The company has a publicly stated anti-bribery and corruption commitment, which details the company's stance against any form of corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company's leadership.<\/p>\n"},{"question":55,"commitment_area":7,"score":"2","comments":"
The company publishes an explicit anti-bribery and corruption policy, which makes specific reference to the prohibition of bribery, payments to public officials, commercial bribery, and facilitation payments. This policy clearly applies to all employees and board members, regardless of their seniority, as well as the staff and leadership of subsidiaries and other controlled entities.<\/p>\n"},{"question":56,"commitment_area":7,"score":"2","comments":"
There is evidence that a board committee \u2013 the Nominating and Corporate Governance Committee \u2013 is ultimately responsible for the oversight of the company's anti-bribery and corruption programme. The committee receives reports from the Senior Vice President Internal Audit, Ethics & Sustainability regarding the company\u2019s ethics and business conduct programme. In addition, as part of the company\u2019s anti-corruption policies, the Senior Vice President, Ethics and Enterprise Assurance reports significant audit matters to the Audit Committee of the board. <\/p>\n"},{"question":57,"commitment_area":7,"score":"2","comments":"
There is evidence that a senior executive, the Senior Vice President Ethics and Enterprise Assurance, has ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. This position has a direct reporting line to the Chairman, President and CEO, executive leadership team and the Nominating and Corporate Governance Committee and Audit Committee of the board. The Senior Vice President Ethics and Enterprise Assurance provides frequent summary reports on the company\u2019s ethics programme to board members and responds to their feedback. <\/p>\n"},{"question":58,"commitment_area":8,"score":"1","comments":"
There is evidence that the company has a risk assessment procedure that informs the design of its anti-corruption and bribery programme. The company indicates that it continually monitors corruption risks in order to develop mitigating procedures and that it conducts a biennial Compliance Risk Assessment that includes bribery and corruption risk. It also undertakes a separate annual risk assessment of its international consultants. <\/p>\n
However, it is unclear whether the results of risk assessments are reviewed at board level. <\/p>\n"},{"question":59,"commitment_area":8,"score":"2","comments":"
The company states that its anti-bribery and corruption programme is subject to annual internal audit to ensure that it is consistent with best practice and addresses the business risks facing the company. There is evidence that significant findings are reported to the board-level Audit Committee and, when issues are identified, the company assigns an individual responsible to implement a corrective action plan. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
The company publicly commits to investigating incidents and there is a specific procedure in place to deal with whistleblowing cases, which stipulates documentation and actions to be taken at each step. The procedures cover the whole investigation process from receipt to final outcome and there is evidence that the company takes steps to ensure the independence of its investigations. Ethics officers from the company\u2019s Legal, Ethics, Human Resources, Industrial Security, Internal Audit, or Information Security departments generally perform investigations. The company\u2019s Ethics Office collects information on investigations and presents these to the executive leadership team four times per year. <\/p>\n"},{"question":61,"commitment_area":8,"score":"2","comments":"
There is evidence that the company assures itself of the quality of its internal investigations for incident reports and whistleblowing cases. The company\u2019s investigations policy states that investigators are properly trained to perform this function and receive support from the legal department. There is additional evidence that the company ensures the quality of its investigations procedure by requesting employee feedback, and publishing the results. Furthermore, there is evidence that the company has procedures in place to account for complaints or concerns about Ethics Officers in the investigation process. The company\u2019s investigations procedures are reviewed every three years.<\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
The company makes a clear commitment to disclosing material findings of bribery and corruption to government authorities. The company\u2019s legal team handles this process, obtaining sign-off by an appropriately senior individual, namely the Senior Vice President, General Counsel & Corporate Secretary; although the company does not explicitly state findings are reported to the Board of Directors, this individual is a member of the executive leadership. There is also evidence that there are provisions in place to allow employees to report directly to the Board where appropriate. <\/p>\n"},{"question":63,"commitment_area":8,"score":"2","comments":"
The company publishes high-level information on ethics and compliance-related incidents and investigations involving all company employees covering the last 12 months. This includes the number of ethics contacts made per thousand employees and the percentage of investigations that resulted in disciplinary action. The company states that its data includes investigations originating from internal and external sources, which appears to include reports received through the company\u2019s whistleblowing channel.<\/p>\n"},{"question":64,"commitment_area":9,"score":"2","comments":"
There is evidence that the company provides training on its anti-bribery and corruption policy, which forms part of its broader Ethics Awareness and Business Conduct Compliance Training. It is clear that this covers the whistleblowing options available to employees. The company provides this training to all employees across all divisions and countries of operation, and in all appropriate languages. Employees are required to undertake and refresh this training on an annual basis.<\/p>\n"},{"question":65,"commitment_area":9,"score":"2","comments":"
There is evidence that employees in certain positions receive additional, tailored anti-bribery and corruption training on an annual basis. The company states that these positions include middle management and employees in high-risk positions, for example based on geographical location. There is also evidence that board members and the executive leadership team are required to undertake tailored annual ethics training. <\/p>\n"},{"question":66,"commitment_area":9,"score":"2","comments":"
There is evidence that the company reviews the effectiveness of its anti-bribery and corruption communications and personnel training programme. The company states that it does this by conducting staff surveys and audits of the programme, collecting data on training completion rates and the number of inquiries received, and discussions with subject matter experts. The company conducts these reviews on an annual basis and it is clear that the results of such reviews are used to update specific parts of the company\u2019s anti-bribery and corruption communications and training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"1","comments":"
There is evidence that the company\u2019s incentive schemes incorporate ethical and anti-bribery and corruption principles. Adherence with the company\u2019s ethical principles is included in annual performance assessments for all employees, which, in turn, are a factor in determining employee compensation. <\/p>\n
However, the company does not indicate that incentives must be proportionate to the employee\u2019s salary in the case of high risk employees, such as sales roles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"2","comments":"
The company clearly states that any employee who refuses to act unethically will be protected and supported even where such actions result in a loss of business or another disadvantage to the company. There is evidence that the company assures itself of its employees' confidence in this commitment through confidential surveys. <\/p>\n"},{"question":69,"commitment_area":9,"score":"2","comments":"
The company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents. There is evidence that this policy applies to all employees and third parties with whom the company does business. The company assures itself of its employees\u2019 confidence in this commitment through surveys.<\/p>\n"},{"question":70,"commitment_area":9,"score":"2","comments":"
The company has multiple internal advice channels and a whistleblowing line to seek advice on the company's anti-bribery and corruption programme and report instances of suspected corrupt activity. These channels are available to all employees in all countries of operation, as well as to third parties with whom the company does business. All the channels allow for confidential and anonymous reporting. The company also makes information available to its employees concerning an external hotline operated by the US Department of Defence. <\/p>\n"},{"question":71,"commitment_area":10,"score":"2","comments":"
There is evidence that the company formally addresses conflicts of interest as a corruption risk, and has a clear policy that defines conflicts of interest, including actual, potential and perceived conflicts. The policy explicitly covers all of the categories of possible conflicts listed in the scoring guidance, namely employee relationships, government relationships, financial interests and other employment. The company\u2019s policy applies to all employees and board members, including those of subsidiaries and other controlled entities.<\/p>\n"},{"question":72,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has procedures in place to identify, declare and manage actual, potential and perceived conflicts of interest. The company requires that employees make a written disclosure of conflicts, and states that disciplinary measures will apply if the company\u2019s policies are breached. Potential conflicts of interest are held in a dedicated online depository. All employees have access to this depository, including the company\u2019s Legal Department, which has ultimate oversight and accountability for the handling of individual cases. The policy mentions some examples of criteria for recusal, though detail is limited since the policy is not publicly available.<\/p>\n"},{"question":73,"commitment_area":10,"score":"2","comments":"
There is evidence that the company has a policy which includes controls to assess and regulate employment and offers of employment or consultancy engagements to current and recently departed public officials, including politicians. The company requires a conflict of interest review before an employment or consulting offer is made to a current or former government employee. The company\u2019s Legal Counsel is responsible for advising on post-employment restrictions, which may include permanent or one to two-year post-employment procedures. These restrictions may include a cooling-off period before public officials are permitted to have any form of contact or relationship with their former organisation on the company\u2019s behalf. <\/p>\n"},{"question":74,"commitment_area":10,"score":"1","comments":"
There is evidence that the company does not contract the services of acting or serving politicians due to national laws. <\/p>\n
However, it is not clear that the company prohibits such engagement as a matter of principle, even in countries where such activities are not prohibited by law. <\/p>\n"},{"question":75,"commitment_area":11,"score":"0","comments":"
There is evidence that the company has a policy on political contributions, which allows for donations in some circumstances in the United States. The company therefore receives a score of \u20180\u2019. <\/p>\n"},{"question":76,"commitment_area":11,"score":"2","comments":"
The company publishes information on its political contributions, including details of the recipient, amount, and state of the recipient. As identified in the previous question, the company only makes corporate political contributions in the United States and through the Lockheed Martin Corporation entity, so these disclosures can be interpreted as covering all political donations made by the company. There is evidence that the data is updated on an annual basis. <\/p>\n"},{"question":77,"commitment_area":11,"score":"1","comments":"
There is evidence that the company has policies covering both charitable donations and sponsorships. The company\u2019s policy on charitable contributions sets financial limits, describes the type of organisations that are eligible to receive donations, and specifies a procedure to document, review and approve donations through the Corporate Contributions Committee. Similar provisions are outlined for sponsorships under the gifts, hospitality and business courtesies policy. <\/p>\n
However, the company does not publish details regarding the in-kind or financial charitable contributions it makes on an annual basis, including the recipient, amount, country of recipient and which corporate entity made the payment. <\/p>\n"},{"question":78,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on lobbying which applies to all employees, board members and agents acting on the company\u2019s behalf. The company states that it is committed to responsible lobbying, and provides some examples of what this entails. The company indicates that it has specific controls and oversight mechanisms for its lobbyists, such as conducting audits of its lobbying reporting process and evaluations of registered lobbyists on an annual basis. The company also states that all employees, board members, contractors and contract laborers are required to adhere to the company\u2019s Code of Conduct, which outlines the corruption risks associated with lobbying, throughout the lobbying process. <\/p>\n"},{"question":79,"commitment_area":11,"score":"1","comments":"
The company publishes some information on its lobbying topics and activities in the United States by making its quarterly federal lobbying reports publicly available on its website. <\/p>\n
However, the company does not provide details about its broader public policy aims or positions. The company also does not publish any information about its lobbying activities outside of the US. <\/p>\n"},{"question":80,"commitment_area":11,"score":"1","comments":"
The company publishes some details of its lobbying expenditure, by making its federal quarterly lobbying reports up to the most recently reported financial year available on its website. <\/p>\n
However, this expenditure data is not broken down into internal, external or association lobbyists and does not include an explanation of how these figures have been calculated. Furthermore, the company does not publish its lobbying expenditure worldwide. <\/p>\n"},{"question":81,"commitment_area":11,"score":"2","comments":"
There is evidence that the company has a policy on the giving and receipt of gifts and hospitality, with clear procedures designed to ensure that such promotional expenses are bona fide and not used as vehicles for bribery. This policy establishes financial limits, along with an approval procedure, for the different types of promotional expense that employees may encounter. The policy also explicitly addresses the risks associated with gifts and hospitality given to and\/or received from public officials by specifying different approval procedures. There is evidence that gift and hospitality approvals are recorded in a central register accessible to those responsible for oversight of the process. <\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
There is evidence that the company\u2019s Global Supply Chain Operations department is the sole authority involved in procuring goods and services, and it is clear that this department provides oversight of the company\u2019s supply base. <\/p>\n
However, although the company states that it has procedures for ensuring procurement professionals follow the required onboarding processes for suppliers, it does not provide further details. There is no evidence, for example, that the company conducts an audit of the onboarding process at least every three years. <\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based due diligence when engaging with suppliers. This process explicitly includes establishing the ultimate beneficial ownership of the supplier. Moreover, there is evidence to suggest that the company would not be willing to proceed with a supplier relationship in circumstances where a red flag highlighted cannot be mitigated, although the company does not explicitly state it would terminate existing supplier relationships in these circumstances. The company also indicates that it undertakes enhanced due diligence on suppliers operating in high-risk jurisdictions.<\/p>\n
However, although the company states that due diligence is periodically reassessed and updated, it is not clear that due diligence on suppliers is repeated at least every two years or whenever there is a change in the business relationship. <\/p>\n"},{"question":84,"commitment_area":12,"score":"2","comments":"
There is evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedures in place. In its Supplier Code of Conduct, the company outlines its expectations for suppliers, including its policies prohibiting bribery and facilitation payments, as well as those covering conflicts of interest, gifts & hospitality and whistleblowing. There is evidence that the company takes active steps to ensure this by providing training materials and a self-assessment tool on its website for suppliers to benchmark their own policies and procedures, as well as by requiring suppliers to fill out a questionnaire about these topics. The company assures itself of this when onboarding new suppliers or when there is a significant change in the business relationship.<\/p>\n"},{"question":85,"commitment_area":12,"score":"2","comments":"
There is evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption programme and standards are required of sub-contractors throughout the supply chain. This is in the form of contractual requirements that are flowed down through the supply chain.<\/p>\n"},{"question":86,"commitment_area":12,"score":"1","comments":"
The company states that it includes investigations into suppliers in its annual data on ethics contacts and investigations. <\/p>\n
However, supplier investigations are not disaggregated from investigations involving employees. <\/p>\n"},{"question":87,"commitment_area":13,"score":"2","comments":"
There is evidence that the company has a clear policy on the use of agents, which addresses the corruption risks associated with the use of agents and provides details of specific controls to mitigate these risks. As part of this policy, the company outlines oversight mechanisms and commits to only retaining agents and consultants where there is a sufficient business case justification and where all appropriate laws and regulations are followed. This policy forms part of the company\u2019s overall ethics and anti-corruption policies, which apply to all divisions within the corporation that might employ agents, including subsidiaries and controlled joint ventures. <\/p>\n"},{"question":89,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence prior to engaging any agents and intermediaries. There is evidence that Legal Counsel is involved in determining the appropriate level of anti-corruption due diligence based on exposure to risk, suggesting that higher risk agents and intermediaries are subject to enhanced due diligence. <\/p>\n
However, there is no evidence that the company refreshes its due diligence at least every two years or when there is a significant change in the business relationship. <\/p>\n"},{"question":90,"commitment_area":13,"score":"1","comments":"
The company has formal procedures to establish the beneficial ownership of agents. The company requests this information from agents through its International Anti-Corruption Questionnaire. Where agents and intermediaries fail or refuse to provide the appropriate information the company states that it will immediately terminate the relationship. <\/p>\n
However, the company receives a score of \u20181\u2019 because while it states that it verifies ultimate beneficial ownership, it is not clear whether information provided by high risk agents is independently verified. Furthermore, it is not clear whether the company repeats its due diligence process, including checks on ultimate beneficial ownership, at least every two years or when there is a significant change in the business relationship. <\/p>\n"},{"question":91,"commitment_area":13,"score":"2","comments":"
There is evidence that the company\u2019s anti-bribery and corruption policy applies to all agents and intermediaries acting for or on behalf of the company. All agents and intermediaries are subject to anti-bribery and corruption clauses in their contracts, which include clear audit and termination rights to detect, control and prevent breaches.<\/p>\n"},{"question":92,"commitment_area":13,"score":"2","comments":"
There is evidence that incentive structures for agents are explicitly highlighted and addressed as a bribery and corruption risk factor. The company places a clear threshold on sales-based commissions to agents so that payments do not exceed a proportion of the net fee to the agent, and states that remuneration to agents is structured in staged payments over the course of their contract, based on clear milestones, into local bank accounts.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
The company does not publish any details of the agents currently contracted to act for and\/or on behalf of the company.<\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company publishes any data on ethical or bribery and corruption-related investigations, incidents or the associated disciplinary actions involving agents. <\/p>\n"},{"question":100,"commitment_area":13,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct risk-based anti-bribery and corruption due diligence prior to entering into and while operating in any joint venture agreement. The company states that its due diligence process includes checks on the beneficial ownership of third parties, including joint venture partners. The company also indicates that third parties operating in high-risk jurisdictions may require enhanced due diligence. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that due diligence on joint venture partners is repeated at least every two years; instead, the company states that due diligence is reassessed and updated periodically. <\/p>\n"},{"question":101,"commitment_area":13,"score":"2","comments":"
There is evidence that the company commits to establishing and implementing anti-bribery and corruption policies in its joint ventures. Where it has a non-controlling ownership interest, the company states that it will employ its best efforts to ensure such controls are adopted. The company states that its agreements with joint venture partners must include anti-corruption provisions, procedures and controls in order to ensure ongoing adherence to its anti-bribery and corruption programme, which includes a ban on facilitation payments and foreign and domestic bribery. It conducts periodic reviews to ensure that such policies and procedures are effective. The company indicates that a violation of its anti-corruption policy, which applies to joint venture partners, may result in termination of contract. <\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no evidence that the company commits to taking an active role in preventing bribery and corruption in all of its joint ventures. Although it indicates that it has procedures in place to do so, it does not specify what these are. <\/p>\n
Examples of such procedures could include: stipulating that the Chief Compliance Officer in the joint venture be transferred from, or appointed by, their own company or report directly to the main company\u2019s audit committee; instituting a secondment scheme; taking the lead in providing tailored anti-bribery and corruption training; ensuring provisions for real-time access to electronic books and records; or establishing a separate internal audit function.<\/p>\n"},{"question":103,"commitment_area":14,"score":"2","comments":"
There is evidence that the company has policies and procedures in place to address the corruption risks associated with offset contracting and ensures any offset partners adhere to its anti-bribery and corruption standards through appropriate contractual clauses. The company has a dedicated body responsible for the monitoring and oversight of the company\u2019s offset activities throughout the lifecycle of each project, and there is evidence that the employees in this department receive dedicated training on the specific risks associated with offsets. <\/p>\n"},{"question":104,"commitment_area":14,"score":"1","comments":"
There is evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on all aspects of its offset obligations. This process specifically includes checks on the beneficial ownership of any offset brokers or beneficiaries. As part of this process, the company's policy also commits to establishing and verifying that the offset obligation proposed is founded on a legitimate rationale.<\/p>\n
However, the company does not specifically mention checks on conflicts of interest for offset brokers and beneficiaries. It is also not clear whether the company refreshes due diligence at least every two years or whenever there is a significant change in the business relationship or nature of the partner.<\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
The company does not publish any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of the company. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
The company does not publish any details of its offset obligations and\/or contracts.<\/p>\n"},{"question":107,"commitment_area":15,"score":"2","comments":"
The company acknowledges the corruption risks associated with operating in different markets, and there is evidence that it has a risk assessment process in place to account for these specific risks, with clear risk management procedures in place. The results of risk assessments have a direct impact on business decisions and inform the development and implementation of additional controls. The company provides examples of such possible controls.<\/p>\n"},{"question":108,"commitment_area":15,"score":"1","comments":"
The company discloses a list of its subsidiaries in its annual filing to the U.S. Securities and Exchange Commission.<\/p>\n
However, the company receives a score of \u20181\u2019 because this disclosure does not show the percentage ownership for each entity, and there is evidence to suggest that the list is not complete. While the company refers to the place of incorporation of the subsidiaries listed, it does not provide information on the subsidiaries\u2019 countries of operation. <\/p>\n"},{"question":109,"commitment_area":15,"score":"2","comments":"
The company is publicly-listed on the New York Stock Exchange and therefore automatically receives a score of \u20182\u2019. <\/p>\n"},{"question":110,"commitment_area":15,"score":"1","comments":"
The company publishes a percentage breakdown of the customers that account for 60% of its defence sales for the most recently reported financial year. The company also discloses that approximately 12% of its commercial sales go to the U.S. Government, but it does not provide any additional detail on the remaining 28% of its international sales (i.e. customer or defence\/commercial). <\/p>\n
The company receives a score of \u20181\u2019 because it does not publish at least 80% of its sales.<\/p>\n"},{"question":111,"commitment_area":16,"score":"N\/A","comments":""},{"question":112,"commitment_area":16,"score":"N\/A","comments":""},{"question":113,"commitment_area":16,"score":"N\/A","comments":""},{"question":114,"commitment_area":16,"score":"N\/A","comments":""},{"question":115,"commitment_area":16,"score":"N\/A","comments":""}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/596","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies"}],"about":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/types\/companies"}],"wp:attachment":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/media?parent=596"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=596"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}