Engineers at Lockheed Martin in Littleton, Colorado celebrating a spacecraft mission.

Anti-Bribery and Corruption Controls


Objective

Prevent bribery and corruption among employees, suppliers and contractors.

Management

An important aspect of our commitment to ethical business practices is establishing and maintaining strong anti-bribery and corruption controls. We work diligently to promote adoption of anti-corruption practices by our employees and business operations, and we apply the same standards throughout our value chain. The Lockheed Martin Compliance with Anti-Corruption Laws policy statement directs our approach to anti-bribery and corruption, which applies to all of our employees around the world. We encourage employees to engage their local Ethics Officer, the Corporate Ethics Office, Human Resources (HR) or our Legal team for guidance, to ask questions and to raise concerns. We also offer employees access to an interactive guide called the Gifts Decision Tree, which helps individuals apply our standards for giving and receiving gifts, hospitality and other business courtesies.

We make a variety of additional resources and guidance available through our intranet and Anti-Corruption Program and Polices site. We regularly review and update resources on the site to address changes in laws, regulations and the global environment.

Lockheed Martin has a zero-tolerance policy for corruption and we investigate any allegation of such incidents. We routinely assess publicly reported incidents of corruption involving businesses and countries around the world, and update our risk analyses, policies and procedures and trainings accordingly.

We extend our anti-bribery and corruption standards across our value chain with the Lockheed Martin Supplier Code of Conduct explicitly referencing our expectations of suppliers. We prohibit anyone who is conducting business on our behalf, including suppliers, from offering or making improper payments of money or anything of value to government officials, political parties, candidates for public office, or other persons.

In 2020, we took key steps to strengthen our anti-bribery and corruption control policies, including the anti-corruption section of our Code of Ethics and Business Conduct. Please refer to the Ethical Governance and Leadership section of this report for additional information about changes to our Code of Ethics and Business Conduct. Also in 2020, we shifted oversight of third-party consultants under the purview of Lockheed Martin’s Legal team. This addressed the identification of third-party consultants as a potentially vulnerable group related to corruption and bribery risks.

2020 SMP Goals

Achieve 100% completion rate of applicable employee training on Business Courtesies and International Business Conduct Compliance Training (BCCT) modules.

Achievement

Success: 100% completion rate of applicable employee training on Business Courtesies and International Business Conduct Compliance Training (BCCT) modules.

Achieve 100% completion rate of applicable training on Ethics for business consultants.

Achievement

Success: 100% overall completion of 2020 Ethics and Compliance Training for U.S. and Internal Business Development Consultants who operate under specific Corporate Policies.

Assess risks for all international consultants and other consultants identified through audits.

Achievement

Success: We completed the annual risk assessments and completed the audit plan of international business development consultants.

Anti-Bribery and Corruption Controls
Evolution of Ethics and Compliance Training for Lockheed Martin Consultants

Lockheed Martin has always emphasized the importance of Ethics and Compliance training for our Business Development consultants; however, the manner in which our consultants have been educated on Lockheed Martin culture, policy and legal expectations has evolved over time. Originally, the Lockheed Martin business personnel responsible for managing the consultants’ activities delivered this training. In order to improve the effectiveness of this training, since 2015 our International Regional Ethics Officers covering Europe, Middle East and Africa (EMEA) and Asia Pacific (APAC) Regions started delivering in-person ethics and compliance training to consultants on a biennial rotational basis, alternating with due diligence and anti-corruption compliance discussions conducted by our legal team. In 2019, this direct training by a Lockheed Martin Ethics Officer was expanded to include in-person consultant training in Canada by our Canada-based Ethics Officer. In 2020, a further expansion saw our U.S-based Ethics Officers also now delivering this training to U.S.-based international consultants. More agility and adaptation was required when COVID-19 emerged in March, and training was accomplished by Ethics Officers in a virtual environment. The ethics and compliance consultant training content is continually improved every year, and requires each consultant to sign an acknowledgement form confirming receipt of the training and their agreement to abide by the Lockheed Martin Code of Ethics and Business Conduct.

Business Integrity

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