The policy contains 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. In particular, the company clearly sets upper limits for gift exchange.

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. In particular, the company sets upper limits for hospitality exchange.

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 prohibits political contributions, except in particular cases. The company prohibits political contributions, unless they are individual contributions related to personal interest or if the law allows the company to make such contributions. In the latter case, a permission for such expenditure is required.

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 some evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. However, the detailed guidance is only available on the company intranet and it is therefore not possible to assess whether this includes illustrations of particular situations or case studies. The Code of Conduct includes some scenarios to explain the anti-corruption agenda. The company therefore scores 1.

Based on public information, there is evidence that the company provides training for the Code of Conduct, which includes an anti-corruption policy. However, there is no evidence that the company has an explicit anti-corruption module. The company therefore scores 1.

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 evidence that the company has a formal process by which employees declare conflicts of interest. The employees are encouraged to disclose the issue to a member of the leadership team for review with the Law Department. However, the details of the process are not made clear, specifically in regard to the Law Department’s review of each disclosure. The company therefore scores 1.

Based on public information, there is evidence that the company ‘may’ apply disciplinary procedures to employees found to have violated the Code of Conduct. The company therefore scores 1. To score higher it must be stated that disciplinary procedures also apply to Board members, and that any violations ‘will’ result in disciplinary action.

Based on public information, there is evidence that employees can report concerns or instances of suspected corrupt activity using multiple, well-publicised channels. Employees can send reports to a member of Law Department or call the Code of Conduct helpline anonomously, with the contact details available on the company website. However, there is no evidence of an independent reporting channel. The company therefore scores 1.

Based on public information, there is evidence that whistleblowing channels are available to all employees, in all geographies. Employees may contact the Law Department and the Code of Conduct helpline is available in the United States, United Kingdom, Switzerland and China.

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.

Based on public information, there is some evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. Employees are directed to contact the Law Department. However, it is not clear that staff in this department are trained for this role. The company therefore scores 1.

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 breaches of this commitment will result in disciplinary procedures. The company therefore scores 1.