Daewoo Shipbuilding and Marine Engineering

Based on public information, there is evidence that the President and CEO of the company made several statements supporting the ethics and anti-corruption agenda of the company in the last two years.

Based on public information, there is some evidence that the Company’s leadership demonstrates external facing commitment to ethics. However, the anti-corruption focus remains limited and the extent of this commitment is seen only through one publication. The company therefore scores 1.

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 such a statement, including trust, honesty, and transparency. The company goes into detail about these values and they are translated into company policies and codes. TI notes that the company also outlines a Roadmap for an Ethical Management system from 2014 to 2020 to position ethics as a ‘priority value’.

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promotes anti-corruption or business ethics with a significant focus on anti-corruption. TI notes that the company is a member of the Sustainable Shipping Initiative (SSI), which brings together companies from across the industry and around the world, to plan how shipping can contribute to and thrive in a sustainable future.

Based on public information, there is evidence that the company refers to an Ethical Management System which identifies the Audit Committee, with the Corporate Auditing and Consulting Team, with responsibility for the ethics and anti-corruption agenda.

Based on public information, there is evidence that the Corporate Auditing and Consulting Team Leader monitors corruption investigations and ethics compliance reporting to the Audit Committee. The person, however, is not identifiable by name. The company therefore scores 1.

Based on public information, there is some evidence that the company’s Auditing and Consulting team undertakes regular monitoring of the company’s ethics and anti-corruption policy. However, it remains unclear whether the senior level review of the company’s policies takes place at least once annually. Therefore, the company scores 1.

Based on public information, there is insufficient evidence of a formal written plan on which the review of the ethics and anti-corruption agenda by the Board or senior management is based.

Based on public information, there is some evidence that the company reviews its policies in alleged cases of violations. However, there is no readily available evidence of a formal process in place. The company therefore scores 1.

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 no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its 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.

Based on public information, there is evidence that the company communicates its ethics and anti-corruption agenda down the supply chain, and has contractual rights to apply sanctions in the event of a breach of its contract.

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 company has an explicit policy of zero tolerance as set out on its website.

Based on public information, there is evidence that the company’s anti-corruption agenda is easily accessible to Board members, employees and third parties.

Based on public information, there is evidence that the company’s anti-corruption agenda is easily understandable and clear to Board members, employees and third parties.

Based on public information, there is evidence that the Code of Ethics and the Anti-Corruption principles apply to all employees and Board members.

Based on public information, there is some evidence that the Company regulates conflicts of interest, but it does not provide a clear definition and illustrative examples to facilitate the implementation. The company therefore scores 1.

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. TI notes that there is a reference in the Code of Ethics and there is a specific section in the Code of Ethics Implementation Guidelines. A maximum gift limit is stated although TI notes there is no obligation to notify the Ethics Team unless the employee receives the gift against his will.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality (‘entertainment/favors’) to ensure that such transactions are bona fide and not a subterfuge for bribery. TI notes that there is a reference in the Code of Ethics and there is a specific section in the Code of Ethics Implementation Guidelines. A maximum hospitality limit is stated although TI notes there is no obligation to notify the Ethics Team unless the employee receives the hospitality against his will.

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 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 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. Specifically, there is the Code of Ethics Implementation Guidelines which gives examples of certain conduct or situations which are not permitted. However, it is not clear from the website if there is other written guidance available. The company therefore scores 1.

Based on public information, there is evidence that the company has an ethics training programme that includes anti-corruption elements.

Based on public information, there is evidence that anti-corruption training is provided for all employees, including expatriate employees.

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 some evidence that the company provides tailored ethics training to employees in sensitive positions. However, it is unclear whether this tailored training specifically covers anti-corruption or how it is tailored to different levels of risk. The company therefore scores 1.

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.

Based on public information, there is evidence that the company may apply disciplinary procedures to employees and Board members who have violated its anti-corruption policy in accordance with its regulations and the law. TI notes the additional company commitment that there will be ‘No Leniency for Corruptors’. However, this statement is not equal to an explicit commitment to apply disciplinary measures to employees, Directors and Board members found to have engaged in corrupt activities. The company therefore scores 1.

Based on public information, there is evidence that the company has some 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. However, there is no evidence that employees can report to an independent 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 Audit & Assurance Service Team, available by phone, fax and mail. The company therefore scores 1.

Based on public information, there is no readily available evidence of formal and comprehensive mechanisms by which the company assures itself that whistleblowing by employees is not deterred, or that whistleblowers are treated supportively.

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, including trained counsellors.

Based on public information, there is evidence that the company has a clear, non-retaliation policy for bona fide reporting of corruption. The company sates that employees breaching this policy are ‘subject to disciplinary action’.