GE Aviation

Based on public information, there is evidence that the CEO Jeff Immelt has released one strong statement supporting the ethics agenda of the company. However, TI has found no evidence of a statement in the last two years supporting the company’s strong stance against corruption specifically, or several statements in the last two years promoting the ethics and anti-corruption agenda, under which it is clear that anti-corruption is a significant component. The company therefore scores 1.

Based on public information, there is evidence that the CEO of GE Aviation displays a strong external facing commitment to the ethics and anti-corruption agenda of the company, as a member of the DII Steering Committee. In addition, the CEO of GE contributed to the magazine Ethisphere, in which he displayed a good engagement with the ethics engagement of the company.

Based on public information, there is no readily available evidence that the CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. TI is aware of statements that the company’s ‘leaders’ play a strong role in engaging employees about ethics, but it is not clear if this relates to the CEO in particular.

Based on public information, there is limited evidence that the company publishes a statement of values representing high standards of business conduct. TI recognises some of the values are present in the short Code of Conduct, with ‘integrity’ appearing across General Electric publications, however these are not presented as a clear statement of company values. The company therefore scores 1.

Based on public information, there is evidence that the company belongs to the United National Global Compact and the Defense Industry Initiative on Business Ethics and Conduct (DII).

Based on public information, there is evidence suggesting that the Audit Committee has responsibility for oversight of the company’s ethics and anti-corruption agenda. The Audit Committee charter states the Audit Committee will review and investigate any matters pertaining to the integrity of management or adherence to standards of business conduct as required in the policies of the Company.

Based on public information, there is some 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, and who has a direct reporting line to the Board. This individual is Senior Vice President and General Counsel, Brackett B. Denniston. However, the scope of his role and duties is not clear. The company therefore scores 1.

Based on public information, there is evidence that the Audit Committee regularly reviews compliance processes and programmes. However, the scope of the review appears to be more of a continuous monitoring than a major periodic review, and its focus is broader than the ethics and anti-corruption agenda. TI notes that the company provided internal information for the 2012 CI which was openly published in the survey report with the company’s permission. However, the public assessment score remains 1 as this part of the survey is seeking to understand company transparency.

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.

Based on public information, there is evidence that the company has a process to review and where appropriate update its policies in the event of an actual or alleged instance of corruption.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. There are regular (annual) management risk assessments forcode of conduct and regulatory compliance. There is evidence of implementation processes and risk ownership.

Based on public information, there is insufficient evidence that the company has an anti-corruption risk assessment procedure for assessing proposed business decisions. The level of available detail is assessed to be low with, for example, no information on the the degree of formality or the circumstances under which such a procedure should be applied.

Based on public information, there is some evidence that the company conducts due diligence that minimises corruption risk when selecting agents. However, there is no evidence that the company refreshes the due diligence at least every 3 years and / 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 control of agents with respect to countering corruption. However, TI has found no readily available evidence that the company has the right to monitor and audit agents. The company therefore scores 1.

Based on public information, there is evidence that company employees working with third-parties must require parties to agree to comply with compliance policies. There is also sufficient evidence of contractual rights for disciplinary action to be taken when needed, for example when offering gratuities to Government officials.

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 the giving and receiving of bribes, and is explicit on the various forms corruption can take.

Based on public information, there is evidence of a zero-tolerance anti-corruption policy, with the integrity policy stressing bribery or corruption of any kind is not permitted.

Based on public information, there is evidence that the company has an anti-corruption policy easily accessible to the Board and employees. The Integrity policy and the Simple Reference Guide are available in 29 different languages and can be accessed on the public website and intranet website. GE employees working with third parties must provide information on the policy.

Based on public information, there is evidence that the company’s anti-corruption policy is understandable and clear to Board members, employees and third parties. While the integrity policy could be better structured with clear definitions and examples, the company provides a simplified form of the document, as well as an interactive eBook format of the integrity policy on the company’s intranet website.

Based on public information, there is evidence that the anti-corruption policy explicitly applies to all employees and members of the Board. It is clearly stated that anyone who works for the company, including directors, must follow its integrity policy.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest providing a definition and guidance.

Based on public information, there is evidence of a statement on the giving and receipt of gifts. TI notes that it is prohibited to give gifts without proper GE counsel approval. However, the policy is less clear about the receipt of gifts by GE employees. For example, employees appear to be allowed to accept gifts of ‘nominal value’; however, it is not made clear what the company means by this. The company therefore scores 1.

Based on public information, there is evidence of a statement on the giving of hospitality (entertainment). TI notes that it is prohibited to give hospitality without proper GE counsel approval. However, the policy does not clearly address the receipt of hospitality by GE employees. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. However, the company provides minimal supplementary information on how the policy is to be implemented in practice. The company therefore scores 1.

Based on public information, there is evidence that the company’s political contributions must be authorised by the vice president for Government Affairs & Policy, with the compliance counsel ensuring all contributions comply with laws and regulations. The Corporate Oversight Board meets on a regular basis to review this expenditure and the controls in place. Recipients of General Electric corporate political contributions for the last 6 years are listed on the website.

Based on public information, there is evidence that the company has a policy that clearly regulates lobbying activity and discloses the issues on which it lobbies.

Based on public information, there is no readily available evidence that the company regulates charitable contributions to prevent undue influence or other corrupt intent. The difference between corporate charitable contributions and GE Foundation contributions is unclear. While the recipients for the two forms of contribitions for the last year is on the website, the lack of evidence regarding regulations prevents the company from scoring higher.

Based on public information, there is evidence that employees have access to a simplified Code of Conduct, decision-making guide and rules to remember document. Evidence also suggests that employees have access to an interactive eBook format of the integrity policy, along with additional resources including a database of frequently asked questions, compliance stories, videos and links to online training.

Based on public information, there is evidence that the company has an online training programme as part of its integrity systems but it is not clear if there is a specific anti-corruption training module. The company therefore scores 1.

Based on public information, there is evidence that the company provides online integrity training. However, it is not explicitly clear that this is available in all countries where the company operates. 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 limited evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. TI notes that ‘employees in shipping and receiving areas’ are provided with ‘additional training on effective supply chain security controls’ but it is not clear that this includes specific ethics and anti-corruption training.

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. The Spirit and The Letter only provides general guidelines for employees to follow. TI is unable to access the Conflict of Interest disclosure tool to assess this.

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. The Spirit & The Letter states that employees and leaders who do not follow their integrity responsibilities ‘face’ disciplinary action.

Based on public information, there is evidence that employees and third parties have access to multiple channels to report concerns or instances of suspected corrupt activity. Managers are trained to deal with ethical reports, while the contact details for the GE Corporate Ombudsman and GE Board of Directors are located in the Integrity Policy. A global network of ombuspersons allows all employees to report concerns or instances of corrupt activity, with the option of anonymity. However, TI found no readily available evidence that employees have access to independent channels. The company therefore scores 1.

Based on public information, there is evidence that the company has a global network of ombudspersons in every business and country in which GE operates.

Based on public information, there is 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. The ombusperson global network is assessed to ensure it is operating effectively, while the provision of manager training has led to an increase in reporting concerning the ethics policy. Reporting figures are given, including types of disciplinary action.

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. This includes trained managers and a global network of ombudspersons. Employees are made aware of these resources via frequent comminications such as articles and Company intranet sites.

Based on public information, there is evidence that there is a commitment to non-retaliation for bona fide reporting of corruption, with the company explicitly stating disciplinary measures may be taken in response to retaliation against an employee.