Israel Aerospace Industries Ltd

Based on public information, there is evidence that the company published two statements from the Chairman and the President and CEO supporting the ethics and anti-corruption agenda of the company. The company therefore scores 1. To score higher the company would need to provide evidence of at least one more statement from the last two years, or one statement that specifically supports the company’s strong stance against corruption.

Based on public information, there is some evidence that the President and CEO demonstrate a personal, external facing commitment to the ethics and anti-corruption agenda of the company. The company therefore scores 1.

Based on public information, there is some evidence that the CEO demonstrates a strong, personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. In his June 2012 inaugration speech, the CEO stated that the company will continue to enforce rigorous controls to prevent unethical behaviour. The company therefore scores 1. To score higher the company would need to provide at least two other examples of such personal engagement over the last two years.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including honesty, trust, transparency, openness, and integrity.

Based on public information, there is evidence that the company is a member of IFBEC. TI notes that the company is also a member of TRACE International and the Society of Corporate Compliance and Ethics (“SCCE”). By joining TRACE a company must provide a copy of its anti-bribery policy and sign a membership agreement confirming its commitment to complying with international anti-bribery laws. However, no evidence of the successful implementation of this policy is required by TRACE and membership of this organisation alone is not considered enough to merit a higher score here. Furthermore, there is no obligation to prove a commitment to anti-corruption by membership of SCCE.

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.

Based on public information, there is evidence that the company has appointed the Chief Compliance Officer with responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board. This individual is named as Itzhak Sharon.

Based on public information, there is some evidence that there is regular monitoring and review of the performance of the company’s ethics and anti-corruption agenda by the Compliance Officer who reports directly to the Board. However, TI notes that it is not clear how regularly this happens and to what extent the Board is involved in the process. The company therefore scores 1.

Based on public information, there is some evidence of a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda is based. Although the company states that policies and practices are updated as appropriate, no evidence of improvement plans being implemented was found. The company therefore scores 1.

Based on public information, there is no readily available evidence that there is a formal process for review and update in response to actual or alleged instances of corruption. The senior management review is understood to be reasonably regular but it is not evident what happens in terms of review when there is actual or alleged malpractice.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. However, no information is provided regarding this risk assessment process beyond the statement of its existence and it is unclear how this is applied. The company therefore scores 1.

Based on public information, there is evidence that the company conducts due diligence when selecting its ‘marketing consultants’ (agents) and that this is renewed at least every 2 years.

Based on public information, there is evidence that the company has contractual rights and processes for the monitoring, control and audit of ‘marketing consultants’ (agents) with respect to countering corruption. There is an extensive monitoring process in place that includes template contracts and senior approval of signing contracts, their renewal and possible termination.

Based on public information, there is 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. However, there is no readily available evidence of such contractual terms. 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 evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers, and that this is refreshed at least every 2 years.

Based on public information, there is evidence that the company has an ‘Anti-Bribery Compliance Program’. However, the company is not explicit on all the forms that corruption might take. TI further notes the limited focus of the programme on ‘combating corruption and bribery of foreign officials in international transactions’. The company therefore scores 1.

Based on public information, there is 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 is easily accessible to Board members, contracted staff and other connected staff.

Based on public information, there is some evidence that the company’s anti-corruption policy is understandable and clear to Board members, employees and third parties. However, TI notes the legalistic language of some of the documents. The company therefore scores 1.

Based on public information, there is evidence that the company’s anti-corruption policy 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 and that it applies to both employees and board members. The company also indicates what a conflict of interest might consist of, namely a conflicting business interest. The policy also covers conflicts of interest pertaining to suppliers and contractors.

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, it does not publish evidence of upper limits or a specific threshold necessary for senior authorisation. The company therefore 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, it does not publish evidence of upper limits or a specific threshold necessary for senior authorisation. Indeed, aside from an initial statement highlighting hospitality, the term is not mentioned specifically again. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. However, the company provides no guidance or supplementary information on how the policy is to be implemented in practice. The company therefore scores 1.

Based on public information, there is evidence that the company is prohibited from making political contributions.

Based on public information there is insufficient evidence that the company has a clear policy on regulating lobbying activities, in order to prevent undue influence or other corrupt intent. To score higher, the company would need to provide evidence of an authorisation process or other controls around this activity. The company therefore scores 0.

Based on public information, there is evidence that the company is prohibited from making charitable contributions to prevent undue influence or other corrupt intent.

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. However, the guidance is limited in some cases and is weakened by a lack of illustration and scenarios. The company therefore scores 1.

Based on public information, there is evidence that the company has a training programme on its anti-corruption and compliance programme.

Based on public information, there is evidence that the company provides training on its anti-corruption and compliance programme in all of the geographic areas where the company operates.

Based on public information, there is evidence that the company provides training on the company’s anti-corruption and compliance programme to the Board. However, there is no readily available evidence that the Board are re-trained at least every three years. The company therefore scores 1.

Based on public information, there is evidence that the company provides training on the company’s anti-corruption and compliance programme to employees in sensitive positions.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest in writing either to a manager or an independent department. TI notes that the company Code of Ethics indicates a formal process for suppliers and contractors to declare conflicts of interest.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to employees found to have enagaged in corrupt activities. The company policies apply also to directors and managers.

Based on public information, there is evidence that the company has at least one communication channel (an anonymous 24 hour hotline) to report concerns or instances of suspected corrupt activity. Employees are also encouraged to seek help and advice from the Chief Compliance Offer and his staff. However, the hotline does not appear to be particularly well publicised and there are no independent sources to report to. The company therefore scores 1.

Based on public information, there is evidence that the company has at least one channel (an anonymous 24 hour telephone hotline) available for all employees across geographies to contact. However, for employees without access to the Chief Compliance Officer and his staff there only appears to be access to this one channel. The company therefore scores 1.

Based on public information, there is no 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. Such mechanisms could include detailed analysis of whistleblowing data, independent employee surveys or evidence of follow up with individual whistleblowers.

Based on public information, there is evidence that the company has resources available to employees where help and advice can be sought on corruption-related issues. This includes access to the Chief Compliance Officer and his staff, as well as access to an anonymous 24 hour hotline.

Based on public information, there is evidence that the company is commited to non-retaliation for bona fide reporting of corrupting. However, there is no evidence that disciplinary measures are applied to employees who breach this policy. The company therefore scores 1.