Elbit Systems Ltd

Based on public information, there is evidence that the company’s President and Chief Executive Officer has made a statement relating to accountability, transparency, and ethical conduct in the 2012 Social Sustainability Report. The President and CEO also refers to business integrity and ethical standards in a statement in the Supplier Code of Conduct. Beyond this, TI has found no readily available evidence of a statement that supports a strong stance against corruption specifically. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company’s CEO 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 at all levels of the company structure.

Based on public information, there is evidence that the company has published a Code of Business Conduct and Ethics, which represents high business standards and is supplemented by other policies and procedures. The Social Sustainability Report and the company website outline the company’s values, which include accountability, honesty, integrity, respect, ethical conduct, and social responsibility.

Based on public information, there is evidence that the company is a member of the International Forum on Business Ethical Conduct for the Aerospace and Defense Industry (IFBEC).

Based on public information, there is some evidence that internal Ethics Committees are responsible for resolving issues, facilitating the transparency of decision making and effective communications regarding ethics matters. The Committees investigate reports and, where relevant, issues are reported to the Audit Committee of the Board. However, although members of the Audit Committee are publicly named on the company website there are no terms of reference to indicate whether the Audit Committee has overall corporate responsibility for the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the company has appointed and named a Chief Compliance Officer. Although, the terms of reference are not listed in one place, evidence suggests that this is a senior level position within the company with overall responsibility for the company’s ethics and anti-corruption agenda. The individual is named as David Block Temin.

Based on public information, there is evidence that the company’s Board conducts regular reviews of ethics-related activities. The Social Sustainability Report indicates that this takes place on an annual or semi-annual basis as part of the Board’s broader oversight function, rather than a major review of the whole ethics and compliance programme. 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 no readily available evidence of formal processes for review of company policies and practices in response to actual or alleged instances of corruption. TI notes that the company appears to have recently updated a number of its ethics-related policies.

Based on public information, there is evidence that the company has a formal risk management procedure. The 2013 Annual Report identifies compliance with procurement and anti-bribery rules and regulations as a risk area. In addition, the Risk Management Review Committees meet quarterly to discuss a range of risks including ethics. However, TI has found no readily available evidence of risk mitigation plans with clear ownership and timelines for implementation. The company therefore scores 1.

Based on public information, there is evidence that the company has a formal risk assessment procedure. However, TI has found no readily available evidence of a formal anti-corruption risk assessment procedure for assessing proposed business decisions.

Based on public information, there is evidence that the company conducts due diligence when selecting agents. However, TI has found no readily available evidence of the due diligence being renewed at least every three 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 for monitoring and audit of agents with respect to countering corruption. However, there is no readily available evidence of disciplinary measures being taken in the event of a violation. The company therefore scores 1.

Based on public information, there is evidence that the company has a Suppliers Code of Conduct, which makes clear to contractors, sub-contractors, and suppliers through policy and contractual terms, its stance on bribery and corruption. However, it does not make clear the consequences of breaching this stance. The company therefore scores 1.

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 evidence that the company’s Code of Business Conduct and Ethics provides guidance on public disclosures, insider trading, fair dealing, conflicts of interest, (including offering and acceptance of gifts, entertainment, and other personal benefits, and other indirect violations), political activity, and reporting unethical Illegal and unethical behaviour. The Anti-Bribery Compliance Policy provides guidance on compliance with anti-bribery laws and regulations and compliance with Company policy on business entertainment and gifts. The Policy prohibits the giving, offering, or promising of a bribe, and provides detailed definitions and examples. Similarly, the company has limitations on the receipt of gifts and entertainment. However, these prohibitions and limitations only explicitly apply to government officials. The company therefore scores 1.

Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. However, the company has a zero tolerance policy of violations of the Code of Business Ethics and Conduct, as shown by its explicit stance on disciplinary procedures in the event of a violation by any employee or director. The company therefore scores 1.

Based on public information, there is evidence that the company’s Anti-Bribery Compliance Policy, Code of Business Conduct and Ethics, and Supplier Code of Conduct are available online. The Anti-Bribery Compliance Policy and Code of Ethics are available in English and Hebrew.

Based on public information, there is evidence that the company’s Code of Business Conduct and Ethics, Anti-Bribery Compliance Policy and Supplier Code of Conduct are written in accessible, comprehensible language. The Code of Ethics provides detailed examples and all three documents provide clear definitions of key terminology.

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 policy on potential conflicts of interest, which includes a definition and examples.

Based on public information, there is evidence that the company has a policy for the giving and receiving of gifts and has set upper limits along with senior authorisation. TI notes that the provisions for the giving of gifts, as outlined in the Anti-Bribery Compliance Policy, are more detailed than those for the receipt of gifts.

Based on public information, there is evidence that the company has a policy which sets upper limits and procedures for senior authorisation for the giving and receipt of hospitality, under the terms of travel expenses and business entertainment. TI notes that the provisions for the giving of hospitality, as outlined in the Anti-Bribery Compliance Policy, are more detailed than those for the receipt of hospitality or other benefits.

Based on public information, there is evidence that the company explicitly prohibits facilitation payments. However, there is no readily available evidence that the company provides guidance or supplementary information on how this is to be implemented in practice. The company therefore scores 1.

Based on public information, there is some evidence that the company prohibits political contributions. Specifically, the Code of Business Conduct and Ethics states that it is not the company’s policy to promote specific political affiliations, or use company property or resources for political purposes. However, the Social Sustainability Report states that the company’s general policy is not to make donations to political or politically affiliated organisations. This suggests that there may be exceptions to the general policy. The company therefore scores 1.

Based on public information, there is evidence that the Supplier Code of Conduct prohibits members of the Supply Chain from engaging in lobbying activities designed to influence government policies. Beyond this, TI has found no readily available evidence of clear policies on engagement in lobbying activities.

Based on public information, there is evidence that the company makes charitable contributions and appears to regulate them. It is not clear that all contributions are publicly disclosed. The company therefore scores 1.

Based on public information, there is evidence that the Code of Business Conduct and Ethics provides written guidance and examples to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. The Anti-Bribery Compliance Policy provides detailed information on relevant legislation and definitions of key terminology, and the Supplier Code of Conduct also provides some clarification on relevant company policies. However, there is no further evidence of scenarios or case-studies to assist emplooyees and Board members in their understanding of the ethics and anti-corruption agenda. The company therefore scores 1.

Based on public information, there is evidence that the company provides employees with training regarding the Anti-Bribery Compliance Policy and the Code of Ethics and Business Conduct.

Based on public information, there is evidence that the company provides ethics training for all new employees. Training is available via several channels and is provided in the language applicable to each operating subsidiary. The Code of Ethics and Business Conduct has also been translated into languages applicable to several worldwide subsidiaries.

Based on public information, there is evidence that Board members were trained on the Code of Ethics in 2009/2010. However, it is not clear that this training has been refreshed since then. The company therefore scores 1.

Based on public information, there is evidence that the company attempted to embed an ethical culture at middle management level at Elbit Systems of America in 2011 and 2012. Beyond this, TI has found no readily available evidence of tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is evidence that the company has a formal process by which employees declare conflicts of interest to an independent Legal department.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to those who violate the Code of Ethics and Business Conduct.

Based on public information, there is evidence that the company has multiple, well-publicised, internal channels, for employees to report concerns or suspected illegal activity. However, there is no evidence that the company provides an externally operated whistleblowing channel. The company therefore scores 1.

Based on public information, there is evidence that the company’s whistleblowing channels can be accessed via post, email and phone. Employees are invited to report via the Senior Counsel or any member of the Audit Committee from any location.

Based on public information, there is some evidence of efforts by the company to ensure whistleblowing is not deterred. However, there is no readily available evidence of formal and comprehensive mechanisms to ensure that whistleblowers are treated supportively, such as detailed analysis of whistleblowing data or independent employee surveys.

Based on public information, there is evidence that the company has a Chief Compliance Officer from whom employees can seek guidance on corruption-related issues. However, this resource is limited in nature since it involves just one person. The company therefore scores 1.

Based on public information, there is evidence that the company has a clear, legally-enforceable, non-retaliation policy for bona fide reporting of corruption. Although, the policy mentions investigating reported acts of retaliation, there is no readily available evidence that disciplinary measures are applied to employees who breach the policy. The company therefore scores 1.