Anti-Corruption Program and Policies

Lockheed Martin – a signatory of the Defense Industry Initiative for Ethical Business Conduct (DII) and a charter member of the International Forum on Business Ethical Conduct (IFBEC) – is committed to the highest standards for ethical business conduct as a key component to our business strategy. When it comes to anti-corruption, our continued commitment to increased transparency helps to ensure a level playing field and prevent the devastating social and economic consequences of corruption in the places where we do business. 

“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.

Form C-730-1, International Anti-Corruption Questionnaire

Form C-730-2, Anti-Corruption Law Certification

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.

Bribery and Corruption Red Flags are facts, events, circumstances or other information that may indicate a potential legal compliance concern for illegal or unethical business conduct, particularly with regard to corrupt practices and non-compliance with anti-corruption laws. When conducting due diligence on a third party (or any intermediary), these “red flag” examples should always trigger concern and appropriate review by Legal.

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.

Other Policies Related to Our Anti-Corruption Program

Contact Corporate Ethics

Corporate Ethics HelpLine:

800-LM-ETHIC (800-563-8442)
Monday-Friday 8 a.m. - 5 p.m. ET

Email Address:

Corporate.Ethics@lmco.com

Mailing Address:

6801 Rockledge Drive
Bethesda, MD 20817

All contacts to the Ethics organization are handled confidentially.
For more information on contacting Ethics, please review our 
How the Ethics Process Works  brochure.