Nexter Group

Based on public information, there is no readily available evidence that the company publishes a statement from the CEO supporting the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s CEO demonstrates 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 CEO demonstrates a strong personal, internal-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 has a statement of values representing high standards of ethical business conduct. The five values promoted by the company are responsibility, customer focus, innovation, performance and people development.

Based on public information, there is readily available evidence that the company is a signatory to the ASD Common Industry Standards.

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. TI notes that it is unclear if the Audit Committee has such responsibility as part of its responsibility for internal compliance.

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 of a formal, 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. The company has a risk management system but there is no evidence that corruption is specified as a risk to be identified and mitigated.

Based on public information, there is no readly available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. The company has a risk management system but there is no evidence that corruption is specified as a risk to be identified and mitigated in relation to proposed business decisions.

Based on public information, there is no readily available evidence that the company conducts due diligence 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 does note the references made to developing partnerships with 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 when selecting its offset partners and brokers.

Based on public information, there is no readily available evidence that the company has an anti-corruption policy.

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

Based on public information, there is no readily available 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 no readily available evidence that the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy explicitly applies to all employees and members of the Board.

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

Based on public information, there is no readily available 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.

Based on public information, there is no readily available 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.

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 or regulates political contributions, in order to prevent undue influence or other corrupt intent. Nor does the company record and publicly disclose all political contributions.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, nor does it disclose the issues on which the company lobbies.

Based on public information, there is no readily available evidence that the company regulates charitable 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 the company has a training programme that explicitly covers anti-corruption.

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 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 acitivites.

Based on public information, there is no readily available evidence of multiple, well-publicised channels that are accessible and guarantee confidentiality or anonymity, to report concerns or instances of suspected corrupt activity.

Based on public information, there is no readily available evidence of whistleblowing channels.

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.

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

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