DynCorp International

Based on public information, there is evidence that the company publishes a statement from the Chief Executive Officer and the Chairman supporting the ethics and anti-corruption agenda of the company. The company therefore scores 1. To score higher the company would need to provide evidence of at least two other such statements from the last two years, or one statement from the last two years that specifically supports the company strong stance against corruption.

Based on public information, there is evidence that the company’s Chief Executive Officer and Chairman demonstrates a personal, external facing commitment to the ethics and anti- corruption agenda of the company. The CEO is a member of the NDIA Ethics Commitee, and he also appeared on the website of GovConExec, making a clear statement about his commitment to promoting the values 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 representing high standards of business conduct, including integrity and honesty. The company demonstrates how these values are translated into company policies and codes. The company therefore scores 1. To score higher the company would need to provide evidence of other such values and display that they are explained in detail.

Based on public information, there is evidence that 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 company has appointed the Business Ethics and Compliance Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Committee’s duties and responsibilities are clearly outlined in the Committee Charter, which is publicly available.

Based on public information, there is evidence that the company has appointed the Chief Compliance Officer with responsibility for implementing the company’s ethics and anti- corruption agenda, and who has a direct reporting line to the Board. This individual is identified as Joe Kale.

Based on public information, there is evidence of periodic Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. In particular the Code of Ethics and Business Conduct is reviewed at least annually.

Based on public information, there is limited evidence of a written plan that guides the review of the company’s ethics and anti-corruption agenda. As part of its responsibilities the Business Ethics and Compliance Committee reviews the company’s policies and procedures, makes recommendations addressing the company’s compliance practices generally, and reviews complaints received by the company. The company therefore scores 1.

Based on public information, there is 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 some evidence that the company has an Enterprise Risk Management (ERM) process implemented enterprise-wide. However, it is unclear if this process includes a formal anti-corruption risk assessment, as limited information is provided about the ERM process.

Based on public information, there is some evidence that the company has an Enterprise Risk Management (ERM) process implemented enterprise-wide. However, it is unclear if this process includes a formal anti-corruption risk assessment, as limited information is provided about the ERM process.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents. However, it is not clear that the company refreshes the due diligence at least every 3 years or when there is a significant change in the business relationship. The company therefore scores 1.

Based on public information, there is evidence that the company has contractual rights and processes for the behaviour of agents with respect to countering corruption. However, there is no evidence of agents being monitored. The company therefore scores 1.

Based on public information, there is 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 engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages 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 the company has a zero tolerance policy of violations of the Code of Ethics and Business Conduct, but not of corruption specifically. The company therefore scores 1.

Based on public information, there is evidence that the company's anti-corruption policy is easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company. Employees are each provided with a copy of the Code of Ethics and Business Conduct upon joining the company, and must confirm they have received and read this document.

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. Despite the company’s Code of Ethics and Business Conduct using some legalistic terms, helpful and practical examples are provided throughout this document to aid the understanding of each section.

Based on public information, there is evidence that the company’s anti-corruption policy explicitly applies to all employees and members of the Board.

Based on public information, there is evidence that the company has a detailed policy on potential conflicts of interest, which applies to both employees and board members. The policy includes a definition and examples of potential conflicts of interest.

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. However, where it is permitted to accept gifts, such as from non-U.S. Government business contacts, the company does not publish evidence of upper limits 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. However, where it is permitted to accept hospitality, such as from non-U.S. Government business contacts, the company does not publish evidence of upper limits 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 prohibits political contributions in order to prevent undue influence or other corrupt intent. However, evidence states that exceptions to this prohibition may be allowed if permitted by law and approved by the Chairman and CEO. As the company has not provided any guidelines concerning this exception rule, the company has scored 1.

Based on public information, there is evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent. Evidence states that all applicable employees must register as federal lobbyists and file periodic activity reports.

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. The Code of Ethics and Business Conduct is written very much as a handbook and provides numerous illustrative examples.

Based on public information, there is evidence that the company has a training programme that covers the Code of Ethics and Business Conduct and that employees undergo compliance training applicable to their positions. However, it is not clear if this training includes a specific anti-corruption module. The company therefore scores 1.

Based on public information, there is evidence that all employees are provided with training that covers the Code of Ethics and Business Conduct and that employees undergo compliance training applicable to their positions. Given the company operates in multiple countries and it states that all employees are trained, evidence suggests that training is provided in all countries where the company operates or has sites.

Based on public information, there is evidence that Board members receive compliance training applicable to their positions. However, it is unclear how often this training is refreshed. The company therefore scores 1.

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. TI notes that the company only indicates that all employees and Board members are required to complete all compliance training applicable to their positions.

Based on public information, there is no readily available evidence that the company has a formal process by which employees declare conflicts of interest. The Code of Ethics and Business Conduct advises employees to consult the Legal COE immediately, but it is unclear if this is a formal process as opposed to simply guidance.

Based on public information, there is evidence that the company may apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities. The company therefore scores 1. To score higher the company would need to provide evidence of a stronger commitment, using language such as ‘will’ rather than ‘may’.

Based on public information, there is evidence of multiple, well-publicised 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. In particular, employees can report to the EthicsPoint website, which is independently operated and facilitates anonymous reporting.

Based on public information, there is evidence that across geographies, all employees have access to more than one whistleblowing channel.

Based on public information, there is evidence that the company treats whistleblowers supportively. For example, the company offers a comprehensive FAQ document covering the EthicsPoint system used by the company. 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.

Based on public information, there is evidence that the company has a commitment to non- retaliation for bona fide reporting of corruption. However, there is no evidence that disciplinary measures are applied to employees who breach this commitment. The company therefore scores 1.