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Ownership
PRIVATE
Defence revenue, USD
2460m (2013)
Defence revenue, %
97% (2013)
Country
INDIA
Internal information
NO
Based on public information, there is some evidence that the Chairman demonstrates a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. In 2013, the Chairman signed a Memorandum of Understanding with Transparency International India regarding the adoption of an Integrity Pact, becoming the first defence PSU to do so. The company therefore scores 1. To score higher the company would need to provide at least one more example of the Chairman’s active external engagement in anti-corruption matters.
Based on public information, there is limited evidence that the Chairman, who fulfils the role of CEO, demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. Evidence shows that the Chairman supports the company’s vigilance department, by actively taking part in the annual Vigilance Awareness Week. The company therefore scores 1. To score higher the company would need to provide at least two more examples of such engagement.
Based on public information, there is evidence that the company has published a statement of values representing high standards of business conduct, including trust and integrity. To work with integrity the company has a commitment to be honest and trustworthy, and to achieve trust requires transparency. The values are briefly explained on the company’s website and in company documents.
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. The company’s Vigilance Department is responsible for the company’s anti-corruption intiatives, but it is not a Board committee.
Based on public information, there is evidence that the company has appointed the Chief Vigilance Officer with responsibility for implementing its ethics and anti-corruption agenda. The Chief Vigilance Officer is identified as Shri Anurag Sahay.
Based on public information, there is limited evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. The Chairman of the Audit Committee receives quarterly reports from the Director of Human Resources or the Head of Systems Audit, in regard to whistleblowing reports. The company therefore scores 1. To score higher the company would need to provide evidence of a formal Board level review of the company’s entire ethics and anti-corruption agenda, or that it commissions a similar external review.
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. TI notes that there is some evidence that improvement plans have been implemented when issues have been identified; for example, the company’s Vigilance Manuals have been revised.
Based on public information, there is evidence that the company has a process to review and also updates its policies and practices, in response to actual or alleged instances of corruption. This is the responsibility of the Vigilance Department and the Chief Vigilance Officer. Evidence suggests that in response to unethical consultant appointments the Vigilance Department introduced a detailed policy for the appointment of consultants.
Based on public information, there is some evidence that the company has a corruption risk management system implemented enterprise-wide. A system has been implemented that identifies, assesses and mitigates risks. It has been recently introduced and the Management Committee of the Board has mandated the Vigilance department to work on the modalities of the implementation. TI notes that the Chief Vigilance Officer ensures that assessments are made of the scope and modes of corruption, and suggests measures to check them. However, there is no further evidence of when and how mitigation plans should be applied. 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, with clear requirements on the circumstances under which such a procedure should be applied.
Based on public information, there is evidence that the company does not use agents in the procurement process.
Based on public information, there is evidence that the company does not use agents in the procurement process.
Based on public information, there is evidence that the company has made clear to suppliers through contractual terms, its stance on bribery and corruption, and the consequences of breaches to this stance. Vendors and suppliers are required to sign the Integrity Pact, which states that both parties must not exercise any corrupt influence on any part of the contract. Similarly, the Purchase Manual shows that the company has the right to disqualify a contractor from the tender process in response to corrupt activities.
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.
Based on public information, there is evidence that the company has an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence that it explicitly prohibits many of the forms that corruption might take, for example the giving and receiving of bribes and kickbacks.
Based on public information, there is evidence that the company’s anti-corruption policy is explicitly one of zero-tolerance. The company states that Board members and Senior Management must work for the eradication of corruption in all spheres of life.
Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily accessible to Board members, contracted staff and third parties. The four volumes of the company’s Vigilance Manual, the Code of Business Conduct and Ethics for Board members and Senior Management, and the Rules booklet are all available on the company’s website.
Based on public information, there is some evidence that the company’s ethics and anti-corruption policies are easily understandable and clear to Board members, employees and third parties. However, TI assesses that the company’s Vigilance Manual is dense and it does not clearly provide guidance on corruption related issues. The company therefore scores 1.
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. However, the policy is spread across numerous documents and does not offer a clear definition of a conflict of interest. The company therefore scores 1.
Based on public information, there is evidence that the company has a policy for the receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. Gifts worth more Rs.1500 received by an officer or any of their family members must be sanctioned by the Competent Authority. The company therefore scores 1. To score higher the company would need to provide evidence that a similar policy applies to giving gifts.
Based on public information, there is evidence that the company has a policy for the receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. Company officers must avoid accepting lavish or frequent hospitality from any individual or firm that they conduct activities with. Furthermore, as a gift is defined as any service or pecuniary advantage provided by a person other than a near relative or a personal friend that has no official dealings with the officer, the company’s rule that the Competent Authority must sanctions gifts worth more that Rs.1500 received by an officer or any of their family members, applies to hospitality. The company therefore scores 1. To score higher the company would need to provide evidence of a policy that explicitly applies to the giving of hospitality.
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 has a policy that prohibits or regulates political activities, in order to prevent undue influence or other corrupt intent. The company prohibits the personal political activities of its officers, but there is no evidence of similar prohibitions for corporate political contributions.
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 charitable contributions, or regulates such 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 company’s ethics and anti-corruption agenda.
Based on public information, there is evidence that the company has an explicit anti-corruption module as part of its ethics and compliance training programme.
Based on public information, there is evidence that company divisions receive Vigilance Awareness programmes and training, which includes education on anti-corruption measures. The company therefore scores 1. To score higher the company would need to provide evidence that this anti-corruption training is provided to all company employees.
Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to Board members.
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 of a clear and formal process by which employees declare conflicts of interest. Officers must inform their management through a section/departmental head, about employment of their near relatives in firms with which the company conducts business activities. However, there is no evidence that this declaration is conducted formally and in writing, or that it applies to other conflicts of interest.
Based on public information, there is evidence that the company has an explicit policy to apply disciplinary procedures to employees and Board members who have violated the company’s rules and Code of Ethics.
Based on public information, there is evidence that the company has multiple channels for employees to report concerns or instances of suspected corrupt activity. Channels include the Chairman of the Audit Committee, the Director of Human Resources, the Head of Systems Audit, the Vigilance Department, and the CVC. The company therefore scores 1. To score higher the company would need to provide evidence that employees are able to report anonymously.
Based on public information, there is evidence that whistleblowing channels are available across geographies, to all employees. Channels include the Vigilance Department and the CVC.
Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms, such as analysis of reporting channel usage statistics or follow up with individual whistleblowers, 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 the Chairman of the Audit Committee, the Director of Human Resources and vigilance officers posted throughout the company’s divisions.
Based on public information, there is evidence that the company has a non-retaliation policy for bona fide reporting of corruption. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary measures are applied to employees who breach this policy.
Based on public information, there is evidence that the company publishes statements from the Chairman supporting the ethics and anti-corruption agenda of the company. Statements in regard to anti-corruption and integrity can be found in the Annual Report 2012-2013 and several editions of the company magazine Marg Darshan.