Rockwell Collins, Inc.

Based on public information, there is evidence that the company publishes statements from the CEO and President supporting the ethics agenda of the company. The company therefore scores 1. To score higher the company would need to provide evidence of at least one other statement from the last two years supporting the ethics agenda of the company, or one statement specifically supporting the company’s strong stance against corruption.

Based on public information, there is evidence that the CEO and President demonstrate a personal, external facing commitment to the company’s ethics agenda. In addition, there is evidence of this engagement being delegated to others in the organisation.

Based on public information, there is some evidence to indicate that the company’s Chief Executive Officer demonstrates a personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. However, these are largely written communications, which do not allow for the highest score to be awarded. The company therefore scores 1.

Based on public information, there is evidence that the company publishes a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability. The company also demonstrates how these values can be translated into company policy.

Based on public information, there is evidence that the company is a member of the Defense Industry Initiative (DII).

Based on public information, there is evidence that the company has the Business Standards Compliance Committee with overall corporate responsibility for its ethics and anti-corruption agenda. There are clear terms of reference detailing what this responsibility entails.

Based on public information, there is evidence that the company has appointed Senior Vice President, General Counsel and Secretary, Robert Perna, with responsibility for implementing the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence that there is periodic Board level monitoring and review of some aspects of the company’s ethics and anti-corruption agenda. TI notes that the scope for the review appears to be more monitoring on a continuous basis than a major review. The company therefore scores 1.

Based on public information, there is no readily available evidence of a formal, clear, written plan that guides Board or senior management review, or evidence that improvement plans are put in place when issues are identified. TI notes that the Audit Committee Charter does not explicitly address the ethics and anti-corruption agenda, but rather focuses on financial audit and legal compliance.

Based on public information, there is some evidence that the company has a formal process for review and update of company policies in the event of an actual or alleged instance of corruption. TI notes the Ombudsman Investigation Process particularly. However, it is not clear that policies and practices would always be reviewed and updated in the event of an actual or alleged instance of corruption. The company therefore scores 1.

Based on public information, there is evidence that the company has a formal risk assessment procedure and it is understood that anti-corruption forms part of this risk assessment. However, there is limited evidence provided about this process and no readily available evidence of mitigation plans with clear ownership and timelines. The company therefore scores 1.

Based on public information, there is some evidence that the company has a formal risk assessment procedure for assessing proposed business decisions, including third party risk areas. However, it is unclear how this procedure should be applied or to precisely which business decisions it applies. The company therefore scores 1.

Based on public information, there is evidence that the company has formal due diligence procedures for agents. However, there is no readily available evidence that the company refreshes the due diligence at least every 3 years and / or when there is a significant change in the business relationship. The company therefore scores 1.

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 evidence that the company makes clear its ethics and anti-corruption policies to suppliers, contractors and sub-contractors. However, only basic information is provided publicly and there is no readily available evidence of contractual rights with regard to bribery and anti-corruption. TI notes that further information is likely provided on the Supplier Portal. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company explicitly addresses offset contracting risk.

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.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms, including the giving and receiving of bribes.

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

Based on public information, there is evidence that the company’s anti-corruption policy is easily available for all employees, contracted staff, and affiliated organisations. TI notes that the company’s Standards of Business Conduct are available in several languages.

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

Based on public information, there is evidence that the company’s policy 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, which includes a definition and several examples.

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. This policy sets upper limits for gift exchange.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. This policy sets upper limits for hospitality exchange.

Based on public information, there is evidence that the company prohibits facilitation payments to government or party officials. If employees are requested to make such a payment, they must notify the Office of the General Counsel immediately.

Based on public information, there is evidence that the company regulates political contributions to prevent corruption or other undue influence.

Based on public information, there is evidence of a policy that clearly regulates lobbying activity to prevent undue influence or other corrupt intent, and guidelines on its application are clear. The company discloses its federal lobbying activities.

Based on public information, there is some evidence that the company regulates such contributions to prevent corruption or other undue influence. However, the procedure for donations is not clear and there is no readily available evidence that donations are publicly declared. The company therefore scores 1.

Based on public information, there is evidence that employees have access to some materials such as the Standards of Business Conduct on the website, which includes some examples. The company also provides training and communications programmes which aid employees’ understanding of ethical and anti-corruption policies.

Based on public information, there is evidence that the company has an explicit anti-corruption module as part of its ethics and compliance training programme.

Based on public information, there is evidence that 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 targeted anti-corruption training to members of the Board, but it is not clear that 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 to employees in high risk positions.

Based on public information, there is evidence that the company has a clear and formal process for employees to declare conflicts of interest, but this is to leadership. There is some indication that independent departments – Human Resources and the Ombudsman – are involved, but there is insufficient public information to underpin a higher score. The company therefore scores 1.

Based on public information, the company has an explicit commitment to apply disciplinary procedures to employees who have violated its anti-corruption policy. The company Standards of Business conduct also apply to Members of the Board of Directors.

Based on public information, the company has multiple internal channels to report instances of suspected corrupt activity that are well publicised and allow for anonymity. However, the company does not have a portal that would allow for two-way communication whilst preserving anonymity, and lacks a channel operated independently (the Ombudsman, while an independent department, is part of the company). The company therefore scores 1.

Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel.

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, or that whistleblowers are treated supportively.

Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. This includes trained managers, helplines, and an internal ombudsman.

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