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  • LOCKHEED MARTIN 11/09/14 HTTP://WWW.LOCKHEEDMARTIN.COM/

    FINAL ASSESSMENT

    LOCKHEED MARTIN CORPORATION

    The following pages contain the detailed scoring for your company based on

    public information.

    The following table represents a summary of your scores:

    Topic Number of

    questions

    % score based

    on public

    information

    Leadership, Governance and

    Organisation

    10 85%

    Risk Management 7 78.6%

    Company Policy and Codes 12 100%

    Training 5 100%

    Personnel and Helplines 7 85.7%

    Total 41 90.2%

  • LOCKHEED MARTIN 11/09/14 HTTP://WWW.LOCKHEEDMARTIN.COM/

    A1:

    Does the company publish a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company?

    Score:

    2

    Comments:

    Based on public information, there is evidence that the company has published several statements from the CEO, specifically supporting the companys strong stance against corruption.

    References:

    Public: Code of Conduct (2014), p.ii: A Message from our Chairman, President and Chief Executive Officer Dear Colleague: At Lockheed Martin, we are committed to our core values. We Do Whats Right, Respect Others and Perform with Excellence. We never allow our ethics or integrity to be compromised by our desire to succeed, regardless of the circumstances of our business. As we continue to expand our reach in the global marketplace, strengthen our position as a leading technology innovator, and find new solutions to our customers complex challenges, we must hold firm to our high standards for ethical conduct. Our values and ethics are fundamental to who we are and what we do. They not only define us, they distinguish us. When we demonstrate integrity in all of our dealings, we build bonds of trust, which lead to stronger, more enduring relationships. Its these trusted relationships that create the opportunity for new and repeat business, and thats what will secure our future. We hold every Lockheed Martin employee accountable for upholding our ethical standards. Those standards go well beyond compliance with laws, rules and regulations that govern our business. They require each of us to abide by our values in every decision we make and every action we take. Setting the Standard is our Code of Ethics and Business Conduct. It 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. And, it serves as the most basic building block for future success. In addition to relying on our Code, I encourage you to consult other valuable resources, including your manager, Ethics officer and Human Resources business partner, whenever an

  • LOCKHEED MARTIN 11/09/14 HTTP://WWW.LOCKHEEDMARTIN.COM/

    ethics-related issue or question arises. They can provide additional guidance and insight when you need it. Thank you for embracing and implementing our core values, and for committing to the high standards for ethics and integrity that define who we are at Lockheed Martin. http://www.lockheedmartin.com/content/dam/lockheed/data/corporate/documents/ethics/code-of-conduct.pdf

    Company website: Our Continued Commitment to the Highest Legal and Ethical Standards (18 June 2013)

    A Message From Marilyn

    To: All Lockheed Martin Employees

    As we begin our annual ethics awareness training across the Corporation, Id like to underscore the importance of complying with all laws governing our business, especially as we grow our international portfolio.

    For all of us, and particularly for those of you contributing to Lockheed Martins growth internationally, its critically important we continue to adhere to our policy on Compliance with the Anti-Corruption Laws, CPS-730 and the principles of ethical and legal compliance set forth in our Code of Ethics and Business Conduct.

    As a reminder, our company has a zero-tolerance policy for corruption and expects anyone acting on behalf of Lockheed Martin to strictly adhere to all U.S. and foreign anti-corruption laws. Under no circumstances will we sacrifice our integrity. We would rather lose a business opportunity than violate the law or look the other way while a violation is taking place.

    I am proud of Lockheed Martins commitment to comply with the Foreign Corrupt Practices Act and foreign anti-corruption laws, and I ask each of you to continue to set the standard through your daily actions. Our customers value and respect our unwavering commitment to ethics and integrity. Thanks to your dedication, our company is well positioned for continued growth abroad.

    http://www.lockheedmartin.com/us/employees/enr/0618-hewson.html

    Company website: A Message from Marilyn (9 December 2014)

    To All Lockheed Martin Employees:

    Today is International Anti-Corruption Day, designated by the United Nations General Assembly as a day to highlight efforts to prevent corrupt business practices around the world. To recognize its importance, I would like to take this opportunity to thank you for upholding the Corporations high standards of ethics and values-based conduct in every aspect of our business.

    As we continue to strengthen our international portfolio, its more important than ever to hold true to these high standards.

    Our policy of zero tolerance for corruptioncombined with an expectation that anyone who acts on behalf of Lockheed Martin adhere to all applicable anti-corruption lawssustains our reputation for integrity and enables us to win business around the world.

    As a U.S.-based company, any actions on behalf of Lockheed Martin in any corner of the

    http://www.lockheedmartin.com/content/dam/lockheed/data/corporate/documents/ethics/code-of-conduct.pdfhttp://www.lockheedmartin.com/content/dam/lockheed/data/corporate/documents/ethics/code-of-conduct.pdfhttp://www.lockheedmartin.com/us/employees/enr/0618-hewson.html

  • LOCKHEED MARTIN 11/09/14 HTTP://WWW.LOCKHEEDMARTIN.COM/

    world are subject to the U.S. Foreign Corruption Practices Act. Similarly, our global operations obligate us to adhere to the anti-corruption laws, such as the UK Bribery Act, of many other nations.

    While we certainly abide by all of these laws, Im proud that our commitment to ethical business practices goes beyond the letter of the law. We will not compromise our values or act in a way that damages the trust and transparency necessary to conduct our business. We will not tolerate any questionable dealings. Our Code of Ethics and Business Conduct sets the standard for how we will live our values in our daily work lives.

    Thank you for your continued dedication to meeting the high standards we set for doing business around the world. Together, we can create a better climate for doing business everywhere.

    http://www.lockheedmartin.com/us/employees/enr/1209-hewson.html YouTube website: Marillyn Hewson on DII Video on importance of ethics and business integrity. https://www.youtube.com/watch?v=lpTjQGb5Pck

    Company website: Voicing Our Values

    Chairman, President and CEO video introduction to ethics.

    Our foundations is our values.

    Highest standards of ethics and integrity.

    Each of us is responsible for living our values daily.

    Zero tolerance for corrupt practices.

    Our colleagues, our customers and our suppliers want to know we are trustworthy in all our dealings. Honesty and integrity are fundamental to those relationships, and critical to the success of our business.

    You play a critical role in upholding Lockheed Martins commitment to the highest standards of ethical business conduct.

    http://www.lockheedmartin.co.uk/us/who-we-are/ethics/training/voicing-values-training.html

    http://www.lockheedmartin.com/us/employees/enr/1209-hewson.htmlhttps://www.youtube.com/watch?v=lpTjQGb5Pckhttp://www.lockheedmartin.co.uk/us/who-we-are/ethics/training/voicing-values-training.htmlhttp://www.lockheedmartin.co.uk/us/who-we-are/ethics/training/voicing-values-training.html

  • LOCKHEED MARTIN 11/09/14 HTTP://WWW.LOCKHEEDMARTIN.COM/

    A2:

    Does the companys Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company?

    Score:

    2

    Comments:

    Based on public information, there is evidence that the companys CEO, Marillyn Hewson is the Chair of the DII Steering Committee. Further, Leo Mackay (VP Ethics and Sustainability) is Chair of the DII Working Group.

    References:

    Public:

    Defence Industry Initiative:

    http://www.dii.org/dii-steering-committee

    http://www.dii.org/dii-working-group

    Interview excerpt on ethics: http://www.worldofceos.com/dossiers/marillyn-hewson

    http://www.dii.org/dii-steering-committeehttp://www.dii.org/dii-working-grouphttp://www.worldofceos.com/dossiers/marillyn-hewson

  • LOCKHEED MARTIN 11/09/14 HTTP://WWW.LOCKHEEDMARTIN.COM/

    A3:

    Does the companys Chief Executive Officer demonstrate a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure?

    Score:

    1

    Comments:

    Based on public information, there is evidence that the CEO has demonstrated an internal-facing commitment to the companys anti-corruption agenda. The CEO provides a video introduction to the companys Voicing Our Values 2014, directed towards employees. The company therefore scores 1. To score

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