FLIR Systems, Inc.

Based on public information, there is evidence that the company has published a statement from the Chief Executive Officer 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’s strong stance against corruption.

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 principles representing high standards of business conduct, including honesty, trust and integrity. However, these values are explained in a limited amount of detail and fall short of the range of values required by this quesiton. The company therefore scores 1.

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

Based on public information, there is evidence that the company has appointed a Board committee with responsibility for the Code of Ethical Conduct. This is the Corporate Governance Committee, whose charter is openly published. TI notes that the Audit Committee is responsible for the Code of Ethics for Senior Financial Officers.

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. TI notes that the company makes reference to an ethics officer, but this individual’s duties and responsibilities are not available.

Based on public information, there is evidence that there is an annual review of the Corporate Governance Principles of the company by the Corporate Governance Committee, as well as a review of the Code of Ethical Business Conduct. However, it is not clear that this includes a major review of the entire ethics and anti-corruption agenda. The company therefore scores 1.

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 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 some evidence that the company has contractual rights and processes for the behaviour and control of agents with respect to countering corruption. However, there is no evidence of monitoring agents. 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 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 has an anti-corruption policy that prohibits corruption in its various forms. However, TI notes the limited focus of the policy on operations inside the US. The company therefore scores 1.

Based on public information, there is evidence that the company has zero-tolerance for bribery.

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible and available in several languages.

Based on public information, there is evidence that the company’s anti-corruption policy is clear and easily understandable for Board members, employees and third parties.

Based on public information, there is evidence that the company’s anti-corruption policy 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. However, TI notes that upper limits are only provided with reference to US government officials. The company therefore scores 1.

Based on public information, there is evidence of a statement on the giving and receipt of hospitality, that ensures that such transactions are bona fide and not a subterfuge for bribery. However, TI notes that upper limits are only provided with reference to US government officials. 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 regulates political contributions in order to prevent undue influence or other corrupt intent. However, there is no readily available evidence that the company publicly discloses all political contributions. The company therefore scores 1.

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 limited evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. However, a number of these documents are not publicly available and therefore could not be fully assessed. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption.

Based on public information, there is no readily available evidence that anti-corruption training is provided in all countries where the company operates or has company sites.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board. TI notes that new directors receive briefings on the company’s compliance programs, but it is unclear if this includes an anti-corruption training module.

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 some evidence that the company has a formal process by which employees declare conflicts of interest. Employees are directed to speak to their supervisors, the HR department or the Law department. However, the details of the process are not made clear, specifically in regard to who employees should contact first and how each department is involved in the process. The company therefore scores 1.

Based on public information, there is 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, 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, an online-reporting system is operated by an independent third party and facilitates anonymous reporting.

Based on public information, there is evidence that the company has whistleblowing channels available to all empoyees in the US. It is unclear what channels are open to those operating outside of the US, if any. The company therefore scores a 1.

Based on public information, there is some evidence to indicate that the company does not deter whistleblowing. However, there is no readily available evidence of formal and comprehensive mechanisms to ensure that whistleblowers are treated supportively. Such mechanisms could include analysis of whistleblowing data, employee surveys or procedures to follow up with individual whistleblowers.

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 evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. There is evidence that disciplinary measures are applied to those who breach this policy.