Well implemented programs drive strong culture and reduce ethical risks. Every company should ask itself, "Is our compliance program meeting expectations?"
At Aerojet Rocketdyne (AR) Holdings we implement the following elements to assess our ethical culture; these tools allow us to evaluate what we are doing right and what areas have an opportunity for improvement:
- Leadership Commitment Scorecard
Our Leader Commitment Scorecard reflects our intent to demonstrate leadership commitment to practice high ethical standards and foster trust. "Ethics Champions" (Ethics representatives at each site and business unit) assess the performance of their leader against six objectives regarding leader accessibility, ethical behavior, and their adherence to compliance requirements. Reviewing the scorecard with the leader each month allows for continuous ethical messaging and also will highlight areas needing improvement.
- Bi-Monthly Ethics Poll
Every other month a poll is delivered to a random sample of the workforce and asks "Does your manager demonstrate his or her commitment to the highest ethical standards?" Employees respond using an anonymous online polling process to record their answer and submit comments.
Our commitment to communicate our ethical standards is more than a matter of providing information - it embodies our vision that managers "walk the talk" and demonstrate their personal commitment to ethical business practices in everything they do.
Employee feedback is a valued barometer which helps assess our progress in embedding a culture of responsible business conduct. All employee feedback is reviewed and strongly encouraged.
- Defense Industry Benchmark (DIB) Survey
Bi-annually, AR Holdings participates in the DIB, managed by Ethics Resource Center (ERC). The DIB survey acts as a basic ethical barometer and allows us to measure specific facets of our ethical culture, leadership, and engagement against other comparable companies in the aerospace industry.
Results of the survey allow us to focus on areas that are below the defense industry standard, as well as to reinforce areas shown to be strong program elements.
AR Holdings conducts annual self-assessments of its Ethics & Compliance program to ensure it maintains and adequately fulfills all the elements of a world-class Ethics & Compliance Program. The program is baselined against criteria set forth by the Federal Sentencing Guidelines (FSG), the Federal Acquisition Regulations (FAR), and the Defense Industry Initiative (DII) standards. This approach allows for a continuous improvement process aimed at identifying evolving requirements, incorporating the latest standards, and adopting industry best practices.
- Internal Audits & Risk Monitoring
AR Holdings maintains specific resources to review internal operating functions and adherence to governing policies and regulations. Results are consolidated, elevated for proper action as needed, and tracked to resolution across the enterprise. AR Holdings has also adopted a formal Enterprise Risk Management program to identify, track, and mitigate risk to the business, its operations, and our ongoing ability to meet our customer, regulatory, and community obligations.
- Independent Third-Party Assessment
AR Holdings utilizes independent third-party expertise to periodically assess our overall Ethics & Compliance Program to identify opportunities and any recommended or needed improvements. The third-party perspective complement the recurring internal audits, reviews, and self-assessment process to ensure all the essential elements of a healthy, high-functioning Ethics & Compliance program are incorporated and maintained. These results are periodically presented to the AR Holdings Board of Directors for visibility, awareness, and resource allocation as needed.