If you perform work internationally, you are subject to the laws and regulations of the countries where we do business. You may find conflicts between the laws of the countries where we operate and the laws of the U.S. or our Corporation’s policy.
Unless prohibited or penalized by U.S. law, you are responsible for complying with the national and local laws of the countries in which we operate.
Why We Do It
Our high standards of ethical business conduct are a key component of our business strategy that enables us to build customer relationships and win programs around the world.
Bribes, export and import violations and illegal boycotts damage the trust and transparency needed to transact business.
Corruption creates unfair competition, increases cost and jeopardizes the quality and capability of our products and services.
Non-compliance can result in potential debarment, incarceration and monetary penalties.
Corruption destabilizes economies and damages the fabric of society.
You must strictly comply with the anti-corruption laws that govern our operations in the countries where we do business. These laws include the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act and similar laws in other countries.
What do these laws do?
Prohibit direct or indirect bribery of U.S. and international government officials, political parties, party officials, or candidates for public office or employees of commercial organizations to obtain or retain business or an improper business advantage.
Prohibit knowingly falsifying books and records or knowingly circumventing or failing to implement adequate internal accounting controls, which could facilitate or conceal bribery.
Our policy prohibits offering or making improper payments of money or anything of value. The policy applies to
conducting business on behalf of Lockheed Martin.
We require strict compliance with all export and import laws and regulations that cover the transfer of certain technical data, equipment and technology between countries.
You may not obligate Lockheed Martin to engage in trade in any country subject to trade restrictions imposed by the U.S. government.
Before you negotiate or enter into an international transaction, consult with the International Trade Compliance Office, Legal Department or Ethics Office.
These restrictions can include sanctions or embargoes that prohibit Lockheed Martin from engaging in certain business activities in specified countries, and with specified individuals and entities. For example, U.S. law prohibits interaction with identified terrorist states and organizations.
International trade laws and regulations are complex. Be careful to avoid even inadvertent violations.
Do not engage in or support restrictive international trade practices or boycotts not sanctioned by the U.S. government.
Do not enter into an agreement, provide any information or take any action that would cause Lockheed Martin to refuse to deal with potential or actual customers, suppliers or others in support of an illegal boycott.
All requests, whether written or oral, must be reported immediately to the Legal Department or Ethics Office.