MBDA Missile Systems

Based on public information, there is evidence that the company publishes a statement from the Chief Executive Officer supporting the ethics and compliance agenda of the company. However, this statement does not explicitly reference corruption. The company therefore scores 1. To score higher the company would need to provide evidence of at least two other such statements from the last two years, or one statement from the last two years that specifically supports the company’s strong stance against corruption.

Based on public information, there is no readily available evidence that the Chief Executive Officer or Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. TI notes the Chief Executive Officer’s position on the Board of ASD, but has found no evidence that this role involves work on ethics and anti-corruption issues.

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.

Based on public information, the company publishes a statement of values representing high standards of business conduct, including honesty and integrity, and demonstrates that these are translated into company policies and codes. However, the range values falls short of those sought by the question. The company therefore scores 1.

Based on public information, there is evidence that the company is a member of IFBEC and has signed up to the ASD Common Industry Standards.

Based on public information, there is evidence that the company has appointed the Business Ethics Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The company website provides detail about the remit and activities of the Committee responsible.

Based on public information, there is evidence that the Group Compliance Officer is responsible for the company’s ethics and anti-corruption agenda. The Group Compliance Officer reports directly to the CEO, but is not identifiable by name. The company therefore scores 1.

Based on public information, there is some evidence that there is regular Board level monitoring and review of the company’s Integrity Programme. However, it is unclear how often this review process occurs. The company therefore scores 1.

Based on public information, there is limited evidence of a formal, written plan on which the review of the ethics and anti-corruption agenda by senior management is based. The Business Ethics Committee reviews the Integrity Programme based upon risk assessments and integrity programme reviews, the company’s policies and procedures, and communication and training. Evidence suggests that improvement plans are implemented when issues are identified, but no further details are provided. The company therefore scores 1.

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. TI notes that the company has an Integrity Programme in place, but it remains unclear whether this also includes a formal process of response to actual or alleged instances of corruption.

Based on public information, there is some evidence that the company has an anti-corruption risk assessment procedure implemented enterprise-wide. However, there is insufficient evidence of anti-corruption risk ownership and the development of mitigation plans. The company therefore scores 1.

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 some evidence that the company has procedures to minimise corruption risk when selecting or reappointing its agents. However, it is not clear that due diligence forms part of this process and there is no evidence that the company refreshes its due diligence at least every three years and/or when there is a significant change in the business relationship. The company therefore scores 0.

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 some evidence that the company makes clear to suppliers its stance on business ethics and its pillars of corporate social responsibility. However, there is no readily available information on the consequences to suppliers of breaches to these policies. Further, there seems to be no information on contractual terms that may apply in this regard. 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 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 an anti-corruption policy that prohibits corruption in its various forms.

Based on public information, there is no readily available evidence that the 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, employees, contracted staff and any other organisations acting with or on behalf of the company.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear to Board members, employees and third parties. References to anti-corruption can be found in the Code of Ethics, the website and the Corporate Social Responsibility report, and the language is easy to read.

Based on public information, there is evidence that the anti-corruption policy applies to all employees, though it is not clear if this includes members of the Board. TI notes that there are additional responsibilities ascribed to the managers, but the scope of the policies does not explicitly cover senior management and Board members. The company therefore scores 1.

Based on public information, the company has a policy on potential conflicts of interest. However, the company does not provide a definition or examples of potential conflicts of interest, nor is there evidence of its application to Board members. The company therefore scores 1.

Based on public information, the company has a policy for the giving and receipt of gifts; however, little guidance is given with respect to reasonable limits or the need for senior authorisation. The company therefore scores 1.

Based on public information, the company has a policy for the giving and receipt of hospitality; however, little guidance is given with respect to reasonable limits or the need for senior authorisation. 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 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.

Based on public information, there is evidence of a procedure to control charitable contributions. TI notes that there is a list of recipients in the CSR Report, but it is not clear how extensive this is. The company therefore scores 1.

Based on public information, there is insufficient 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 information in the Code of Ethics on manager responsibility suggests that specific guidance may be in place, but this remains unclear from public information. TI does note that the company website refers to internal company policies and an intranet.

Based on public information, there is evidence that the company has a training programme on its ethics and compliance systems, which includes an anti-corruption policy. However, there is no evidence of a specific anti-corruption training module. The company therefore scores 1.

Based on public information, there is evidence that anti-corruption training is offered to all employees. However, it is not clear that training is provided in all countries where the company operates or has company sites. The company therefore scores 1.

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 limited evidence that suggests the company provides tailored training to the most exposed employees. However, the scope and the content of these training sessions remains unclear. The company therefore scores 1.

Based on public information, there is limited evidence that the company has a process by which employees declare conflicts of interest, primarily through reporting it to their manager. However, it is not clear that declarations must be made formally and in writing. The company therefore scores 0.

Based on public information, there is insufficient readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have violated the Code of Ethics and the respective policies. TI notes that the Code of Ethics refers to cases of violations of the policies and procedures, but this falls short of providing an explicit commitment to disciplinary measures.

Based on public information, there is evidence that the company has some channels for reporting concerns or instances of suspected corrupt activity. However, there is no evidence that these channels include independent sources or facilitate anonymous reporting. The company therefore scores 1.

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 limited evidence of efforts to ensure whistleblowing is not deterred. However, there is no evidence of mechanisms designed to ensure that whistleblowers are supported, such as detailed analysis of whistleblowing data or independent employee surveys. The company therefore scores 1.

Based on public information, employees have access to well-publicised resources where help and advice can be sought on corruption-related issues. For example, employees may talk to their supervisor. However, there is no evidence that he or she is trained for the advisory job. The company therefore scores 1.

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