DCNS

Based on public information, there is evidence that the company has published a statement from the CEO supporting the ethics agenda of the company. This statement can be found on the company website. A similar statement in the company’s Code of Ethics is inapplicable, as it was published over two years ago. The company therefore scores 1. To score higher the company would need to provide evidence of at least two more strong statements from the CEO in the last two years, which promote its ethics and anti-corruption agenda. Alternatively, the company would need to have published one statement from the CEO or Chairman in the last two years, which specifically supports the company’s strong stance against corruption.

Based on public information, there is no readily available evidence that the company’s CEO demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. However, evidence shows that this engagement is delegated. For example, Chief Compliance Officer Adam Smith, gave an external lecture on Joint Venture corruption risks. The company therefore scores 1. To score higher the company would need to provide evidence that the CEO has demonstrated active external engagement in anti-corruption matters, on more than one occassion over the last two years.

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 evidence that the company publishes a statement of values representing high standards of ethical business conduct. This includes trust, honesty transparency. Further, the company demonstrates that these values are translated into company policies and codes.

Based on public information, there is readily available evidence that the company is a member of IFBEC and a signatory to the ASD Common Industry Standards. The company plans to sign the United Nations Global Compact in 2014.

Based on public information, there is evidence that the company’s Ethics and Corporate Social Responsibility Managerial Committee has responsibility for defining and verifying the company’s Ethics and Corporate Social Responsibility Policy. In addition, ethics and compliance fall under the remit of the Ethics Committee, the Corporate Responsibility Committee and the Compliance Department. The responsibilities of these groups are clearly outlined.

Based on public information, there is evidence that the company has appointed Chief Compliance Officer Adam Smith, with responsibility for implementing the company’s ethics and anti-corruption agenda. Specifically, the Chief Compliance Officer is responsible for developing the company’s ethics and anti-corruption programme, and improving its policies and procedures.

Based on public information, there is some evidence of regular Board level monitoring, of the company’s Integrity Program. However, it is not clear if this is a major, periodic review of the anti-corruption agenda. 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, or evidence of improvement plans being implemented when issues are identified.

Based on public information, there is evidence that the Committee for ethical management and corporate responsibility monitors the implementation of the Code, launches necessary inquiries in the event of non-compliance and proposes possible actions to be taken. However, it is not clear whether this is part of a formal process to update policies and pracices in response to alleged instances of corruption. The company therefore scores 1.

Based on public information, there is some evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The company implemented an internal risk assessment to formulate its Integrity Programme, which includes focus on corruption issues. It is unclear if this risk assessment was a one-off event or whether the company conducts regular assessments. The company therefore scores 1. To score higher the company would need to provide further evidence of the anti-corruption risk assessment procedure, including the implementation of mitigation plans.

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 when selecting agents. The company therefore scores 1. To score higher the company would need to provide evidence it refreshes the due diligence at least every 3 years and/or when there is a significant change in the business relationship.

Based on public information, there is evidence that the company has contractual rights for the behaviour, monitoring and audit of agents with respect to countering corruption. In particular, the company clearly outlines the consequences of engaging in corrupt activities.

Based on public information, there is evidence that company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance.

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 some evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. However, TI notes that the Code of Ethics only appears to limit staff granting advantages. The company therefore scores 1. To score higher the company would need to provide evidence that it explicitly prohibits corruption in its various forms, including both the giving and receiving of bribes.

Based on public information, there is evidence that the company has zero tolerance for corruption.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily accessible to Board members, employees and third parties. In particular when the Code of Ethics was first published, it was sent to the home of every employee.

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

Based on public information, there is evidence that the company’s ethics and anti-corruption policies apply to all employees. The company therefore scores 1. To score higher the company would need to provide evidence that these policies apply to Board members.

Based on public information, there is no readily available evidence that the company has a policy on potential conflicts of interest. TI notes that the only information available applies to employee relations with suppliers and subcontractors. Further, a definition of a conflict of interest is not provided and examples of possible conflicts of interest are not given. In addition, it is unclear if this policy also applies to Board members.

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. The company states that there are upper limits for gift exchange, with each country having specific upper limits.

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. The company states that there are upper limits and each country has specific upper limits.

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.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, or discloses the issues on which it lobbies.

Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent.

Based on public information, there is evidence that the company provides a Practical Guide to Ethical Behaviour, to help Board members and employees understand and implement its ethics and anti-corruption agenda. However, as only the contents of this guide are publically available, its level of explanation is unclear. The company therefore scores 1.

Based on public information, there is evidence that the company has a training programme on its ethics and compliance systems, which includes an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence of a specific anti-corruption training module.

Based on public information, there is evidence that the company provides training on its ethics and compliance systems. However, there is no readily available evidence of how widely this training is undertaken across the company.

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 evidence that the company provides tailored ethics training for sales personnel and sales representatives abroad. The company therefore scores 1. To score higher the company would need to provide evidence that all employees in high risk positions receive tailored ethics and anti-corruption training.

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 is explicit in its commitment to apply disciplinary procedures to ‘collaborateurs’ (understood to include employees and Directors) breaching company policies. However, it is not clear from publicly available evidence that this commitment to discipline explicitly extends to the company’s broader anti-corruption policy. The company therefore scores 1.

Based on public information, there is evidence that the company has some channels, for employees to report concerns or instances of suspected corrupt activity. These channels include employees’ managers or the Ethical Management and Corporate Responsibility committee. The company therefore scores 1. To score higher the company would need to provide evidence that employees may report anonymously and to an independent source.

Based on public information, there is evidence that across all geographies, employees have access to one sufficient reporting channel, the Committee for Ethical Management and Corporate Responsibility. The company therefore scores 1. To score higher the company would need to provide evidence of at least one more 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.

Based on public information, there is evidence that company employees are able to contact the Ethical Management and Corporate Responsibility Committee, for help and advice on corruption-related issues.

Based on public information, there is no readily available evidence of a commitment to non-retaliation for bona fide reporting of corruption.