Thales Group

Based on public information, there is evidence that the CEO has issued several statements that promote the company’s ethics agenda, under which anti-corruption is a significant component. These can be found on the company website, in the Code of Ethics and two letters published on the company website.

Based on public information, there is evidence that the company’s CEO demonstrates personal involvement in the B20 Task Force on Transparency and Anti-corruption. In addition, Dominique Lamoureux, VP Ethics and Corporate Responsibility, is an active contributor to the ICC’s Fighting Against Corruption Handbook and has spoken on the subject of transparency in arms exports.

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. TI notes the CEO’s presentation on the Ambition 10 plan, which had a limited focus on ethics.

Based on public information, the company publishes statements of values including honesty, transparency (on matters relating to the code), accountability and integrity and demonstrates that these are translated into company policies and codes.

Based on public information, there is evidence that the company is a founding member of IFBEC and ASD’s Business Ethics Task Force, and has signed up to the United Nations Global Compact.

Based on public information, there is evidence that the company has appointed the Ethics and Corporate Responsibility Committee with overall corporate responsibility for its ethics and anti-corruption agenda. This involves determining the company’s ethics strategy, coordinating Ethics Officers and responding to ethical issues.

Based on public information, Thales has instituted the Ethics and Corporate Responsibility Committee as one of its three governance bodies. The Ethics and Corporate Responsibility Department is headed by a Vice President. This individual is identified as Dominique Lamoureux.

Based on public information, there is evidence that the Ethics and Corporate Responsibility Committee submits an annual report that is reviewed by the company Board.

Based on public information, there is limited evidence of a formal, clear, written plan that guides the Board review of the ethics and anti-corruption agenda. However, it is clear that the Ethics and Corporate Responsibility Committee identifies issues and proactively proposes guidelines to mitigate them. Therefore, it proposes improvement plans to management. TI notes that no specific examples are provided of improvement plans being implemented. The company therefore scores 1.

Based on public information, there is readily available evidence that the company has a formal process for review of its policies and practices in response to actual or alleged instances of corruption. The Ethics and Corporate Responsibility Committee must launch enquiries into possible infractions of the Code of Ethics and make proposals to management about action to be taken.

Based on public information, there is evidence that the company has a risk management system implemented enterprise wide, which includes corruption as one of the 19 major identified risks. The Risk Management Committee is responsible for ensuring the risk management system is comprehensive, and allocates responsibilities for coordinating and monitoring these risks to the relevant operational departments. Enterprise Risk Officers ensure that identified Risk Owners have action plans to mitigate risks.

Based on public information, there is some evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. However, there is no further readily available evidence clearly outlining the circumstances under which such a procedure should be applied. The company therefore scores 1.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting agents. Key Industrial Partners (KIPs) go through a three stage process that involves an internal/external ethics evaluation, an operational assessment questionnaire and an analysis by the KIP manager. Furthermore, the company states that KIPs are approved for a three-year period, suggesting the due diligence process is conducted at these intervals.

Based on public information, there is some evidence that the company has contractual rights and processes for the behaviour, monitoring and control of agents with respect to countering corruption, including the termination of a contract due to non-compliance.

Based on public information, there is evidence that the company requires its suppliers to adhere to the principles of corporate citizenship in corruption prevention. All suppliers are required to sign Thales’s Purchasing and Corporate Responsibility Charter where there is also a statement on the consequences of non-compliance including termination of the contract.

Based on public information, there is evidence that the company explicitly addresses the corruption risks associated with offset contracting. The company’s indirect offset operations are managed by a dedicated structure and has an additional qualification procedure to be used prior to the creation of a contract with indirect offset partners.

Based on public information, there is evidence that the company collaborates with SMEs and KIPs to enable the Group to meet its offset obligations. Furthermore, there is evidence that the company conducts due diligence when selecting its offset partners. However, the scope is not entirely clear and there is no further information on the frequency of renewal. The company therefore scores 1.

Based on public information, the company has an anti-corruption policy which prohibits corruption in its various forms.

Based on public information, the company’s anti-corruption policy is explicitly one of zero tolerance.

The company’s Code of Ethics and Corporate Social Responsibility are easily available for all employees, contracted staff, and affiliated organisations. These documents are available in French and English.

Based on public information, 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 is applicable to the group’s permanent and temporary staff. However, there is no readily available evidence to suggest that it specifically applies to Board members. The company therefore scores 1.

Based on public information, there is evidence of an extensive policy on conflicts of interest with specific scenarios and guidelines. However, it is not clear whether the policy applies to Board members. The company therefore scores 1.

Based on public information, there is information 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 may only provide gifts to a customer within reasonable limits, in accordance with generally accepted practices, and after management approval. However, to score higher, the company would need to provide evidence of clear upper limits on the acceptable value of a gift and/or the requirement for senior management authorisation if a value threshold is exceeded. The company therefore scores 1. TI notes a Thales UK Ethics Awareness presentation on gifts and hospitality, which states UK employees must not give or receive gifts above £50. However, TI is looking for a Group-wide policy.

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. Employees may only provide hospitality to a customer within reasonable limits, in accordance with generally accepted practices, and after management approval. However, to score higher, the company would need to provide evidence of clear upper limits on the acceptable value of hospitality and/or the requirement for senior management authorisation if a value threshold is exceeded. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company explicitly prohibits facilitation payments. To score higher, the company would need to provide guidance or supplementary information on how the policy is to be implemented in practice.

Based on public information, there is evidence that the company does not make financial contributions to political candidates, elected representatives or political parties.

Based on public information, there is evidence that the company has produced a best practices guide to lobbying, to help employees discern the line between legitimate promotion and corruption. This guide is publically available and provides employees with detailed information regarding company policy on lobbying, different national regulations on lobbying, and potential red flags. Although, TI notes that the company refers to national legislations on disclosure, TI assesses the company’s emphasis on transparency around lobbying to be strong enough evidence to score 2 here.

Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is evidence that the company provides employees with access to a range of guidance material on the company intranet.

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 ethics training, under which anti-corruption sits, is provided globally through e-learning and face to face 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 evidence that the company provides tailored anti-corruption training to employees in sensitive position such as purchasing, sales, and projects.

Based on public information, there is evidence that the company has a policy that directs employees to declare conflicts of interest to their manager and to the Ethics or HR department. However, TI notes that no formal, written declaration must be made when employees are reporting to their manager, preventing the company from scoring higher. The company therefore scores 1.

Based on public information, there is evidence that the company is committed to apply sanctions for infringements of its ethical standards. However, TI feels this statement lacks an explicit commitment to disciplinary measures, using language such as ‘will.’ To score higher the company would need to provide evidence of an explicit statement that it will apply disciplinary procedures to employees, Directors and Board members who have violated its anti-corruption policy. The company therefore scores 1.

Based on public information, the company has multiple channels that are accessible and guarantee confidentiality, to report concerns or instances of suspected corruption activity. Employees are able to utilise the ethics alert facility and report to an ethics officer, the country ethics committee of their country or the Group’s Ethics and Corporate Responsibility Committee. However, there is no readily available evidence of independent sources to report to, or that anonymous reporting is permitted. The company therefore scores 1.

Based on public information, there is evidence that the company provides employees in all geographies with more than one whistleblowing channel. For example, employees can contact the Ethics and Corporate Responsibility Committee by e-mail or telephone.

Based on public information, there is evidence of some efforts to ensure whistleblowing is not deterred. For example, the Code of Ethics devotes several pages to whistleblowing channels and procedures, and the Corporate Responsibility Report 2013 displays a ‘Speak Up’ poster from the Thales UK ethics awareness campaign. However, to score higher, the company would need to provide evidence of the ways whistleblowers are supported, such as detailed analysis of whistleblowing data or independent employee surveys. The company therefore scores 1.

Based on public information, there is evidence that the company provides well-publicised resources to all employees where help and advice can be sought on corruption-related issues, such as ethics officers.

Based on public evidence, there is no readily available evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption.