Lockheed Martin Corporation

Based on public information, there is evidence that the company has published several statements from the CEO, specifically supporting the company’s strong stance against corruption.

Based on public information, there is evidence that the company’s CEO, Marillyn Hewson is the Chair of the DII Steering Committee. Further, Leo Mackay (VP Ethics and Sustainability) is Chair of the DII Working Group.

Based on public information, there is evidence that the CEO has demonstrated an internal-facing commitment to the company’s anti-corruption agenda. The CEO provides a video introduction to the company’s Voicing Our Values 2014, directed towards employees. The company therefore scores 1. To score higher the company would need to provide at least two other examples of this internal engagement, such as speaking at training events or chairing a review of anti-corruption programmes.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including integrity and honesty. The company explains these values and demonstrates that these are translated into company policies and codes. In particular, the CEO provides a video introduction to the company’s Voicing Our Values 2014, directed towards employees.

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

Based on public information, there is evidence that the Ethics and Sustainability Committee has overall corporate responsibility for the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the Vice President Ethics and Sustainability is responsible for implementing the company’s ethics and anti-corruption agenda. This individual is identifiable by name, Leo Mackay, Vice President of Ethics and Sustainability.

Based on public information, there is evidence that the Ethics and Sustainability Committee monitors and reviews the performance of the company’s ethics and anti-corruption agenda. Evidence suggests this review takes place at least annually, as the Committee meets at least three times a year.

Based on public information, there is no readily available evidence of a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board is based, or evidence of improvement plans being implemented when issues are identified.

Based on public information, there is evidence that the company reviews its policies to assess any deviations that may occur from its anti-bribery and anti-corruption policies. There is public information to suggest the company updated its training program under the guidance of the risk and compliance committee. The Sustainability Report explicitly states that policies, procedures and training are updated from monitoring incidents of corruption.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. However, there is insufficient detail provided regarding mitigation plans and no evidence of who owns the process. The company therefore scores 1.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with criteria as to when this procedure needs to be applied.

Based on public information, there is evidence that the company conducts due diligence when selecting agents. Evidence shows that an international consultant agreement has a maximum term of two years, with due diligence refreshed at such intervals.

Based on public information, there is evidence that the company has agreement monitors who are tasked with ensuring agents comply with the company’s policies. Further, the company makes clear that agents must report any suspicious activities to their agreement monitors immediately. However, there is no direct evidence of contractual arrangements. The company therefore scores 1.

Based on public information, there is evidence that the company audits compliance of suppliers and sub-contractors to ensure they comply with the company anti-corruption policies. The consequences of breaches to the company stance are also made clear.

Based on public information, there is evidence that the company addresses the corruption risks associated with offset contracting at a general level. The company’s conducts due diligence that minimises corruption risk when selecting its offset brokers, as part of the company’s procedure for international consultants. The company therefore scores 1. To score higher the company would need to provide evidence that corruption risk is explicitly addressed in the company’s offset policies, procedures and contractual terms.

Based on public information, there is evidence that the company’s conducts due diligence that minimises corruption risk when selecting its offset brokers, as part of the company’s procedure for international consultants. Evidence shows that an international consultant agreement has a maximum term of two years, with due diligence refreshed at such intervals.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms.

Based on public information, there is evidence that the company has a zero tolerance policy to corruption.

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible to Board members, employees, and contracted staff. TI notes that the policy is available in multiple languages.

Based on public information, there is evidence that the company provides various tools to help everyone understand their anti-corruption policies. This includes an easy to understand code of conduct, various videos explaining ethics on the company’s website, scenario-based exercises, a document explaining how the code works, and a clearly written anti-corruption policy.

Based on public information, there is evidence that the company’s code applies to all employees including the Board of directors.

Based on public information, there is evidence that the company has a policy on conflicts of interest and it applies to both employees and Board directors.

Based on public information, there is evidence that the company has a policy on business courtesies that sets upper limits for gift exchange with both government and non-government employees.

Based on public information, there is evidence that the company has a policy on business courtesies that sets upper limits for hospitality exchange with both government and non-government employees.

Based on public information, there is evidence that the company prohibits facilitation payments. The company also provides guidance on how to implement this policy.

Based on public information, there is evidence that the company prohibits political contributions to non-US candidates and parties. In the USA the company’s Washington Operations has responsibility for managing and the company’s political activities. The company’s state contributions and Governors Association contributions are publically disclosed on its website.

Based on public information, there is evidence that the company advises personnel to consult the legal department before making contact with government officials. There is also evidence that the company discloses the issues on which it lobbies.

Based on public information, there is evidence that the company regulates charitable contributions. The company conducts due diligence before making charitable contributions and publicly declares recipients via a publicly accessible online platform.

Based on public information, there is evidence that the company provides guidance to help all concerned parties understand and implement the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the company has a training programme which explicitly covers anti-corruption.

Based on public information, there is evidence that the company requires all directors and officers to complete anti-corruption training.

Based on public information, there is evidence that the company requires all employees, including members of the Board, to complete anti-corruption training. Available information suggests this training is refreshed annually

Based on public information, there is evidence that the company provides specific anti-corruption training to relevant employees and those doing business internationally. The company tailors its ethics and anti-corruption training programme for employees facing different levels of risk.

Based on public information, there is evidence that the company has a clear and formal process for employees to declare conflicts of interest, in which they are declared to the Legal department in writing.

Based on public information, there is evidence that the company may apply disciplinary procedures against employees and Board members found to have engaged in corrupt activities. The company therefore scores 1. To score higher the company would need to provide evidence that the company has an explicit commitment to apply disciplinary procedures to employees who have violated its anti-corruption policy, using language such as “will”, rather than “may”.

Based on public information, there is evidence that the company provides several channels for employees to report instances of corruption. These channels include an ethics officer, the Corporate Office of Ethics and Business Conduct and the Audit Committee. Employees can remain anonymous if they wish to. The company therefore scores 1. To score higher the company would need to provide evidence of an independent channel for reporting concerns.

Based on public information, there is evidence that various reporting channels are available in all geographies. This includes Ethics Officers, an Ethics Helpline and an Ethics email address. The company provides resources instructing employees on how to use the ethics helpline when abroad.

Based on public information, there is evidence that the company has a range of practices to ensure that whistleblowing is encouraged and not penalised. The company conducts periodic surveys which ask employees about their willingness to report unethical behaviour, and the Ethics Office conducts regular analysis of the whistleblowing data and implements assessments at business locations each year to ensure the whistleblowing process is operating correctly. In particular, whistleblowers are encouraged to complete a voluntary feedback form, and if they disagree with the outcome of an investigation, whistleblowers have two opportunities to request a review.

Based on public information, there is evidence that the company provides well-publicised resources to all employees where help and advice can be sought on corruption-related issues. Resources include an ethics officer, a human resources business partner, or the Corporate Ethics Officer.

Based on public information, there is evidence that the company have a commitment to non-retaliation for bona fide reporting of corruption. There is also evidence that disciplinary measures may be applied to employees who breach this commitment.