Precision Castparts Corp.

Based on public information, there is insufficient 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. TI notes that there is an introduction to the company’s Code of Conduct by the CEO; however, the Code of Conduct dates from 2008 and TI is looking for statements made within the last two years.

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 insufficient evidence that the company publishes a statement of values or principles representing high standards of business conduct within the Code of Conduct. The only value explicitly mentioned is integrity, although reference is made to the importance of maintaining high ‘ethical standards.’ However, the statements made about company culture do not go into sufficient depth by explaining what is meant by such standards and why they matter to the organisation.

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.

Based on public information, there is evidence that the company has appointed the Audit Committee to oversee the company’s compliance with legal and regulatory requirements and its maintenance of ethical standards and adherence to the Code of Conduct. This committee has clear terms of reference detailing what this responsibility entails within its Charter.

Based on public information, there is evidence that the company has appointed the Chief Compliance Officer with responsibility for implementing the company’s ethics and anti-corruption agenda. The individual is named as Emi A. Donis.

Based on public information, there is some evidence that there is there is a review by the Audit Committee, but the scope for the review is assessed to be more continuous monitoring than a major periodic review, and there is no mention of how often it occurs. The company therefore scores 1.

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.

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 some evidence that the company has a formal risk assessment procedure; however, it is not clear that this includes an anti-corruption element.

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. TI notes the recognition in the company’s annual report of the risks associated with acquisitions; however, insufficient detail about this process is assessed to be available.

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 some evidence that the company makes clear to suppliers, through policy terms, its stance on bribery and corruption. However, it is not clear that this is outlined in contractual terms and that the consequences of breaches to this stance are also made 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. The company has a policy that prohibits the giving and receiving of bribes, and is explicit on the various forms corruption can take.

Based on public information, there is evidence of a zero-tolerance policy towards violations of the Code of Conduct, and zero tolerance of bribery is mentioned specifically under the ‘Improper Payments’ section of the company’s Code of Conduct.

Based on public information, there is evidence that the company’s Code of Conduct is accessible to Board members, employees and third parties. The Code is available online in English, but evidence suggests that the company operates in numerous locations worldwide. The company therefore scores 1.

Based on public information, there is evidence that the company’s policy is written in accessible, comprehensible language.

Based on public information, there is evidence that the company has an anti-corruption policy that applies to all employees and Board members.

Based on public information, there is evidence that the company has a policy on and examples of potential conflicts of interest.

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, there is no evidence of clear upper limits being set or of a threshold for senior authorisation. Employees are requested to seek advice if they are unsure of what is ‘reasonable and customary’. The company therefore scores 1.

Based on public information, there is evidence of a statement on the giving and receipt of hospitality (entertainment) that ensures that such transactions are bona fide and not a subterfuge for bribery. However, there is no evidence of clear upper limits being set or of a threshold for senior authorisation. Employees are requested to seek advice if they are unsure of what is ‘reasonable and customary’. The company therefore scores 1.

Based on public information, there is no readily available evidence of a policy explicitly prohibiting facilitation payments. TI notes that such payments are not allowed unless prior written approval is obtained, which suggests that there might be occasions when these payments are allowed. In addition, the company provides no guidance or supplementary information publicly on how the policy is to be implemented in practice.

Based on public information, there is evidence that the company generally prohibits political contributions, and regulates such contributions in order to prevent undue influence or other corrupt intent. However, it is not clear that recipients are publicly declared. The company therefore scores 1.

Based on public information, there is insufficient evidence that the company has a policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent.

Based on public information, there is evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent. However, it is not clear that recipients are publicly declared. The company therefore scores 1.

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 evidence that the company provides training on compliance and the Code of Conduct to members of the Board, but it is not clear whether they are re-trained at least every 3 years. The company therefore scores 1.

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 for employees to declare conflicts of interest, which involves conflicts being reported to an independent department.

Based on public information, there is 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. The Code of Conduct applies to all employees and the Board of Directors and TI notes that employee violations of the code are subject to disciplinary action.

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.

Based on public information, there is evidence that the company has whistleblowing channels available to employees in all geographies, since the telephone number is specified as different for international locations and there is a service available online.

Based on public information, there is evidence of some efforts to ensure whistleblowing is encouraged; however, there is no readily available evidence of formal mechanisms designed to ensure that whistleblowing is not deterred, such as detailed analysis of whistleblowing data or independent employee surveys.

Based on public information, there is evidence that employees have access to resources but these resources are assessed to be limited in nature. For example, a policy exists of employees taking the initiative to talk to their supervisor or manager when issues arise. However, there is no evidence that he or she is trained for the advisory job. The company therefore scores 1.

Based on public information, there is evidence that the company has a clear, legally enforceable, non-retaliation policy for bona fide reporting of corruption, and there is evidence that disciplinary measures are applied to employees who breach this policy.