Sapura Secured Technologies Group

Based on public information, there is no readily available evidence that the company publishes a statement from the CEO or Chair of the Board, supporting the ethics and anti-corruption agenda of the company.

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 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.

Based on public information, there is no readily available evidence, that the company publishes a statement of values or principles, representing high standards of ethical business conduct.

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 specific responsibility for implementing the ethics and anti-corruption agenda.

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 on which the review of the ethics and anti-corruption agenda is based, nor 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 that the company has an anti-corruption policy that prohibits corruption in its various forms.

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 company's anti-corruption policy is easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company.

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 anti-corruption policy explicitly applies to all employees and members of the Board.

Based on public information, there is no readily available evidence that the company has a policy on potential conflicts of interest.

Based on public information, there is no readily available 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.

Based on public information, there is no readily available evidence that the company has a policy for the giving and receipt of hospitality, which 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 or regulates political 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.

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 company’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 the company has a training programme that explicitly covers anti-corruption.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to Board members.

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.

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, to report concerns or instances of suspected corrupt activity.

Based on public information, there is no readily available evidence that the company’s 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 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.

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.