Day & Zimmermann

Based on public information, there is 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. However, the introduction to the Code of Ethics and Standards of Business Conduct was published in January 2011 and is not understood to have been revised since. In addition, although there is a strong emphasis on the ‘difference between right and wrong’ in the statements found, anti-corruption is not mentioned specifically. The company therefore scores 1.

Based on public information, there is evidence of the company’s Chief Executive Officer or the Chair of the Board demonstrating a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. For example, the company’s Chairman and Chief Executive Officer is a member of the steering committee of the Defense Industry Initiative on Business Ethics and Conduct.

Based on public information, there is insufficient 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.

Based on public information, there is evidence that the company publishes a statement of values or principles representing high standards of business conduct, including integrity, accountability and trust. Although these values fall short of those listed in the question, the company clearly demonstrates that these values are translated into policies and codes.

Based on public information, there is 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. Specifically, the company is a member of the Defense Industry Initiative on Business Ethics and Conduct (DII).

Based on public information, there is evidence that the Ethics Committee overall corporate responsibility for the company’s ethics and anti-corruption agenda. It reviews and analyses complaints and suggests responses including audits and additional training.

Based on public information, there is evidence that the company has appointed the Chief Ethics Officer with responsibility for implementing the company’s ethics and anti-corruption agenda. The individual is named as Jamal Ahmed.

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. However, there is no public evidence that the Board conducts a review of the entire ethics and anti-corruption agenda at least annually. The company therefore scores 1.

Based on public information, there is 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. However, no public evidence could be found of improvement plans being implemented when issues are identified. The company therefore scores 1.

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 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 of agents with respect to countering corruption. TI notes the references to subcontractors and suppliers but is looking for evidence relating to agents specifically.

Based on public information, there is evidence that the company makes clear to suppliers, through policy and contractual terms, its stance on ethics and business standards. However, it is not clear that the consequences of breaches to this stance are made clear. The company therefore scores 1.

The company has informed TI that it does not engage in offset contracting.

The company has informed TI that it does not engage 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 violations of the company’s Code of Ethics and Standards of Business Conduct will not be tolerated; however, there is no readily available evidence that the company’s anti-corruption policy is explicitly one of zero tolerance. The company therefore scores 1.

Based on public information, there is evidence that the company's anti-corruption policy easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company.

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. TI notes that the policy is written in clear and accessible language.

Based on public information, there is evidence that the anti-corruption policy explicitly applies to all employees; however, it is not clear if this includes members of the Board. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest that applies to all employees; however, it is not clear if this includes members of the Board. 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 employees are not permitted to give or receive gifts, although ‘Reasonable meals and entertainment, and small, inexpensive gifts may be exchanged’. However, it is unclear what ‘Reasonable’ might mean and there is no readily available evidence of an upper limit or a specific threshold necessary for senior authorisation. The company therefore scores 1.

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. TI notes that employees are not permitted to give or accept hospitality, although ‘Reasonable meals and entertainment, and small, inexpensive gifts may be exchanged’. However, it is unclear what ‘Reasonable’ might mean and there is no readily available evidence of an upper limit or a specific threshold necessary for senior authorisation. 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. However, it is not clear that where company funds are used for the benefit of political parties and candidates, once approved by the Law Department or the Company’s Vice President of Government Affairs, that the information is publicly disclosed. The company therefore scores 1.

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, and 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 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 evidence that the company provides ethics training and training on the Code of Ethics (which includes an anti-corruption policy) to all employees. The company therefore scores 1.

Based on public information, there is evidence that the company provides anti-corruption training to all employees. Further all employees go through Refresher’s Training and Code of Conduct Orientation.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board (Leadership Council).

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 in writing. TI notes that the options for reporting include the option to report to another department.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to employees. However, TI notes that this commitment remains unclear with regard to Directors and Board members. The company therefore scores 1.

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 (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity.

Based on public information, there is evidence that the whistleblowing channels are available to all employees in all geographies.

Based on public information, there is evidence that the company supports and encourages whistleblowing; however, it is not clear that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, such as ways to follow up with whistleblowers and monitor their experience. 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. TI notes that the company has a network of Ethics Officers throughout its office locations.

Based on public information, there is evidence that there is a commitment to non-retaliation for bona fide reporting of corruption within the company and to disciplining those who breach this commitment.