By public info, this company is placed in Band A

Ownership

PUBLIC

Defence revenue, USD

22,047.60m (2013)

Defence revenue, %

93% (2013)

Country

US

Internal information

YES

Leadership 80%
1.
score
2

Based on public information, there is evidence that the company has published a statement from the CEO in the last two years, specifically supporting its strong stance against corruption.

COMMENTS -+
2.
score
2

Based on public information, there is evidence that the company’s CEO and Chairman, Thomas Kennedy, has demonstrated a strong, personal, external facing commitment to its ethics and anti-corruption agenda. Specifically, the CEO and Chairman is on the DII Steering Committee. TI also notes the company’s Director of Business Ethics & Compliance is the Deputy Chair of IFBEC.

COMMENTS -+
3.
score
0

Based on public information, there is no readily available evidence that the company’s CEO demonstrates a strong, internal-facing commitment to the company’s ethics and anti-corruption agenda. This commitment could include speaking at training events or chairing reviews of anti-corruption programmes.

COMMENTS -+
4.
score
2

Based on public information, there is evidence that the company publishes a statement of values representing high standards of ethical business conduct, including integrity and honesty. The company explains these values and why they are important to the organisation, while also mentioning trustworthiness, accountability and transparency.

COMMENTS -+
5.
score
2

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

COMMENTS -+
6.
score
2

Based on public information the company has appointed the Audit Committee and the Public Affairs Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Audit Committee’s responsibilities include reviewing adherence to the company’s Code of Business Conduct and Ethics, and periodically reviewing procedures for complaints on unethical conduct. The Public Affairs Committee’s responsibilities include reviewing ethics policies and practices.

COMMENTS -+
7.
score
2

Based on public information, there is evidence that the company has appointed Vice President Business Ethics and Compliance, Patricia J. Ellis, with responsibility for implementing its ethics and anti-corruption agenda.

COMMENTS -+
8.
score
2

Based on public information, there is evidence that the company’s Public Affairs Committee conducts a regular review of its ethics and anti-corruption agenda. This includes reviewing policies and practices in regard to offsets, political contributions, and foreign and domestic consultants and representatives. Evidence suggests that this review occurs at least annually, as the Committee meets quarterly.

COMMENTS -+
8a.
score
0

Based on public information, there is no readily available evidence of 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. The Public Affairs Committee conducts a regular review of the company’s ethics and anti-corruption agenda. However, the basis of this review is unclear, with no evidence suggesting a formal, clear, written plan is used.

COMMENTS -+
9.
score
2

Based on public information, there is evidence that the company has a formal process to review and update its policies and practices, in response to actual or alleged instances of corruption. The company states that the Ethics Office is responsible for conducting investigations of alleged violations of the Code of Conduct, with resolution measures including instituting improved internal controls.

COMMENTS -+
Risk management 86%
9a.
score
2

Based on public information, there is evidence that the company has an enterprise-wide risk management programme. The top risks and associated mitigation plans are followed by senior management. Specifically the Ethics Office works with the Anti-Corruption Sustainment team to assess the company’s internal controls in regard to corruption. The General Counsel at each business unit is also responsible for the anti-corruption risk assessment process, including mitigation plans.

COMMENTS -+
10.
score
2

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business dealings. The company conducts due diligence for all international parties, including JV parties, customers, sales representatives, and offset providers.

COMMENTS -+
11.
score
2

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting and reappointing its agents. Due diligence is updated prior to renewing international representative and consultant agreements, that are respectively limited to two and one years.

COMMENTS -+
12.
score
1

Based on public information, there is evidence that the company has contractual rights for the behaviour and control of agents, with respect to countering corruption. Representatives and consultants must comply with the company’s Code of Conduct and applicable anti-corruption laws. However, there is a lack of information regarding the monitoring and auditing of agents, as well as contractual rights to deal with the occurrence of violations. The company therefore scores 1. To score higher the company would need to provide evidence of such rights.

COMMENTS -+
13.
score
2

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, its stance on bribery and corruption and the consequences of breaches to this stance. All third parties must acknowledge that they understand and agree to comply with the company’s anti-corruption policies. International purchase orders contain warranties of compliance with applicable anti-corruption laws, and the company has the right to cancel the purchase order as a result of breaches of these warranties.

COMMENTS -+
13a.
score
2

Based on public information, there is evidence that the company explicitly addresses the corruption risks associated with offset contracting. The company has specific policies in regard to offset contracting, for example policy 109-RP, International Industrial Cooperation.

COMMENTS -+
13b.
score
1

Based on public information, there is evidence that the company conducts due diligence to minimise corruption risk when selecting its offset partners and brokers. However, it is unclear if offset providers are included in the policy that specifies that international representatives and consultants undergo due diligence when renewing their agreements. The company therefore scores 1. To score higher the company would need to provide evidence that due diligence is refreshed at least every 3 years and/or when there is a significant change in the business relationship.

COMMENTS -+
Policies & codes 96%
15.
score
2

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms, including facilitation payments, conflicts of interest and gifts and hospitality.

COMMENTS -+
16.
score
2

Based on public information, there is evidence that the company’s anti-corruption policy is explicitly one of zero tolerance.

COMMENTS -+
17.
score
2

Based on public information, there is evidence that the company’s anti-corruption and ethics policies are easily accessible to Board members, employees and third parties. The company’s Anti-Corruption Policy, summaries of key anti-corruption policies, and the Code of Conduct are accessible on its website, with the latter available in multiple languages.

COMMENTS -+
17a.
score
2

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily understandable and clear to Board members, employees and third parties. The Code of Conduct contains various scenarios to help illustrate the company’s ethics and anti-corruption policies. The Anti-Corruption Policy and related policies are written in accessible, comprehensible language without dense, legal terms.

COMMENTS -+
18.
score
2

Based on public information, there is evidence that the company’s Code of Conduct and Anti-Corruption Policy apply to all employees and Board members.

COMMENTS -+
20.
score
2

Based on public information, there is evidence that the company has a policy on potential conflicts of interest, which applies to both employees and Board members. The policy clearly defines a conflict of interest and contains examples of potential conflicts of interest.

COMMENTS -+
21.
score
2

Based on public information, there is 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. All employees must ensure that gifts and gratuities have a bona fide business purpose, are appropriate for the occasion and are in compliance with all applicable laws, policies, and regulations. With supervisory approval and where there is no conflict of interest, employees are able to accept gifts worth up to $100; gifts worth more than $100 must be approved by the Ethics Office. Employees involved in purchasing goods and services must not accept gifts from suppliers worth more than $20. The company states that specific dollar limits and approval procedures are given in the gifts and gratuities policy.

COMMENTS -+
22.
score
2

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, that ensures that such transactions are bona fide and not a subterfuge for bribery. All employees must ensure that gifts and gratuities have a bona fide business purpose, are appropriate for the occasion and are in compliance with all applicable laws, policies, and regulations. The company states that specific dollar limits and approval procedures are given in the gifts and gratuities policy.

COMMENTS -+
23.
score
2

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. If facilitation payments are made they are reported to the Office of the General Counsel and recorded in the company’s records.

COMMENTS -+
24.
score
2

Based on public information, there is evidence that the company regulates political contributions, in order to prevent undue influence or other corrupt intent. No contribution can be made to any state or local candidate, political committee or political party, without the approval of Raytheon's Political Expenditure Review Committee (PERC). The company discloses annual amounts for section 527 contributions and state and local contributions.

COMMENTS -+
25.
score
2

Based on public information, there is evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent. The company complies with all laws and regulations applicable to its federal lobbying activities, and issues periodic reports with state and local agencies, as required by relevant state and local laws.

COMMENTS -+
25a.
score
1

Based on public information, there is evidence that the company regulates charitable contributions, to ensure that they are not made to secure improper business advantage. However, it is not clear that the company discloses the recipients of such contributions. The company therefore scores 1. To score higher the company would need to provide evidence showing that recipients are publically declared.

COMMENTS -+
Training 80%
26.
score
2

Based on public information, there is evidence that the company provides written guidance to help Board members and employees understand and implement the company’s ethics and anti-corruption agenda. The Code of Conduct contains numerous scenarios that illustrate how policies may be applied. In particular, three awareness videos that explain key company policies are permanently available for employees.

COMMENTS -+
27.
score
2

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

COMMENTS -+
28.
score
2

Based on public information, there is evidence that the company provides anti-corruption training in all countries where the company operates. Every business unit must ensure that periodic core anti-corruption training is completed by all applicable employees, both inside and outside the USA.

COMMENTS -+
29.
score
0

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

COMMENTS -+
30.
score
2

Based on public information, there is evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. Business units conduct specific anti-corruption training for employees in areas such as finance, supply chain, contracts, and programme office.

COMMENTS -+
Personnel 79%
31.
score
2

Based on public information, there is evidence that the company has a clear and formal process by which employees declare conflicts of interest. Employees must disclose conflicts of interest to the Ethics Office or the Office of the General Counsel.

COMMENTS -+
32.
score
1

Based on public information, there is evidence that the company may apply disciplinary procedures to those found to have engaged in corrupt activities. As the company’s anti-corruption policies apply to Board members, TI assumes that disciplinary procedures also apply. The company therefore scores 1. To score higher the company would need to provide evidence of an explicit commitment to apply disciplinary procedures, to those found to have engaged in corrupt activities.

COMMENTS -+
33.
score
1

Based on public information, there is evidence that the company has multiple, well-publicised, secure channels, for employees to report concerns or instances of suspected corrupt activity. These channels include the Ethics Office, the Audit Committee and the Office of Business Ethics and Compliance. In particular, employees may report to the Ethics Office anonymously. The company therefore scores 1. To score higher the company would need to provide evidence that employees are able to report using an independent channel.

COMMENTS -+
33a.
score
2

Based on public information, there is evidence that across geographies, all employees have access to the Ethics Office and the Office of Business Ethics and Compliance.

COMMENTS -+
33b.
score
2

Based on public information, there is evidence that the company has formal and comprehensive mechanisms, to ensure that whistleblowing is not deterred and that whistleblowers are treated supportively. The company monitors whistleblowing channel usage statistics, with 280 investigations taking place in 2013. The General Counsel also maintains a log of all complaints, their investigations and their resolutions, with a periodic summary report issued to the Audit Committee.

COMMENTS -+
34.
score
2

Based on public information, there is evidence that employees have access to well-publicised resources, where help and advice can be sought on corruption-related issues. These resources include the Ethics Office and the Office of Business Ethics and Compliance.

COMMENTS -+
35.
score
1

Based on public information, there is evidence that the company has a commitment to non-retaliation, for bona fide reporting of corruption. The company therefore scores 1. To score higher the company would need to make a specific statement that disciplinary measures are applied to those breaching the non-retaliation policy.

COMMENTS -+
Band & analysis based on internal and public information: band A
Leadership 85%
Risk management 100%
Policies & codes 96%
Training 90%
Personnel 79%