Objective

Advancing standards and controls for ethical business conduct that strengthen customer relationships, supplier partnerships, and workplace integrity.

The Science

We apply proven methodologies and innovative training techniques to cultivate ethical thinking among our employees, and develop resources and tools to advance integrity across our industry.

The Science

Conducting business with the utmost integrity engenders trust and fosters a resilient value chain and a high-performing, transparent work environment. This not only attracts more customers and helps us retain the best talent, it reduces risk and ensures corruption does not subvert societies’ or citizens’ safety.

Business Integrity

TIER 1

  • Ethical Governance and LeadershipMaintaining consistent, transparent, and high ethical standards, policies, practices, and leadership across our business.

  • Anti-Bribery and Corruption ControlsPreventing bribery and corruption among employees, suppliers, and contractors.

  • Supplier ConductHelping suppliers strengthen management and disclosure on ethical, labor, human rights, and environmental issues.

  • Responsible SalesEnsuring sales are conducted ethically and fairly, with careful consideration for export controls and trade policies, product and services’ intended use, and impact on civilian needs.

TIER 2

  • Human and Labor RightsEfforts to prevent abusive labor practices and civil liberties violations in business operations and the supply chain in a manner consistent with internationally recognized standards.

  • Supplier DiversityEfforts to enhance procurement opportunities for small business suppliers by supporting their organizational development and competitiveness.

  • Conflict MineralsEfforts to monitor and manage conflict mineral use, as defined in section 1502 of the Dodd-Frank Act, in our product manufacturing supply chain.

ELEMENTS OF AN EFFECTIVE ETHICS PROGRAM

Our Ethics Supplier Mentoring Program organizes the complex concept of an “ethics program” into 12 distinct elements. These elements of an effective ethics program are based on key global standards for ethics, compliance, and anti-corruption programs.

Company values

Company values

Program structure and oversight

Program structure and oversight

Risk assessment

Risk assessment

Policies and procedures

Policies and procedures

Code of conduct

Code of conduct

Training

Training

Communication

Communication

Leadership commitment

Leadership commitment

Reporting mechanisms

Reporting mechanisms

Investigations and disclosures

Investigations and disclosures

Disciplines and incentives

Disciplines and incentives

Program evaluation

Program evaluation

SUPPLIER MENTORING PROGRAM BENEFITS

  • Review of ethics program
  • Discussion of best practices
  • Access to our resources
  • Recognition as program participant
  • Enhanced relationship with us

CASE STUDY

Uphold the Code: Sikorsky CH-53K Helicopter
Positioned to Serve

What we did

Given how critical our supply chain is for delivering on the customer’s mission, we make sure every supplier understands the importance of our values and our clear expectations throughout the supply chain. The Sikorsky CH-53K helicopter has a critical mission that spans humanitarian aid, Special Operations forces, troop transport, combat search and rescue, and equipment transport for the U.S. Marines. When delivering to the U.S. Marine customer in support of their mission, there is no place for doubt about quality, safety, or the authenticity of parts.

Supplier material makes up 73% of the cost of the CH-53K program, which links cost, quality, and technical factors with the dependability of our suppliers. As an extension of our internal Lockheed Martin ethical values, the Supplier Code of Conduct is part of every purchase order issued for this program — and all others — and details our expectations for our supply chain. The Code is a natural extension of our company’s values to do what’s right, respect others, and perform with excellence. These values not only provide our customers with the confidence that we know where our focus is every day, they also correlate to each of the 21 areas of focus in the Supplier Code of Conduct.

Why it matters

As the CH-53K program prepares for its first major milestone in 2023, with sights set on international expansion, our customers can rest assured the program is positioned to meet the mission with dependable suppliers held accountable to the requirements of the Supplier Code of Conduct throughout our supply chain.

Read more in the report Learn more about the CH-53K
Sikorsky CH-53K Helicopter Positioned to Serve

The CH-53 series has a 50-year legacy of heavy lift solutions.

Read more in the report
Learn more about the CH-53K

Ethics Contacts

(per 1,000 employees)
GuidancesCases

Investigation Feedback Scores

(satisfaction scored on a five-point scale)
Reporting PartySubject

Highlights

The L-100, a versatile  aircraft

With over 1.6 million fleet flight hours and nearly 95% availability, the S‐92® helicopter is the industry’s standard for safety and reliability.

The L-100, a versatile aircraft

  • Lockheed Martin provides logistics and technical support for the L-100, a versatile commercial transport aircraft which has been used to carry live animals, including the black rhino, in support of species conservation. The L-100 legacy continues with the LM-100J, which is certified for operation in any commercial airport in the world.
  • This year, the Sikorsky S-92 helicopter aided in the search and rescue mission for hundreds of passengers after their cruise ship encountered trouble in high seas off the Norwegian coast – among thousands of lives this and other Sikorsky aircraft have helped to save worldwide.
  • International trade compliance teams throughout the Lockheed Martin enterprise maintain thousands of active export/import authorizations and support international business and partnerships throughout the world.
Read more in the report

Tier 2

Human and Labor Rights

Objective

Efforts to prevent abusive labor practices and civil liberties violations in business operations and the supply chain in a manner consistent with internationally recognized standards.

Management

We guard against human rights violations and have corporate policies to set clear principles and expectations. Our global policies, procedures, and practices reflect our strong commitment to good corporate citizenship and are informed by relevant expertise, stipulate expectations for employees and suppliers, and are embedded throughout the enterprise. This commitment applies to all employees, the Board of Directors, and others who represent or act for us. Our Code of Ethics and Business Conduct and Supplier Code of Conduct publicly express our commitment to meet our human rights responsibilities. We prohibit harassment, bullying and discrimination, use of child, compulsory or forced labor, trafficking in persons, and any acts associated with modern day slavery for any purpose. We have mandatory Business Conduct Compliance Training (BCCT) for all employees to heighten the awareness and prevention of human trafficking, and to encourage the use of widely accessible and trusted grievance mechanisms. This training educates employees in every country where Lockheed Martin operates about the standards of conduct that apply to their jobs and the potential consequences of violations.

We regularly evaluate our efforts to ensure business is conducted ethically and fairly, with careful consideration for export controls and trade policies, products’ intended use and impact on civilian needs. All of our military sales are inextricably intertwined with the practices of specific states, including the United States and its allies, and are regulated by the U.S. Government and reviewed and approved by both its Executive Branch and Congress. In addition, we support the Dodd-Frank Act’s objective of preventing armed groups in the Covered Countries from benefitting from the sourcing of Conflict Minerals from that region and are committed to responsible sourcing of materials for our products. 

We have also established a due diligence program which follows the framework established by the Organization for Economic Cooperation and Development (OECD) for conflict minerals. The OECD Due Diligence Guidance provides detailed recommendations to help companies respect human rights and avoid contributing to conflict through their mineral purchasing decisions and practices. Additionally, we financially support the Responsible Mining Initiative Smelter Audit Fund, with the goal of providing resources sufficient to support smelter participation in the audit program, resulting in additional validation of conformant sourcing practices.


Supplier Diversity

Objective

Efforts to enhance procurement opportunities for small business suppliers by supporting their organizational development and competitiveness.

Management

It is our policy to conduct socioeconomic subcontracting programs in recognition of compelling moral, social and economic necessity. It is also the corporation's policy to facilitate the achievement of its negotiated subcontracting goals by developing the capabilities of and pursuing opportunities to award subcontracts and other procurements to small and small disadvantaged businesses, HUBZone, women- and veteran-owned businesses, and service-disabled veteran-owned businesses. Our program also promotes the utilization of suppliers with disabilities, the LGBT community, historically black and tribally owned colleges and universities, and other minority institutions as well as those we work with globally.

Our small business representatives also travel to national and local events geared toward a range of small businesses to engage diverse talent. We also regularly update and publicize our events calendar, supplier resources, and awards and recognitions on our Supplier Diversity webpage. The page also links to Supplier Wire, our dedicated site for suppliers that provides information on our immediate needs, updates on sustainability, and relevant news about Lockheed Martin and how small businesses can learn about the corporation, receive training, and work with us as a supplier. For example, we have training webinars led by affiliates, including the Veteran Institute for Procurement, Women Impact Public Policy, and the National Center American Indian Procurement Technical Assistance Center.


Conflict Minerals

Objective

Efforts to monitor and manage conflict mineral use, as defined in section 1502 of the Dodd-Frank Act, in our product manufacturing supply chain.

Management

We are committed to the responsible sourcing of materials for our products, including the sourcing of conflict minerals. Lockheed Martin expects to file its annual disclosure report for 2019 with the SEC in May 2020. Lockheed Martin depends upon our complex, multi-tiered supply chain for insight into sources of raw materials. If identified as an applicable supplier, we will send over a request and detailed instructions.

Our Supplier Code of Conduct includes our expectations that suppliers take steps to determine if their products contain Conflict Minerals and if so, implement supply chain due diligence processes to identify sources of these minerals and support efforts to eradicate the use of Conflict Minerals which directly or indirectly finance or benefit armed groups in the Covered Countries.

We support with financial and human capital industry-wide initiatives, including the Responsible Minerals Initiative (RMI) and Aerospace Industries Association (AIA) which assists with our benchmarking and smelter analysis efforts. More information on our conflict minerals rules are also available from our filings on the SEC website.

Read about our Core Issues

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