Anti-Corruption Program and Policies

Anti-Corruption Program and Policies

Lockheed Martin has established a comprehensive Anti-Corruption Program (ACP) to identify, manage, and mitigate corruption risks associated with the Corporation’s business activities. The primary objective of the ACP is to effectively promote an organizational culture that encourages conduct compliant with anti-corruption laws and Lockheed Martin’s Code of Ethics and Business Conduct, Setting the Standard.  The ACP is built upon the following principles:

  • Commitment from Leadership to lead and foster a culture of anti-corruption compliance where individuals are encouraged to ask questions and report concerns;
  • Establishment of roles and responsibilities for individuals including appropriate levels of authority and accountability to oversee the implementation of the ACP and assure proper allocation of resources;
  • Continuous assessment and monitoring of corruption risks to ensure appropriate steps are taken to mitigate and prevent occurrence;
  • Effective and continuous training to ensure that the Corporation’s policies are effectively communicated, understood, and followed;
  • Effective enforcement of the ACP through timely and fair application of appropriate incentives and discipline;
  • Performance of risk-based due diligence of business relations;
  • Provision of efficient, timely, and uniform anti-corruption legal advice across the Corporation.

Click here to view a message commemorating International Anti-Corruption Day from Lockheed Martin Chairman, President & CEO, Jim Taiclet.


Anti-Corruption Program Resources

Lockheed Martin policies and procedures, including CPS-008 and CPS-730, are reviewed and updated on a regular basis to identify and address changes in laws, regulations, and the global environment, as well as any gaps, issues or lessons learned. Updates may occur as frequently as every year.

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.

Due Diligence: Lockheed Martin policies, including CPS-730 (Compliance with Anti-Corruption Laws and CRX-011 (International Business Development Consultants), require that the company exercise risk-based due diligence before entering into third-party agreements, including for joint venture or teaming agreements and with suppliers and international consultants. Due diligence processes include, but are not limited to, establishing the third party’s associated persons and ultimate beneficial ownership, ensuring a legitimate business justification and the legality of the proposed relationship, and confirming the continuing, likely legal and ethical business conduct of the party.  These processes require fact-finding to identify any potential “red flags” and, even where no specific flags may otherwise be present, an understanding and application of general risk.  For example, a potential business partner operating in a country with a Transparency International Corruption Perceptions Index score below 50 may require enhanced due diligence based on that fact alone.  The due diligence process is not complete until appropriate anti-corruption representations and warranties, or other similar contract terms or certifications are obtained from the third party which require its understanding and agreement to abide by anti-bribery and anti-corruption standards. This requirement to abide by applicable anti-corruption standards is flowed down to subcontractors used by such third parties.

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

Conflict of Interest FAQs

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.