Russian Helicopters JSC

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. TI notes that the General Manager introduces the Code of Ethics. However, this document is dated 2009 - which is before the consolidation of the company completed in 2011 - and this is outside the two year timeframe of this question.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or the 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 company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

Based on public information, there is evidence that the company has published a Code of Ethics, which identifies a number of values, ethical principles, and standards of behavior for employees. However, this document does not refer to honesty, trust, transparency, openness, integrity, or accountability. Evidence suggests that the company is a fully owned subsidiary of Oboronprom, which is part of Rostec Corporation (Russian Technologies). However, there is no readily available evidence to confirm that the company publicly subscribes to the policies of Oboronprom and Rostec, and these companies do not seem to publish a statement of values representing the above-mentioned standards.

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 no readily available 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.

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.

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.

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.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption 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 no readily available evidence of an anti-corruption policy that prohibits corruption in its various forms. TI notes that there is evidence that the company states a commitment to ‘high legal, business and ethical standards’ and developing a culture of combatting the abuse of office. There is also a clear link to the policies of Oboronprom and Rostec, although they are not publicly endorsed by the company. The Rostec anti-corruption statement, however, remains legalistic and refers to the national legal framework of the Russian Federation, without developing the company’s own anti-corruption policies and procedures.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is explicitly one of zero tolerance.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is easily accessible to Board members, employees and third parties.

Based on public information, there is no readily available 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 no readily available evidence that the company’s anti-corruption policy explicitly applies to all employees and Board members.

Based on public information, there is no readily available evidence that the company has a policy on potential conflicts of interest. TI notes that Russian Technologies have a Committee on Conflicts of Interest, but it does not include any publicly available definitions or stipulations.

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. However, the information provided is limited, as it does not provide details of upper limits and it is unclear what is meant by ‘generally accepted perceptions of business gifts’. The company therefore scores 1.

Based on public information, there is no readily available evidence of 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.

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 prohibits political contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which the company lobbies.

Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent. TI notes that the Rostec corporation, of which the company is a part, allows charitable contributions.

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.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption.

Based on public information, there is no readily available evidence that anti-corruption training is provided in all countries where the company operates or has company sites.

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 can declare conflicts of interest. TI notes that the Rostec Corporation has in place a Committee for supervising conflicts of interest. However, evidence refers only to the members of the Committee and the general framework within which the Committee operates, rather than a formal process by which employees can declare conflicts of interest.

Based on public information, there is no readily available evidence that the company has an explicit commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is evidence that the company provides a whistleblowing channel for employees to report concerns or instances of suspected corrupt activity. The Hotline is available via fax, telephone, e-mail or post, with confidentiality guaranteed. The company therefore scores 1. To score higher the company would need to provide evidence of at least one other whistleblowing channel that is externally operated and facilitates anonymous reporting.

Based on public information, there is evidence that across geographies, all employees have access to the Hotline. The company therefore scores 1. To score higher the company would need to provide evidence that across geographies, all employees have access to more than one whistleblowing 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 no readily available evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. It is unclear if employees can receive help and advice from the Helpline, rather than just report corruption incidents.

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