4.1 Does the company have a policy defining conflicts of interest–actual, potential and perceived–that applies to all employees and board members?
HII requires every employee to avoid any situation that would result in, or give the appearance of, a conflict between any personal interests and the interests of HII and its customers. We do not intend to unnecessarily restrict employees’ ability to engage in outside businesses or other activities that do not conflict with or substantially impair the performance of their job responsibilities or other obligations to HII. We do, however, expect all employees to fulfill the duties and responsibilities of their jobs in a manner that does not result in (or create the perception of) their job performance being influenced by outside factors that cause them to put personal interests before those of HII and its customers.
Conflicts of interest are also prominently addressed in our Code of Ethics and Business Conduct, which applies to all officers, directors, and employees (as well as non-employees who work on HII’s behalf). Recognizing the importance of this issue, we have made compliance with laws, rules, and regulations related to conflicts of interest a Core Element of our Compliance Program. Dedicated Work Plans at the Corporate and Division levels are developed on an annual basis to manage this risk, with responsible managers at all levels of HII.
We have also implemented a formal procedure, Personal Conflicts of Interest, that specifically addresses conflicts of interest and applies to all employees and board members. The Personal Conflicts of Interest Procedure addresses, among other things, conflicts involving: (i) other employment by HII personnel, including government employment; (ii) financial conflicts, including personal and familial interests in companies doing business with HII; (iii) business courtesies; and (iv) dealing with former HII employees.
4.2 Are there procedures in place to identify, declare and manage conflicts of interest, which are overseen by a body or individual ultimately accountable for the appropriate management and handling of conflict of interest cases?
Under the Personal Conflicts of Interest Procedure, employees are required to promptly disclose any relationship or activity that could result in or create the perception of a conflict of interest. Such disclosures are made in a specially-designed form and provided in the first instance to the individual’s direct manager. Potential conflicts that require disclosure include, among other things: (i) performance of outside work (whether compensated or not) for a present or prospective customer, supplier, or other business associate; (ii) any financial interest (held personally or by a family member) in a customer, supplier or business associate;
(iii) establishment of a debtor/creditor relationship by the employee or his or her family member and a customer, supplier, or business associate; (iv) stock ownership in any entity with whom the company does business; and (v) investment or speculation, by the employee or any family member, in equipment, real estate, materials, or other property purchased or sold by the company or the purchase or sale of which is contemplated by the company.
After the manager has made an assessment of the potential conflict, he or she will document the assessment in the same disclosure form. The form will then be submitted to the appropriate Ethics and Business Conduct Office, which, in consultation with the Law Department, will make the final determination on the conflict of interest. All declarations are maintained by the Ethics and Business Conduct Office for a minimum period of six years.
Failure to disclose a potential conflict can result in discipline up to and including termination.
4.3 Does the company have a policy and procedure regulating the appointment of directors, employees or consultants from the public sector?
As a U.S. federal government contractor, HII is subject to various U.S. laws governing the retention of current and former U.S. government employees. As such, HII has careful controls in place around the appointment of current or former public officials. A Core Element, “Revolving Door” has been established to assess and mitigate the risk. Several procedures govern and restrict the practice including Public Integrity Act Compliance and Employment of Current and Former U.S. Government Officials. Under company policy, we will not engage in any employment discussion with any current public official where such discussion would violate laws or give the appearance of the conflict. We closely follow U.S. laws that prevent us from compensating former U.S. government officials for a period of one year following their departure from the government if they served in significant procurement-related positions or otherwise made decisions related to HII. For certain U.S. Department of Defense employees, our restrictions extend to two years from when the individual left the Department of Defense.
HII is likewise committed to observing the laws of all relevant jurisdictions concerning employment of former foreign public officials. Employment of former foreign public officials is also restricted by our Foreign Corrupt Practices and Anti-Bribery Procedure.
Candidates for employment are required to complete various forms in order to allow HII to assess eligibility for employment. Under HII policy, if an applicant’s forms suggest that employment might be restricted due to prior government employment, the candidate may not be hired until the Law Department provides a written opinion.
4.4 Does the company report details of the contracted services of serving politicians to the company?
HII does not contract serving U.S. politicians. HII will only engage a foreign politician if his or her duties are entirely unrelated to HII business and will not create an actual or apparent conflict of interest with his or her responsibilities with HII. HII does not currently engage any foreign politicians.