- A
- B
- C
- D
- E
- F
Ownership
PUBLIC
Defence revenue, USD
Unknown
Defence revenue, %
Unknown
Country
FRANCE
Internal information
YES
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 evidence that the company publishes a statement of principles representing high standards of business conduct, including honesty and integrity with transparency also mentioned in relation to employees. However, unlike the company’s core values of humility, realism, the entreperneurial spirit and respect, these principles are not explained. The company therefore scores 1. To score higher the company must clearly explain why its principles representing high standards of business conduct matter to the organisation and how they are translated into company policies.
Based on public information, there is evidence that the company participates in the United Nations Global Compact.
Based on public information, there is no readily available evidence that the company has appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda. It is unclear if the Audit Committee has this responsibility as part of its task of supervising the quality and methods of internal and external control.
Based on public information, there is evidence that the company has appointed the company’s Ethics Officer with responsibility for implementing the company’s ethics and anti-corruption agenda. The company’s Ethics Officer reports directly to the Chairman of the Management Board. The Group Communication Director is the Executive Vice-President Communications and Investor Relations: Pierre-Antony Vastra.
Based on public information, there is evidence that the company undertook a major review of the company’s Code of Ethics in 2013. However, it is unclear if this was carried out at the Board level and how often future major reviews will occur. The company therefore scores 1.
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. However, there is some evidence to suggest that the Code of Ethics was improved in response to identified issues. The company therefore scores 0.
Based on public information, there is no readily available evidence that the company has a formal process for review and potential updates of its policies and practices 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. TI notes that non-compliance risk is part of the company’s risk management policy, but this appears to concentrate on employee behaviour rather than wider enterprise issues. The formality of the process is not clear and there is no evidence of risk mitigation plans.
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.
Based on public information, there is some evidence that the company makes clear to contractors, sub-contractors, and suppliers through policy, its stance on bribery and corruption and the consequences of breaches to this stance. The Code of Ethics states that the company only works with suppliers who accept the values of the Group and the Annual Report 2012-2013 details that employees have been trained to better explain policies to suppliers. The company therefore scores 1. To score higher the company must clearly explain the consequences of non-compliance and any contractual rights or sanctions.
Based on public information, there is evidence that the company has an anti-corruption policy in the Code of Ethics. However, the Code of Ethics does not cover all forms of corruption. TI notes it covers conflicts of interest, gift exchange and hospitality exchange. The company therefore scores 1. To score higher the company must have an anti-corruption policy that is explicit on the various forms corruption can take, in particular prohibiting the giving and receiving of bribes.
Based on public information, there is no readily available evidence that the company’s anti-corruption policy is explicitly one of zero tolerance.
Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible to employees. The Code of Ethics is communicated to every new employee and is available on the company’s intranet. Each Business Unit CEO must ensure that the Code of Ethics has been communicated to all their employees and corporate officers on a regular basis. TI notes that supervisory board members must sign an ethics charter but this is not publically available.
Based on public information, there is evidence that the company’s anti-corruption policy is reasonably understandable and clear to employees.
Based on public information, there is evidence that the anti-corruption policy explicitly applies to all employees. However, it is unclear if the anti-corruption policy applies to all members of the Board. The Supervisory Board is bound to an ethics charter that is not publically available, so TI is unable to determine if it is applicable. The company therefore scores 1.
Based on public information, there is evidence that the company has a policy on potential conflicts of interest. TI notes that a definition of a conflict of interest and example are provided.
Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts. However, the policy does not clearly state what gifts are acceptable to give or receive, instead referencing gifts that would form part of ‘normal business.’ The company therefore scores 1. To score higher the company would need to provide evidence of clear upper limits or a specific threshold necessary for senior authorisation.
Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality. However, the policy does not clearly state what hospitality is acceptable to give or receive, instead referencing hospitality that would form part of ‘normal business.’ It also does not explicitly specify hospitality, instead using the terms ‘gifts, invitations and other favours.’ The company therefore scores 1. To score higher the company would need to provide evidence of clear upper limits or a specific threshold necessary for senior authorisation.
Based on public information, there is no readily available evidence that the company has a policy that prohibits facilitation payments. TI notes that the company does indicate that payments to public officers are not permitted. However, TI assesses this is not an explicit statement against facilitation payments.
Based on public information, there is no readily available evidence that the company prohibits political 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 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 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. The Code of Ethics is not particularly detailed and contains few scenarios or other guidance material.
Based on public information, there is 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. Anti-corruption training is only provided to employees who are most exposed to corruption risks. The company therefore scores 0.
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 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 in writing. TI notes that employees are simply directed to their manager, who will decide whether this information needs to be transmitted to the company’s Ethics Officer.
Based on public information, there is no readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.
Based on public information, there is evidence that employees can report concerns or instances of suspected corrupt activity to the Group’s Ethics Officer. The company therefore scores a 1. To score higher, the company would need to provide evidence that employees may also report anonymously and to an independent channel.
Based on public information, there is no readily available evidence that the company has whistleblowing channels available to all employees in all geographies. It is unclear if globally employees can report to the Group’s Ethics Officer, as their contact details are not publically available. Also, TI deems reporting to a line manager as a limited whistleblowing channel.
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 resources available to all employees where help and advice can be sought on corruption-related issues, but these resources are very limited in nature. Employees are instructed to consult their manager or the company’s Ethics Officer in the event of uncertainties with the Code of Ethics. However, it is not clear that the contact details for the company’s Ethics Officer are well-publicised. The company therefore scores 1.
Based on public information, there is no readily available evidence that there is a commitment to non-retaliation for bona fide reporting of corruption.
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.