RUAG Holding Ltd

Based on public information, there is no readily available 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. A statement in the Code of Conduct is a weak statement that makes no mention of anti-corruption, and is signed by the Executive Board, rather than the CEO.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or 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 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 bussines conduct, including trust, integrity, openness and transparency. These values are briefly referenced on the website and in the Code of Conduct. However, these values do not feature on the ‘Our Values’ webpage.

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 no readily available evidence that the company has appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda.

Based on public information, there is limited 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. The General Counsel and Head of Legal, Thomas Kopp, advises the company in all legal and complaince matters. However, it is unclear if this role includes the responsibility for overall implementation of the company’s ethics and anti-corruption agenda. The company therefore scores 1.

Based on public information, there is no readily available evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. TI notes that there is some evidence that the company regularly reviews the principles in the Code of Conduct and carries out monitoring in the form of staff surveys. However, it is not clear whether this takes the form of a major Board-level or external review.

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, or evidence of improvement plans being implemented when issues are identified.

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 no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. TI notes that despite the company having a general risk assessment procedure, it is unclear whether assessing corruption risks is a fundamental part of the process.

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, with clear requirements on the circumstances under which such a procedure should be applied.

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 no readily available evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance. Although the Code of Conduct states that suppliers are carefully and objectively chosen according to objective criteria, it is unclear if the company’s stance on bribery and corruption are passed on as part of this process.

Based on public information, there is no readily available evidence that the company addresses the corrruption risks associated with offset contracting.

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 all forms of corruption in all company operations, including the giving and receiving bribes.

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

Based on public information, there is evidence that the company has an anti-corruption policy easily accessible to Board members, employees and third parties. The Code of Conduct, available in English and German on the company website, clearly states that all staff members are given a copy at the start of their employment.

Based on public information, there is evidence that the company’s anti-corruption policy is 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. However, evidence does not suggest that the anti-corruption policy also applies to Board members. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. It declares all employees must avoid conflicts of interest and those that are unavoidable must be made transparent. The company therefore scores 1. To score higher the company would need to provide evidence that it clearly defines a conflict of interest and provides examples.

Based on public information, there is evidence of a company policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. However, it is extremely minimal and provides very little guidance for employees. The company therefore scores 1. To score higher the company must provide evidence that gift exchange is controlled, in particular with upper limits for gift exchange or a specific threshold necessary for senior authorisation.

Based on public information, there is evidence of a company policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. However, it is extremely minimal and provides very little guidance for employees. The company therefore scores 1. To score higher the company must provide evidence that hospitality exchange is controlled, in particular the company with upper limits for hospitality exchange or a specific threshold necessary for senior authorisation.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is no readily available evidence that the company’s political contributions are prohibited or regulated in order to prevent undue influence or other corrupt intent. TI notes it is insufficient for the company to state it only allows political contributions when it is legally permissible. To score higher the company must clearly prohibit or regulate political contributions, with it made clear how the regulations are applied, and publically declare the recipients.

Based on public information, there is no readily available evidence that the company’s lobbying activities are prohibited or regulated in order to prevent undue influence or other corrupt intent. TI notes it is insufficient for the company to state it wields no unfair influence on governments and authorities, and acts according to legal requirements. To score higher the company must clearly prohibit or regulate lobbying activities, with it made clear how the regulations are applied, and publically declare the issues on which it lobbies.

Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent.

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. The Code of Conduct is not detailed and no scenarios or examples are provided. To score on this question the company would need to provide written guidance that is both unambiguous and suitably illustrated.

Based on public information, there is evidence that the company has a training programme on its Code of Conduct, which contains an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence that it has an explicit anti-corruption training module.

Based on public information, there is evidence that employees receive training on the company’s Code of Conduct, which contains an anti-corruption policy. However, there is no specific evidence that this training is available in all countries where the company operates or has company sites. 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.

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 no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest. TI notes that the company states that employees should make unavoidable conflicts of interest transparent.

Based on public information, there is no readily available 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.

Based on public information, there is no readily available 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 (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity.

Based on public information, there is no readily available evidence that whistleblowing channels are available to all employees, in all geographies.

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, and 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. Employees are able to contact the Compliance Office for information and advice, with contact details provided in the Legal Compliance document.

Based on public information, there is no readily available evidence that there is a commitment to non-retaliation for bona fide reporting of corruption.