Ultra Electronics Holdings plc

Based on public information, there is evidence that the company publishes a statement from both the Chief Executive Officer and Chair of the Board supporting the ethics and anti-corruption agenda of the company. TI has found evidence of two such clear statements in the last two years. The company therefore scores 1.

Based on public information, there is no readily available evidence that the 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 no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

Based on public information, there is limited evidence that the company publishes a statement of values representing high standards of business conduct. Integrity and accountability are mentioned in the Chairman’s Governance Statement. However, this falls short of the range of values sought by the question. The company therefore scores 1.

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 evidence that the company has appointed the Ethics Overview Committee with overall corporate responsibility for its ethics and anti-corruption agenda.

Based on public information, there is evidence that the company has appointed the General Counsel with responsibility for implementing the ethics and anti-corruption agenda of the company. The individual is identified as Sharon Harris.

Based on public information, there is evidence of regular Board level monitoring and review of the performance of divisional compliance performance reports. Ethics and anti-corruption policies are reviewed biannually by the Board and there is an Ethics Overview Committee that meets quarterly.

Based on public information, there is evidence of a plan that guides the Board when reviewing the anti-corruption policy and the Code of Ethics. However, there is no further evidence of monitoring indicators on which improvement plans might be based. The company therefore scores 1.

Based on public information, there is evidence that the company conducts regular reviews of its anti-corruption policy and updates its procedures if they are found to be ineffective in preventing corruption.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide.

Based on public information, there is some evidence that the company has a formal risk assessment procedure for assessing compliance in proposed business decisions. However, details of the process, including the full circumstances under which the process would apply, are not available publicly. The company therefore scores 1.

Based on public information, there is evidence that the company conducts due diligence on third parties, which is repeated at intervals of no more than 2 years.

Based on public information, there is some evidence that the company has contractual rights and processes for the behaviour and audit of agents with respect to countering corruption. However, there is no explicit evidence of contractual terms in place or the exact procedure of monitoring of third parties. The company therefore scores 1.

Based on public information, there is some evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption. However, there is no evidence of contractual terms that will allow sanctions in the event of a breach. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms.

Based on public information, there is evidence that the company’s anti-corruption policy is one of a zero-tolerance.

Based on public information, there is evidence that Board members, employees, contracted staff and other organisations can publicly access the Anti-Corruption and Bribery Policy and the Code of Ethics and Business Conduct. Further information is available on the Company’s intranet. However, it is not clear that these documents are available in languages other than English. The company therefore scores 1.

Based on public information, there is evidence that the company’s policies are written in comprehensive language that is easily understandable and clear.

Based on public information, there is evidence that the company has an anti-corruption policy and it 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. However, there is no clear definition of conflicts of interest or further guidance and examples. The company therefore scores 1.

Based on public information, there is evidence that the company regulates giving and receiving of gifts, with clear set upper limits.

Based on public information, there is evidence that the company regulates the giving and receiving of hospitality, with set upper limits and an approval procedure in place.

Based on public information, there is evidence that the company prohibits facilitation payments and provides guidance on what to do when asked for such payments.

Based on public information, there is evidence that the company prohibits 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 the company lobbies.

Based on public information, there is evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent. However, there is no readily available evidence that the recipients of donations are publicly declared. The company therefore scores 1.

Based on public information, there is some evidence that the company provides guidance on anti-corruption to employees. However, it is not clear from publicly available evidence that this includes scenarios and examples to ensure better understanding of the policies in place. The company therefore scores 1.

Based on public information, there is evidence that the company has a training programme that covers anti-corruption.

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

Based on public information, there is evidence that the company provides anti-corruption training to Directors. However, it is not clear how often this training is refreshed. The company therefore scores 1.

Based on public information, there is evidence that the company provides tailored anti-corruption training to employees in higher risk positions, such as the ones conducting business overseas. However, it is unclear which other positions might receive this training. The company therefore scores 1.

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. TI notes that employees are instructed to discuss conflicts of interest with a line manager. However, there is no evidence that this is done in writing.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to all employees found to have engaged in corrupt activities. The Anti-Corruption and Bribery Policy also applies to directors. The company therefore scores 2.

Based on public information, there is 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. In particular, the Employee Helpline is independently operated and facilitates anonymous reporting.

Based on public information, there is evidence that across geographies, all employees have access to the Employee Hotline. The company therefore 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 some evidence that the company has mechanisms to assure itself that whistleblowing by employees is not deterred, through the process of monitoring and review. However, there is no further evidence of formal monitoring indicators, statistics and independent employee surveys. The company therefore scores 1.

Based on public information, there is evidence of well-publicised resources for employees to receive help and advice on corruption-related issues. These resources include line managers, the General Counsel or using the company hotline.

Based on public information, there is evidence that the company is committed to non-retaliation for reporting of violations in good faith. However, it is not explicitly clear whether disciplinary measures will be applied in cases of retaliation. The company therefore scores 1.