- A
- B
- C
- D
- E
- F
Ownership
PUBLIC
Defence revenue, USD
861m (2013)
Defence revenue, %
33% (2013)
Country
USA
Internal information
NO
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. TI notes that the company describes integrity as a value, but does not explain any of the other values sought by this question.
Based on public information, there is no readily available evidence that the company is a member of 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 limited evidence that the company has appointed the Audit Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The company therefore scores 1. To score higher the company would need to provide evidence that outlines in greater detail the responsibilities of the Audit Committee.
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, and no 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 evidence that the company makes clear to suppliers, through policy and contractual terms, its stance on bribery and corruption. However, the company only appears to make the consequences of breaches to its gratuities policy clear. The company therefore scores 1.
Based on public information, there is no readily available evidence that the company engages in offset contracting.
Based on public information, there is no readily available evidence that the company engages in offset contracting.
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 company’s anti-corruption policy is 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.
Based on public information, there is evidence that the company has an anti-corruption policy which applies to all employees. However, it is unclear whether this applies to members of the Board as well. The company therefore scores 1.
Based on public information, there is evidence that the company has a policy on potential conflicts of interest, which applies to both employees and Board members. However, conflicts of interest are not clearly defined and limited examples are provided. The company therefore scores 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. However, it is not clear that the company sets upper limits for gift exchange or requires senior authorisation. The company therefore scores 1.
Based on public information, there is evidence of a statement on the giving and receipt of hospitality, that ensures that such transactions are bona fide and not a subterfuge for bribery. However, it is not clear that the company sets upper limits for hospitality exchange or requires senior authorisation. 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 no readily available evidence that the company prohibits political contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent. TI notes that employees are prohibited from promoting political parties as a representative of the company, but there is no evidence that the company addresses the issue of company political contributions.
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 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 no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda.
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. TI notes that the company instructs employees to bring any potential conflicts of interest to the attention of management. However, evidence does not suggest that this is done in writing.
Based on public information, there is no readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.
Based on public information, there is evidence that the company has multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee, to report concerns or instances of suspected corrupt activity. In particular, the company has a confidential Ethics Hotline. However, there is no evidence that the company provides employees with access to an external or independent reporting channel. 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 evidence that the company has mechanisms to insure that whistleblowers are treated supportively. However, there is no evidence that mechanisms are in place to ensure whistleblowing by employees is not deterred, such as by the detailed analysis of whistleblowing data or the implementation of independent employee surveys. The company therefore scores 1.
Based on public information, there is some evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. Specifically, employees are directed to speak to their managers, supervisors or the HR department. However, there is no evidence that these individuals have been trained for this additional role. The company therefore scores 1.
Based on public information, there is evidence that there is a commitment to non-retaliation for bona fide reporting of corruption. It is also clear that those violating this commitment will be subject to disciplinary proceedings.
Based on public information, there is evidence that the company publishes a statement from the Chief Executive Officer and Chair of the Board supporting the ethics and anti-corruption agenda of the company. 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.