Anti-Corruption Program and Policies
Lockheed Martin – a signatory of the Defense Industry Initiative for Ethical Business Conduct (DII) and a charter member of the International Forum on Business Ethical Conduct (IFBEC) – is committed to the highest standards for ethical business conduct as a key component to our business strategy.
When it comes to anti-corruption, our continued commitment to increased transparency helps to ensure a level playing field and prevent the devastating social and economic consequences of corruption in the places where we do business.
- Corruption creates unfair competition, increases cost and jeopardizes the quality and capability of our products and services.
- Bribes, export and import violations and illegal boycotts damage the trust and transparency needed to transact business.
- Lockheed Martin has zero tolerance for corrupt practices. Whether in the United States or internationally, all Lockheed Martin employees are responsible for complying with applicable laws to avoid corruption.
“As you know, the first of Lockheed Martin’s core values is to 'do what’s right.' For this reason, we have a policy of zero tolerance for corruption. We believe corruption erodes trust in government institutions, distorts markets and creates unfair competition that ultimately increases costs and negatively affects the quality of products and services. We expect our employees – and anyone who acts on behalf of the corporation – to comply with applicable Anti-Corruption Laws whether they are located in the United States or abroad."
Marillyn A. Hewson
Chairman, President and CEO
From the United States:
From Outside the United States:
Use the International Access Code listing to find the AT&T Direct Access Code for your country and dial this number before dialing
From a TTY Machine:
The Corporate Ethics HelpLine is answered from 8am to 5pm EST Monday through Friday, except on days
when Corporate Headquarters is closed. All contacts to the Ethics organization are handled confidentially.
Anti-Corruption Program Resources
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.
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.
- Gift Letter Template - Commercial Entity Recipient
- Gift Letter Template - Government Entity Recipient
- Compliance Certification - Sponsorships U.S. Recipient
- Compliance Certification - Sponsorships Non-U.S. Recipient
- CPS-008 Frequently Asked Questions
- CPS-008 Sponsorship and Gift Exception Request Form
- Gifts Decision Tree Tool
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.
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
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.
Related Anti-Corruption Policies
- CPS-004 Political Activity prohibits contributions of any type to non-U.S. candidates, parties or political committees. Lockheed Martin discloses its Corporate State Contributions, Governors Association Contributions, and LMEPAC Disbursements, as well as its policy on engagement in lobbying activities and the issues on which the Corporation lobbies, publicly on our Political Disclosures webpage.
- CPS-016, Mergers, Acquisitions, Divestitures, Business Ventures, and Investments mandates compliance with all laws and regulations that apply to these activities. The policy also requires the appropriate due diligence be conducted on the target entity.
- CPS-113, Acquisition of Goods and Services provides specific direction that all sourcing and procurement activities comply with the applicable laws and regulations wherever we conduct business. The policy establishes evaluation requirements for prospective suppliers in compliance with the applicable laws and regulations. This policy lists specific country procedures for the United States, Australia, Canada, the Netherlands, and the United Kingdom.
- CPS-716, Compliance with the Anti-Kickback Act of 1986 requires that employees who buy goods or services for Lockheed Martin or are involved in the procurement process must not accept gifts from subcontractors and suppliers, except advertising or promotional items of nominal value. Global Supply Chain Operations (GSCO) must ensure that Lockheed Martin informs its suppliers and subcontractors annually in writing of its policy pertaining to gifts, gratuities, and business courtesies, emphasizing that it is unacceptable for Lockheed Martin employees to violate this policy, and that potential violations of this policy should be reported to Lockheed Martin management.
- CPS-718, Disclosures to the United States Government requires timely reporting to the Office of Inspector General and Contracting Officer when there is credible evidence of potential violation of certain federal criminal laws, a violation of the U.S. Civil False Claims Act, or a significant overpayment. The policy further states that there may be some violations of law or significant employee misconduct that are not Reportable Violations under FAR 52.203-13 but that Lockheed Martin wishes to disclose these voluntarily in the spirit of maintaining the highest standards of business ethics and transparency with U.S. government agencies. Examples of such conduct may include violations of the federal securities laws, violations of the Anti-Corruption Laws for commercial contracts, or violations of procurement laws that are not covered by FAR 52.203-13.
- CPS-720, Compliance with Antitrust Laws defines specific practices prohibited by the Antitrust Laws and provides guidelines for understanding the primary areas of antitrust concern. The policy also specifies the ramifications of violation for the employee and Lockheed Martin.
- CRX-010 Domestic Business Development Consultants and CRX-011 International Consultants describe the Corporation’s process for conducting due diligence on domestic and international consultants, respectively, at the time of the consultants’ initial appointment or contract renewal. The policies limit consultant agreements to a maximum term of two years, with due diligence refreshed at such intervals. The policies also require that consultants receive, acknowledge, are trained on and comply with the Corporation’s Code of Ethics and Business Conduct. CRX-011 International Consultants applies to offset partners and brokers as well as consultants.
- CRX-014 Individual Conflict of Interest, which applies to all Lockheed Martin employees and consultants, outlines activities that may constitute a conflict of interest, situations requiring disclosure, and the formal process for declaring a potential conflict of interest.
- CRX-025, Teaming Agreements outlines implementation plans governing the identification of teammates and the negotiation, execution, performance, and termination of teaming agreements. Each agreement specifically requires performance of an antitrust analysis by Legal Counsel and compliance with the due diligence obligations.
- CRX-251 Charitable Contributions defines spending limits and allocation, describes desired characteristics of recipients, and specifies that contributions must be documented, approved, transmitted and tracked.
- CRX-325, Business Travel requires compliance with applicable laws and regulations, customer requirements, Lockheed Martin’s Code of Ethics & Business Conduct and applicable policies and procedures, including compliance with U.S. Anti-boycott and Anti-Corruption Laws.
- CRX-327, Commercial Cards explains when and why these tools are used for the payment of authorized expenses. The policy specifically prohibits use of commercial cards for any payments to a Public Official or for consultant services.
- CRX-454 Offset/Countertrade Commitments explicitly addresses the corruption risks associated with offset contracting, including the risks presented by subcontracts and selling or trading offset credits. The policy explains the process for obtaining approval for offset commitments and shows who within the company is responsible for approving different types of offset commitments.
- CRX-526, Corporate Aircraft describes the process for using corporate aircraft, procedure for scheduling, and associated responsibilities. The policy specifies required approvals to transport any non-employee, including Public Officials, on corporate aircraft.