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Ownership
UNKNOWN
Defence revenue, USD
6324m(2013)
Defence revenue, %
93% (2013)
Country
USA
Internal information
NO
Based on public information, there is some evidence that the company’s Chief Executive Officer has demonstrated a personal, external facing commitment to the ethics and anti-corruption agenda of the company in the last two years. The Chief Executive Officer gave a speech at the Old Dominion University, which included a focus on leading wih integrity. TI also notes a statement made by the Chief Executive Officer, which is outside the two year timeframe of the question. The company therefore scores 1.
Based on public information, there is no readily available evidence that the Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure of personal engagement with employees on this issue.
Based on public information, there is evidence the company publishes a number of statements of values and commitments representing high standards of business conduct, including honesty, trust, integrity. The company clearly demonstrates how these are translated into company policies and codes.
Based on public information, there is 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. Specifically, the company is a member of the Defense Industry Initiative on Business Ethics and Conduct (DII).
Based on public information, there is evidence that the company has appointed a Board committee with overall corporate responsibility for its ethics and anti-corruption agenda. TI notes that the Audit Committee has this responsibility and its duties and authorities are outlined in an Audit Committee Charter.
Based on public information, there is evidence 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. TI notes that Kenneth Rogers holds the position of Corporate Director Compliance and Ethics.
Based on public information, there is evidence that the Audit Committee meets both quarterly and at least annually to review the implementation and effectiveness of the company’s compliance program with the General Counsel.
Based on public information, there is no readily available evidence a formal, clear, written plan is in place on which the review of the ethics and anti-corruption agenda by the Audit Committee is based, and evidence of improvement plans being implemented when issues are identified. TI notes the Audit Committee Charter provides a brief overview of the Committee’s review procedure, which is insufficient evidence to score on this question.
Based on public information, there is evidence that the company has a formal process for review of its policies and practices in response to actual or alleged instances of corruption. Indeed, it is the responsibility of the General Counsel ‘to communicate directly to the Committee, promptly, about actual and alleged violations of the Code of Ethics and Business Conduct, including any matters involving criminal or potential criminal conduct’. However, it is not clear that updates are made in response to such conduct. The company therefore scores 1.
Based on public information, there is limited evidence that the company has a formal risk assessment procedure implemented enterprise-wide. TI found no readily available details outlining this procedure and nothing indicating that it comprises a specific focus on anti-corruption.
Based on public information, there is limited evidence that the company has a formal risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied. TI found no readily available details outlining this procedure and nothing indicating that it comprises a specific focus on anti-corruption.
Based on public information, there is no readily available evidence that the company conducts due diligence when selecting 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 evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy terms, its stance on bribery and corruption and the consequences of breaches to this stance. The Supply Chains section of the company website states that any supplier in breach of the company’s code of values will be subject to termination.
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 ethics and business conduct program that prohibits corruption in some of its forms. Specifically, TI notes that the policy is not as explicit as it could be on the various forms of corruption that exist. The company therefore scores 1.
Based on public information, there is no readily available evidence that the company’s anti-corruption policy is explicitly one of zero tolerance. However, the company has a zero tolerance policy of violations of the Code of Ethics and Business Conduct. The company therefore scores 1.
Based on public information, there is evidence that the company's anti-corruption policy is accessible on the company website to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company. However, TI notes that the documents are only available in English. The company therefore scores 1.
Based on public information, there is evidence that the policy is largely understandable; however, TI notes the use of legal language and legal references, which might be more difficult to understand for a non-legal audience. TI also notes the lack of examples or detail on some points, which would have added to the clarity of the policy. The company therefore scores 1.
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 does have a policy on potential conflicts of interest that applies to both employees and board members. TI notes that the company provides examples of potential conflicts of interest.
Based on public information, there is evidence that the company provides general guidance for the giving and receipt of gifts but it is lacking in specifics, such as upper limits or a threshold for senior authorisation. TI notes that further information may be provided in the company’s Business Courtesies Policy; however, this is not publicly available. The company therefore scores 1.
Based on public information, there is evidence that the company provides general guidance for the giving and receipt of hospitality but it is lacking in specifics, such as upper limits or a threshold for senior authorisation. TI notes that further information may be provided in the company’s Business Courtesies Policy; however, this is not publicly available. The company therefore scores 1.
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 prohibits “the payment or offering of anything of value directly or indirectly to a foreign government official, political party, party official or candidate”, under FCPA guidelines, and “the use of federally appropriated money to pay any person for influencing or attempting to influence officials of the Executive or Legislative branches, including members of Congress and their staffs, in connection with the award or modification of U.S. government contracts”, under the Byrd Amendment. However, there remains scope outside these legally defined terms to undertake political contributions and no readily available evidence was found to indicate that the company has addressed this. The company therefore scores 1.
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, and discloses the issues on which the company lobbies.
Based on public information, there is no readily available evidence the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.
Based on public information, there some evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. TI notes that the Code of Ethics and Business Conduct provides some guidance. However, it is lacking detailed example scenarios and broader illustration of the points made. The company therefore scores 1.
Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption. TI notes that only limited information about employee training is available publicly.
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. TI notes that only limited information about employee training is available publicly.
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 evidence that the company has a clear and formal process by which employees declare conflicts of interest. TI notes that this system includes escalating difficult issues to a higher independent authority.
Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have violated ethical standards or the Code of Ethics and Business Conduct, which includes the company’s anti-corruption policy.
Based on public information, there is 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 evidence that the whistleblowing channels are available to all employees in all geographies.
Based on publicly available information, there is evidence that the company seeks to encourage employees to report on instances of malpractice; however, it is not clear that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, such as ways to follow up with whistleblowers and monitor their experience.
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. TI notes particularly the existence of Business Conduct Officers within the company.
Based on public information, there is evidence of a commitment to non-retaliation for bona fide reporting of corruption. However, it is not made clear what disciplinary measures are applied to employees who breach this commitment. The company therefore scores 1.
Based on public information, there is evidence the company publishes statements from the Chief Executive Officer supporting the ethics and anti-corruption agenda of the company. TI notes that this includes a video released in January 2014. However, the main statement within the Code of Ethics and Business Conduct dates from March 2011. The company therefore scores 1.