By public info, this company is placed in Band F

Ownership

PRIVATE

Defence revenue, USD

Unknown

Defence revenue, %

Unknown

Country

POLAND

Internal information

NO

Leadership 0%
1.
score
0

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company.

COMMENTS -+
2.
score
0

Based on public information, there is no readily available evidence that the company’s 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. TI notes that Marcin Idzik, the current Chair of the Board, held the post of Plenipotentiary for Anti-Corruption Procedures at the Ministry of National Defence in 2008-9. When Deputy Minister of Defence, Idzik was reported to have had an excellent relationship with the Central Anti-Corruption Bureau (CBA), and was invited to audit possible instances of corruption within the defence sector in 2011.

COMMENTS -+
3.
score
0

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.

COMMENTS -+
4.
score
0

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. The values section of the PHO website focuses on efficiency, prioritising client needs and co-operation within and outside the company. TI notes that PHO comprises 15 companies. One of the constituent companies—PCO SA—states that it does have a Code of Ethics which binds it to an ethical way of doing business. However, this Code of Conduct is not published on the company’s website.

COMMENTS -+
5.
score
0

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption. TI notes that one of its subsidiary companies, Cenrex, is a member of Trace International.

COMMENTS -+
6.
score
0

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.

COMMENTS -+
7.
score
0

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.

COMMENTS -+
8.
score
0

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.

COMMENTS -+
8a.
score
0

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.

COMMENTS -+
9.
score
0

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.

COMMENTS -+
Risk management 0%
9a.
score
0

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide.

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
0

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.

COMMENTS -+
12.
score
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.

COMMENTS -+
13.
score
0

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.

COMMENTS -+
13a.
score
0

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

COMMENTS -+
13b.
score
0

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.

COMMENTS -+
Policies & codes 0%
15.
score
0

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

COMMENTS -+
16.
score
0

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

COMMENTS -+
17.
score
0

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is easily accessible to Board members, employees and contracted staff.

COMMENTS -+
17a.
score
0

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

COMMENTS -+
18.
score
0

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

COMMENTS -+
20.
score
0

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

COMMENTS -+
21.
score
0

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.

COMMENTS -+
22.
score
0

Based on public information, there is no readily available 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.

COMMENTS -+
23.
score
0

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

COMMENTS -+
24.
score
0

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.

COMMENTS -+
25.
score
0

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.

COMMENTS -+
25a.
score
0

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. TI notes that the company discloses its charitable contributions, but there is no evidence of a more general policy on how these contributions are approved or refused.

COMMENTS -+
Training 0%
26.
score
0

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.

COMMENTS -+
27.
score
0

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

COMMENTS -+
28.
score
0

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. TI notes that there is no evidence that the company has sites outside of Poland.

COMMENTS -+
29.
score
0

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

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 0%
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.

COMMENTS -+
32.
score
0

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.

COMMENTS -+
33.
score
0

Based on public information, there is no readily available 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 (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity.

COMMENTS -+
33a.
score
0

Based on public information, there is no readily available evidence that the company’s whistleblowing channels are available to all employees in all geographies.

COMMENTS -+
33b.
score
0

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.

COMMENTS -+
34.
score
0

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

COMMENTS -+
35.
score
0

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

COMMENTS -+