Korea Aerospace Industries

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

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, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

Based on public information, there is no readily available evidence that the company publishes a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity, and accountability.

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.

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 no readily available evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda.

Based on public information, there is no readily available 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.

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.

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.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing 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 no readily available 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. TI notes that the company expects to share high ethical standards with its suppliers.

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 and offset brokers.

Based on public information, there is evidence that the company has a policy on corruption. However, it is not a clear statement and it is not explicit on all the forms that such corruption might take. The company therefore scores 1.

Based on public information, there is no readily available evidence of a zero-tolerance anti-corruption policy.

Based on public information, there is evidence that the company has an Ethics Code that is easily accessible to Board members, employees and third parties. The Code is available in English and Korean.

Based on public information, there is evidence that the company’s Ethics Code is somewhat understandable. However, the Ethics Code does not describe company policies in detail and is not written in clearly comprehensible language. The company therefore scores 1.

Based on public information, there is evidence that the company's Ethics Code applies to all employees. However, there is no evidence that the Ethics Code also applies to Board members. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a policy on potential conflicts of interest.

Based on public information, there is some 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. The company states that inappropriate behaviours, such as the transfer of money, goods, privileges, advantages and entertainment to and from concerned parties, is not permitted. However, there is no evidence that the company sets upper limits for gift exchange and/or the requirement for senior management authorisation if a value threshold is exceeded. The company therefore scores 1.

Based on public information, there is some 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. The company states that inappropriate behaviours, such as the transfer of money, goods, privileges, advantages and entertainment to and from concerned parties, is not permitted. However, there is no evidence that the company sets upper limits for hospitality exchange and/or the requirement for senior management authorisation if a value threshold is exceeded. 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 political contributions in order to prevent undue influence or other corrupt intent.

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 the company lobbies. TI notes that political activities are not permitted within the company, but it is unclear if this includes lobbying activities.

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 evidence that the company provides written guidance to help employees understand and implement the firm’s ethics and anti-corruption agenda. However, this guidance cannot be assessed as it is not publicly available. 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.

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.

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 no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

Based on public information, there is evidence that the company is committed to apply disciplinary procedures to employees found to have engaged in corrupt activities. However, it is unclear if this commitment applies to Directors and Board members. The company therefore scores 1.

Based on public information, there is evidence that the company has multiple channels to report concerns or instances of suspected corrupt activity. However, there is no evidence that the company offers independent whistleblowing channels or channels that allow for anonymity. The company therefore scores 1.

Based on public information, there is evidence that across geographies, all employees have access to at least one whistleblowing channel, a department head. However, there is no evidence that across geographies, all employees have access to more than one reporting channel. The company therefore scores 1.

Based on public information, there is no readily available 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.

Based on public information, there is no readily available evidence that the company has resources available to all employees where help and advice can be sought on corruption-related issues.

Based on public information, there is no readily available evidence that there is a commitment to non-retaliation for bona fide reporting of corruption.