- A
- B
- C
- D
- E
- F
Ownership
PRIVATE
Defence revenue, USD
490m (2013)
Defence revenue, %
100% (2013)
Country
US
Internal information
YES
Based on public information, there is no readily available evidence that the company’s CEO demonstrates a strong, personal, external facing commitment to its ethics and anti-corruption agenda.
Based on public information, there is no readily available evidence that the CEO demonstrates a strong, personal, internal-facing commitment to its ethics and anti-corruption agenda of the company. The CEO states on the company’s website that he has a direct involvement with monitoring the ethics and anti-corruption agenda. However, TI would need to see evidence of this involvement to award a score on this question.
Based on public information, there is evidence that the company has published a statement of values representing high standards of ethical business conduct, including integrity, honesty and accountability. In particular, integrity is explained throughout the Code of Business Ethics and Conduct. However, these values are assessed to fall short of those required by the question. The company therefore scores 1.
Based on public information there is evidence, that the company has appointed a Board committee or an individual Board member, with overall corporate responsibility for its ethics and anti-corruption agenda. Specifically, the company states that the Board of Managers maintains oversight of the company’s ethics programme,
Based on public information, there is evidence that the company has appointed the Ethics Officer, with responsibility for implementing the company’s ethics and anti-corruption agenda. Annually the Ethics Officer reports to the Board of Managers in regard to the company’s ethics programme. The Ethics Officer is also clearly identifiable by name.
Based on public information, there is evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. The Ethics Officer meets with the Board of Managers annually, to give an overview of the ethics programme and to consider any improvement plans.
Based on public information, there is some evidence of a formal, clear, written plan in place, on which the annual review of the ethics and anti-corruption agenda by the Board of Managers and Ethics Officer is based. The company states improvement plans are also considered during the annual review; however, no further evidence of this is provided. The company therefore scores 1.
Based on public information, there is some evidence, that the company has a formal process to review and where appropriate, updates its policies and practices in response to actual or alleged instances of corruption. However, it remains unclear from the evidence available that such a review would take place in every case. 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, implemented enterprise-wide. Evidence shows that the company has an Enterprise Risk Management Policy. However, there is no evidence that corruption risks are identified and mitigated as part of this procedure.
Based on public information, there is limited evidence that the company has a formal anti-corruption risk assessment procedure, for assessing proposed business decisions. TI notes that the company states that it has strict approval requirements for consultants and that before contracting with any foreign business partner, the Contracts & Procurement Department will obtain a completed FCPA questionnaire. However, to score higher the company would need to provide evidence that it has a formal anti-corruption risk assessment procedure for proposed business decisions.
Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting its agents. The company states that it has strict approval requirements for consultants and that before contracting with any foreign business partner, the Contracts & Procurement Department will obtain a completed FCPA questionnaire. It is also clear that certifications and representations by business partners are refreshed on an annual basis.
Based on public information, there is evidence that the company has contractual rights and processes for the control of agents, with respect to countering corruption. However, TI has found no readily available evidence that the company has monitoring and auditing rights. The company therefore scores 1.
Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, its stance on bribery and corruption. There is also evidence of contractual rights to apply sanctions in the event of a breach of contract.
Based on public information, there is evidence that the company does not enter into offset contracts due to the risks of corruption.
Based on public information, there is evidence that the company does not enter into offset contracts due to the risks of corruption.
Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. The company prohibits the giving and/or receiving of bribes, kickbacks and corrupt gifts and hospitality.
Based on public information, there is evidence that the company has zero tolerance for corruption.
Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily accessible to Board members, employees and third parties. The Statement of Mission Essential’s Anti-Corruption Position and the Code of Business Ethics and Conduct are available to download on the company’s website.
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. The Statement of Mission Essential’s Anti-Corruption Position and the Code of Business Ethics and Conduct are written in comprehensible language, without dense, legal terms.
Based on public information, there is evidence that the company’s ethics and anti-corruption policies explicitly apply to employees and Board members.
Based on public information, there is evidence that the company has a policy on potential conflicts of interest. The policy contains several examples of potential conflicts of interest and applies to both employees and Board members.
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 must be of a reasonable value and be in support of business activities, and senior authorisation must be obtained before employees offer gifts to foreign officials. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of all gifts and/or requires senior management authorisation if a value threshold is exceeded.
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 must be of a reasonable value and be in support of business activities, and senior authorisation must be obtained before employees offer hospitality to foreign officials. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of all hospitality and/or requires senior management authorisation if a value threshold is exceeded.
Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments. The company makes multiple statements that facilitation payments must be made with written approval from the Legal Department, despite one brief statement that prohibits improper payments, including facilitating contributions.
Based on public information, there is some evidence that the company prohibits political contributions, in order to prevent undue influence or other corrupt intent. This is inferred from the company encouraging employees to personally participate in the political process and for the company to state that many countries prohibit corporate political contributions. The company therefore scores 1. To score higher the company would need to provide evidence that it either explicitly prohibits corporate political contributions, or that it regulates corporate political contributions and publically declares recipients.
Based on public information, there is limited evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent. The company instructs lobbyists to abide by US lobbying law, but does not provide evidence of company procedures in regard to lobbying. However, the company does state that lobbyists must comply with the US Lobbying Disclosure Act. The company therefore scores 1. To score higher the company would need to provide evidence of a company policy that clearly regulates lobbying activities.
Based on public information, there is evidence that the company regulates charitable contributions, in order to prevent undue influence or other corrupt intent. Before a charitable contribution is approved due diligence is conducted.The company discloses some of the recipients of charitable contributions on its website. The company therefore scores 1. To score higher the company would need to provide further information about the recipients of its charitable contributions.
Based on public information, there is insufficient evidence that the company provides written guidance, to help Board members and employees understand and implement the company’s ethics and anti-corruption agenda. TI understands that employees have access to additional guidance materials; however, these materials are not publicly available and as such, have not been assessed.
Based on public information, there is evidence that the company has explicit anti-corruption modules, as part of its ethics and compliance training programme.
Based on public information, there is evidence that the company provides anti-corruption training to employees in all countries where it operates.
Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to Board members.
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 evidence that the company has a clear and formal process by which employees declare conflicts of interest. The Code of Business Ethics and Conduct contains a disclosure form for employees to complete and provide to their supervisor. The company therefore scores 1. To score higher the company would need to provide evidence that employees are instructed to report conflicts of interest to an independent department. It is unclear if in the Statement of Mission Essential’s Anti-Corruption Position the company informs employees to report conflicts of interest to the Legal Department, or that supervisors must submit received information to the Legal Department.
Based on public information, there is evidence that the company has an explicit commitment, to apply disciplinary procedures to employees and Board members, found to have violated the Code of Conduct.
Based on public information, there is evidence that the company has accessible, secure, channels, for employees to report concerns or instances of suspected corrupt activity. These cannels include the HR and Legal departments, the Ethics Officer and the Ethics Hotline, which is monitored by the Ethics Officer. The company therefore scores 1. To score higher the company would need to provide evidence that it has at least one channel that is externally operated and allows employees to report anonymously.
Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. Employees can report to the HR and Legal departments, the Ethics Officer or the Ethics Hotline, which is monitored by the Ethics Officer.
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, and that whistleblowers are treated supportively. Such formal mechanisms could include analysis of whistleblowing data, an employee survey or a procedure for following 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. These resources include the HR, Legal and Compliance departments, the Ethics Officer and the Ethics Hotline.
Based on public information, there is evidence that the company has a non-retaliation policy for bona fide reporting of corruption, and that disciplinary measures are applied to employees who breach this policy.
Based on public information, there is evidence that the company has published statements from the CEO and Chairman, supporting its ethics and anti-corruption agenda. These statements can be found in the Code of Business Ethics and Conduct and on the company’s website. The company therefore scores 1. To score higher the company would need to have published at least one more strong statement from the CEO and Chairman from the last two years, which promotes its ethics and anti-corruption agenda. Alternatively, the company would need to have published one statement from the CEO and Chairman from the last two years, which specifically supports the company’s strong stance against corruption.