6.1 Does the company require the involvement of its procurement department in the establishment of new supplier relationships and in the oversight of its supplier base?
HII has detailed controls around its procurement and purchasing process. Central among these controls is the involvement of a dedicated procurement department within each division, the Supply Chain Management Department, in the establishment and monitoring of supplier relationships.
Under HII’s供应链管理Procedure, when material and/or services are required to be purchased from external (non-HII) sources in support of Company operations and/or production schedules, Supply Chain Management has the sole responsibility to establish and manage the external contractual relationship.
The procurement process is also subject to regular and extensive internal and external audit. On an annual basis, our procurement process is audited by the Internal Audit department. The procurement process is also subject to audit by external auditors as well as government auditors such as the U.S. Navy’s Supervisor of Shipbuilding.
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6.2 Does the company conduct risk-based anti-bribery and corruption due diligence when engaging or re-engaging with its suppliers?
As a U.S. government contractor, we understand the need to ensure that our suppliers are conducting business in an ethical manner. We consider carefully not just each supplier’s performance, but also their reputation for ethical practices when selecting suppliers. We apply an extensive due diligence screening process to each of our suppliers, including checks on the beneficial owners of each. Any suppliers that present as high risk from a corruption standpoint will be subject to additional review by the Law Department.
Specific due diligence procedures are developed by each Division, depending on the level and types of risks presented by their own suppliers. Each Division is also responsible for establishing a process for an annual review of its active suppliers.
HII希望其所有供应商,无论合同价格或与供应商的互动频率如何,都以符合供应商行为守则的方式开展业务。HII以其合同条款和条件的条款来支持这一期望:“如果违反了《供应商行为准则》中规定的任何期望,[HII]可能会采取纠正措施来纠正这种情况,直到并包括终止该合同。”
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6.3 Does the company require all of its suppliers to have adequate standards of anti-bribery and corruption policies and procedures in place?
HII的供应商《行为准则》描述了我们供应商的一系列高道德标准。至少,我们希望我们的供应商完全遵守适用于其业务的法律和法规。
As part of the onboarding process, HII requires that all suppliers have adequate anti-bribery and corruption policies in place to prevent and detect misconduct. Such policies and procedures must cover gift and business courtesies, conflicts of interest, and whistleblower protections.
《供应商行为准则》清楚地表明,HII的供应商不得向政府官员,政党,公职候选人或其他人提供任何不当付款或任何有价值的款项。这包括禁止促进旨在加快或确保执行常规政府行动的付款,例如获得签证或关税。
为了确保遵守HII的反腐败计划和适用的反贿赂和腐败法,我们采取了积极的步骤来评估供应商的行为,包括何时在业务关系发生重大变化时。
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6.4 Does the company ensure that its suppliers require all their sub-contractors to have anti-corruption programs in place that at a minimum adhere to the standards established by the main contractor?
We work with suppliers of various sizes and anti-corruption risk profiles. We expect our suppliers to have management systems in place to support compliance with laws, including anti-corruption laws, understanding that smaller and less sophisticated suppliers may have less formal and advanced compliance programs. At a minimum, we encourage our suppliers to implement their own written code of conduct and to flow down the principles of a code of conduct to their own suppliers and subcontractors.
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6.5 Does the company publish high-level results from ethical incident investigations and disciplinary actions against suppliers?
HII致力于调查其供应商的所有不道德和腐败行为的报告。每个案例都进行了彻底的研究。如果事实证明违反了适用的反贿赂或腐败法或《供应商的行为准则》,我们将立即采取纠正措施来纠正违规行为,包括可能终止业务关系。在适当的情况下,HII还将向政府机构实例披露,其中它意识到供应商不当行为的可靠证据。