By public info, this company is placed in Band B

Ownership

PUBLIC

Defence revenue, USD

1,015.40m (2013)

Defence revenue, %

38% (2013)

Country

UK

Internal information

YES

Leadership 75%
1.
score
1

Based on public information, there is evidence that the company has published a statement from the Chairman supporting the ethics agenda of the company. The Chairman states that the company has zero tolerance for anything other than fair business and describes the company’s ethics programme of the company as an industry leader. The company therefore scores 1. To score higher the company would need to provide evidence of two more statements from the last two years that support the ethics agenda of the company, or a single statement from the last two years that specifically supports the company’s stance against corruption. TI notes that a statement from the former CEO in the company Ethics and Business Conduct booklet is over two years old.

COMMENTS -+
2.
score
1

Based on public information, there is no readily available evidence that the CEO or Chairman demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. However, there is evidence of delegated engagement. In 2012, Corporate Affairs Director Philip Green presented a lecture on business ethics. The company therefore scores 1. To score higher the company would need to provide evidence that the CEO or Chairman have demonstrated active engagement in anti-corruption matters on more than once occasion over the last two years.

COMMENTS -+
3.
score
1

Based on public information, there is evidence that the company’s CEO demonstrates a strong personal, internal-facing committment to the ethics and anti-corruption agenda of the company. The CEO sits on the Ethics and Trade Compliance Committee, which has overall corporate responsibility for the company’s ethics and anti-corruption agenda. The company therefore scores 1. To score higher the company would need to provide at least two more examples of the CEO’s personal engagement with management and staff, in promoting the ethics and anti-corruption agenda within the company.

COMMENTS -+
4.
score
2

Based on public information, there is evidence that the company publishes a statement of values representing high standards of ethical business conduct, including integrity and honesty. These values are addressed in the Ethics and Business Conduct Policy, the Code of Conduct and the Adding Values document, with the Code of Conduct detailing how these values are translated into company policies and practices. A video on the company website describes what integrity means in the different areas of the company.

COMMENTS -+
5.
score
2

Based on public information, there is evidence that the company belongs to the International Forum on Business Conduct (IFBEC), the Institute of Business Ethics (IBE) and the Ethics and Compliance Officer Association (ECOA).

COMMENTS -+
6.
score
2

Based on public information, there is evidence that the company has appointed the Ethics and Trade Compliance Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The committee’s terms of reference are published online and its responsibilities include ensuring that resources are avalable for the implemention of policies and programmes.

COMMENTS -+
7.
score
2

Based on public information, there is evidence that Group Corporate Affairs Director, Philip Green, has responsibility for implementing the company’s ethics and anti-corruption agenda. The Group Corporate Affairs Director reports to the Board at least once a year.

COMMENTS -+
8.
score
2

Based on public information, there is evidence that the Ethics and Trade Compliance Committee conducts monitoring of the company’s ethics and anti-corruption agenda. The Committee meets quarterly and its duties include ensuring that appropriate training is provided and having oversight of any ethics violations and on the overall ethics and business conduct and compliance. The Board has oversight of the ethics and anti-corruption agenda at least once a year.

COMMENTS -+
8a.
score
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 the Board or senior management is based. The Ethics and Trade Compliance Committee meets quarterly and its duties include ensuring that appropriate training is provided and having oversight of any ethics violations. Improvement plans have been recently implemented, including revisions to the Ethics and Business Conduct Policy, Code of Conduct and Anti-Corruption Policy. The company therefore scores 1. To score higher the company would need to provide further evidence of the formal, written plan guiding the review of the ethics and anti-corruption agenda.

COMMENTS -+
9.
score
1

Based on public information, there is limited evidence that the company has a formal process to review and where appropriate update its policies and practices in response to actual or alleged instances of corruption. The Ethics and Trade Compliance Committee has oversight of any significant ethics or compliance violations and the actions that must be taken in response. The company therefore scores 1. To score higher the company would need to provide evidence on the procedure for investigating ethics or compliance violations, and the resulting updates to its policies and practices.

COMMENTS -+
Risk management 60%
9a.
score
2

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. As part of the company’s risk management framework, legal and regulatory risks are identified, including bribery and corruption. Mitigation plans include ethics training, the anti-corruption policy, external audits, and the Ethics line. The company therefore scores 2.

COMMENTS -+
10.
score
0

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.

COMMENTS -+
11.
score
1

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting agents. Full vetting of all sales representatives and distributors is carried out through an independent organisation such as TRACE International. However, it is unclear if due diligence is refreshed when agents’ contracts expire. The company therefore scores 1. To score higher the company would need to provide evidence that it refreshes due diligence at least every three years and/or when there is a significant change in the business relationship.

COMMENTS -+
12.
score
1

Based on public information, there is evidence that the company has some contractual rights and processes for the behaviour and audit of agents with respect to countering corruption. Sales representatives must avoid any unlawful practices and act in accordance with the company’s Code of Conduct. The company’s internal audit and external resources have the right to periodically audit sales representatives. The company therefore scores 1. To score higher the company would need to provide evidence of monitoring and contractual rights to apply sanctions in the event of a breach of its contract.

COMMENTS -+
13.
score
2

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. The Corporate Responsibility Policy states that suppliers are encouraged to adopt the standards the company sets in its policies and code of conduct. The Global Standard Purchasing Conditions – applicable to suppliers working with company sites in the USA, UK, Singapore, and India – details the company’s right to terminate a contract if a supplier has acted corruptly.

COMMENTS -+
13a.
score
N/A

The company has informed TI that it does not engage in offset contracting.

COMMENTS -+
13b.
score
N/A

The company has informed TI that it does not engage in offset contracting.

COMMENTS -+
Policies & codes 75%
15.
score
2

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits the giving and receiving bribes. It is explicit on the various forms of corruption that can take place, including facilitation payments, kickbacks and conflicts of interest.

COMMENTS -+
16.
score
2

Based on public information, there is evidence that the company is explicit that bribery is never permitted.

COMMENTS -+
17.
score
2

Based on public information, there is evidence that all ethics and anti-corruption policies are provided to employees and directors. These policies are also available on the company’s website and in the Ethics and Business Conduct booklet, which contains all three ethics policies, is available in seven different languages.

COMMENTS -+
17a.
score
2

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily understandable and clear to Board members, employees and third parties. In particular, the Anti-Corruption Policy defines key forms of corruption and includes examples.

COMMENTS -+
18.
score
2

Based on public information, there is evidence that the company’s ethics and anti-corruption policies explicitly apply to all employees and Board members. The Ethics and Business Conduct booklet states that a Code of Conduct is provided to all employees and directors, directing them on their ethical responsibilities.

COMMENTS -+
20.
score
2

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. The Anti-Corruption Policy defines conflicts of interest and provides several examples. Directors have a separate conflicts of interest policy.

COMMENTS -+
21.
score
1

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. Gifts may not be accepted if they are cash, considered extravagant or frequent, or are an attempt to influence a decision. Employees must seek approval from their supervisors before giving a gift and payments to public officials must be authorised by Legal Counsel or VP, Ethics and Business Conduct. The company therefore scores 1. To score higher the company would need to provide evidence of clear upper limits on the acceptable value of a gift and/or senior management authorisation if a value threshold is exceeded.

COMMENTS -+
22.
score
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. Hospitality may not be accepted if it is considered extravagant or frequent, or an attempt to influence a decision. Employees must seek approval from their supervisors before giving hospitality and payments to public officials must be authorised by Legal Counsel or VP, Ethics and Business Conduct. The company therefore scores 1. To score higher the company would need to provide evidence of clear upper limits on the acceptable value of hospitality and/or senior management authorisation if a value threshold is exceeded.

COMMENTS -+
23.
score
1

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. The policy is clear and provides several examples of facilitation payments. The company therefore scores 1. To score higher the company would need to provide guidance on how the policy is to be implemented in practice.

COMMENTS -+
24.
score
2

Based on public information, there is evidence that the company prohibits all political contributions.

COMMENTS -+
25.
score
1

Based on public information, there is evidence that the company has a policy that clearly regulates lobbying activities. The company’s Legal Counsel are responsible for overseeing the activities and employees must consult their line managers before any non-routine contact is made with government officials or employees. The company therefore scores 1. To score higher the company would need to provide evidence that it publically discloses the issues on which it lobbies.

COMMENTS -+
25a.
score
0

Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent.

COMMENTS -+
Training 60%
26.
score
1

Based on public information, there is 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. The Anti-Corruption Policy contains a few examples, but some sections have dense language. The company therefore scores 1. To score higher the company would need to provide evidence of written guidance that is unambiguous and contains numerous scenarios.

COMMENTS -+
27.
score
2

Based on public information, there is evidence that the company has an explicit anti-corruption module as part of its ethics and compliance training programme. This training is mandatory for all employees, officers and directors. In 2013, training was provided on the UK Bribery Act.

COMMENTS -+
28.
score
2

Based on public information, there is evidence that the company’s anti-corruption training is mandatory for all employees, officers and directors, suggesting all company sites receive such training.

COMMENTS -+
29.
score
1

Based on public information, there is evidence that the Board members receive anti-corruption training, but its frequency remains unclear. The company therefore scores 1.

COMMENTS -+
30.
score
0

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.

COMMENTS -+
Personnel 71%
31.
score
0

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. Employees are instructed to disclose any conflicts of interest or potential conflicts of internet to their line manager. To score on this question the company would need to provide evidence that employees are instructed to declare conflicts of interest, either to a manager in writing or to an independent department.

COMMENTS -+
32.
score
2

Based on public information, there is evidence that the company has a commitment to apply disciplinary measures to employees, Directors and Board members found to have engaged in corrupt activities.

COMMENTS -+
33.
score
2

Based on public information, there is evidence that the company has multiple, well-publicised channels that are easily accessible, secure and guarantee confidentiality, which employees can use to report concerns or instances of suspected corrupt activity. Employess may report to the company Legal Counsel, the Vice President of Ethics and Business Conduct or the Group Corporate Affairs Director. In particular the Ethics Line is avaible 24/7, is independently operated and allows anonymous reporting. The company has recently launched a web based application for the Ethics Line.

COMMENTS -+
33a.
score
2

Based on public information, there is evidence that the company has whistleblowing channels available to all employees, in all geographies. Employees may report to the company Legal Counsel, the Vice President of Ethics and Business Conduct or the Group Corporate Affairs Director. Employees may also report to the Ethics Line using the web based application or one of the free Ethics Line numbers.

COMMENTS -+
33b.
score
1

Based on public information, there is some evidence that the company has formal mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively. The Audit Committee reviews the process for handling allegations from whistleblowers annually. The company therefore scores 1. To score higher the company would need to provide further evidence of mechanisms designed to support whistleblowing, such as detailed analysis of whistleblowing data or independent employee surveys.

COMMENTS -+
34.
score
2

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. Resources available to employes include their on-site Ethics Coodinator, the Vice President of Ethics and Business Conduct, the Group Corporate Affairs, or the Ethics Line.

COMMENTS -+
35.
score
1

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. However, the company does not have an explicit statement that disciplinary measures will be taken against those who retaliate. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary measures are applied to employees who breach the non-retaliation policy.

COMMENTS -+
Band & analysis based on internal and public information: band B
Leadership 75%
Risk management 90%
Policies & codes 75%
Training 60%
Personnel 79%