Conflict Minerals

Gold, along with tin, tantalum and tungsten are defined conflict minerals.

Background
In 2012, the Securities and Exchange Commission (SEC) adopted rules implementing the conflict minerals provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), which require public companies to disclose certain information when a company manufactures or contracts to manufacture products containing Conflict Minerals that are necessary to the functionality or production of those products if the company has reason to believe that the Conflict Minerals may have originated in the Democratic Republic of the Congo (DRC) and the adjoining countries of  Angola, Burundi, the Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia (the Covered Countries). The term “Conflict Minerals” is defined in the conflict minerals rules and refers to tin, tantalum, tungsten and gold (the Conflict Minerals or 3TG).

Our Policy

Lockheed Martin supports the Dodd-Frank Act’s objective of preventing armed groups in the Covered Countries from benefitting from the sourcing of Conflict Minerals from that region. Substantially all of our products contain 3TG. We are committed to responsible sourcing of materials for our products, including the sourcing of Conflict Minerals, and we expect that our suppliers are likewise committed to responsible sourcing. We recognize that the mining of the Conflict Minerals are an important economic driver in the region and are committed to supporting legitimate mining operations. We have established a due diligence program which follows the framework established by the Organisation for Economic Cooperation and Development (OECD). Due to the enormity of Lockheed Martin’s and its suppliers’ respective supply chains, it will take time for many suppliers to fully adopt program elements that help verify the origin of conflict minerals.

We expect our suppliers to comply with our Supplier Code of Conduct, which is referenced under our Supplier Ethics and Supplier Sustainability webpages and is incorporated into our purchase orders.  Our Supplier Code of Conduct includes our expectations that suppliers take steps to determine if their products contain Conflict Minerals and if so, implement supply chain due diligence processes to identify sources of these minerals and support efforts to eradicate the use of Conflict Minerals which directly or indirectly finance or benefit armed groups in the Covered Countries.

We support with financial and human capital industry-wide initiatives, including the Conflict-Free Sourcing Initiative (CFSI) and Aerospace Industries Association (AIA) which assists with our benchmarking and smelter analysis efforts.

We will comply with the requirements of the Dodd-Frank Act, including filing a report annually with the SEC and making such report available on our public website.

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For questions regarding our conflict minerals policy, email us at conflict.minerals.info@lmco.com or call our Corporate Ethics HelpLine at 1-800-LM-ETHIC.