L3 Communications Holdings Inc.

Based on public information, there is evidence that the company has published several strong statements from Chairman, President and CEO Michael T. Strianese, supporting the ethics and anti-corruption agenda of the company. These statements can be found in the Code of Ethics and Business Conduct, the Annual Reports and on the company website.

Based on public information, there is evidence that the company’s Chairman, President and CEO demonstrates a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. TI also notes that the company’s Chairman, President and CEO currently holds the Chairmanship of the AIA (Aerospace Industries Association). However, this evidence is inapplicable, as the AIA does not have a sufficient anti-corruption focus.

Based on public information, there is no readily available evidence that the company’s CEO demonstrates a strong, personal, internal-facing commitment to its ethics and anti-corruption agenda.

Based on public information, there is evidence that the company has a statement of values representing high standards of ethical business conduct, including integrity, honesty, trust and accountability. The company explains what they mean by such values and why they matter to the organisation.

Based on public information, there is evidence that the company is a member of DII and IFBEC.

Based on public information, there is evidence that the company’s Audit Committee has overall corporate responsibility for the company’s ethics and anti-corruption agenda. Clear terms of reference detail what this responsibility entails, including reviewing any ethical matters brought to the attention of the Corporate Ethics Officer.

Based on public information, there is evidence that the company has appointed Corporate Ethics Officer Alfred Piccirillo, with responsibility for implementing the company’s ethics and compliance agenda. Evidence suggests that the Corporate Ethics Officer has a direct reporting line to the Audit Committee.

Based on public information, there is evidence that the Audit Committee annually reviews the ethics and compliance agenda. This process includes evaluating the training programme and considering changes to the Code of Ethics and Business Conduct.

Based on public information, there is no readily available evidence of a formal, clear plan that guides the review of the ethics agenda, or that improvement plans are implemented when issues are identified.

Based on public information, there is evidence that the company has a formal process to review and update its policies and practices, in response to actual or alleged instances of corruption.

Based on public information, there is limited evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The Audit Committee discusses with management guidelines and policies, with respect to risk assessment and risk management. Also, the company identifies compliance with anti-corruption legislation as a risk when carrying out international sales. However, there is no readily available evidence of the formality of the process, the existence of mitigation plans or the ownership of implementation

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied.

Based on public information, there is evidence that the company conducts due diligence when selecting third parties. TI understands this to include agents. However, there is no readily available evidence that the due diligence is refreshed at least every three years or when there is a significant change in the business relationship. The company therefore scores 1.

Based on public information, there is evidence that the company expects third parties to conform to its Code of Conduct. However, there is no readily available evidence that the company has contractual rights and processes for the monitoring, control, and audit of agents, with respect to countering corruption.

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, its stance on bribery and corruption. The terms and conditions for suppliers include an affirmation that the supplier will conduct business ethically, and adhere to the company's Code of Ethics and Business Conduct. The company has the right to termination if a supplier violates the contract.

Based on public information, there is no readily available evidence that the company addresses the corruption risks associated with offset contracting.

Based on public information, there is no readily available evidence that the company conducts due diligence when selecting its offset partners and brokers. TI notes the company states that it conducts due diligence on third parties, but is looking for an explicit reference to offset partners and offset brokers.

Based on public information, there is evidence that the Code of Ethics and Business Conduct prohibits corruption in its various forms, including the giving or receiving of bribes, kickbacks and conflicts of interest.

Based on public information, there is evidence that the company has zero tolerance of bribery.

Based on public information, there is evidence that the company’s Code of Ethics and Business Conduct is easily accessible to Board members, employees and third parties. It is available on the company website in multiple languages.

Based on public information, there is evidence that the company’s Code of Ethics and Business Conduct is written in accessible, comprehensible language. The Code is well structured, includes numerous examples and does not contain dense, legal terms.

Based on public information, there is evidence that the Code of Ethics and Business Conduct applies to all employees and members of the Board.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. The policy is clearly written, with a definition and examples provided. The Corporate Governance Guidelines state that directors must inform the chairperson of the Nominating/Corporate Governance Committee and the CEO, before commencing any business activities that may create a conflict of interest.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. The company provides a clear upper limit for gifts.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. The policy is unclear, as employees are instructed to only exchange hospitality that is consistent with marketplace practices, infrequent in nature, not lavish or extravagant, and that does not violate any laws. However, employees are prohibited from soliciting any hospitality and the company provides seperate requirements for interactions with U.S. and foreign government officials. The company therefore scores 1. To score higher the company would need to provide evidence that it sets clear upper limits for hospitality exchange, or has the requirement for senior management authroisation if a value threshold is exceeded.

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. However, there is no readily available evidence of guidance or supplementary information on how the policy is to be implemented in practice. The company therefore scores 1.

Based on public information, it is unclear if the company prohibits or regulates political contributions; however, there is some evidence that such contributions are regulated. The Political Contributions Policy states that company funds may not be used to contribute to any political parties, political committees or political candidates. However, the Code of Ethics and Business Conduct details that it is prohibited for company funds to be used for political contributions anywhere in the world, unless approved in advance by the company's General Counsel. The company therefore scores 1. To score higher the company would have to provide evidence to clarify its policy on political contributions, and provide evidence that it publically discloses all political contributions that are made.

Based on public information, there is evidence that the company has a policy on engagement in lobbying activities. The Government Relations Office and the Legal Department coordinate all employees who contact government officials regarding public policy. The Senior Vice President for Washington operations is responsible for all of the company's political activities. The company therefore scores 1. To score higher the company would need to provide evidence that it publicly discloses the issues on which it lobbies.

Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent.

Based on public information, there is evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. The Code of Conduct contains numerous scenarios to help explain different forms of corruption and related company policies.

Based on public information, there is evidence that the company has a training programme on its ethics and compliance systems, which includes an anti-corruption policy. The company therefore scores 1. To score higher the company would need to provide evidence that it has an explicit anti-corruption training module.

Based on public information, there is some evidence that training on the Code of Ethics and Business Conduct is provided to employees. However, it is unclear if this training is available in all countries where the company operates. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to Board members.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is evidence that the company has a formal process by which employees declare conflicts of interest. Employees are instructed to complete a Disclosure of Personal Conflict of Interest form and a manager or ethics officer will then assist in resolving any issues.

Based on public information, there is evidence that the company has an explicit commitment to apply disciplinary procedures, to individuals who have violated the Code of Ethics and Business Conduct.

Based on public information, there is evidence that the company has multiple, well-publicised, secure channels, for employees to report concerns or instances of suspected corrupt activity. Channels include a manager, the applicable subject matter expert such as HR, or the Corporate Ethics Officer. In particular, an independently managed Ethics Helpline provides an online reporting tool in 11 languages, which allows anonoymous reporting.

Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. Channels include the applicable subject expert, such as HR or Legal, the Corporate Ethics Officer or the independently run Ethics Helpline.

Based on public information, there is limited evidence that the company has mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively. Specifically, the Audit Committee reviews the status of any ethics matters brought to the Corporate Ethics Officer and the Committee, and the resolution of such matters. The company therefore scores 1. To score higher the company would need to provide evidence of detailed analysis of whistleblowing data or independent employee surveys.

Based on public information, there is evidence that the company has well-publicised resources available to all employees, where help and advice can be sought on corruption-related issues. Resources include a manager or any other company reporting resources. This suggests that employees can seek advice from company departments such as HR and Legal, the Corporate Ethics Officer and the Ethics Helpline.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. The company therefore scores 1. To score higher the company would need to make a specific statement that disciplinary measures are applied to those breaching the non-retaliation policy.