Harris Corporation

Based on public information, there is evidence that the company publishes several statements from the Chairman, President and Chief Executive Officer supporting the company’s ethics and anti-corruption agenda. These statements can be found on the company’s website, in the Code of Conduct, in the Intermediary and Supplier Standards of Business Conduct, and the Directors Edition of the Standards of Business Conduct.

Based on public information, there is evidence that the company’s Chairman, President and Chief Executive Officer demonstrates a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. The Chairman, President and Chief Executive Officer is a member of the DII steering committee. We understand that the DII Steering Committee meets on a regular basis each year.

Based on public information, there is some evidence that the company’s Chairman, President and Chief Executive Officer, demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. The Chairman, President and Chief Executive Officer is the chair of the Management Business Conduct Committee, which is responsible for setting the Busines Conduct Policies and Practices for the Company. The company therefore scores 1. To score higher the company would need to provide at least two more examples of such internal engagement.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including integrity. The value is described in the Intermediary and Supplier Standards of Bussinses Conduct as being composed of honesty and accountability. The Code of Conduct explains integrity in further detail, demonstrating how the value is translated into company policies.

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

Based on public information, there is evidence that the company has appointed the Business Conduct and Corporate Responsibility Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Committee’s responsibilities include reviewing the processes, standards and controls regarding compliance with the Code of Conduct, and monitoring the company’s charitable, civic, educational and philanthropic contributions and activities.

Based on public information, there is evidence that the company has appointed the Director of Business Conduct with responsibility for implementing its ethics and anti-corruption agenda. The Director of Business Conduct is identified as Denise King, with her contact details well-publicised throughout the company’s documents and on its website.

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 Business Conduct and Corporate Responsibility Committee reviews compliance with the Code of Conduct, audit and investigation results, and reports from the Director of Business Conduct. It recommends actions to the Board of Directors to ensure legal compliance and ethical business practices. Evidence suggests that this review process takes place at least annually, due to the annual schedule of Committee meetings.

Based on public information, there is limited 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 takes place. The Business Conduct and Corporate Responsibility Committee reviews compliance with the Code of Conduct, audit and investigation results, and reports from the Director of Business Conduct. It recommends actions to the Board of Directors to ensure legal compliance and ethical business practices. However, it is unclear if this review forms the basis of the written plan and there is no readily available evidence of improvement plans being implemented. The company therefore scores 1.

Based on public information, there is limited 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. The Business Conduct and Corporate Responsibility Committee reviews audit and investigation results, regarding compliance with the business conduct program. The Committee also recommends to the Board of Directors actions to assure legal compliance and ethical business practices. The company therefore scores 1. To score higher the company would need to provide specific evidence that these two processes are linked, showing that it has a formal process to update its policies and practices in response to 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. Despite the company identifying non-compliance as a risk, the company does not provide evidence of a corresponding anti-corruption risk assessment procedure.

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, with clear requirements on the circumstances under which such a procedure should be applied.

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 no readily available evidence that the company has contractual rights and processes for the monitoring, control, and audit of agents with respect to countering corruption. However, evidence shows that intermediaries are expected to conduct themselves in compliance with the company's Standards of Business Conduct and Code of Ethics, which include applicable international anti-bribery legislation.

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy, its stance on bribery and corruption. Suppliers are expected to conduct themselves in compliance with the company's Standards of Business Conduct and Code of Ethics, which include applicable international anti-bribery legislation. The company therefore scores 1. To score higher the company would need to provide evidence that is has contractual rights to apply sanctions in the event of a breach of its contract.

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. This includes the giving and receiving of bribes, kickbacks and corrupt gifts and hospitality.

Based on public information, there is evidence that the company clearly prohibits bribery and emphasizes its commitment to legal compliance; however, its policy is not assessed to be explicitly one of zero tolerance.

Based on public information, there is evidence that the company's ethics and anti-corruption policies are easily accessible to Board members, employees and third parties only in English. However, these policies are only available in English, with evidence suggesting that the company operates in different locations around the world. The company therefore scores 1.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily understandable and clear to Board members, employees and third parties. The Code of Conduct and the Intermediary and Supplier Standards of Business Conduct are written in clear, comprehensible language.

Based on public information, there is evidence that the company's ethics and anti-corruption policies explicitly apply to all employees and Board members.

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 of conflicts of interest and provides numerous examples.

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. Employees are unable to give or receive gifts that are cash, excessive in value or could create embarassment for the company. Instead gifts should be of a nominal value and part of normal business conduct. However, the company does not specify a nominal value, only describing it as roughly $20, which may vary depending on the country. Similarly, the company states that some gifts may need approval from management, but does not specify at what value this is required. The company therefore scores 1. To score higher the company would need to set clear upper limits on the acceptable value of a gift, and/or have the requirement for senior management authorisation if a value threshold is exceeded.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. Employees are unable to give or receive hospitality that is excessive in value or could create embarassment for the company. Instead hospitality should be of a nominal value and part of normal business conduct. However, the company does not specify a nominal value, only describing it as roughly $20, which may vary depending on the country. Similarly, the company states that some hospitality may need approval from management, but does not specify at what value this is required. The company therefore scores 1. To score higher the company would need to set clear upper limits on the acceptable value of hospitality, and/or have the requirement for senior management authorisation if a value threshold is exceeded.

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. Where corporate political contributions are permitted, employees must receive advanced approval from the Government Relations Office and an appropriate level of management. 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 evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent. Employees must consult the Government Relations Office before commencing lobbying activities or hiring an outside lobbyist on the company behalf. The company's policy on engaging and retaining lobbyists is not publically available. The company therefore scores 1. To score higher the company would need to provide evidence that it publically discloses the issues on which it lobbies.

Based on public information, there is some evidence that the company regulates charitable contributions, in order to prevent undue influence or other corrupt intent. The company recognises in the Code of Conduct that charitable contributions can be a form of bribery. The Business Conduct and Corporate Responsibility Committee is responsible for monitoring the company's charitable contributions. The company therefore scores 1. To score higher the company would need to provide evidence that it publically declares all the recipients of such contributions.

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 anti-corruption agenda. The Code of Conduct contains numerous examples, and links to FAQs and applicable policies.

Based on public information, there is evidence that the company has a training programme on its Code of Conduct, which includes an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence that it has an explicit anti-corruption module, as part of its ethics and compliance training programme.

Based on public information, there is evidence that employees receive training as part of the company’s Business Conduct and Ethics Programme, with required training courses dependent on an employee’s role. The company therefore scores 1. To score higher the company would need to provide 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 evidence that the company has a varied ethics and anti-corruption training programme. Employees are required to take training courses dependent on their specific roles. The company therefore scores 1. To score higher the company would need to provide evidence that it tailors its ethics and anti-corruption training programme for employees facing different levels of risk.

Based on public information, there is some evidence that the company has a clear and formal process by which employees declare conflicts of interest. Employees are instructed to declare a conflict of interest to a manager or ethics advisor. The company therefore scores 1. To score higher the company would need to provide evidence that employees are instructed to declare conflicts of interest to a manager in writing, or provide further evidence of the process of declaring such conflicts to an ethics advisor.

Based on public information, there is evidence that the company may apply disciplinary procedures to employees and Board members who have violated the Code of Conduct. The company therefore scores 1. To score higher the company would need to provide evidence of an explicit commitment, using language such as ‘will’, to apply disciplinary procedures to employees and Board members who have violated the Code of Conduct.

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. These channels include an ethics advisor, a Human Resources business partner, a member of the Legal Department, and the Director of Business Conduct. In particular, the company’s Adviceline allows anonymous reporting and is operated externally.

Based on public information, there is evidence that across geographies, all employees have access to more than one whistleblowing channel. This includes an ethics advisor, the Director of Business Conduct or the company’s Adviceline.

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, or 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. These resources include an ethics advisor, the Director of Business Conduct or the company’s Adviceline.

Based on public information, there is evidence that the company has a non-retaliation policy for bona fide reporting of corruption, and that disciplinary measures are applied to employees who breach this policy.