1.1. Does the company have a publicly stated anti-bribery and corruption commitment, which is authorised by its leadership?
In our day-to-day operations, HII emphasizes and reinforces our deeply engrained value culture. This culture starts at the top, and is lived by employees at all levels. Our core company values—integrity, safety, honesty, engagement, responsibility, and performance—are described in detail for employees and the public, and form the pillars on which our shared commitment to ethical behavior rests. At HII, ethical business practices are viewed as paramount. Our Chief Executive Officer, Mike Petters, sends regular reminders to employees regarding their compliance obligations. His stance on ethical behavior is featured prominently on the Ethics and Compliance page of our website. His approach to and position on anti-corruption compliance is clear in our Anti-Corruption Program Statement. “HII is committed to delivering quality products and services. That means we do not tolerate bribery or corruption, and that we are committed to ethical and compliant business practices everywhere we do business.”
As a responsible government contractor, HII is responsible for preventing and detecting all forms of misconduct. To fulfill that responsibility, we created an overarching anti-corruption program that articulates our zero-tolerance approach toward corruption and bribery. This program is described on our website, which includes a clear statement that HII does not tolerate bribery and corruption. Our anti-bribery and corruption commitment is also articulated clearly in our道德与商业守则,可在我们的网站上找到。
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1.2。该公司是否具有全面的反贿赂和腐败政策,明确适用于以下两个类别:
a)所有员工,包括子公司和其他受控实体的员工和领导;
b) All board members, including non-executive directors.
HII has a comprehensive anti-bribery and corruption procedure that applies to all directors, officers, employees, and anyone else acting on HII’s behalf. OurForeign Corrupt Practices and Anti-Bribery Procedure严格禁止董事,高级管理人员和雇员或代表HII行事的任何人,包括分部和子公司,不参与贿赂和腐败行为。
禁止活动的范围包括向外国官员,商业贿赂,促进付款和其他形式的腐败付款。任何被发现已违反HII程序或适用的反贿赂法的雇员将遵守纪律处分,包括可能的终止。
1.3. Does the board or a dedicated board committee provide oversight of the company’s anti-bribery and corruption program?
HII’sBoard of Directorsandbeplay体育怎么下载提供合规计划的监督。自2013年以来,HII首席合规官Chad Boudreaux和HII首席法律官Kellye Walker定期向全部董事会报告HII合规计划的实施和有效性,包括反贿赂和反腐败计划。这些报告至少每年发生,包括与合规计划各个方面以及有关合规计划的其他指标有关的外部和内部审核的发现的最新信息。
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1.4 Is responsibility for implementing and managing the company’s anti-bribery and corruption program ultimately assigned to a senior executive, and does he or she have a direct reporting line to the board or board committee providing oversight of the company’s program?
HII的公司副总裁,秘书兼副法律顾问已被指定为HII的反腐败计划的负责任副总裁。秘书对与反腐败计划有关的政策和程序负有职能责任,例如《外国腐败法》和反贿赂程序以及与第三方代表程序的协议。秘书以这种身份直接向首席合规官报告,他对合规计划的管理和持续发展负有总体责任。首席合规官至少每年就合规计划向董事会报告。