Anti-Corruption Program and Policies
“As you know, the first of Lockheed Martin’s core values is to 'do what’s right.' For this reason, we have a policy of zero tolerance for corruption. We believe corruption erodes trust in government institutions, distorts markets and creates unfair competition that ultimately increases costs and negatively affects the quality of products and services. We expect our employees – and anyone who acts on behalf of the corporation – to comply with applicable Anti-Corruption Laws whether they are located in the United States or abroad."
Marillyn A. Hewson
Chairman, President and CEO
Anti-Corruption Program Resources
CPS-730, Compliance with the Anti-Corruption Laws states that the Corporation “will not engage in, or otherwise tolerate, any form of bribery or corruption in its business dealings.” The policy outlines the Corporation’s formal anti-corruption risk assessment procedure, the circumstances under which such a procedure should be applied, and the internal stakeholders responsible for different aspects of the procedure. The policy strictly prohibits facilitating payments. This policy requires that this or a similar anti-corruption program is adopted by our subsidiaries, and that we use our best efforts to ensure that entities in which we own a substantial interest have anti-corruption controls.
CPS-008, Gifts, Hospitality, Other Business Courtesies, and Sponsorships provides specific guidance on the exchange of gifts, hospitality, other business courtesies and sponsorships with different types of organizations, including representatives of commercial entities or academic institutions, U.S. state and local employees, U.S. Executive Branch employees, U.S. Legislative Branch employees, members of the U.S. Judiciary, and non-U.S. public officials. This policy requires that our guidance on gifts, hospitality, other business courtesies and sponsorships is adopted, in substantial part, by our subsidiaries. It also requires that we communicate an expectation that similar guidance is adopted by entities in which we own a substantial interest.
International Hospitality Rules. Giving gifts, hospitality, and other business courtesies to Lockheed Martin international business relations may be governed by the anti-corruption laws and regulations of other countries. Accordingly, Lockheed Martin has developed guidance for its employees through its “International Hospitality Rules” for more than 100 countries where the Corporation currently does or may do business. Those who are not Lockheed Martin employees, but who are working on its behalf, are not allowed to provide anything of value on behalf of Lockheed Martin without prior approval and direction of their point of contact within the Corporation.
Code of Ethics & Business Conduct, Setting the Standard explains how we must conduct ourselves when representing or acting on behalf of our company. It details the high expectations we set for employee behavior, from our commitment to good citizenship to our zero tolerance policy on corruption.
CPS-001, Ethics and Business Conduct is our overarching policy governing our ethics program and how we ensure that those who work on our behalf are made aware of and held accountable to our ethics and business conduct standards. This policy requires that our ethics and business conduct program is adopted in substantial part by our subsidiaries, and that we communicate an expectation that a similar ethics program is adopted by entities in which we own a substantial interest.
CONTACT CORPORATE ETHICS
Corporate Ethics HelpLine:
Monday-Friday 8am-5pm ET
6801 Rockledge Drive
Bethesda, MD 20817
For more information on contacting Ethics, please review our How the Ethics Process Works brochure.