Lockheed Martin’s success depends on our commitment to integrity. Our core values – Do What’s Right, Respect Others and Perform with Excellence – are fundamental to who we are and what we do. At Lockheed Martin, we believe that doing what’s right is more than just obeying laws and regulations. It’s holding ourselves to a higher standard, even when the law may not require us to do so. We refuse to allow our integrity to be compromised by our desire to succeed, regardless of the circumstances of our business.
Our Code of Ethics and Business Conduct, Setting the Standard, outlines our high expectations for employees and others who act on behalf of our company and provides the foundation for our award-winning Ethics program. We require all employees, consultants, contract laborers and Board members to agree to abide by our Code of Conduct.
We help them understand and mitigate the legal and regulatory risks they may face by providing interactive Business Conduct Compliance Training courses. And we use our annual leader-led Ethics Awareness Training to prepare employees to recognize and respond to situations that require ethical decision making.
We also communicate with employees year-round on key ethics and compliance topics, including but certainly not limited to Corruption and Human Trafficking. Our episodic Integrity Minute series is one of the primary communications tools we use to keep Ethics top of mind.
The Senior Vice President (SVP), Ethics and Enterprise Assurance (EEA) reports directly to the Chairman, President and CEO and reports regularly to the Nominating and Corporate Governance Committee of the Board of Directors. The SVP, EEA provides the Board members with frequent updates on the Ethics and Enterprise Assurance activities of the corporation, including providing summary reports on Ethics and Business Conduct activities, and responds to their feedback. These summaries include reports on key metrics such as ethics office contacts, including investigations. Ethics and Business Conduct activity summaries and metrics are also presented to the corporation’s Executive Leadership team four times per year.
Ethics is of such importance at Lockheed Martin that it is our first corporate policy: CPS-001. In addition, all Lockheed Martin employees have included in their annual performance assessments an evaluation of their adherence to the Lockheed Martin ethical principles. Performance assessments are a significant factor in determining multiple aspects of the employee experience, including employee compensation.
Lockheed Martin promptly and thoroughly investigates all alleged violations of laws, regulations, policies, procedures, or the Lockheed Martin Code of Ethics & Business Conduct, “Setting the Standard,” that occur in the workplace or in off-premises situations with a relationship to the workplace or that affect the workplace. Potential violations may be identified through normal compliance channels or raised by whistleblowers and other concerned employees. This includes any potential violation of the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and other international anti-corruption laws (together, “Anti-Corruption Laws”), whether the allegations involve individuals employed directly by Lockheed Martin or those with whom we partner, such as agents and suppliers. For more details on internal investigations at Lockheed Martin, see CRX-021, Internal Investigations. This procedure covers incident investigations reported through both internal and external reporting channels. The procedure is reviewed whenever associated regulations change. In addition, it is Lockheed Martin’s practice to annually identify any policies that have not been updated in 3 years, and, if needed, assess the need for them to be reviewed.
Lockheed Martin employees are required to report suspected violations of law or policy, including potential violations of the Anti-Corruption Laws, so that the Corporation can investigate and, if appropriate, disclose the misconduct to the cognizant government entity or entities. Transparency is paramount to Lockheed Martin’s ethics and compliance program. CPS-718, Disclosures to the U.S. Government ensures that Lockheed Martin promptly and fully discloses to the responsible authorities all violations of federal law and instances of significant employee misconduct affecting or influencing its operations.
There are several avenues for employees to report suspected misconduct, including through Management, the Ethics Office, the Legal Department, and Security. For a complete list of these avenues, all of which include the option for confidential and anonymous reporting, see the pamphlet How the Ethics Process Works. In addition, posters referencing external reporting channels, such as the Department of Defense (DOD) waste, fraud, and abuse hotline, are posted in Lockheed Martin facilities. The Corporation has the necessary controls in place to ensure the confidentiality of whistleblowers and other confidential reporting parties. We commit to supporting and protecting employees who refuse to act unethically. The corporation assesses employee beliefs in this commitment through regular confidential all-employee surveys that measure Ethics-related concepts such as ethical accountability, ethical leadership, and non-retaliation. In our most recent 2019 all-employee survey, we asked a total of sixteen (16) Ethics questions, such as: “I am comfortable raising concerns about compliance or ethics with my manager,” “I can report unethical practices without fear of retaliation,” “I do not feel pressure to compromise ethical or compliance standards to get my work done,” and “Unethical behavior is not tolerated at Lockheed Martin.” Lockheed Martin does not tolerate retaliation of any kind.
Metrics: Ethics Investigations and Requests for Guidance
*The metrics provided represent investigations related to individuals regardless of organizational level.
**If any Ethics investigations were conducted into third parties, such as contractors or suppliers, they are included in the figures above.
***The metrics provided include investigations on reports from all sources, both internal and external, if any.
****In 52.6% of ethics investigations conducted in 2018, disciplinary action was taken.
When employees face ethical dilemmas in their workplace, they are encouraged to use the Voicing Our Values techniques - Ask Questions, Obtain Data, Talk to Others, and Reframe the Issue. If unable to resolve the conflict using these techniques, or in the event of a compliance breach, employees should report any possible violations to their manager, Human Resources Business Partner, Legal, Security, Internal Audit, EESH or Ethics.
Corporate Ethics HelpLine:
Monday-Friday 8 a.m. - 5 p.m. ET
6801 Rockledge Drive
Bethesda, MD 20817