- A
- B
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- D
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- F
Ownership
PRIVATE
Defence revenue, USD
730m (2013)
Defence revenue, %
18% (2013)
Country
GERMANY
Internal information
YES
Based on public information, there is no readily available evidence that the company’s CEO or Chair of the Board demonstrates 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 CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company.
Based on public information, there is insufficient evidence of a statement of values representing high standards of ethical business conduct. The company website and the General Business Principles of the Diehl Corporate Group contain statements that briefly reference the values of integrity and transparency. However, the values are not assessed to be systematically identified and explained, nor linked to the policies clearly.
Based on public information, there is evidence that the company belongs to an international initiative that promotes anti-corruption or business ethics with a significant focus on anti-corruption. Specifically, the company is a member of ASD. As such, TI understands that the company adheres to the ASD Common Industry Standards.
Based on public information, there is evidence that the company has appointed the Compliance Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Compliance Committee checks business processes for compliance with the company’s General Buisiness Principles, identifies compliance problem areas and investigates recognised violations.
Based on public information, there is evidence that the company has appointed a Corporate Compliance Officer with responsibility for the implementation of its ethics and anti-corruption agenda. The individual is identified as Mr Esser; he has a direct reporting line to the Executive Board.
Based on public information, there is some evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. The Compliance Committee audits business processes with respect to compliance with the General Business Principles, identifies compliance problem areas and investigates recognised violations. However, there is no evidence of a regular review of the whole compliance agenda. The company therefore scores 1.
Based on public information, there is no readily available evidence of a formal, written plan that guides the review of the ethics and anti-corruption agenda by the Board or senior management. The Compliance Committee audits business processes with respect to compliance with the General Business Principles, identifies compliance problem areas and investigates recognised violations. However, there is no evidence to suggest this forms the basis of a review of the ethics and anti-corruption agenda.
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. The Compliance Committee identifies compliance problem areas and investigates violations. However, there is a lack of evidence to suggest there is a formal review process, including in particular an update of the company’s policies and practices.
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.
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 no readily available evidence that the company makes clear to 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. The company only states that relationships with suppliers must be carried out with transparency.
Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting. However, as recently as June 2013 the Diehl Defence CEO stated that offset arrangements were a ‘”necessary” component in doing business and winning orders.’ The company is a member of the Global Offset and Countertrade Association.
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 bribery. However, the policy is not explicit on all the forms that corruption may take. To score higher the company would need to explicitly prohibit forms of bribery such as kickbacks. The company therefore scores 1.
Based on public information, there is evidence that the company has a zero tolerance policy of bribery.
Based on public information, there is evidence that the company’s anti-corruption policy is published on its website and is easily accessible to every interested party. It is available in multiple languages.
Based on public information, there is evidence that the policy is written in clear and understandable language.
Based on public information, there is evidence that the company’s General Business Principles are applicable to employees at all hierarchical levels. However, it is not clear that the General Business Principles also apply to Board members.The company therefore scores 1.
Based on public information, there is evidence that the company has a policy on potential conflicts of interest. Despite the policy defining conflicts of interest it does not provide examples of potential conflicts of interest, nor is there a suggestion that the policy applies to Board members. 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. All gifts may only be accepted or given after approval by a respective company superior or responsible person.
Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality (“benefits”) to ensure that such transactions are bona fide and not a subterfuge for bribery. All benefits may only be accepted or given after approval by a respective company superior or responsible person.
Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments. The company’s General Business Principles state that ‘every kind of bribery’ is forbidden, but there is no mention of facilitation payments.
Based on public information, there is no readily available evidence that the company prohibits or regulates political contributions in order to prevent undue influence or other corrupt intent.
Based on public information, the company does not have a clear policy on engagement in lobbying activities, not does it disclose 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 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. The General Business Principles state that supervisors and management staff must ensure employees are familiar with its content, but there is no evidence to suggest that written guidance is used to facilitate this
Based on public information, there is evidence that the company has a training programme on its compliance programme, which includes an anti-corruption policy. The training programme contains an “emphasis on corruption prevention”.
Based on public information, there is readily available evidence that the company provides compliance training, which includes an anti-corruption element, in all countries where the company has 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 readily available evidence that the company tailors its ethics and anti-corruption training programme for particular corruption risk departments, such as sales and purchasing.
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 found to have engaged in corrupt activities. To score higher, the company would need to use wording that stresses an explicit commitment to apply disciplinary procedures such as ‘will’ rather than ‘can,’ as well as its applicability to Directors and Board members. The company therefore scores 1.
Based on public information, there is evidence that the company has two well-publicised channels for employees to report suspected corrupt activity, which are accessible and guarantee confidentiality. Employees can contact both the Corporate Compliance Officer and the external Ombudsman by phone, fax, mobile and email and are also able to report anonymously.
Based on public information, there is evidence that all employees in all geographies can contact the Corporate Compliance Officer and the external Ombudsman by phone, fax, mobile and email.
Based on public information, there is no readily available evidence that the company has formal comprehensive mechanisms to ensure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively. In particular there is no evidence of detailed analysis of whistleblowing data or independent employee surveys.
Based on public information, there is evidence that employees may seek advice from the Corporate Compliance Officer and its office. Furthermore, they also have the possibility to contact the external ombudsman when reporting improper business practices.
Based on public information, there is no readily available evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption.
Based on public information, there is no readily available evidence that the company has published a statement from the CEO or Chair of the Board in the last two years, supporting the ethics and anti-corruption agenda of the company.