Efforts to Eradicate Human Trafficking and Slavery within the Supply Chain

California Transparency in Supply Chains Act of 2010

Effective January 1, 2012, the California Transparency in Supply Chains Act of 2010 requires retailers and manufacturers doing business in California to disclose efforts to eradicate slavery and human trafficking from its direct supply chain.  Lockheed Martin is committed to ensuring that its employees and suppliers take appropriate steps to mitigate the risk of human trafficking and slavery from occurring in any aspects of its supply chain. In accordance with the Act, Lockheed Martin makes the following disclosures:

Verification of Supply Chain
Lockheed Martin verifies product supply chains through several methods, including site evaluations, inspections, verification of government debarred and denied parties lists and other means. Third parties are not utilized for verification. Lockheed Martin requires all suppliers agree as a condition of contract that they will comply with all applicable laws and regulations. With respect to suppliers outside the United States, suppliers are required to comply with their local laws as well as applicable laws of the United States.

Evaluation of Supplier Compliance
Lockheed Martin does not conduct audits of suppliers to evaluate supplier compliance with company standards specifically for trafficking and slavery in supply chains. For anyone who observes conduct contrary to the principles set forth in Lockheed Martin’s “Setting the Standard”, Lockheed Martin maintains an ethics hotline at 1-800-LM-ETHIC. The ethics hotline number is included in all supply contracts. Lockheed Martin promptly investigates all reported matters and takes action as needed, including disclosure to governmental authorities as appropriate.

Supplier Certification
Lockheed Martin requires as a condition of contract that all suppliers commit to comply with applicable laws and regulations, but does not require suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.

Internal Accountability Standards
Lockheed Martin maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking. Lockheed Martin has implemented several internal policies addressing this requirement. Corporate Policy Statement (CPS)-021 Good Corporate Citizenship and Respect for Human Rights, which states that Lockheed Martin seeks to improve the global society in which we operate, advance technological and economic development, communicate honestly and forthrightly, and hold ourselves accountable to deliver consistently what we promise to our stakeholders (customers, stockholders, employees, partners, suppliers, and communities); and minimize any negative consequences of our business activities. In furtherance of the foregoing the policy identifies specific principles, including:

  • promoting fair employment practices,
  • providing fair and competitive wages,
  • prohibiting harassment, bullying, and discrimination, use of child or forced labor,
  • trafficking in persons for any purpose.

Lockheed Martin also expects our suppliers to conduct themselves in a manner consistent with Lockheed Martin’s code of conduct, Setting the Standard and the principles expressed in CPS-021 and includes provisions in its supply contracts addressing this expectation. Additionally, Lockheed Martin has implemented CPS-734 Trafficking in Persons establishing requirements for compliance with the United States Government’s zero tolerance policy on trafficking in persons. Employees and covered supply chain contractors are required to comply with the Lockheed Martin policies and Federal Acquisition Regulation 52.222-50 Combating Trafficking in Persons.

Management Training
Lockheed Martin provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products. Lockheed Martin sends periodic communications to suppliers informing them about the risk of human trafficking and slavery and their obligations to comply with all applicable laws and regulations.