8.1 Does the company explicitly address the corruption risks associated with offset contracting, and is a dedicated body, department or team responsible for oversight of the company’s offset activities?
HII does not currently, and has not historically, entered into contracts that require an offset obligation. However, HII recognizes that certain foreign governments impose offset conditions as a matter of course. Offsets involve significant commercial, legal, and regulatory risks. For a U.S. defense contractor such as HII, offsets involve certain reporting requirements to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS). Such contracts also carry commercial and corruption risks. As a result, HII has adopted a formal procedure to govern offsets should the issue arise.
Under HII’s procedure, all offsets must be approved at the Corporate level with input from relevant departments including legal, finance, and compliance. HII is committed to ensuring that any offset contract has been fully assessed for corruption risks and cleared by the Compliance Office.
8.2 Does the company conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations, which includes an assessment of the legitimate business rationale for the investment?
HII does not currently, and has not historically, entered into contracts that require an offset obligation. However, we are committed to ensuring compliance with anti-corruption laws in all aspects of our domestic and international operations. To the extent we are presented with a business opportunity that involves an offset contract, we will conduct a full review for anti-corruption compliance. This will include a careful assessment of the business rationale for the investment.
8.3 Does the company publish details of all offset agents and brokers currently contracted to act with and/or on behalf of the company?
HII does not engage offset agents or brokers.
8.4 Does the company publish details about the beneficiaries of its indirect offset projects?
HII does not currently, and has not historically, entered into contracts that require an offset obligation, whether direct or indirect.