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Ownership
PUBLIC
Defence revenue, USD
582.1m (2013)
Defence revenue, %
4.9% (2013)
Country
USA
Internal information
YES
Based on public information, there is some 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. He delivered a public speech on the importance of ethics but no other similar or related events/instances have been found.
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 through, for example, direct involvement with the staff on ethics or speaking at training events.
Based on public information, there is evidence that the company publishes a statement of values representing high standards of ethical business conduct, including honesty, trust, transparency and integrity. These values are described on the company website and throughout company documents, such as the Annual Report, the Code of Conduct and the Anti-Corruption Guidelines.
Based on public information, there is no readily available evidence that the company belongs to any national or international initiatives that promote anti-corruption or business ethics.
Based on public information, there is some evidence that the company has appointed a Board governed Audit Committee with overall corporate responsibility for its ethics agenda. However, the terms of reference in regard to matters of anti-corruption are not clear. The company therefore scores 1.
Based on public information, there is no readily available evidence that 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.
Based on public information, there is little evidence of regular monitoring of the performance of the company’s ethics and anti-corruption agenda and no readily available evidence of major reviews conducted at least annually.
Based on public information, there is no readily available evidence that the company has 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.
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 has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The Sustainability Report states that business units are analysed for corruption risk, but there is no further detail provided about this process or evidence of mitigation plans being put in place.
Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for mergers and acquisitions. The company states it has a complex due diligence process for mergers and acquisitions, which is much broader than just bribery and corruption. The company therefore scores 1. To score higher, the company would need to provide further information of the due diligence process for mergers and acquisitions or evidence of anti-corruption risk assessment procedures for other proposed business decisions.
Based on public information, there is evidence that the company conducts detailed due diligence that minimises corruption risk when selecting or reappointing its agents. The company therefore scores 1. To score higher the company would need to provide evidence that the company refreshes the due diligence at least every 3 years and/or when there is a significant change in the business relationship.
Based on public information, there is 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 and contractual terms, its stance on bribery and corruption. The Supplier Code of Conduct states suppliers must comply with the company’s anti-corruption policy. The Anti-Corruption Guidelines detail that the company will monitor the performance of suppliers and taken action when appropriate, suggesting contractual rights to apply sanctions in the event of a breach of the contract.
Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms, including facilitation payments and kickbacks.
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 Anti-corruption Guidelines and associated documents are easily accessible online. However, TI notes that the company’s documentation only appears to be available in English. The company therefore scores 1.
Based on public information, there is evidence that the Anti-Corruption Guidelines and associated documents are written in accessible, comprehensible language.
Based on public information, there is evidence that the Code of Conduct explicitly applies to all employees and Board members. TI notes that the company also has a Code of Business Conduct and Ethics for Board Members that contains details specific to Board members.
Based on public information, there is evidence that the company has a policy on potential conflicts of interest, applicable to both employees and board members, which contains a definition and relevant 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. However, the policy lacks clarity, as employees are only instructed that gifts must not be lavish or extravagant. The company therefore scores 1. To score higher the company would need to provide evidence of clear upper limits or specific thresholds necessary for senior authorisation.
Based on public information, there is evidence that the company has a policy on the giving and receiving of hospitality to ensure that such transactions are bona fide and not a subterfuge for bribery. However, the policy lacks clarity, as employees are only instructed that hospitality must be reasonable, moderate and proportional. The company therefore scores 1. To score higher the company would need to provide evidence of clear upper limits or specific thresholds necessary for senior authorisation.
Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments, except in situations where the safety or welfare of an employee or family member is threatened. Employees are instructed to notify company authorities for proper handling and follow-up in such cases.
Based on public information, there is readily available evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent. Political contributions go through multiple reviews, including legal for compliance with all applicable laws. The company therefore scores 1. To score higher the company would need to provide evidence that recipients are publically declared.
Based on public information, there is some evidence that the company has a policy on for engagement in lobbying activities. However, there is no readily available evidence that the company publically discloses the issues on which it lobbies. The company therefore scores 1.
Based on public information, there is evidence that the company’s charitable contributions are regulated in order to prevent undue influence or other corrupt intent. For example, for all contributions there are strict criteria and approval must be sought from the Executive Vice President of Finance and Administration. The company states that all corporate charitable contributions are made through the Jacobs Engineering Foundation. The company therefore scores 1. To score higher the company would need to provide evidence that recipients are publically declared.
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 Anti-Corruption Guidelines contain questions and answers, and lists a range of resources that are available to help employees understand and follow procedures.
Based on public information, there is evidence that anti-corruption training is explicitly provided as a separate training programme, albeit to certain employees. However, further evidence implies that the guidelines of the FCPA are incorporated into wider employee annual training.
Based on public information, there is evidence that the company has an anti-corruption training programme. The 2013 Sustainability Report states that in FY2012 nearly 25,000 employees completed on-line anti-corruption policy training, out of nearly 50,000 permanent employees. However, it is unclear if this training programme is provided in all countries where the company operates or has company sites. The company therefore scores 1. To score higher, the company must 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. Evidence suggests that training was provided to ‘leaders’ but it does not specify whether Board Members were included.
Based on public information, there is evidence that the company has a varied ethics and anti-corruption training programme for employees. For example, classroom anti-corruption training is provided to 618 people, suggesting particular employees receive additional training. The company therefore scores 1. To score higher, the company would need to provide evidence that its ethics and anti-corruption training programme is tailored for employees facing different levels of risk.
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. The company only states that employees in a situation that involves a potential conflict of interest must immediately contact their manager. To score higher the company would need to provide evidence that employees are instructed to inform either their managers formally in writing or an independent department.
Based on public information, there is evidence that the company has an explicit commitment to apply disciplinary procedures to employees, Directors and Board members found to have violated its Code of Conduct and Anti-Corruption Guidelines.
Based on public information, there is evidence that the company has multiple, well-publicised channels that are easily accessible, to guarantee confidentiality or anonymity where requested by the employee, to report concerns or instances of suspected corrupt activity. Channels include reporting to the Corporate Compliance Officer by phone or email, or using one of the numerous toll-free numbers for the Integrity Hotline. Evidence suggests that employees may report anonymously using the Integrity Hotline.
Based on public information, there is evidence that the company’s whistleblowing channels are available to all employees in all geographies. Employees are able to report to the Corporate Compliance Officer by phone or email, and the Integrity Hotline has toll-free numbers worldwide.
Based on public information, there is some evidence that the company encourages employees to report any concerns or violations of the Code of Conduct and the Anti-Corruption Guidelines. However, there is no readily available evidence of formal mechanisms to ensure employees are comfortable reporting concerns, such as monitoring of whistleblowing channel usage statistics, commissioning independent employee surveys or formal procedures for follow up with whistleblowers.
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, such as the Corporate Compliance Officer or the Integrity Hotline.
Based on public information, there is evidence available that the company makes a commitment to non-retaliation for bona fide reporting of corruption. However, there is no readily available evidence that the company applies disciplinary measures to employees who breach this policy. The company therefore scores 1.
Based on public information, there is evidence that the company publishes statements from the Chief Executive Officer supporting the ethics and integrity agenda of the company. These appear on the website, in the 2013 annual report and as an introduction to the Code of Ethics, where anti- corruption is directly mentioned.