Esterline Technologies Corporation

Based on public information, there is evidence that the company publishes a statement from the Chief Executive Officer supporting the ethics and anti-corruption agenda of the company. The CEO supplies a foreword to the Code of Ethics, published in September 2012. The company therefore scores 1. To score higher the company needs 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’s strong stance against corruption.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or Chairman demonstrate 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 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 insufficient evidence that the company publishes a statement of values or principles representing high standards of business conduct. The Code of Business Conduct and Ethics mentions integrity, but it falls significantly short of the range of values sought by this question or the depth of explanation.

Based on public information, there is no readily available evidence that the company belongs to any national or international initiatives that promote anti-corruption, or business ethics with a significant focus on anti-corruption.

Based on public information, there is insufficient evidence that the company appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda. It is unclear if the Audit Committee and the Regulatory Compliance Subcommittee have this responsibility.

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 evidence that there is Audit Committee monitors compliance with legal and regulatory requirements. However, ethics and anti-corruption are not mentioned specifically and the scope of the review is more of a continuous monitoring than a major periodic review.

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

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 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. TI notes that the Esterline Code of Business Conduct and Ethics refers to its applicability to agents, but there are no details about how this is enforced.

Based on public information, there is no readily available evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption.

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’s anti-corruption policy is explicitly one of zero tolerance.

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. The company’s Code of Business Conduct and Ethics is available on the company website.

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. The Code of Business Conduct and Ethics is written in accessible, clear language.

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 applies to both employees and board members. The policy contains 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. Although, the company does not set clear upper limits or a specific threshold necessary for senior authorisation, it does go into detail to explain what is and is not acceptable.

Based on public information, there is evidence that the company’s anti-corruption policy includes a statement on the giving and receipt of hospitality, that ensures that such transactions are bona fide and not a subterfuge for bribery. Although, the company does not set clear upper limits or a specific threshold necessary for senior authorisation, it does go into detail to explain what is and is not acceptable.

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

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. TI notes that the Code of Business Conduct and Ethics refers to political donations by employees in their personal capacities, but does not deal with donations made by the company.

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 it 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 some evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. In particular, the Code of Business Conduct and Ethics contains some examples to illustrate particular situations. The company therefore scores 1.

Based on public information, there is some evidence that the company has a training programme on its ethics and compliance systems. However, there is no evidence of a specific anti-corruption training module. 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 that is provided to employees worldwide.

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 evidence that the company has a formal process by which employees declare conflicts of interest. Employees are encouraged to disclose the issue to a manager or an ethics officer. The company therefore scores 1. To score higher the company would need to provide evidence that conflicts of interest are always disclosed to an independent department, such as an ethics officer.

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 evidence that the company has multiple internal channels to report instances of suspected corrupt activity, which are well publicised and allow anonymous reporting. However, there is no evidence that the company offers an independently operated channel for employees to report to. The company therefore scores 1.

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 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 evidence that the company has well-publicised resources, such as trained managers, advisers, helplines, and an external ombudsman, to provide employees with guidance on corruption-related issues.

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