General Dynamics Corporation

Based on public information, there is evidence that the company has published a statement from the Chairman and CEO Phebe Novakovic, in the Standards of Business Ethics and Conduct, which promotes the company’s whole ethics and anti-corruption agenda. 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 evidence that Chairman and CEO Phebe Novakovic, sits on the DII Steering Committee. TI understands that the DII Steering Committee meets several times a year.

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, trust and integrity. The values are described on the company’s website.

Based on public information, there is evidence that the company is a member of IFBEC and a signatory of the DII.

Based on public information, there is evidence that the company’s Audit Committee has overall corporate responsibility for the company’s ethics programme. The Committee monitors the management’s implementation of the policies and practices of the Standards of Business Ethics and Conduct Programme.

Based on public information, there is evidence that the company has appointed a Chief Ethics Officer with responsibility for implementing the company’s ethics programme. The Chief Ethics Officer has overall leadership of 13 business unit ethics officers and 120 local ethics officers who implement the ethics programme; he or she reports directly to the Chairman and CEO, and the Audit Committee. The company therefore scores 1. To score higher the company would need to provide evidence that the Chief Ethics Officer is identifiable by name.

Based on public information, there is evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. The Chief Ethics Officer briefs the Audit Committee twice a year at scheduled meetings on all ethics programme matters.

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 evidence that the company has a formal process for review and update of company policies in the event of an actual or alleged instance of corruption. Ethics officers will conduct thorough and objective investigations of all reported allegations of suspected ethical misconduct. The company states it will take corrective action in response to ethical violations, including the implementation of system-wide changes. Evidence suggests that the Audit Committee is responsible for reviewing the Standards of Business Ethics and Conduct in response to violations.

Based on public information, there is limited evidence that the company has a risk assessment procedure implemented enterprise-wide, which includes an anti-corruption element. The Audit Committee has oversight of the company’s policies and practices concerning risk assessment and senior management is responsible for conducting risk management activities. However, it is not clear whether these processes contain an anti-corruption element, nor is there evidence of mitigation plans, their ownership or their implementation timelines.

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. TI notes that the Board’s risk management procedure includes operational risks, but there is no evidence that this includes an anti-corruption element.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing 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. Despite the Standards of Business Ethics and Conduct Code stating that consultants must follow its guidance on ethical business practice, there is no evidence of contractual rights and formal processes, nor does it specify that consultants include agents.

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, its stance on bribery and corruption. The Standards of Business Ethics and Conduct states that suppliers must develop ethics and compliance programmes that are consistent with the company’s values in all material respects. However, there is no evidence that the consequences of non-compliance are made clear or that there are contractual rights to apply sanctions in the event of a breach of a supplier’s contract. The company therefore scores 1.

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 when selecting its offset partners and brokers.

Based on public information, there is readily available evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. The Code of Conduct prohibits the giving or receiving of bribes and identifies forms of corruption such as kickbacks and corrupt gift and hospitality exchange.

Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. TI notes that the company states that its employees should not engage in bribery or kickbacks, but this is not considered to be an explicit zero tolerance policy of bribery or corruption.

Based on public information, there is evidence that the company’s Code of Conduct is easily accessible to Board members, employees and third parties. It is provided to all new employees and is available on the company website in numerous languages.

Based on public information, there is evidence that the company’s Standards of Business Ethics and Conduct is easily understandable and clear to Board members, employees and third parties. It is written in accessible, comprehensible language.

Based on public information, there is evidence that the ethics and anti-corruption policy applies to all employees and Board members. The Standards of Business Ethics and Conduct applies to all officers and employees, while the Code of Conduct for Members of the Board of Directors applies to Board members. An additional Code of Ethics for Financial Professionals applies to the CEO, CFO, controller and any person performing similar financial functions. TI notes that the Code of Conduct for Members of the Board of Directors does not explicitly state that it is supplementary to the broader Standards of Business Ethics and Conduct, nor does it specifically address corruption or bribery.

Based on public information, there is evidence that the company has a policy on conflicts of interest. It is written with clear wording and a definition and examples are provided. The Code of Conduct for Members of the Board of Directors includes a conflicts of interest policy for Board members.

Based on public information, there is evidence that the company has a policy that regulates the giving and receipt of gifts. However, the rules of the policy are unclear. Employees must avoid giving or receiving gifts above a modest value when dealing with commercial customers, and are instructed to consult their business unit’s ethics officer before offering or retaining any gift of greater than nominal value. The company therefore scores 1. To score higher the company would need to provide evidence of upper limits for gift exchange and/or a specific threshold necessary for senior authorisation.

Based on public information, there is evidence that the company has a policy that regulates the giving and receipt of hospitality. However, the rules of the policy are unclear. Employees must ensure meals and entertainment have valid business purposes and that they are of reasonable value. The company therefore scores 1. To score higher the company would need to provide evidence of upper limits for hospitality exchange and/or a specific threshold necessary for senior authorisation.

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. All corporate political contributions must be approved by the Senior Vice President, Planning and Development. The company's Board of Directors receives annual briefings on prior-year corporate-wide political spending. The company discloses the amount it discloses yearly, but not the recipients.

Based on public information, there is evidence that the company has a policy on engagement in lobbying activities. The policy states that all lobbying contacts with covered government officials must be coordinated with and approved by the Senior Vice President, Planning and Development. Each quarter the company files a publicly available federal Lobbying Disclosure Act report that provides specific information on all General Dynamics lobbying activities. The company website details the total company lobbying expenditures for the past three years.

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. The Standards of Business Ethics and Conduct contains an Ethical Decision-Making Model and some conflicts of interest examples. The company therefore scores 1. To score higher the company would need to provide evidence of written guidance that contains scenarios to illustrate particular situations.

Based on public information, there is evidence that the company has a training programme on its ethics programme. However, evidence does not suggest the company has an explicit anti-corruption module as part of this programme. The company therefore scores 1.

Based on public information, there is evidence that the company’s training on its ethics programme, which includes an anti-corruption policy, is provided to all employees.

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. TI notes that the company states that employees receive training on any specific topic areas that are critical to the performance of their jobs. However, there is no suggestion that this is tailored anti-corruption training for employees in sensitive positions.

Based on public information, there is evidence that the company has a clear and formal process by which employees declare conflicts of interest, which involves conflicts being reported to their business unit’s ethics officer.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to all employees who violate the Code of Conduct. The company uses wording that signifies an explicit commitment such as ‘will.’ However, evidence does not show that the company has a commitment to apply disciplinary procedures to Board members.

Based on public information, there is evidence of multiple, well-publicised channels that are accessible and secure for employees to report concerns or instances of suspected corrupt activity. Employees are able to report to their business unit’s ethics officer, the Legal Department or the corporate Ethics Office. An Ethics Helpline managed by a third party is available 24/7, by Freephone or by online reporting tool, which allows anonymous reporting. Calls can be accepted in 30 different languages and the Ethics Helpline website lists numbers for every country in which the company has employees.

Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. For example, employees can report to the Ethics Helpline, their business unit’s ethics officer, the Legal Department, or the corporate Ethics Office.

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 available to all employees where help and advice can be sought on corruption-related issues. For example, employees can raise ethics concerns with their business unit’s ethics officer, the Legal Department or the Ethics Helpline.

Based on public information, there is evidence that the company has a commitment to non-retaliation 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.