VSE Corporation

Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board publishes a statement supporting the ethics and anti-corruption agenda of the company. A single statement published in the preface to the Supplier’s Code of Conduct discusses ethical standards but the date of publication is not known.

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 personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. There is evidence that the CEO has a column in the VSE Connection company newsletter, which can be used to promote the company values. However, this question is seeking engagement such as speaking at training events or chairing reviews of anti-corruption programmes, rather than written statements.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, namely integrity, openness and honesty. These values are clearly demonstrated across company policies and documentation. TI notes that there appear to be annual awards to employees based on the company’s Core Values.

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 Nominating and Corporate Governance Committee with overall corporate responsibility for its ethics and anti-corruption agenda. Its responsibilities include reviewing and making recommendations in regard to the Code of Business Conduct and Ethics, providing guidance on conflicts of interest, and providing guidance on business conduct and ethics.

Based on public information, there is evidence that the company has appointed the Vice President and General Counsel with responsibility for implementing the company’s legal affairs and corporate compliance. The individual is identified as Mr Kiernan.

Based on public information, there is evidence that the Nominating and Corporate Governance Committee monitors and reviews the Code of Business Conduct. Evidence suggests that this review takes place at the Committee’s biannual meetings. The company therefore scores 1. To score higher the company would need to provide evidence of a major, heavyweight review of the company’s entire ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that there is 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, and no 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 to review and where appropriate updates its policies and practices, in responce 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.

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.

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. The company refers to ‘teaming partners’ in its Supplier Code of Conduct, but it is unclear if this covers agents.

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, through the Supplier Code of Conduct, its stance on bribery and corruption. However, it is not clear that the consequences of breaches to this stance are fully outlined. 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. The policy prohibits the giving of bribes to promote company interests and conflicts of interest. The company therefore scores 1. To score higher the company would need to explicitly prohibit both the giving and receiving of bribes, and the various forms that corruption may take.

Based on public information, there is no readily available evidence that the company’s policy is explicitly one of zero-tolerance.

Based on public information, there is evidence that the company’s Code of Business Conduct and Ethics and Supplier Code of Conduct are easily accessible to Board members, employees and third parties. Both documents are available on the company’s website in English. The company therefore scores 1. To score higher the company would need to provide evidence that these documents are available in at least one other language, as evidence suggests that the company operates outside of the USA.

Based on public information, there is evidence that the company’s Code of Business Conduct and Ethics and Supplier Code of Conduct is easily understandable and clear to Board members, employees and third parties. The documents are written in comprehensible language.

Based on public information, there is evidence that the company’s Code of Business Conduct and Ethics 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. The policy defines a conflict of interest, provides multiple examples and is applicable to Board members.

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. The policy includes upper limits for gifts and guidelines for reporting.

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 policy includes upper limits for hospitality and guidelines for reporting.

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 companyregulates political contributions, in order to prevent undue influence or other corrupt intent. TI notes that the company only states that all political contributions abide by campaign laws and regulations.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities.

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 no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the firm’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 anti-corruption training is provided in all countries where the company operates or has company sites.

Based on public information, there is limited evidence that the company provides targeted ethics training to Board members. The company therefore scores 1. To score higher the company would need to provide evidence of the scope and frequency of the ethics training.

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 clear and formal process by which employees declare conflicts of interest. Employees are told to notify either the Chief Executive Officer or the Director of Human Resources, and receive approval from the Board of Directors or the Board’s Audit Committee.

Based on public information, there is evidence that the company has a commitment to apply disciplinary procedures to employees found to have violated the Code of Business Conduct and Ethics. The company therefore scores 1. To score higher the company would need to provide evidence of an explicit commitment, using language such as ‘will’, to apply disciplinary procedures to employees and Board members found to have violated the Code of Business Conduct and Ethics.

Based on public information, there is evidence that the company has multiple, accessible, secure channels for employees to report concerns or instances of suspected corrupt activity. Channels include the Director of Human Resources, a local HR representative, the DOD Hotline or the VSE Audit Committee Hotline. Employees may report anonymously using the Hotlines. The company therefore scores 1. To score higher the company would need to provide evidence of an externally operated channel for employees to report to.

Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. Employees can report using a local HR representative, the DOD Hotline or the VSE Audit Committee Hotline.

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 evidence that the company has well-publicised resources available to all employees, where help and advice can be sought on corruption-related issues. These resources include local HR representatives and the Director of Human Resources.

Based on public information, there is evidence that the company has a non-retaliation policy 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.