Internal Controls

All employees involved in sales and business development apply our Responsible Trading Principles, our Product Trading Policy and, where relevant, policies on other issues such as facilitation payments, use of advisers, gifts and hospitality (see key policies). 

Our Product Trading Policy is designed to help employees identify and address any responsible trading risks.

It is applied to the development, production, sale, transfer, or disposal of any product or service. It takes into account risks associated with the product and its intended end use, the country of origin and delivery, and the customer. It requires employees to consider factors such as:

  • Does the product fulfil its intended purpose and match the customer’s stated requirement?
  • Does the product conform to our product safety policy?
  • Is the product able to distinguish planned from unintended targets? Is it proportionate to the role and necessary for its intended purpose?
  • Can it reasonably be anticipated that the product will be controlled or prohibited in the foreseeable future?
  • Is the product an entirely new class of weapon or capability?
  • Is there a significant, specific and foreseeable risk of the product being diverted or transferred to an unapproved user or utilised for an unauthorised purpose?
  • Does the product create a significant lasting adverse environmental or health impact over and above that reasonably necessary in its manufacture, storage, deployment, use or disposal?
  • Can the product’s end use reasonably be expected to violate civil liberties or human rights?

Contracts identified as posing a responsible trading risk must be approved at a more senior level of the company, up to and including the Chief Executive, and will be managed through our Lifecycle Management Framework, which includes regular management review.

Export sales must also comply with our Pursuit of Export Opportunities Policy. We categorise existing and potential markets according to their commercial importance and whether they could pose a reputational risk to our business. Risks considered include corruption and human rights risks, and the risk of product diversion (when a product is sold on or when a dual use product is converted from civilian to military use). Sales that could pose a responsible trading risk must be reviewed/ approved by senior management.