General Atomics

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the Chair of the Board supporting 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 or the Chair of the Board 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 strong personal, internal-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 publishes a statement of values representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability.

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 no readily available evidence that the company has appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda.

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 no readily available evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda.

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 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 readly 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 minimuses 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.

Based on public information, there is limited evidence that the company makes clear to contractors, sub-contractors, and suppliers, its stance on bribery and corruption and the consequences of breaches to this stance. Contractual regulations for suppliers that specifically address bribery and corruption are stated, albeit that they are understood to be drawn from U.S. federal government guidelines, rather than forming company policy. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company 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 minimizes corruption risk when selecting its offset partners and brokers.

Based on public information, there is no readily available evidence that the company has an anti-corruption policy that prohibits corruption in its various forms.

Based on public information, there is no readily available evidence that the company has an anti-corruption policy that is explicitly one of zero tolerance.

Based on public information, there is no readily available 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.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is easily understandable and clear to Board members, employees and third parties.

Based on public information, there is no readily available evidence that the anti-corruption policy explicitly applies to all employees and members of the Board.

Based on public information, there is no readily available evidence that the company has a policy on conflicts of interest.

Based on public information, there is no readily available 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.

Based on public information, there is no readily available evidence that the company has a policy that regulates the giving and receipt of hospitality to ensure that such transactions are bona fide and not a subterfuge for bribery.

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 no readily available evidence that the company prohibits or regulates political contributions in order to prevent undue influence or other corrupt intent.

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 or regulates charitable contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the ethics and anti-corruption agenda.

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.

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 no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

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 no readily available 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 (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity.

Based on public information, there is no readily available evidence that whistleblowing channels are available to all employees in all geographies.

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 no readily available 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 is no readily available evidence of a commitment to non-retaliation for bona fide reporting of corruption.