QinetiQ Group plc

Based on public information, there is evidence that the CEO has issued two strong statements in the last two years that support the ethics agenda of the company. The Chairman has issued several statements that discuss the importance of corporate responsibility.

Based on public information, there is no readily available evidence that the company’s CEO or Chairman demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is some 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. The CEO sits on the Risk & CSR Committee, which has overall corporate responsibility for the company’s business ethics programme. The company therefore scores 1.

Based on public information, there is evidence that the company has a statement of values representing high standards of ethical business conduct, which includes transparency, honesty, trust and integrity. The company is clear about what these values mean to the organisation and illustrates that they are translated into company policies and codes.

Based on public information, there is evidence that the company belongs to the ADS Business Ethics Forum and is a signatory to ASD Common Industry Standards.

Based on public information, there is evidence that the company’s Risk & CSR Committee has overall corporate responsibility for the company’s business ethics programme. The Risk & CSR Committee meets regularly and receives reports on the company’s busness ethics, so as to monitor the application of the company’s business ethics principles.

Based on public information, there is evidence that the company has appointed two Chief Ethics Officers with responsibility for implementing the company’s ethics agenda. The Chief Ethics Officers report directly to the Board of Directors. However, while the Ethics Officer for North America is named, the Group Ethics officer is not. The company therefore scores 1.

Based on public information, there is evidence that there is regular monitoring and review of the performance of the company’s ethics agenda. According to the Annual Reports, performance of the company with respect to anti-corruption and ethics is reviewed externally and benchmarked against others in the sector. The Group Risk & CSR Committee meets regularly and receives reports on the company’s business ethics, so as to monitor the application of the company’s business ethics principles. The Compliance Implementation Director and Compliance Audit Director are responsible for implementing the Compliance System and undertaking periodic audits respectively to provide assurance that the company’s obligations are being met.

Based on public information, there is no readily available evidence of a formal written plan that guides the review of the ethics agenda. The available information provides a basis for concluding that reviews do occur, but does not provide enough detail to assess whether a formal plan exists.

Based on public information, there is no readily available evidence that the company has have 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 evidence that the company has a risk assessment procedure implemented enterprise-wide, which includes anti-bribery, ethics and regulatory elements. The Risk & CSR committee oversees the risk management system, monitors non-financial risk exposure, including ethics, and monitors adherence to the general compliance system. Managers are responsible for the identification, evaluation and mitigation of significant risks in their areas of business. The Governance Committee is the executive review body for risk management. An example of the risk assessment procedure is in regard to undertaking business in overseas jurisdictions. A country risk table has been developed that categorises countries using a traffic-light code, which is compiled, among other things, on measures in respect to bribery and corruption. The Board’s approval is required for certain types of contract proposals in ‘amber’ and ‘red’ jurisdictions and quarterly reports must be sent to the Board for signed overseas contract in excess of £10 million.

Based on public information, there is evidence that managers are responsible for managing significant risks in their business areas, although anti-corruption risk is not specifically mentioned. There is evidence that when the company is proposing an M&A transaction, risk analysis is required during the due diligence phase. However, there is only implied evidence that these processes cover anti-corruption. The company therefore scores 1.

Based on public information, there is evidence that the company conducts due diligence when selecting agents, using a range of third parties such as TRACE. However, there is no public evidence that the company refreshes the due diligence every three years or when there is a significant change in the business relationship. The company therefore scores 1

Based on public information, there is limited readily available evidence that the company has processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption. The 2014 Annual Report states that the company has a process for undertaking due diligence, monitoring and audit of its use of commercial intermediaries, and the Code of Conduct details that the company expects appropriate standards from their business partners. However, there is no evidence of contractual rights in place. The company therefore scores 1.

Based on public information, there is some evidence that the company makes clear to contractors, sub-contractors, and suppliers, its stance on bribery and corruption, via sharing of the Code of Conduct. However, there is no public evidence of contractual rights to apply sanctions in the event a supplier breaches a contract with the company. The company therefore scores 1.

The company has informed TI that it does not currently engage in offset contracting.

The company has informed TI that it does not currently engage in offset contracting.

Based on public information, there is evidence that the company’s anti-corruption policy prohibits corruption in its various forms. The Code of Conduct prohibits the giving or receiving of bribes and identifies forms of corruption such as conflicts of interest and gift and hospitality exchange.

Based on public information, there is evidence that the company has an explicit zero tolerance policy of corruption and bribery.

Based on public information, there is evidence that the company’s Code of Conduct is easily accessible to Board members, employees and third parties. It is available on the company website and all employees, directors, officers of the company and its subsidiaries, operating groups and consultants, must read the Code of Conduct. Furthermore, it is provided to all third parties working with or on behalf of the Company. However, TI notes the Code of Conduct is only available in English and as such, may be less accessible for those from non-English speaking parts of the world. The company therefore scores 1.

Based on public information, there is evidence that the company’s Code of Conduct is written in accessible, comprehensible language. The Code is well structured and contains numerous scenarios, for example in the Conflicts of Interest section.

Based on public information, there is evidence that the policy applies to all employees and Board directors.

Based on public information, there is evidence that the company has a policy on conflicts of interest. It is written with clear wording and a definition and examples are provided.

Based on public information, there is evidence that the company has a policy that regulates the giving and receipt of gifts. However, the rules of the policy are unclear, as employees are instructed to use their own judgement when determining if a gift is appropriate, and the policy only raises the possibility of a discussion with a supervisor for providing a gift, not receiving. Moreover, while recording of the giving and receiving of gifts is referred to as ‘good practice’, it is not required. The company therefore scores 1. To score higher, the company must indicate that there are either set upper limits for gift exchange or a specific threshold necessary for senior authorisation.

Based on public information, there is evidence that the company has a policy that regulates the giving and receipt of hospitality or entertainment. However, the rules of the policy are unclear, as employees are instructed to use their own judgement when determining if hospitality is appropriate, and the policy only raises the possibility of a discussion with a supervisor for providing hospitality, not receiving. Moreover, while recording of the giving and receiving of hospitality is referred to as ‘good practice’, it is not required. The company therefore scores 1. To score higher, the company must indicate that there are either set upper limits for hospitality exchange or a specific threshold necessary for senior authorisation.

Based on public information, there is evidence that the company has a policy that prohibits facilitation payments. A definition explains what facilitation payments are and how applicable laws may consider it a form of bribery. However, TI notes that there appears to be no guidance or supplementary information on how the policy is to be implemented in practice. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company prohibits or regulates political contributions in order to prevent corrupt intent, nor that the company records and publicly discloses its political contributions. The Code of Conduct states that political donations may in some cases be construed as bribes, but leaves decisions on how to proceed to employees. Evidence suggests that the company makes political contributions and abides by all relevant laws.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities and discloses the issues on which it lobbies.

Based on public information, there is some evidence that the company regulates charitable contributions, in order to prevent undue influence or other corrupt intent. The company supports several corporate charities but it is not clear that all recipients are publicly declared. The Code of Conduct states that charitable donations may in some cases be construed as bribes, but leaves decisions on how to proceed to employees. The company therefore scores 1.

Based on public information, there is limited evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. The Code of Conduct contains numerous examples in the conflicts of interest section, but is not very detailed in other areas. TI found no other readily available evidence of written guidance. The company therefore scores 1.

Based on public information, there is evidence that the company’s annual business ethics training covers a range of issues including anti-bribery and anti-corruption.

Based on public information, there is evidence that the company’s annual business ethics training is mandatory for all employees across the Group. This suggests that all company sites are provided with this training.

Based on public information, there is evidence that the company provides anti-corruption training to members of the Board on an annual basis.

Based on public information, there is evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions, for example those who carry out overseas business.

Based on public information, there is evidence that the company has a clear and formal process by which employees primarily declare conflicts of interest to their regional Ethics Officer. The contact details of Ethics Officers are provided in the Code of Conduct.

Based on public information, there is evidence that the company is commited to apply disciplinary procedures to all who violate the Code of Conduct. The company also uses strong phrasing (‘will’) in its statements of intent.

Based on public information, there is evidence of multiple, well-publicised channels that are accessible and secure, to report instances of suspected corrupt activity. Employees are able to report a concern to their manager, the company Secretary, the company Internal Audit Manager, the company General Counsel or company Ethics Officers. A whistleblowing line, independently run and available 24/7 around the world, and an online reporting tool allow anonymous reporting.

Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. For example, employees can report to company Ethics Officers, and utilise the whistleblowing line or online reporting tool. TI notes that there is no evidence of the channels being available in languages other than English.

Based on public information, there is some 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. TI notes that the audit committee reviews the effectiveness of the process for reporting and investigating whistleblowing allegations on an annual basis. The company therefore scores 1. To score higher, the company would have to provide further evidence of mechanisms, such as detailed anaylsis of whistleblowing data or independent employee surveys.

Based on public information, there is evidence the company has well-publicised resources available to all employees where advice can be sought on corruption-related issues. Employees can raise ethics concerns with an ethics officer, the company’s General Counsel or the whistleblowing line, by phone or online reporting tool.

Based on public information, there is evidence that there is a commitment to non-retaliation for bona fide reporting of corruption, including disciplinary measures for employees who retaliate against those who report misconduct.