Saab AB

Based on public information, there is evidence that the CEO and Chairman have made several strong statements that promote the company’s anti-corruption and ethics agenda, under which it is clear that anti-corruption is a significant component. These statements are located on the company website, the 2012 Annual Report and the 2013 Annual Report.

Based on public information, there is evidence that the CEO and Chairman have demonstrated active external engagement in anti-corruption matters on several occasions over the last two years. The Chairman gave an applicable speech at the Annual General Meeting 2014 and both the Chairman and CEO gave relevant speeches at the Annual General Meeting 2013. In 2014 the CEO took part in an interview with a Brazilian magazine, in which the topic of corruption was briefly discussed.

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

Based on public information, there is evidence that the company has published a statement of values representing high standards of ethical business conduct. The value of trust is explained thoughout the company’s website and documents, with the Code of Conduct demonstrating why it is important to the company. Integrity, honesty, openness and transparency are referenced in this explanation.

Based on public information, there is evidence that the company is a member of the European Aerospace and Defence Industry Association (ASD) and the International Forum on Business Ethical Conduct (IFBEC), and it has adopted the principles of the UN Global Compact.

Based on public information, there is evidence that the company’s Audit Committee has overall corporate responsibility for the ethics and anti-corruption agenda. It annually monitors and evaluates the company’s business ethics. The Ethics and Compliance Board informs the Audit Committee of non-compliance with the company’s business ethical standards.

Based on public information, there is evidence that the company has appointed General Counsel Annika Bäremo, with responsibility for implementing the company’s ethics and anti-corruption agenda. The General Counsel heads the Ethics and Compliance Board and reports to the company’s Audit Committee.

Based on public information, there is evidence that the Audit Committee annually assesses and evaluates the company’s compliance programme for business ethical conduct. This includes examining the company’s organization, policies and procedures, risk assessment, and training. The Audit Committee receives reporting from the Ethics and Compliance Board, which meets six times a year.

Based on public information, there is limited evidence of a formal, clear, written plan that guides the Audit Committee’s review of the company’s ethics and anti-corruption agenda. The Audit Committee’s annual evaluation focuses on the company’s organisation, regulations and processes, risk analysis, and education and training. There is some evidence of improvement plans being implemented with a new external whistleblowing system planned for 2014. The company therefore scores 1. To score higher the company needs to provide detailed evidence of a formal, written plan on which the Audit Committee conducts its annual review, and further evidence that improvement plans are put in place when issues are identified.

Based on public information, there is no readily available evidence of a formal process for review and update of the company’s 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. While the Audit Committee evaluates the risk analysis of the company’s business ethics, it is unclear how this is applied in practice and how risks are mitigated as a result. TI notes that work has begun on the new system with the aim to being implementation during the second quarter of 2014; however TI has not seen further evidence of how anti-corruption risk assessment will be applied enterprise-wide.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. The company states that every market or business initiative is subjected to a corruption risk assessment. As part of an assessment six key factors are examined, including the country, the customer and the business case.

Based on public information, there is evidence that the company conducts due diligence when selecting agents. This includes questionnaires, external inquiries and interviews. The company therefore scores 1. To score higher the company would need to provide evidence that it refreshes due diligence at least every 3 years and/or when there is a significant change in the business relationships.

Based on public information, there is evidence that the company has processes for the behaviour, monitoring and control of agents with respect to countering corruption. Intermediaries receive anti-corruption and compliance training, and sign a commitment that they will follow the company’s guidelines. The company has the right to monitor the performance of all intermediaries. The company therefore scores 1. To score higher the company would need to provide evidence of the contractual rights to audit intermediaries and terminate a contract in the event of a breach.

Based on public information, there is evidence that the company communicates its ethics and anti-corruption agenda down the supply chain, and makes clear its requirement for suppliers to conform to its Code of Conduct. It has contractual rights to apply sanctions in the event of a breach of its contract.

Based on public information, there is evidence that the company addresses offset contracting corruption risk at a general level. The company ensures that certain offset partners are managed and controlled in regard to the company’s standards on business ethical conduct. The company therefore scores 1. To score higher the company would need to provide evidence that offset contracting corruption risk is explicitly addressed in its offset policies, procedures and contractual terms.

Based on public information, there is evidence that the company conducts due diligence when selecting offset partners and offset brokers. This is part of the due diligence process for intermediaries, which includes questionnaires, external inquiries and interviews. The company therefore scores 1. To score higher the company would need to provide evidence that it refreshes due diligence at least every 3 years and/or when there is a significant change in the business relationships.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms.

Based on public information, there is evidence that the company explicitly states that it has zero tolerance for corruption.

Based on public information, there is evidence that the company’s Code of Conduct is easily accessible to Board members, employees and third parties. The Code of Conduct is available on the company’s website in English and Swedish.

Based on public information, there is evidence that the company’s Code of Conduct is written in accessible, comprehensible language. It does not have dense, legal terms and is easily understandable for employees and third parties.

Based on public information, there is evidence that the company’s Code of Conduct applies to the management of the company and its employees. The company therefore scores 1. To score higher the company would need to provide evidence that the Code of Conduct explicitly applies to Board members.

Based on public information, there is evidence that the company has a policy on conflicts of interest. However, the policy is assessed to use vague wording and is only specified in regard to employing or engaging with former public officials. The company therefore scores 1. To score higher the company would need to provide evidence that conflicts of interest are explained in greater detail, including the use of examples to show where the policy might apply.

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. The policy states that employees must never offer gifts of a value or nature that may be seen as an attempt to improperly influence a business decision or to obtain improper advantages. Similarly employees may only accept gifts that are reasonable to the related business. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of a gift and/or the requirement for senior management authorisation if a value threshold is exceeded.

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. The policy states that employees must never offer hospitality of a value or nature that may be seen as an attempt to improperly influence a business decision or to obtain improper advantages. Similarly employees may only accept hospitality that is reasonable to the related business. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits on the acceptable value of hospitality and/or the requirement for senior management authorisation if a value threshold is exceeded.

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 evidence that the company prohibits political sponsoring.

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 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 evidence that the company provides written guidance to help Board members and employees understand and implement the company’s ethics and anti-corruption agenda. This includes three easily understandable booklets, such as the Corruption Risk Management booklet. The company therefore scores 2.

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 the company provides anti-corruption training in all countries where it operates or has sites. This is primarily via an anti-corruption e-learning course.

Based on public information, there is evidence that the company provides targeted anti-corruption training to Board members. The company therefore scores 1. To score higher the company would need to provide evidence that Board members are re-trained at least every 3 years.

Based on public information, there is evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. All marketing and sales employees undergo advanced ethics and anti-corruption training, which includes general risk awareness and the use of company tools for managing corruption risks. In the 2013 Annual Report the company states that it is reviewing the need to expand this training beyond the marketing organisation. The company therefore scores 1. To score higher the company would need to provide evidence all high risk positions receive tailored ethics and anti-corruption training.

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.

Based on public information, there is limited evidence that the company may apply disciplinary procedures, to employees found to have violated the Code of Conduct. However, the company does not have an explicit commitment, using language such as ‘will’, to apply disciplinary procedures. The company therefore scores 1. To score higher the company would need to provide evidence, that it has an explicit commitment to apply disciplinary procedures to both employees and Board members, who violate the Code of Conduct.

Based on public information, there is evidence of multiple, secure, accessible channels, which allow employees to report instances of suspected corrupt activity, including the Ethics and Corporate Responsibility Council. Employees are able to report anonoymously by sending an email using an outside email account. The company therefore scores 1. To score higher the company would need to provide evidence that employees can report to an independent channel.

Based on public information, there is evidence that across geographies, all employees are able to report to the Ethics and Corporate Responsibility Council. 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, and that whistleblowers are treated supportively. Mechanisms could include then monitoring of whistleblowing channel usage statistics, independent employee surveys or follow ups with whistleblowers after serious incidents have been investigated.

Based on public information, there is evidence that employees can seek help and advice on corruption-related issues from the company’s Legal Affairs department. However, there is no further evidence that there are officers specifically trained to provide advice and help on corruption-related issues. The company therefore scores 1.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. In particular, the company’s CEO has made a strong statement prohibiting retaliation. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary measures are applied to employees who breach this policy.