Honeywell

Based on public information, there is insufficient evidence that the company publishes a statement from the Chief Executive Officer supporting the ethics and anti-corruption agenda of the company. TI notes a statement emphasising ethics and integrity is published in the introduction to the Code of Conduct. However, this statement was last published in 2011 and does not directly relate to anti-corruption.

Based on public information, there is evidence that the company’s Chief Executive Officer demonstrates a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. The CEO is on the Steering Committee of the DII. TI understands that the Steering Committee meets on a regular basis.

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. TI notes that the company provided internal information for the CI 2012, which was openly published in the survey report with the company’s permission. However, the public assessment score remains 0 as this part of the survey is seeking to understand company transparency.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including integrity and honesty. The company provides some explanation of these values, referencing transparency, trust and openness. The company therefore scores 1. To score higher the company would need to explain in greater detail why these values matter to the organisation and how they are translated into company policies.

Based on public information, there is evidence that the company belongs to the DII and the company’s CEO is on the steering committee.

Based on public information, there is some evidence that the company has appointed the Corporate Governance and Responsibility Committee with overall corporate responsibility for its ethics and anti-corruption agenda. Specifically, the Committee is responsible for the Code of Conduct. However, there is no readily available evidence that it has responsibility for the rest of the company’s ethics and anti-corruption agenda. The company therefore scores 1.

Based on public information, there is some evidence that the company has appointed the Vice President, Global Compliance, with responsibility for implementing the company’s ethics and anti-corruption agenda. This individual is identified as Douglas Perry. However, there is limited information provided about the scope of this individual’s responsibilities regarding the company’s ethics and anti-corruption agenda. The company therefore scores 1.

Based on public information, there is evidence that the company’s Corporate Governance and Responsibility Committee reviews the ethics agenda. This Committee is supported in a structured manner by the Corporate Integrity and Compliance Council & the Business Unit Integrity and Compliance Leadership Function to conduct regular monitoring & reviews. However, these reviews do not appear to be major reviews of the complete anti-corruption agenda. The company therefore scores 1.

Based on public information, there is little 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, or evidence of improvement plans being implemented when issues are identified. TI notes that the company’s Corporate Governance and Responsibility Committee reviews the ethics agenda against a defined timetable and an overall structure.

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 have a formal anti-corruption risk assessment procedure implemented enterprise-wide.

Based on public information, there is limited evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. TI notes that compliance functions do have a responsibility for ensuring compliance with company policies, but it is unclear if this addresses business decisions.

Based on public information, there is no evidence that the company conduct due diligence that minimises corruption risk when selecting or reappointing its agents. TI notes a statement placing the onus of selecting reputable agents on employees, but it does not suggest a structured process of due diligence.

Based on public information, there is no 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, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance. The Code of Business Conduct only mentions entering into contracts with supplier who have a “record of and commitment to integrity”. However, details on how this process is ensured are not available. TI notes that there is a supplier portal which, according to an overview, includes ethics expectations, but this is password protected.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is 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’s anti-corruption policy is explicitly one of zero tolerance.

Based on public information, there is evidence that the company’s anti-corruption policy, contained in its Code of Business Conduct, is easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company. The Code is available to download from the company website in 22 languages.

Based on public information, there is evidence that the company has a clear anti-corruption policy that is easily understandable and clear to Board members, employees and third parties. It is written in clear language that educates employees on corruption in its various forms.

Based on public information, there is evidence that the company’s anti-corruption policy explicitly applies to all employees and members of the Board.

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. It contains a definition and numerous examples of potential conflicts of interest.

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. However, the policy has no clear process for the approval required for accepting and giving gifts, and leaves this up to the persons involved. Therefore the company scores 1.

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. However, the policy has no clear process for the approval required for accepting and giving hospitality, and leaves this up to the persons involved. The company therefore scores 1.

Based on public information, there is no evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is evidence that the company has a policy on political contributions and regulates such contributions in order to prevent undue influence or other corrupt intent. The company’s US operations are bound by the country law governing declaration of political activity and 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, and discloses the issues on which it lobbies.

Based on public information, there is evidence that the company has a clear policy to regulate charitable contributions. However, it is not clear that the company publicly declares such contributions. The company therefore scores 1.

Based on public information, there is 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 Code of Conduct contains example cases to explain particular situations and ensure employees better understand the company’s policies towards anti-corruption.

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

Based on public information, there is no evidence that the company provides anti-corruption training in all countries where the company operates or has company sites.

Based on public information, there is no evidence that the company provides targeted anti-corruption training to members of the Board.

Based on public information, there is no evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is evidence that the company has a formal process by which employees declare conflicts of interest. Employees are encouraged to disclose the issue by speaking with a supervisor, or contacting the Law Department or the company’s Integrity and Compliance Office. The company therefore scores 2.

Based on public information, there is some evidence that the company commits to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities. The disciplinary procedures apply on violation of the Code of Business Conduct, containing the anti-corruption provision, which applies to all employees including Directors. However, there is no evidence of an explicit commitment to apply disciplinary procedures, as the company uses language such as “may”, rather than “will”. The company therefore scores 1.

Based on public information, there is evidence that the company has well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee to report concerns or instances of suspected corrupt activity. These channels include integrity and compliance representatives and the ACCESS Integrity Helpline, which is a 24-hour independent service.

Based on public information, there is evidence that across geographies, all employees have access to more than one whistleblowing channel.

Based on public information, there is some 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. There is a structured approach to the compliance and anti-corruption efforts in which various compliance and integrity officers are providing an aiding role to whistleblowers. However, specific details of how these efforts have resulted in positive results towards whistleblowing is not available. The company therefore scores 1.

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.

Based on public information, there is evidence that the company makes a commitment to non-retaliation for bona fide reporting of corruption. However, there is no clear evidence that employees breaching this commitment are disciplined. The company therefore scores 1.