Teledyne Technologies Incorporated

Based on public information, there is evidence that statements have been made by the Chairman, President and Chief Executive Officer supporting the ethics and anti-corruption agenda of the company in the Global Code of Ethical Business Conduct and Code of Conduct for Service Providers.

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 some evidence of the senior leadership’s internal-facing commitment to the ethics and anti-corruption agenda of the company through publicly available videos on ethics. However, there is no readily available evidence that the CEO demonstrates a strong personal, internal-facing commitment.

Based on public information, there is evidence that the company publishes such a statement of values which refers to integrity, honesty, and respect. However, the company’s values are assessed to fall short of the range sought by the question.The company therefore scores 1.

Based on public information, there is evidence that the company has been a signatory of the Defense Industry Initiative on Business Ethics and Conduct since 2013.

Based on public information, there is evidence that the company has appointed the Audit Committee with overall corporate responsibility for compliance oversight but it is not clear whether the terms of reference include the anti-corruption agenda. The Chairman of the Board is reported to on matters of ethics and compliance, but the terms of reference are not clear. The company therefore scores 1.

Based on public information, there is evidence that Ethics Officers are appointed to individual Teledyne companies for providing guidance and there is a Chief Compliance Officer, George C Bobb III, who has a direct reporting line to the CEO. The Chief Compliance Officer reports on ‘matters related to the Teledyne ethics and compliance programs’.

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 and weak evidence of regular monitoring.

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. TI notes the review process for prohibited acts by executive officers but this is assessed to be restrictive and does not cover update 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 evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption. The company has a service provider’s code of conduct which suppliers, contractors, agents, consultants, representatives and distributors have to abide by and which states that ‘corrective action may include terminating our business relationship with a Service Provider that does not comply with these requirements’.

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 anti-corruption policies. It ensures contractual rights to terminate the contract in the event of breach of its contract.

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 evidence that the company has a policy that prohibits the giving and receiving of bribes, and is explicit on the various forms corruption can take.

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

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible for all employees, contracted staff, and affiliated organizations, but appears to only be available in English. The company therefore scores 1.

Based on public information, there is evidence that the company’s anti-corruption policy is written in accessible, comprehensible language.

Based on public information, there is evidence that the company’s anti-corruption policy applies to all employees and members of the Board.

Based on public information, there is evidence that the company has a policy for and examples of potential conflicts of interest.

Based on public information, there is evidence that the company has a policy on the giving and receiving of gifts, but there is no readily available evidence of clear upper limits or a threshold for senior approval. The company therefore scores 1.

Based on public information, there is evidence that the company has such a policy for government contracts and lists entertainment as part of their gifts policy. However, the policy does not appear to set clear upper limits or a threshold for senior approval. The company therefore scores 1.

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 contributions without prior approval from the Chief Compliance Officer. However, the policy does not mention a public disclosure requirement. The company therefore scores 1.

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 evidence that the company recognises the risks associated with charitable contributions. However, TI has found insufficient evidence that such contributions are regulated.

Based on public information, there is evidence that employees have access to a comprehensive global code of conduct with example scenarios. The company also has a Directors code of conduct that goes into more detail on specific issues.

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 evidence that the company has a process by which employees declare conflicts of interest to their supervisors, but it is not clear if this is in writing or verbally.

Based on public information, there is evidence that the company clearly states that it will apply disciplinary measures to employees, Directors and Board members who have violated its anti-corruption policy.

Based on public information, there is evidence that the company has multiple internal and independent channels to report instances of suspected corrupt activity that are well publicised and allow for anonymity. This includes one channel operated by an independent third party.

Based on public information, there is evidence that several whistleblowing channels are available to all employees in all geographies. This includes the Help line, an ethics officer and the Vice President and Chief Compliance Officer

Based on public information, there is evidence of some efforts to ensure whistleblowing is not deterred, but there is no readily available evidence of formal and comprehensive mechanisms designed to support whistleblowers, such as detailed analysis of whistleblowing data or independent employee data.

Based on public information, there is evidence that employees have access to a helpline, and trained ethics officers to provide them with guidance on ethical issues.

Based on public information, there is evidence that the company has a clear, legally enforceable, non retaliation policy for bona fide reporting of corruption. Any employees who engage in retaliation is subject to disciplinary action, up to and including termination of employment.