Textron Inc.

Based on public information, there is evidence that the company has published a statement from the Chief Executive Officer supporting the ethics and anti-corruption agenda of the company. There appears to be only a single statement on the company website, as the CEO introduction to the Business Conduct Guidelines and this shows a publication date of September 2010. To score other than 0, a statement would need to have been published within the last 2 years.

Based on public information, there is evidence that Chairman and CEO Scott Donnelly, sits on the DII Steering Committee. TI understands that the Steering Committee meets several times a year.

Based on public information, there is no readily available evidence that the CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including integrity, honesty and trust. The meaning and importance of these values is explained in the Business Conduct Guidelines, particularly in a question and answer section.

Based on public information, there is evidence that the company is a member of DII.

Based on public information, there is evidence that the company has appointed the Audit Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The committee must review the implementation and effectiveness of the legal, ethical and regulatory compliance programme with the General Counsel.

Based on public information, there is evidence that the company has appointed the Chief Compliance Officer with responsibility for implementing its ethics and anti-corruption agenda. The Chief Compliance Officer is identified as E. Robert Lupone.

Based on public information, there is evidence that the Audit Committee meets at least annually with the General Counsel, to review the company’s legal, ethical and regulatory compliance programme.

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 Audit Committee is based, or evidence of improvement plans being implemented when issues are identified.

Based on public information, there is 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. Issues are investigated by the relevant corporate and/or business unit personnel and the company implements corrective actions, including changes to systems, practices and procedures, in response. The Audit Committee and General Counsel is responsible for the review process of policies and practices.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The company’s Ethics and Compliance Steering Committees are responsible for conducting risk assessments and risk mitigation for noncompliance. Each business unit is subject to the company’s Anti-Corruption Compliance Policy and their annual risk-based ethics and compliance action plans are based on this. The Audit Committee assists the Board with oversight of the company’s risk management programme.

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.

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. The company states that people acting with the company must be subject to approval requirements stated in the company’s Global Anti-Corruption Compliance Policy and/or Delegation of Authority document. However, it is unclear if these approval requirements include due diligence.

Based on public information, there is evidence that the company has contractual rights to control the behaviour of agents with respect to countering corruption. The company therefore scores 1. To score higher the company would need to provide evidence that it has the right to monitor and audit agents.

Based on public information, there is limited 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. Each business division appears to publish its own set of contractual terms. An inspection of Bell Helicopters (one of the company’s divisions) Standard Terms and Conditions suggests that the Business Conduct Guidelines are imposed for certain contract value levels and there is a commitment for subcontractors to report wrong-doings. However, there appears to be no general requirement for observing the conduct guidelines and no statement of consequences for breaches of the guidelines.

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 an anti-corruption policy that prohibits corruption in its various forms, including bribery and kickbacks.

Based on public information, there is evidence that the company has zero tolerance for bribery.

Based on public information, there is evidence that the company’s Business Conduct Guidelines are easily accessible to Board members, employees and third parties. The Business Conduct Guidelines are available on the company’s website in numerous languages.

Based on public information, there is evidence that the company’s Business Conduct Guidelines are easily understandable and clear to Board members, employees and third parties. The document is written in comprehensible language, without dense legal terms.

Based on public information, there is evidence that the company’s Business Conduct Guidelines applies to all employees and Board members.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. It contains a definition of a conflict of interest and provides several examples.

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. Employees should not give or receive gifts that are more than a nominal value, and/or to or from people with which the company does business. Any gifts worth more than $75 must receive approval from a supervisor, with the assistance of an ethics and compliance officer or legal counsel.

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 company states that hospitality in the normal course of business is permitted and that lavish meals or inappropriate entertainment should be avoided. The company therefore scores 1. To score higher the company would need to provide evidence that it either sets upper limits for hospitality exchange or a requirement for senior authorisation.

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 regulates political contributions in order to prevent undue influence or other corrupt intent. The use of corporate funds for political contributions is prohibited unless approval is received from the Government Affairs Department and the company legal counsel. The company therefore scores 1. To score higher the company would need to provide evidence that it publically declares the recipients of its political contributions.

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. The Business Conduct Guidelines contains an extensive number of questions and answers, to illustrate particular situations. Evidence also suggests that employees have access to articles on Ethics and Compliance issues and a variety of on-line learning materials on the company’s intranet.

Based on public information, there is limited evidence that the company has a training programme on its ethics and compliance systems, which includes an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence of an explicit anti-corruption training module.

Based on public information, there is evidence that each of the company’s operations conducts ethics and compliance training.

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. Employees are instructed to report conflicts of interest to a direct supervisor, with the assistance of the employee’s ethics and compliance officer or the company’s legal counsel. To score on this question the company would need to provide evidence that conflicts of interest are declared either to a manager in writing or to an independent department.

Based on public information, there is evidence that the company has an explicit commitment to apply disciplinary procedures to employees, Directors and Board members found to have violated the Business Conduct Guidelines, which includes an anti-corruption policy.

Based on public information, there is evidence that the the company has multiple, well-publicised, accessible, secure channels, for employees to report concerns or instances of suspected corrupt activity. These channels include a business units ethics and compliance officer, the Executive Vice President and General Counsel, the company’s legal counsel, and a HR business partner. In particular, employees can report using the company’s Ethics and Compliance HelpLine, which is operated by an independent third party. Where local law permits employees are able to report anonymously.

Based on public information, there is evidence that across geographies all employees have access to more than one reporting channel. This includes a business unit ethics and compliance officer and the Ethics and Compliance HelpLine.

Based on public information, there is limited evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred. The company monitors the activity of the Ethics and Compliance HelpLine and uses feedback to improve the ethics and compliance programme. The company therefore scores 1. To score higher the company would need to provide evidence of other mechanisms to ensire that whistleblowers are treated supportively, such as independent employee surveys and follow up interviews with whistleblowers after an incident has been investigated.

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. Specifically, employees can seek guidance from a business unit’s ethics and compliance officer.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. 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.