Doosan DST Co., Ltd

Based on public information, there is evidence that the company publishes a statement from the Chairman and CEO focusing on the company’s integrity and transparency credo. However, anti-corruption is not explicitly mentioned in the statement and no further statements were found. The company therefore scores 1.

Based on public information, there is no readily available evidence that the Chief Executive Officer or the 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 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 a statement of values or principles representing high standards of business conduct. However, this statement falls short of the range sought by the question.The company therefore scores 1

Based on public information, there is evidence that Doosan Global, of which the Company is a subsidiary, is a member of the UN Global Compact Compact, but it is unclear how this is implemented throughout the subsidiaries. The company is also a member of the KDIA, but its anti-corruption focus remains unclear. The company therefore scores 1.

Based on public information, there is evidence that the CSR committee is responsible for the sustainability management. However, it is not clear whether it also has overall responsibility for the ethics and anti-corruption agenda of the company.

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 no readily available evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda.

Based on public information, there is no readily available 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, 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 updates its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is limited readily available evidence that the company has a formal anti-corruption risk assessment procedure. TI notes that the company assesses corruption as part of the general risks but has not seen further evidence of a formal anti-corruption risk assessment.

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 insufficient evidence that the 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. However, its scope is unclear and it does not address all forms of corruption. The company therefore scores 1.

Based on public information, there is no readily available evidence of a zero-tolerance anti-corruption policy.

Based on public information, there is evidence that the parent company Code of Conduct is easily accessible to Board members, employees and third parties. This is available in Korean and English.

Based on public information, there is insufficient evidence that the company’santi-corruption policy is easily understandable. TI notes that the information available is limited and it is therefore not possible to assess the policy in full.

Based on public information, there is evidence that the Code of Conduct applies to all directors, officers, and employees.

Based on public information, there is insufficient evidence that the company has a policy on potential conflicts of interest.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts. TI notes that the company prohibits the giving or receipt of gifts.

Based on public information, there is evidence of a statement on the giving and receipt of hospitality (meals and entertainment). TI notes that the company prohibits the giving or receipt of hospitality.

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 no readily available evidence that the company prohibits political contributions, or regulates such 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 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.

Based on public information, there is evidence that the company has a training programme that explicitly covers anti-corruption.

Based on public information, there is evidence that the company provides ethics training to employees. However, evidence does not suggest that this training is available in all countries where the company operates, with the company having planed to provide training overseas in 2014. The company therefore scores 1.

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 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 no readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is no readily available 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 no readily available evidence that the company has whistleblowing channels.

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 no readily available evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues.

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