Our programme is embedded in our Operational Framework, through key policies and processes below:
  • Code of Conduct – which explicitly prohibits the giving or receiving of bribes by BAE Systems employees;
  • Advisers Policy – which governs the appointment, management and payment of third parties who are engaged to assist with our sales and marketing activities or the strategic development of the Group;
  • Gifts and Hospitality Policy – which governs the offering, giving or receiving of gifts and hospitality;
  • Conflict of Interest Policy – designed to ensure that personal conflicts of interest do not impair employees’ judgement and damage the Group’s integrity and interests; and
  • Facilitation Payments Policy – designed to ensure that facilitation payments are not paid and that the Group and its employees seek to eliminate the practice of facilitation payments.
Other relevant policies include: Community Investment Policy; Finance Policy; Fraud Prevention Policy; Export Control Policy; Pursuit of Export Opportunities Policy; Lobbying, Political Donations and Other Political Activity Policy; Offset Policy and Procurement Policy, which include measures to address bribery and corruption risks.
The anti-corruption programme guides and supports our employees in making responsible decisions.
2021 total ethics enquiries
We collect data on ethics enquiries and dismissals for reasons relating to unethical behaviour.
During 2021, we received 1,316 enquiries, an increase of 18% compared to 2020. We attribute this upward trend to a drop in enquiries in 2020 due to the onset of COVID-19 and the associated change in working patterns seen around that (for example, working from home means employees are less likely to observe poor behaviour). 2021 has seen more of a return to 2019 levels of enquiries (2019 1,432).
2021 ethics enquiries by type
Of the 1,316 enquiries received, 634 (48%) required investigation, 30% of which were substantiated. The top five categories for investigation were: employee conduct, accounting charge practices, employee relations, management practices, and safety, health and environment. Of the 634 investigations for 2021, 548 were closed and 86 remain open. These will be closed out during 2022.
Seven ethics enquiries were received about our suppliers. One enquiry required investigation but was not substantiated.
2021 ethics enquiries by region
68% of ethics enquiries came from the US. The number of ethics reports varies by region. Factors influencing this include the number of individuals working in that region and the cultural propensity of individuals from that region to utilise Speak Up mechanisms.
2021 anonymity rate
We value openness, and strive to create a culture where people feel they can speak up freely. Our main metric is the number of enquiries made, and more specifically the number of enquiries per 1,000 employees. We also measure the proportion of requests for guidance compared to reports requiring investigation, anonymity rate and contacts made directly to one of our 206 Ethics Officers (one for every 400 employees) across our business. In 2021 our anonymity rate was 35% compared to 32% from 2020, and 35% in 2019, still well below the benchmark rate of 58%3.
42% of reports were made directly to Ethics Officers in 2021 – we encourage this route for making reports, as it allows for an immediate response by someone familiar with the local situation. However, we are pleased that employees are using the options available to report issues or obtain guidance, whether they choose to do so anonymously or otherwise.
2021 dismissals for reasons relating to unethical behaviour
In 2021, 281 employees were dismissed due to misconduct, which may include breaches of the Code. The majority of this 19% increase from 2020 occurred in our US business and generally related to non-compliance with established COVID-19 protocols and requirements.
1. BAE Systems Internal Audit has reviewed and confirmed effective systems, processes and controls are in place to collate and validate this data.
2. We have updated our ethics enquiry reporting categories internally to reflect trends in reporting and to achieve greater commonality in reporting categories across the business.
3. Navex 2021 anonymity benchmark.