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Ownership
PUBLIC
Defence revenue, USD
1,377.40m (2013)
Defence revenue, %
39.7% (2013)
Country
US
Internal information
YES
Based on public information,there is no readily available evidence that the company’s CEO and Chairman demonstrates a strong, personal, external facing commitment to the ethics and anti-corruption agenda of the company. However, there is evidence that such a commitment is delegated. The company therefore scores 1.
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 of the company.
Based on public information, there is evidence that the company has a statement of values representing high standards of ethical business conduct, including honesty, integrity and accountability. The values are described thoughout the company’s websites, with honesty and accountability key components to achieving integrity.
Based on public information, there is evidence that the company is a signatory of the DII and is a member of IFBEC.
Based on public information, there is evidence that the Audit Committee has overall corporate responsibility for the company’s ethics and anti-corruption agenda. The Audit Committee has clear terms of reference, with responsibility for reviewing the company’s policies and practices related to compliance and monitoring compliance through the review of reports. However, TI does note that it is unclear how the Audit Committee’s role works alongside the work of the Corporate Governance & Nominating Committee, which oversees corporate governance, including the Code of Business Conduct.
Based on public information, there is evidence that the Executive Director of Ethics and Compliance is responsible for the company’s policies and he is identifiable by name.
Based on public information, there is evidence that the company conducts regular monitoring and review, of the performance of its ethics and compliance programme. An annual self-assessment is carried out, with the programme baselined against a range of industry criteria. This is complemented by periodic third-party assessments of the company’s ethics and compliance programme.
Based on public information, there is some evidence of an underlying structure guiding the review of the ethics and compliance programme. An annual self-assessment of the company’s ethics and compliance programme is carried out, with the programme baselined against a range of industry criteria. This involves the implementation of improvement plans when issues are identified. Furthermore, there is evidence of a Board oversight in interactions with the Executive Director of Ethics and Compliance. However, there is no evidence of a formal plan that guides the review and whether any improvements follow a specific plan. The company therefore scores 1.
Based on public information, there is some evidence that the company has a procedure to review its policies and practices, in response to actual or alleged instances of corruption. The General Counsel’s Office has responsibility for investigating matters reported through the Helpline, and reports the results of its investigations to the Audit Committee. The Board and the senior management are responsible for ensuring that thorough corrective action is in place; however, there is limited readily available evidence of a formal process. The company therefore scores 1.
Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. However, there is no further information provided about mitigation plans, the ownership of these plans and timelines for implementation. The company therefore scores 1.
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. The company has an Enterprise Risk Management programme, which includes its ability to meet regulatory requirements. However, it is unclear if corruption is identified as a risk and that proposed business decisions are included.
Based on public information, there is some evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing agents. However, it is not clear from readily available information that the company refreshes this due diligence at least every three years or when there is a change in the business relationship. The company therefore scores 1.
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. Despite the Aerojet Rocketdyne Code of Business Conduct stating that agents must conduct business ethically and in compliance with company policies, there is no evidence of contractual rights to prevent or deal with the occurrence of any violations.
Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, its stance on bribery and corruption. Suppliers are made aware of the Aerojet Rocketdyne Code of Business Conduct and the GenCorp Code of Business Conduct, which include the company’s anti-corruption policy. An Aeroject Rocketdyne letter to suppliers states that the mutually beneficial working relationship between the company and a supplier could be jeapordised by violations of company policies, suggesting the contract between the parties would be terminated in response to a breach of the company’s Code of Business Conduct. However, there is no explicit evidence of contractual rights to apply sanctions in the event of a breach. The company therefore scores 1.
Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. This includes bribery, kickbacks, conflicts of interest, and inappropriate gifts and hospitality.
Based on public information, there is evidence that the company has an explicit zero tolerance policy of bribery.
Based on public information, there is readily available evidence that the company ethics and anti-corruption policies are easily accessible to Board members, employees and third parties. Key policies and documents are available on the company website and a number are provided to all new employees. TI understands that these documents are only available in English, but notes that the wide variety of available materials is considered good practice. TI has found no evidence that the company operates outside the US.
Based on public information, there is evidence that the company’s Code of Business Conduct and the Aerojet Rocketdyne Code of Business Conduct are clear and understandable to Board members, employees and third parties.
Based on public information, there is evidence that the company’s ethics and anti-corruption policies state that each Board Director, officer, executive, manager and employee is responsible for compliance.
Based on public information there is evidence that the company has a policy on potential conflicts of interest. This policy includes a definition of a conflict of interest and a number of examples.
Based on public information, there is evidence that the company has a policy that regulates the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. Employees are instructed to keep gifts reasonable and modest to avoid even the appearance of undue influence, and ensure that all gifts are directly related to a legitimate business purpose. In particular, the policy states that any gifts from suppliers over $20 must be returned. The company therefore scores 1. To score higher the company would need to provide upper limits for gift exchange between employees and other third parties.
Based on public information, there is evidence that the company has a policy that regulates the giving and receipt of hospitality. Employees are instructed to keep hospitality reasonable and modest to avoid even the appearance of undue influence, and ensure all hospitality is directly related to a legitimate business purpose. In particular, the company states that the value of entertainment should be kept to less than $100.
Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments. TI does note that the Aeroject Rocketdyne Code of Business Conduct prohibits facilitation payments. In contrast, the GenCorp Code of Business Conduct states that facilitation payments must be sanctioned by the General Counsel or a designee. To score on this question the company would need to provide evidence that the company has a clear 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. All political contributions must be initiated by the Vice President of Corporate Communications and approved by the appropriate company officers, including the General Counsel. The company therefore scores 1. To score higher the company would need to provide evidence that it publically discloses all political contributions.
Based on public information, there is insufficient evidence that the company has a 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 evidence that the company regulates charitable contributions, in order to prevent undue influence or other corrupt intent. The GenCorp Foundation has restrictions and basic procedures for grant applicants, and annual publications detail the recepients of charitable contributions over the year.
Based on public information, there is evidence that the company provides written guidance, to help Board members and employees, understand and implement the company’s ethics and compliance programme. The Aerojet Rocketdyne website has a FAQs page and GenCorp maintains policy awareness via a range of communication channels, such as short videos addressing specific issues.
Based on public information, there is evidence that the company has a training programme that explicitly covers anti-corruption. An annual, targeted, anti-corruption module is aimed at the higher risk areas of Business Development and Program Management. All employees must periodically take training on the Code of Conduct, which includes an anti-corruption policy.
Based on public information, there is readily available evidence that all employees must periodically take training on the company’s Code of Conduct, which includes an anti-corruption policy. The company also has an annual, targeted, anti-corruption module, aimed at the higher risk areas of Business Development and Program Management.
Based on public information, there is evidence that the company provides targeted anti-corruption training to members of the Board. The company provides annual anti-corruption training to Board members and key functional personnel.
Based on public information, there is evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. Board members, key functional personnel and those in high risk areas of Business Development and Program Management, receive annual anti-corruption training.
Based on public information, there is evidence that the company has a clear and formal process by which employees declare conflicts of interest. Employees are instructed to inform the General Counsel, who will ensure a member of the Law Department will review the matter. Aerojet Rocketdyne employees must obtain written approval from the VP of Human Resources, the employee's supervisor and next level of management, before establishing any relationships that may generate a conflict of interest.
Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to all employees and Board members who violate the Code of Conduct. The company uses the word ‘will’, which signifies an explicit commitment to use disciplinary procedures.
Based on public information, there is evidence that the company has multiple, well-publicised, secure channels, for employees to report concerns or instances of suspected corrupt activity. Channels include the HR or Legal departments, an ethics officer or the Ethics and Compliance department. Employees can also report anonoymously using an online reporting tool or the Ethics and Compliance Helpline, both of which are operated by a third party.
Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. Channels include the Ethics and Compliance department or the externally operated Ethics and Compliance Helpline.
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 company collects Ethics and Compliance Helpline usage statistics to distribute to all employees, and to identify potential risk areas, trends and to target areas for improvement. Similarly, the Board of Directors receives quarterly Ethics Helpline metrics. The company encourages a ‘speak up’ culture, which is translated into company policies and documents.
Based on public information, there is evidence that the company has well-publicised resources available to all employees, where advice can be sought on corruption-related issues. These resources include an ethics officer, the Ethics and Compliance department or the externally operated Ethics and Compliance Helpline.
Based on public information, there is evidence that the company has a clear non-retaliation policy for bona fide reporting of corruption. There is evidence that disciplinary measures are applied to employees who breach this policy.
Based on public information, there is evidence that the company has published a statement from the CEO supporting its stance against corruption specifically.