Samsung Techwin Co. Ltd.

Based on public information, there is no readily available evidence that the company has published a statement from the CEO or Chair of the Board supporting the ethics and anti-corruption agenda of the company. TI notes that the CEO has made a statement regarding adherence to the company’s compliance management programme.

Based on public information, there is no readily available evidence that the company’s CEO 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 evidence that in the minutes of the February 2014 Compliance Committee Meeting the CEO stated that “I expect that all of us to conduct our business in a transparent way”. The CEO also mentions compliance, ethics, and transparency in the 2013 Address for the Anniversary of the company’s establishment. In the 2013 New Year’s Address, the CEO refers to the need to systemize ethical management. However, these statements primarily relate to compliance with global standards, rather than actively promoting the ethics and anti-corruption agenda of the company. TI also notes the Demonstration of CEO’s Resolve: ’33 Lessons’ for Right Way Righteous Management’. The company therefore scores 1.

Based on public information, the company’s values are outlined in the Code of Conduct as People, Excellence, Change, Integrity, Co-prosperity. The company’s business principles refer to ethical standards, clean organizational culture, respect, environment/health and safety, and social responsibility. These are broken down into specific policies and statements in the Global Code of Conduct. The company therefore scores 1. To score higher the company would need to provide evidence that at least one other value sought by this question is explained.

Based on public information, there is no readily available evidence that the company belongs to a national or international initiative that promotes anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, the company has appointed the Compliance Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Committee is chaired by the CEO and another internal Board Director is a Commissioner of the Committee. The Committee has delegated responsibility for enacting the Regulation for Compliance with Anti-Corruption Acts to the Compliance Officer, who is not a Board member.

Based on public information, there is evidence that the company has appointed the Compliance Officer with responsibility for implementing the company’s ethics and anti-corruption agenda. 30 business department staff and overseas subsidiary compliance supervisors and personnel have been appointed under the supervision of the Compliance Officer. The Compliance Team has been tasked with surveying “the situations where officers and employees fail even though they know and conduct monitoring” as well as providing education and guidelines to strengthen the system.

Based on public information, there is evidence that the Board-level Compliance Committee monitors and reviews the performance of the company’s compliance and anti-corruption agenda twice a year. In addition, the Chair of the Board reviews the compliance and anti-corruption agenda once a year.

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, and no evidence of improvement plans being implemented when issues are identified.

Based on public information, there is evidence that the Compliance Committee reviews the ethics and anti-corruption agenda on a regular basis. The Compliance Guidelines indicate that the Board monitors compliance-related systems and establishes improvement plans where necessary. However, there is no readily available evidence of policies and practices being updated 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 evidence that the company identifies a number of ‘dangers’ when assessing proposed business decisions. However, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions.

Based on public information, there is evidence that the company conducts due diligence on third parties, including agents, with links to Government Officials. However, evidence does not suggest that due diligence is carried out on all agents, or that it is refreshed at least every three years and/or when there is a significant change in the business relationship. The company therefore scores 1.

Based on public information, there is evidence that the company has contractual rights for the behaviour and audit of third parties, including agents, who deal with Government Officials. However, there is no readily available evidence that the company has contractual rights and processes for the monitoring and control of all agents with respect to countering corruption. The company therefore scores 1.

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. TI notes that the Regulation for Compliance with Anti-Corruption Acts applies to agents, consultants, representatives, joint venture companies, partnership companies and business partners. However, there is no readily available evidence of contractual terms for contractors, sub-contractors, and suppliers.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risk 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 a comprehensive anti-corruption policy, which covers bribery, political donations, facilitation payments, and gifts and hospitality.

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

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible on the company’s website. Documents are available in English and Korean.

Based on public information, there is evidence that the company’s anti-corruption policy is written in legalistic language and is therefore assessed to not be easily understandable to a non-legal audience. The company therefore scores 1.

Based on public information, there is evidence that the company’s anti-corruption policy applies to all employees and management. However, evidence does not suggest it explicitly applies to members of the Board. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy on conflicts of interest. However, there is no evidence that the company defines conflict of interest or whether the specific clauses relating to the policy also apply to Board members. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy on providing gifts to Government Officers, Clients or other third parties (‘Government Officials’). However, there is no reference to non-governmental parties or the receipt of gifts, and there are no upper limits provided for the giving of gifts. The company therefore scores 1.

Based on public information, there is evidence that the company’s anti-corruption policy includes a statement on hospitality. However, the company limits the amount of hospitality dependant on the laws and codes of conduct in each country, rather than according to an internal company limit. The company therefore scores 1.

Based on public information, there is evidence that the company prohibits facilitation payments. However, no guidance is provided on how the policy is to be implemented in practice. The company therefore scores 1.

Based on public information, there is evidence that the company prohibits political involvement or political donations in its name.

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 evidence that the company regulates charitable contributions. The company states that it will verify that these payments are not disguised as corrupt payments to government officials, and that charities are not set up to violate US and international money laundering acts. However, there is no readily available evidence that donations are publicly declared. The company therefore scores 1.

Based on public information, there is evidence that the company defines key terms in its anti-corruption policy. However, there are no examples or scenarios to help illustrate the company’s polices and no other readily available guidance for employees was found.

Based on public information, there is evidence that the company provides anti-corruption training to employees.

Based on public information, there is evidence that the company provides mandatory compliance and anti-corruption training for all employees.

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 evidence that the company conducts basic training for employees that interact with government officials. However, this does not constitute the entirety of sensitive positions and appears not to be tailored.

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 evidence that the company only states that it ‘may’ take civil and criminal action against those found to have engaged in corrupt activities. The company therefore scores 1.

Based on public information, there is evidence that employees can report suspicions to the compliance team via direct visits, telephone, email, or fax. Further the company commits to protect the confidentiality of the person reporting. The Compliance Hotline is publicised on the company website. However, although the confidentiality is guaranteed, individuals are unable to make anonymous reports and personal data must be provided. In addition, there is no readily available evidence that an external, independent channel is provided for employees to use. The company therefore scores 1.

Based on public information, there is evidence that across geographies all employees are able to report to the Compliance Team, via telephone or internal mechanisms. Therefore the company scores 1. To score higher the company would need to provide evidence that across geographies, all employees have access to more than one reporting channel.

Based on public information, there is evidence that the company commits to protecting the identity of whistleblowers and may reward such employees after evaluating the contents of the report. However, it is not clear that the company has other formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, such as ways to follow up with whistleblowers and monitor their experience. The company therefore scores 1.

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 in Korea for example have access to a website that is managed by the Compliance Team, which provides access to trained counsellors.

Based on public information, there is evidence that the company commits to not disadvantaging employees and management with respect to employment when they report suspicions of violations in good faith. Those who retaliate against whistleblowers are subject to disciplinary action.