Rafael Advanced Defense Systems Ltd.

Based on public information, there is evidence that the company publishes statements from the Chief Executive Officer supporting the ethics and anti-corruption agenda of the company. A statement from the CEO published on the company’s website clearly displays the company’s commitment to ethical business practices at all levels. In his introductions to the Compliance Programme and company policies section of the company website, the CEO again shows that ethics, compliance and anti-corruption policy are high on the company’s agenda, a message reiterated in the 2013 Corporate Social Responsibility Report.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. This assessment is based upon a search of the company website and wider internet. TI is looking for evidence of a strong personal external facing commitment to the ethics and anti-corruption agenda. This could include public speeches and interviews, or active involvement in industry anti-corruption initiatives.

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.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability. The statement of values appear in various documents and is clearly translated into company policies and codes.

Based on public information, there is evidence that the company is a member of IFBEC.

Based on public information, there is evidence that the company appointed the Finance Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Internal Audit Division in cooperation with the Finance Committee and the Board of Directors conducts regular internal audits of the anti-corruption policy.

Based on public information, there is 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, and who has a direct reporting line to the Board. This is Mr. Rami Nossen, Vice President and Compliance Officer.

Based on public information, there is evidence of annual monitoring and review of the performance of the company’s entire ethics and anti-corruption agenda by the Compliance Officer. The Board reviews the findings of the Compliance Officer.

Based on public information, there is evidence of an implementation plan in place for the company’s ethics and anti-corruption agenda and that this is reviewed on a regular basis. Although the formality of this process is clear, there is limited evidence of improvement plans being implemented when issues are identified. The company therefore scores 1.

Based on public information, there is evidence that the company has a formal process for review and update of its policies in response to actual or alleged instances of corruption.

Based on public information, there is some evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. However, it is not clear who is responsible for addressing identified risks when they appear. The company therefore scores 1.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure. However, it is not clear that this is applied at the level of operational business decisions, noting that the risk assessment is carried out by the Compliance Officer rather than business managers.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents. This due diligence is refreshed at least every three years.

Based on public information, there is 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 business partners and suppliers through policy its stance on bribery and corruption. However, there is no further evidence of contractual terms and the consequences of breaches to this stance. The company therefore scores 1.

Based on public information, there is some evidence that the company explicitly address the corruption risks associated with offset contracting. However, this is not a separate section of the Policy or Code, and is addressed at a general level through the Due Diligence process on Business Partners through the identification of Red Flags. The company therefore scores 1.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers. This is refreshed at least every three years.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. The company publishes both an Anti Corruption Policy and an Ethical Code.

Based on public information, there is evidence of an explicit statement of zero tolerance to violations of company policy. However, there is no readily available evidence of an explicit zero tolerance policy statement of corruption or bribery specifically. The company therefore scores 1.

Based on public information, there is evidence that the company's anti-corruption policy is easily accessible. It is openly available on the company website in English and Hebrew.

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 anti-corruption policy explicitly applies to all employees and members of the Board.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest that applies to employees. However, the process relating to Board members is not explicitly mentioned. 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. Although this does not publicly state upper limits, the company has a Gifts Committee and thresholds for authorisation. The Anti Corruption Policy focuses on foreign officials and refers to internal procedures, while the Ethical Code is more broad.

Based on public information, there is evidence that the company’s anti-corruption policy includes a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery. Although it does not publicly state upper limits, the company provides significant detail and evidence of authorisation. However, TI notes that the Anti Corruption Policy focuses on providing hospitality to foreign officials and it is not clear that the provision of gifts to other individuals is similarly regulated. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy that prohibits facilitation payments though there is no guidance/supplementary information on its implementation and the evidence provided is simply that the company abides by Israeli Penal Law. The company therefore scores 1.

Based on public information, there is evidence that the company prohibits political contributions.

Based on public information, there is some evidence that the company regulates lobbying activities. Specifically, relations with lobbyists are subject to anti-corruption due diligence. However, there is no further information outlining the company’s policy on lobbying and no evidence that it discloses the issues on which it lobbies. The company therefore scores 1.

Based on public information, there is evidence that the company prohibits charitable contributions.

Based on public information, there is evidence that the company provides written guidance in the form of an Ethics Guide to help employees understand and implement the firm’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the company has a training programme that explicitly covers anti-corruption.

Based on public information, it is unclear whether anti-corruption training is provided in all countries where the company operates or has company sites. The company targets training at specific functions. The Compliance Officer determines which employees should receive anti-corruption training and places them on a Positions List. Although it is not clear that all employees are included on the Positions List, TI assesses that this list covers employees in the principal countries where the company operates. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board. The company targets training at specific functions, but directors and Board members are not specifically mentioned.

Based on public information, there is some evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. However, it is not clear that this is targeted at all high risk positions. The company therefore scores 1.

Based on public information, there is some evidence that the company has a clear process by which employees declare conflicts of interest. TI notes that prospective employees are requested to complete a declaration form upon applying for a role with the company. However, once an employee of the company, if an employee needs to declare additional interests they are only required to discuss the matter with their manager, and the degree of formality of this latter process is not clear. The company therefore scores 1.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to employees found to have engaged in corrupt activities. Whilst Board members and directors are not stated as such, the code itself explicitly applies to them as well as employees.

Based on public information, there is evidence that the company has channels to report concerns or instances of suspected corrupt activity. They are identified in the Ethical Code and the Anti-Corruption Policy, but they seem to be limited to talking directly to HR, an ethics trustee or the legal adviser/General Counsel. There is no readily available evidence of a whistleblowing channel that is externally operated. The company therefore scores 1.

Based on public information, there is evidence that whistleblowing channels are available to all employees in all geographies. Employees are encouraged to contact HR, an ethics trustee, the VP Human Resources and Organisation, or the legal adviser.

Based on public information, there is some evidence that the company encourages whistleblowing. However, it is not clear that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, such as ways to follow up with whistleblowers and monitor their experience, analysis of whistleblowing data or employee surveys. The company therefore scores 0.

Based on public information, there is evidence that the company has made ethical trustees available to all employees where help and advice can be sought on corruption-related issues.

Based on public information, there is evidence of a commitment to non-retaliation for bona fide reporting of corruption and the company commits to disciplinary action up to and including termination of employment for acts of retaliation.