Aerojet Rocketdyne (AR) Holdings fully complies with all anti-corruption and anti-bribery prohibitions as stated in the US Foreign Corrupt Practices Act, the United Kingdom Bribery Act, and all other applicable laws, regulations and company policies.
Company policy states that each Board Director, officer, executive, manager, and employee of AR Holdings is responsible for the compliance with these laws and must report any suspected violations. The importance of complying with these regulations is communicated to each employee through company directives and periodic training. Furthermore company policy requires suspected violations to be fully investigated and the Board of Directors and senior management are responsible to ensure thorough corrective action is taken to prevent recurrence. Resulting or required corrective action can be disciplinary or administrative in nature, applicable to Board members and employees alike, or procedural/regulatory as dictated by the type of violation.
Anti-Bribery and Anti-Corruption risk is also actively managed at the Board of Directors and executive management level through a company-wide Enterprise Risk Management process.
The company also has a targeted anti-corruption module as part of its ethics and compliance training program, more specifically aimed at the higher risk areas of Business Development and Program Management. There is annualized, computer-based interactive anti-corruption/bribery training provided to the Board and these key functional personnel to augment policy understanding, offer practical application, and increase situational awareness to mitigate corruption and bribery risk in daily job execution. Additionally, the company maintains access to services to conduct due diligence that minimizes corruption risk when selecting or reappointing agents.
Lastly, AR Holdings has specifically instituted policies regarding engagement in lobbying activities and protocols for making charitable contributions in order to prevent undue influence or other corrupt intent.