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 Code of Ethics and Business Conduct, available on our website.
Important related documents and links:
1.2. Does the company have a comprehensive anti-bribery and corruption policy that explicitly applies to both of the following categories:
a) All employees, including staff and leadership of subsidiaries and other controlled entities;
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. Our Foreign Corrupt Practices and Anti-Bribery Procedure strictly forbids directors, officers, and employees, or any persons acting on behalf of HII, including divisions and subsidiaries, from engaging in acts of bribery and corruption.
The scope of prohibited activity includes payments to foreign officials, commercial bribery, facilitation payments, and other forms of corruption. Any employee found to have made, authorized, or directed a payment or offer in violation of HII’s procedures or applicable anti-bribery laws will be subject to disciplinary action, including possible termination.
1.3. Does the board or a dedicated board committee provide oversight of the company’s anti-bribery and corruption program?
HII’s Board of Directors and Senior Executive Team provide oversight to the Compliance Program. Chad Boudreaux, HII’s Chief Compliance Officer since 2013, and Kellye Walker, HII’s Chief Legal Officer since 2015, regularly report to the full Board of Directors regarding the implementation and effectiveness of HII’s Compliance Program, including the anti-bribery and anti-corruption program. These reports, occurring at least annually, include updates on findings from external and internal audits related to all aspects of the Compliance Program and other metrics regarding the Compliance Program’s performance.
Important related documents and links:
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’s Corporate Vice President, Secretary and Associate General Counsel has been designated as the Accountable Vice President for the anti-corruption program at HII. The Secretary has functional responsibility for policies and procedures related to the anti-corruption program, such as the Foreign Corrupt Practices Act and Anti-Bribery Procedure and the Agreements with Third Party Representatives Procedure. In this capacity, the Secretary reports directly to the Chief Compliance Officer, who has overall responsibility for the management and continued development of the Compliance Program. The Chief Compliance Officer reports to the Board of Directors at least annually regarding the Compliance Program.