A video message from our Chairman, President and Chief Executive Officer
Click here to view the transcript of this video.
At Lockheed Martin, our core values – to do what’s right, respect others, and perform with excellence – unite us as a team and define how we operate every day. Building trust with our colleagues, customers, and communities depends on the integrity and high standards we share.
That’s why I encourage you to read and understand Lockheed Martin’s “Code of Ethics and Business Conduct,” which provides guidance when we act on behalf of our organization.
We hold every team member to the same standards, policies, and procedures. Many of these standards are higher than local laws or customs may require.
We also expect and encourage you to step forward and speak up if you witness actions or behaviors that are inconsistent with our standards. You can do so with confidence – knowing that our Code of Conduct clearly states our zero-tolerance policy for retaliation, harassment, discrimination, or corruption.
Lockheed Martin’s reputation depends on every one of our team members. So thank you for your commitment to upholding our core values. Together as OneLM, we can ensure our integrity and reputation for excellence continues to guide us.
Jim Taiclet
Chairman, President and Chief Executive Officer
Video Transcript
Introduction
Lead with Integrity
Respect
Others
Demonstrate
Accountability
Conduct
Business Fairly
Our Work Environment
Good Corporate Citizenship
Receipt and
Acknowledgement
Lockheed Martin
Code of Conduct
Page 1
Our Values
DO WHAT’S RIGHT
We are committed to the highest standards of ethical conduct in all that we do.
RESPECT OTHERS
We recognize that our success depends on the talent, skills and expertise of our people.
PERFORM WITH EXCELLENCE
We understand the importance of our missions and the trust our customers place in us.
TABLE OF CONTENTS
Introduction
We Promote Good
Corporate Citizenship
We Lead
with Integrity
We Respect
Others
We Demonstrate
Accountability
We Conduct
Business Fairly
We Care About Our
Work Environment
• CPS-001 Ethics and Business Conduct
Policies
Uphold the Code
Page 2
Lockheed Martin
Code of Conduct
• CPS-001 Ethics and Business Conduct
• CPS-718 Disclosures to the United States Government
• CRX-021 Internal Investigations
Policies
WE SET THE STANDARD
• Our Code establishes the principles by
which we maintain our commitment to ethical business practices, which often go beyond what the law requires.
• Follow both the letter and the spirit of the laws and regulations that govern our business and the countries in which we operate.
• Cooperate in investigations.
• Our Code applies to Lockheed Martin
employees, our Board of Directors, consultants, contract laborers and others representing or acting for our Corporation.
• Any waiver of the Code for executive officers or members of the Board of Directors may be made only by the Board or a Board committee and must be promptly disclosed to our stockholders on our website.
Why It Matters
• Maintaining the trust of employees, our customers and stakeholders is essential to ensuring sustainable success.
What to Watch Out For
• Violations of the Code may result in disciplinary action up to and including termination.
• Leaders are accountable for actions that could influence employees to violate our Code.
Investigations
X
You must notify the Legal Department, Ethics Office or Security if you learn that a government agency or any third party is conducting an investigation or
asking for information pertaining to a suspected violation of law. We must never destroy or alter any documents or electronic records, lie to or mislead an investigator or obstruct the collection of information relating to an investigation or any legal action brought on behalf of, or against, the Corporation. To the greatest extent possible, we will cooperate with government agencies responsible for investigating suspected violations of the law. If requested by Lockheed Martin, we will cooperate with investigations conducted by any government.
X
This prevents waivers of the Code from being hidden from the public and complies with New York Stock Exchange (NYSE) requirements and similar rules under the Securities and Exchange Commission and the Sarbanes-Oxley Act of 2002.
Waiver
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 3
Lockheed Martin
Code of Conduct
• CRX-021 Internal Investigations
Policies
Report Violations
WE SET THE STANDARD
• We take prompt action to report violations of the Code, policy or a contract provision.
• Any one of us may be the only person to see or suspect a potential violation. If we don’t report it, who will?
• Timely reporting may allow issues to be
resolved before they become larger issues.
Why It Matters
• Failure to report may itself be a violation of this Code.
What to Watch Out For
Ethics is here for you for guidance.
You’ll receive information and
resources to help address your
concern:
Call:
1-800-LM ETHIC (1-800-563-8442)
When calling from outside the
U.S., first dial the origin
country’s exit code
Email:
corporate.ethics@lmco.com
Mail:
Corporate Ethics Office
Lockheed Martin Corporation
6801 Rockledge Drive, MP-211
Bethesda, MD 20817
X
If you have reason to believe that questionable or illicit conduct exists, report suspected violations to your supervisor, manager, Human Resources Business Partner, Ethics Officer, Legal, Security, EEO Investigations, Global Diversity and Inclusion, Environment, Safety & Health, Sustainability, Internal Audit or the
Audit Committee.
Reporting
X
Employees may transmit concerns about accounting, internal controls or auditing matters and confidential or anonymous submission of questionable accounting or auditing matters to the Audit Committee of the Lockheed Martin Board of Directors. If you wish to raise a concern to the Audit Committee, you may do so by contacting the Corporate Ethics Office and your concern will be communicated to the Chair of the Audit Committee of the Board.
Audit Committee
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 4
Lockheed Martin
Code of Conduct
• CPS-001 Ethics and Business Conduct
Policies
Participate in Training
WE SET THE STANDARD
• Complete all required Business Conduct Compliance Training and annual Ethics Awareness Training.
• Training prepares us to recognize and effectively react to situations requiring ethical decision making.
Why It Matters
• Be sure to complete your required training by the due date.
What to Watch Out For
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
- Addresses the consequences of compliance violations.
- Helps improve our understanding of topics in this Code.
Page 5
Lockheed Martin
Code of Conduct
• CPS-001 Ethics and Business Conduct
• CPS-718 Disclosures to the United States Government
• CRX-021 Internal Investigations
Policies
Take Action
WE SET THE STANDARD
• Act with integrity, ask tough questions
and understand how our words and
actions affect our colleagues and
the Corporation.
• Use, and encourage others to use, the
Voicing Our Values techniques to help
take action and put our values into
practice.
• Challenges to our values may be a normal occurrence in the work environment, but you must resolve them.
Why It Matters
• Warning signs help you identify and correct
potential problems before they become
larger issues.
• Assumptions and inferences can impact your impartiality and hinder ethical decision-making.
What to Watch Out For
Voicing Our Values Techniques
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 6
Lockheed Martin
Code of Conduct
• CPS-003 Nondiscrimination and Equal Employment Opportunity
• CPS-564 Harassment-Free Workplace
• CPS-734 Combating Trafficking in Persons
• CRX-053 Workplace Security - Maintaining a Safe and Respectful Workplace Free from Threats and Violence
Policies
Zero Tolerance
for Harassment
WE SET THE STANDARD
• Verbal or physical conduct that offends,
abuses, intimidates, torments, degrades or threatens another person is prohibited.
• You will help maintain a work environment that is free of physical, psychological, and verbal harassment or
other abusive conduct.
• Success depends on the talent, skills and expertise of all employees.
• Targets, as well as witnesses, of harassment may struggle to contribute to their full potential.
Why It Matters
• Be knowledgeable of prohibited conduct by
reviewing policy.
• Be mindful of your own behavior and how your actions, words and deeds could impact
someone else.
What to Watch Out For
EXAMPLES OF SEXUAL HARASSMENT INCLUDE:
• Unwanted sexual advances, including verbal sexual advances and propositions.
• Offering employment benefits in exchange for sexual favors.
• Making or threatening reprisals after a negative response to sexual advances.
• Leering or making sexual gestures.
• Displaying pornographic or sexually suggestive objects, pictures, cartoons,
or posters.
• Using inappropriate terms of endearment.
• Verbal abuse of a sexual nature.
• Graphic verbal commentaries about
an individual’s body.
• Sexually degrading words used to describe an individual.
• Suggestive or obscene letters, notes,
or invitations.
• Harassment can occur in many forms, inside and outside of the workplace.
• Be an Upstander and intervene when you
witness, or become aware of, harassing or
discriminatory behavior.
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 7
Lockheed Martin
Code of Conduct
• CPS-003 Nondiscrimination and Equal Employment Opportunity
• CPS-564 Harassment-Free Workplace
• CPS-734 Combating Trafficking in Persons
• CRX-515 Business Resource Groups and Employee Networks
• CRX-537 Military Leave
Policies
Zero Tolerance for Discrimination
WE SET THE STANDARD
• Do not discriminate against employees
or applicants on the basis of characteristics protected by applicable
law or Lockheed Martin policy.
• Follow all policies and laws that relate to recruitment, selection, and other aspects of employment such as promotion, demotion, transfer, layoff, termination, compensation, education, training and disciplinary action.
• Excluding someone based on protected
characteristics - simply by virtue of who they
are - is against the law.
Why It Matters
• Perpetuating stereotypes is a form of
discrimination that can damage the culture
and the performance of the Corporation.
What to Watch Out For
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 8
Lockheed Martin
Code of Conduct
• CPS-001 Ethics and Business Conduct
• CPS-003 Nondiscrimination and Equal Employment Opportunity
• CPS-564 Harassment-Free Workplace
• CPS-575 Providing Reasonable Accommodations in the Workplace and for Applicants
Policies
Do Not Retaliate
WE SET THE STANDARD
• Lockheed Martin does not tolerate retaliation against anyone who, in good faith, makes an inquiry, participates in an
investigation or reports misconduct. Contacting Ethics in “Good Faith” does not mean you have to be right, but it does
mean you believe the information provided is truthful.
Retaliation is the unfair or inappropriate treatment against an employee for reporting
misconduct, filing a complaint, assisting another in making a complaint, participating in a company internal investigation, or making an ethics-related inquiry.
• Fear of retaliation is one of the most common reasons why employees won’t speak up or take action.
• Retaliation destroys trust.
Why It Matters
• If someone tries to stop you from reporting an
issue, that person can be subject to disciplinary
action up to and including termination.
• Retaliation can be subtle, including changes in work assignments or casual work-related
interactions, or it can be overt at times. You are
legally protected from reprisals for reporting
fraud, waste or abuse on government programs.
What to Watch Out For
X
U.S. law also entitles each Lockheed Martin employee to certain rights and protections against reprisals if the employee discloses, to certain governmental officials or to the Legal Department or Ethics Office, information that the employee reasonably believes is evidence of gross waste, mismanagement, abuse of authority, or violations of law related to U.S. government contracts, grants, or funds; or evidence of a substantial and specific danger to public health and safety.
Protected
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 9
Lockheed Martin
Code of Conduct
• CRX-015 Protection of Sensitive Information
• CRX-016 Privacy - United States
• CRX-017 Personal Data Protection - Non-U.S.
Policies
Respect Privacy
WE SET THE STANDARD
• Do not collect, store or access Personal Information / Personal Data (PI / PD) unless there is a legitimate business purpose and you have the proper authorization.
• Respect the privacy and dignity of all individuals and safeguard the confidentiality of employee records and
information.
• Safeguarding PI / PD builds trust with employees and customers.
Why It Matters
• Be sure to use the appropriate Personal Information / Personal Data legend in the subject line of email messages.
• Ensure that you do not share Personal Information / Personal Data on social media or collaborative workspaces.
• Data disclosed to third parties should be limited to only the information necessary to fulfill contractual agreements.
What to Watch Out For
Personal Information (PI) and Personal Data (PD) at Lockheed Martin is defined as any information that permits the identity of an individual to be determined. PI includes identifiable information for persons in the US; PD for persons in non-US countries.
PERSONAL INFORMATION / PERSONAL DATA
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
• When transmitting PI / PD outside the LM network (LMI), use approved secure e-mail and file transfer methods.
• Privacy regulations differ by country.
X
This includes electronic communication systems,
information resources, materials, facilities and equipment.
Property
Page 10
Lockheed Martin
Code of Conduct
• CPS-007 Personal Use of Lockheed Martin Assets
• CPS-037 Proper Use of Computing and Information Resources
• CRX-014 Individual Conflict of Interest
• CRX-156 Purchasing Cards (P-Cards)
• CRX-253 Social Media
• CRX-303 Electronic Messaging
• CRX-325 Business Travel
• CRX-327 Commercial Cards
• TVL-001 Business Travel Handbook
Policies
Use Assets Responsibly
WE SET THE STANDARD
• You are responsible for properly using and protecting our Corporation’s, and our
customers’, property and assets, and ensuring their efficient use.
• Do not waste nor abuse company and
customer assets.
• Our customers expect us to protect resources that they entrust to us.
• Unauthorized use of company assets, as well as third-party information entrusted to the Corporation, can create risks to the Corporation and impact our financial obligations.
• Improper use of assets could result in violations of law and failure to meet contractual obligations and / or deviations from company policies; all of which can have unintended impacts to the
corporation and individuals.
Why It Matters
• Misuse of U.S. Government assets can
constitute a federal crime.
• Activities of concern include:
What to Watch Out For
- Using customer assets for anything that is not specifically or contractually
allowed / authorized.
- Sending / storing / handling sensitive
information on a personal computing
device.
- Sending company information to personal email addresses.
- Using unapproved electronic items to
store data in company / customer assets.
- Personal use of company assets.
- Personal use of your corporate
credit card.
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Keep Accurate Business Records and Accurately Communicate to
the Public
WE SET THE STANDARD
• You will honestly and accurately prepare
all business and financial records.
• Conduct business transparently while not
compromising proprietary or confidential
information.
• Never misrepresent facts or falsify
records.
• Promptly and accurately enter all business transactions in our books and business records.
• You have an obligation to make accurate
disclosures to the public and our
stockholders.
• Customers, regulators and investors expect us to maintain the integrity of our records.
• Complex business processes demand that each of us be able to rely on the accuracy of the data we provide each other to serve our customers.
Why It Matters
• Every business record you provide helps us
provide accurate disclosures to all government and regulatory agencies.
• Be mindful of any proprietary or confidential
information included in any type of public
disclosure / external communication.
• Properly account for all costs, including labor, travel, material and any other expenses.
• If you prepare business or financial records
or public communications on behalf of the
Corporation, ensure that they contain comprehensive, fair, timely, accurate
and understandable information.
• Inaccurate pricing information submitted
in proposals, reporting of business travel expenses, or labor charging, violates policy and
may also be illegal.
What to Watch Out For
Page 11
Lockheed Martin
Code of Conduct
• CPS-011 Internal Control and Enterprise Risk Management
• CPS-020 Fair Disclosure of Material Information and Financial Information to the Investment Community and Public
• CPS-201 Release of Information
• CPS-730 Compliance with Anti-Corruption Laws
• CRX-011 International Business Development Consultants
Policies
X
Public disclosures: Include reports or documents filed
with the U.S. Securities and Exchange Commission and
other regulatory authorities as well as other public
communications made by the Corporation, including
external presentations.
Public Disclosures
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
• Keeping accurate records is critical to accurately recording and reporting financial transactions and meeting our legal and regulatory obligations.
• Our investors rely on accurate
public disclosures.
Protect Sensitive Information
WE SET THE STANDARD
• Use, store and protect Sensitive
Information in accordance with applicable requirements.
• Obtain proper authorization before
disclosing or receiving any Sensitive
Information.
• Do not share Sensitive Information in
unapproved forums.
• We generate, acquire, and access large amounts of valuable information every day. This information provides us and our customers with business, technological, and economic advantage; and can also impact national security interests.
Why It Matters
• Obtain proper approval before publishing or
making external presentations about Lockheed Martin or its customers or partners.
• Wherever we do business there are countryspecific laws and regulations governing import / export issues and unique information handling and safeguarding requirements.
• Use social media responsibly and take extra
care to protect information about the Corporation, your colleagues, customers and
yourself.
• Information protection requirements stay in effect even if your employment or engagement with the Corporation ends.
What to Watch Out For
X
To obtain approval, U.S. employees should visit the PIRA tool (Public Information Release Authorization System - https://pira.us.lmco.com/pira/). Non-U.S. employees should contact Communications for the appropriate point of contact to review their materials.
Proper Approval
Page 12
Lockheed Martin
Code of Conduct
• CPS-022 Ethical Development and Use of Artificial Intelligence
• CPS-201 Release of Information
• CPS-310 International Trade Controls and Compliance
• CPS-569 Security
• CRX-002 Intellectual Property
• CRX-013 Government and Competitor Information
• CRX-015 Protection of Sensitive Information
• CRX-016 Privacy - United States
• CRX-017 Personal Data Protection - Non-U.S.
• CRX-253 Social Media
• CRX-303 Electronic Messaging
Policies
X
Information in any or all of these categories: Personal Information (U.S.), Personal Data (Non-U.S.), Export Controlled Information, Lockheed Martin Proprietary Information, Third-Party Proprietary Information, Attorney-Client Privileged Information and / or Attorney Work Product and Protected Information.
Sensitive Information
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Accurately Charge Labor and Other Costs
WE SET THE STANDARD
• Follow the business-specific labor
recording policies and procedures where
you work.
• Properly account for all costs including
labor, travel, material and other costs.
• You will be held accountable for ensuring that your labor charges are accurate.
• Excessive use of online collaboration tools / Internet for non-work purposes could lead to labor mischarging.
• Inaccurate labor charging or leaders approving / directing mischarging may violate policy and may be illegal.
Why It Matters
What to Watch Out For
X
These costs include, but are not limited to, normal
contract work, work related to normal contract research and development and bid and proposal activities. This means that transactions between the Corporation and outside individuals and the organizations are accounted for and executed in accordance with generally accepted accounting practices and principles in the United States, and in the countries where we do business.
Costs
Page 13
Lockheed Martin
Code of Conduct
• CMS-505 Recording and Verification of Direct Labor Costs
• CPS-441 Cost Estimating/Pricing
• CPS-730 Compliance with Anti-Corruption Laws
• CRX-325 Business Travel
• CRX-327 Commercial Cards
Policies
• The violation of labor charging practices is one of the most frequent case allegations atLockheed Martin.
• Improperly charging time on customer contracts could be considered fraud.
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 14
Lockheed Martin
Code of Conduct
• CPS-008 Gifts, Hospitality, Other Business Courtesies, and Sponsorships
• CPS-730 Compliance with Anti-Corruption Laws
• CRX-010 U.S. Business Development Consultants
• CRX-011 International Business Development Consultants
• CRX-013 Government and Competitor Information
• CRX-014 Individual Conflict of Interest
Policies
Avoid Individual Conflicts of Interest
WE SET THE STANDARD
• Be fair and impartial in all business dealings.
• Place the interest of Lockheed Martin over personal interests in matters relating to the Corporation’s business.
• Avoid actual conflicts of interest as well as activities that create the appearance of one.
• Do not use our contacts or position in
the Corporation to advance outside or
personal interests.
• Our Corporation’s property, information or opportunities will not be used for personal gain.
• We will provide immediate written disclosure of actual or potential conflicts of interest.
• You may think you can balance multiple interests at the same time and not realize when your loyalties are divided.
Why It Matters
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
• Disclose all potential conflicts of interest to get an independent, objective assessment and take appropriate mitigating actions.
What to Watch Out For
Avoid Conflicts of Interest with Government Employees
NOTE: U.S. Government employees should have their government ethics official review their background before applying for work.
WE SET THE STANDARD
• Comply with all conflicts of interest laws and regulations covering employing or acquiring the services of government
employees, which includes military personnel.
• Our success and ability to compete depends on ensuring that we do not hire or work with current or former government employees in a manner that creates a real or perceived conflict of interest.
• The nature of the information and the competitive advantage and / or detail of information that the individual possesses may itself create a conflict.
Why It Matters
• There are rules for contacting or negotiating
with current government employees to discuss their potential future employment or their service as consultants or subcontractors.
• There may be restrictions regarding roles or
responsibilities that former government employees may perform.
What to Watch Out For
Page 15
Lockheed Martin
Code of Conduct
• CPS-008 Gifts, Hospitality, Other Business Courtesies, and Sponsorships
• CRX-014A Conflict of Interest - Government Employment
Policies
X
U.S. Government employees should have their government ethics official review their background before applying for work.
This process may result in a recusal letter (also called a disqualification letter) and an ethics opinion letter which would explain any restrictions or bans on their potential post-government employment.
Review Their Background
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 16
Lockheed Martin
Code of Conduct
• CRX-014E People with Organizational Conflict of Interest Restrictions
• CRX-600 Organizational Conflict of Interest
Policies
WE SET THE STANDARD
Avoid Organizational Conflicts of Interest
• Avoid, neutralize, or mitigate Organizational Conflicts of Interest (OCI).
• Prevent unfair competitive advantage or conflicting roles that might impair
objectivity.
• You may have worked with multiple customer representatives across different programs.
• A conflict on one government contract could compromise our ability to work on another.
• Failure to properly screen new business
opportunities could result in disqualification or loss of business.
• Policies are intended to prevent unfair
competitive advantage and conflicting roles that might bias the Corporation’s judgment.
Why It Matters
• Be sure to report and maintain the disclosure of any OCI restrictions.
What to Watch Out For
X
Visit CRX-600 for the process regarding preparing a screening letter and distributing it through the OCI Reporting System.
OCI Reporting System
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
WE SET THE STANDARD
Do Not Engage in Insider Trading
• You must comply with all applicable
securities laws and avoid even the
appearance of impropriety.
• You must not engage in insider trading,
which means you must not:
• Investors’ trust in us and the public’s trust in financial markets depend on confidence that trades in securities are based on publicly available information.
Why It Matters
• If you learn of important information related to
Lockheed Martin or a third party before the general public knows, there’s a possibility it could be considered material nonpublic information. Communicating such information to others may violate the law, even if you personally do not trade any securities based on such information.
What to Watch Out For
X
Securities include stock (common and preferred),
restricted stock units, employee stock options, bonds, notes, debentures, put or call options, or similar instruments.
Securities
Page 17
[CEROS OBJECT]Lockheed Martin
Code of Conduct
• CPS-016 Mergers, Acquisitions, Divestitures, Business Ventures, and Investments
• CPS-020 Fair Disclosure of Material Information and Financial Information to the Investment Community and Public
• CPS-722 Compliance with United States Securities Laws
Policies
- trade in the securities of any company (including Lockheed Martin) when you possess material, nonpublic information (MNPI) about that company,
- suggest (or “tip”) that others engage in such trading, or
- share MNPI with others (including other employees of Lockheed Martin) unless authorized to do so.
X
Trading includes all transactions in securities, including fund transfers or fund reallocations into or out of the Lockheed Martin stock fund in your savings, benefit or deferred compensation plans; any purchase or sale of common stock (including the sale of shares received from vested restricted stock units); gifts of Lockheed Martin securities if the value of the gift is established for tax purposes at the time the gift is made; and the exercise of employee stock options. It also includes trades executed pursuant to limit orders, even if these were placed prior to your coming into possession of material, nonpublic information.
Trading
X
Information is “material” if there is a substantial likelihood that a reasonable investor would consider it important in deciding whether to trade a security. Both positive and negative information can be “material.”
Material
X
Information is considered “nonpublic” until it is widely disseminated. This means it has been in the news or released in the form of an official announcement and enough time has passed in the open market, privately or in company plans for the information to be assimilated by the general public (typically the next business day).
Nonpublic
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
• You are responsible for making sure that you do not share MNPI with your family and that you do not share MNPI with other employees of Lockheed Martin or third parties without express authorization. You can be held liable for the actions of others with whom you share MNPI.
• Each of the terms “securities,” “trading,” “material” and “nonpublic” have extensive and
complicated legal definitions..
WE SET THE STANDARD
Ensure the Quality and Safety of Our Products and Services
• Be committed to meeting customer and
company expectations by identifying and
adhering to policies and procedures that
ensure Quality, Mission Success, and System Safety Engineering throughout the product or service lifecycle.
• Develop and deliver high-quality products and services that meet all applicable quality and safety standards for their intended use.
• Implement and follow disciplined systems to measure performance and consistency.
• Quality assurance processes detect and correct defects to ensure delivery of safe products and services that meet all contractual, legal and regulatory requirements.
Why It Matters
• All quality concerns will be taken seriously,
whether from inside or outside the company,
and addressed appropriately.
What to Watch Out For
Page 18
Lockheed Martin
Code of Conduct
• CPS-002 Quality, Mission Success, and System Safety
Policies
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
• Seek to continuously advance safety and
quality in the design and manufacture of our
products and services.
• If something does not appear to conform to
the standards expected, use a “See Something, Say Something” approach and notify your leader.
Page 19
Lockheed Martin
Code of Conduct
• CPS-022 Ethical Development and Use of Artificial Intelligence
Policies
Use Artificial Intelligence Responsibly
WE SET THE STANDARD
• The benefits of Artificial Intelligence (AI) will be pursued while ensuring the procurement, development and our internal use are in accordance with our values.
• We have established an Artificial Intelligence Ethics Advisory Committee to develop further guidance and to adjudicate concerns related to the above principles. Employees who have concerns about adherence to our Ethical AI principles should contact Ethics or a member of the Artificial Intelligence Ethics Advisory Committee.
• Practice the ethical development of AI
capabilities and follow our principles in areas
related to AI such as machine learning, data
analytics, and data mining.
• We recognize that AI holds tremendous potential benefits for our customers and our
operations, and we intend to be an industry
leader in this revolutionary technology.
• Increased access to data and high- performance computing has unleashed
unprecedented opportunities in AI that are
changing the way companies operate in all
industry sectors.
• As a rapidly evolving discipline, there may be
risks that must be considered and addressed
in the design and implementation of AI
systems.
• There are significant potential legal risks
associated with the use of third party
AI models, tools and data sets as well as
associated with reliance on AI to perform
tasks and generate content.
Why It Matters
What to Watch Out For
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Lockheed Martin subscribes to the
following ethics principles in our AI design, development, deployment, and internal use:
- Responsible
- Equitable
- Traceable
- Reliable
- Governable
See CPS-022 for details.
• Contact our Artificial Intelligence Ethics Advisory Committee to adjudicate concerns or receive guidance related to our AI principles.
Fair Competition
WE SET THE STANDARD
• Be fair when dealing with customers, suppliers, competitors and employees.
• Ensure all communications and
representations to prospective customers, suppliers and partners are accurate and truthful.
• Perform all contracts in compliance with laws, specifications, requirements, and contract terms and conditions.
• Never request, accept, use, copy or
distribute any information to which
Lockheed Martin is not legitimately entitled.
• These activities not only violate policy, but also may be illegal:
- Discussing, using, copying or distributing any
unauthorized information (especially pricing, bid strategy or customer information obtained during bids or negotiations or in connection with attendance at trade shows, industry groups or training) without seeking guidance from the Legal Department or Ethics Office.
• Maintaining the highest standards of integrity in our procurement processes, and in bidding or negotiating contracts, is essential to performing on current and future contracts, products and services.
• If you receive unauthorized information, or are uncertain as to the Corporation’s legal right to use or share the information, do not copy, distribute or use it until guidance from the Legal Department has been provided.
Why It Matters
What to Watch Out For
Page 20
Lockheed Martin
Code of Conduct
• CPS-009 New Business Opportunity Management
• CPS-441 Cost Estimating/Pricing
• CPS-729 Compliance with United States Antiboycott Laws
• CPS-730 Compliance with Anti-Corruption Laws
• CRX-011 International Business Development Consultants
• CRX-013 Government and Competitor Information
• CRX-015 Protection of Sensitive Information
Policies
• Report any inquiries made to us in connection with our bid or negotiation activities to the
Legal Department.
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Abide by International Trade Laws
WE SET THE STANDARD
• Comply with all export and import laws and regulations that cover the transfer of certain technical data, equipment and technology between countries.
• Do not engage in or support restrictive international trade practices or boycotts not sanctioned by the U.S. Government.
• Comply with U.S. law and the laws of the countries where we do business.
• Any written or oral request request in bids and proposals to comply with boycotts not sanctioned by the U.S Government is a boycott red flag and must be immediately reported to your Element Legal Counsel, even if Lockheed Martin decides not to proceed with the bid / proposal.
• Export and import violations, and illegal
boycotts, damage the trust and transparency needed to transact legitimate and long-term business.
• Customers expect fair and open competition in how we do business worldwide with our competitors, suppliers and customers.
Why It Matters
What to Watch Out For
X
This includes explicit or more subtle contract language such as, “The Seller agrees to fully comply with the Israeli Boycott rules and certifies that the equipment to be supplied under this contract will not be of Israeli origin…” or, “The Seller’s specialists shall abide by all rules and laws of Country X.”
Written or Oral Requests
Page 21
Lockheed Martin
Code of Conduct
• CPS-310 International Trade Controls and Compliance
• CPS-729 Compliance with United States Antiboycott Laws
• CRX-015 Protection of Sensitive Information
Policies
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
• The U.S. maintains sanctions or embargoes that prohibit engaging in certain business activities in specified countries, as well as with specified individuals and entities. For example, U.S. law prohibits interaction with identified terrorist states and organizations.
Actions of Third Parties
WE SET THE STANDARD
• Do not engage with third parties to conduct business in a manner that is contrary to law or to our policies or that would circumvent our values and principles.
• Provide training to certain third parties on our ethical values, policies and compliance requirements.
• Be certain that all third parties, including business development consultants and independent contractors, understand and comply with their obligations to act in accordance with applicable laws and regulations and the Corporation's requirements for doing business.
• Be certain that consultants, representatives and third parties certify that they will comply, and are acting in compliance with, the Corporation’s requirements for doing business on its behalf.
• The actions of third parties who conduct
business on our behalf can impact our reputation.
• Improper actions conducted on our behalf could result in criminal or civil liability for the Corporation or for the employee(s) responsible for the third party.
• We may be accountable for the actions of anyone conducting business on our behalf.
Why It Matters
What to Watch Out For
Page 22
Lockheed Martin
Code of Conduct
• CPS-008 Gifts, Hospitality, Other Business Courtesies, and Sponsorships
• CPS-113 Acquisition of Goods and Services
• CPS-716 Compliance with the Anti-Kickback Act of 1986
• CPS-730 Compliance with Anti-Corruption Laws
• CPS-734 Combating Trafficking in Persons
• CRX-010 U.S. Business Development Consultants
• CRX-011 International Business Development Consultants
• CRX-025 Teaming Agreements
• CRX-106 Managing Major Subcontracts
• CRX-126 Counterfeit Prevention
Policies
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Corruption and Kickbacks will not be Tolerated
WE SET THE STANDARD
• Do not offer, give, solicit or receive any form of bribe or kickback.
• Walk away from any business
engagement that would violate any anticorruption law or our Code of Conduct, or that would create even a perception of impropriety.
• A party’s poor reputation, ties to government and public officials, questionable or unusual circumstances, unusual compensation and questionable accounting or invoicing, or insufficient capabilities are red flags.
• Expressions such as; ‘that’s the way business is done here’, ‘everyone does it’, ‘that is what is expected to win the contract’, or ‘this is normal in this country’ are also red flags.
• Corruption creates unfair competition, increases cost and jeopardizes the quality and capability of our products and services.
• Bribery, including even the attempt to corrupt, is illegal and may be enough to be prosecuted under U.S. and other countries’ laws.
• Conducting business where there is even a hint of impropriety could cause irreparable reputational harm, in addition to legal harm to our business such as,
Why It Matters
What to Watch Out For
Page 23
Lockheed Martin
Code of Conduct
• CPS-008 Gifts, Hospitality, Other Business Courtesies, and Sponsorships
• CPS-021 Good Corporate Citizenship and Respect for Human Rights
• CPS-310 International Trade Controls and Compliance
• CPS-730 Compliance with Anti-Corruption Laws
• CRX-011 International Business Development Consultants
• CRX-015 Protection of Sensitive Information
Policies
X
Bribery is directly or indirectly paying, promising, giving, offering or authorizing to give anything of value to anyone for the purpose of influencing that person to misuse his or her position.
Bribery
X
A “red flag” is a fact, event, or set of circumstances, or other information that may indicate a potential legal compliance concern for illegal or unethical business conduct, particularly with regard to corrupt practices and non-compliance with anti-corruption laws.
Red Flags
X
Corruption is any unlawful, illegitimate or improper behavior intended to gain an advantage and includes bribery, fraud, extortion, theft, abuse of power and money laundering.
Corruption
X
A kickback is any money, fee, commission, credit, gift, gratuity, thing of value, loan, entertainment, service or compensation of any kind that is provided, directly or indirectly, to any prime contractor, prime contractor employee, subcontractor or subcontractor employee for the purpose of improperly obtaining or rewarding favorable treatment in connection with a prime contract with the U.S., or a subcontract in connection with a prime contract with the U.S.
Kickback
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 24
Lockheed Martin
Code of Conduct
• CPS-720 Compliance with the Antitrust Laws
Policies
Strictly Adhere to
all Antitrust Laws
WE SET THE STANDARD
• Do not enter into business arrangements that eliminate or discourage competition or that give us an improper competitive advantage.
• Discussion or agreement with competitors or partners to allocate bids, contracts, customers, markets or territories, or coordinate pricing or limit supply of products or services.
• Antitrust laws apply world-wide and protect trade and commerce from unlawful restraints and monopolies, or unfair business practices, protecting customers, Lockheed Martin and our business partners.
Why It Matters
What to Watch Out For
Antitrust rules apply to more than you might think. They require that you avoid engaging in certain activities and business discussions. Examples from the policy include:
• Price fixing.
• Boycotting suppliers or customers.
• Pricing intended to run a competitor out
of business.
• Disparaging, misrepresenting or
harassing a competitor.
• Teaming with companies to create less
competitive outcomes for customers or
blocking competitors to prevent market
entry.
• Restricting the hiring or salaries of employees
with competitors or suppliers.
• Entering into agreements with competitors to
divide the market by allocating bids, contracts,
territories or markets or restricting the
production or sale of products or product lines.
• Conditioning the sale of one product or service
on the sale of another product or service.
• Conditioning the sale or purchase of product
or services on the requirement that the seller or
purchaser not do business with competitors of
the Corporation.
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 25
Lockheed Martin
Code of Conduct
• CPS-008 Gifts, Hospitality, Other Business Courtesies, and Sponsorships
• CPS-716 Compliance with the Anti-Kickback Act of 1986
• CPS-730 Compliance with Anti-Corruption Laws
• CRX-010 U.S. Business Development Consultants
• CRX-011 International Business Development Consultants
Policies
Accept and Provide Only Appropriate Business Courtesies
WE SET THE STANDARD
• Avoid even the perception that favorable treatment is being sought, received or given.
• Ensure that any business courtesy offered or accepted is permitted by law and policy.
• Complex rules and monetary limits apply when dealing with Public Officials. Consult policy and obtain guidance if you are uncertain if an action is inappropriate or within the allowable limits.
• Understand that a business relation is any
individual or group with whom we do business
or we seek to do business or who seeks to do
business with us.
• We have established country-specific,
permissible thresholds which may not be
exceeded without prior approvals.
• It is not only the value of the business courtesy that matters. The simple act of offering, giving or receiving any business courtesy, or the perception of an intent to gain an improper business advantage, may be illegal or unethical.
• No sponsorship may be undertaken to directly or indirectly procure future business or with the intent to obtain or retain business, secure an improper advantage or induce anyone to act improperly.
• Global Supply Chain Operations employees
and those who are involved in the process of
directing business or funds are held to a
higher standard.
• Giving cash, cash equivalents or gift cards to
business relations is prohibited.
• When people exchange gifts or business courtesies, it can create the perception that favors were granted in order to improperly influence business judgment.
• You will compete on the merits of our products and services and not give business courtesies to gain an unfair competitive advantage.
• Source products and services fairly to avoid accepting business courtesies that may cause even the perception of an inappropriate business relationship.
Why It Matters
What to Watch Out For
X
A business courtesy is any tangible or intangible thing of value for which fair market value is not paid by the recipient.
Business Courtesies
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 26
Lockheed Martin
Code of Conduct
• CPS-015 Environment, Safety and Health (ESH)
Policies
Safe and Healthy
Work Environment
WE SET THE STANDARD
• Provide a safe and healthy work environment and operate in a manner that protects the environment, conserves natural resources and prevents pollution.
• Stop immediately if something that is unsafe or can harm the environment is
identified.
• Report any non-compliance to posted warnings, procedures and regulations.
• Any accident, injury or close call sustained on the job, or any environment, safety or health concern you may have must be reported
immediately.
• Whether working on-site or at home, it is important that our workplace is safe and beneficial to our personal welfare and the environment.
Why It Matters
What to Watch Out For
USE IDEA:
• ID (Identify): assess the situation to identify safety risk
• E (Evaluate): determine the best course of action to address the risk
• A (Act): communicate or report your safety concerns to colleagues and your leader, and mitigate the risk
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Page 27
Lockheed Martin
Code of Conduct
• CRX-525 Tobacco- and Smoke-Free Environment
• CRX-545 Drug-Free Workplace
Policies
Maintain a Drug-Free Workplace
WE SET THE STANDARD
• The possession, use, sale, manufacture, transfer, trafficking in, or being under the influence of illegal drugs, or the abusive use of legal drugs, in the workplace or in the performance of company business, is
prohibited.
• Being under the influence of alcohol in the workplace or in any other location where we perform business on behalf of the Company is prohibited.
• Complying with the Drug-Free Workplace Act of 1988 and federal, state, and local laws and regulations concerning violations of criminal drug statutes in the workplace is a requirement.
• We will not knowingly hire or rehire individuals who possess, use, sell, manufacture, transfer, or traffic in illegal drugs.
• State and local initiatives legalizing the use of marijuana for medical and / or recreational purposes do not alter Lockheed Martin’s obligation as a federal contractor to maintain a drug-free workplace.
• Being “under the influence” doesn’t necessarily mean being above the legal limit.
• If you or a colleague has a drug or alcohol dependency issue, take advantage of company
resources for help.
• Using an illegal substance can negatively impact your ability to perform safely, be productive and obtain or maintain a security clearance or continued employment.
Why It Matters
What to Watch Out For
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
Security
WE SET THE STANDARD
• Protect our people, operations and assets.
• Take action to mitigate threats to
employee safety.
• Properly safeguard all classified material and other information entrusted to us.
• Comply with and seek to exceed
customer and national security policy
requirements.
• Maintain dedicated counterintelligence and insider threat detection programs.
• Use a thorough and objective security investigative process.
information from external sources
regarding company people, facilities, operations, programs or products. It’s up to you to report it.
• Ensure that any unauthorized access to information or assets is reported.
• An email security threat can contain references that may appear to be legitimate
in order to trick you into thinking it’s coming from a legitimate source.
• Security compliance benefits our Corporation, customers, national security and global stability.
• Adherence to security requirements supports contract performance and enables our products and services to be delivered uncompromised.
Why It Matters
What to Watch Out For
Page 28
Lockheed Martin
Code of Conduct
• CPS-569 Security
• CRX-052 Crisis Management
• CRX-053 Workplace Security - Maintaining a Safe and Respectful Workplace Free from Threats and Violence
• CRX-055 Travel or Assignment to Elevated Risk Locations
• CRX-056 International Security Operations
• CRX-057 LMSecurity Procedures
• CRX-059 Insider Threat Detection Program
Policies
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
• A strong security program fosters a safe environment for our workforce.
• We are a prime target for a number of threat actors seeking to gain information or to damage / destroy our capabilities.
• You may be the first person to notice
concerning changes in a colleague’s
behavior, or suspicious or unusual activity, such as inquiries or requests for
Page 29
Lockheed Martin
Code of Conduct
• CPS-021 Good Corporate Citizenship and Respect for Human Rights
• CPS-803 Sustainability
• CRX-202 Restrictions on the Use of Chemical Substances in
Products and Processes
• CRX-350 Energy
Policies
Sustainability and
Responsible Corporate
Citizenship
WE SET THE STANDARD
• Fosters innovation, integrity and security across our platforms and services.
• Maximizes the positive contributions of our products and services on the environment, the economy, community development and infrastructure resilience.
• Seeks to avoid and minimize negative
consequences of business activities across the full value chain.
• Operates in a manner that protects
the environment, as well as people, by
conserving natural resources, preventing pollution an ensuring ethical business conduct.
• Drives affordability, risk mitigation and
innovation throughout our business strategy and our value chain.
Why It Matters
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
• Ensures long-term competitiveness of our business and health of our communities and planet.
• Improves customer and stakeholder collaboration.
• Signifies commitment and fosters a sense of purpose that align with employee values.
Respect and Appreciate Human Rights
WE SET THE STANDARD
• Respect for human rights is an essential element of being a good corporate citizen.
• The importance of human rights across the globe, includes:
• Protecting and advancing human rights:
Why It Matters
Page 30
Lockheed Martin
Code of Conduct
• CPS-001 Ethics and Business Conduct
• CPS-003 Nondiscrimination and Equal Employment Opportunity
• CPS-021 Good Corporate Citizenship and Respect for Human Rights
• CPS-730 Compliance with Anti-Corruption Laws
• CPS-734 Combating Trafficking in Persons
• CPS-803 Sustainability
• CRX-515 Business Resource Groups and Employee Networks
Policies
- Treating employees with respect,
championing diversity and inclusion.
- Promoting fair responsible employment and wage & hour practices.
- Providing fair and competitive wages.
- Prohibiting harassment, bullying,
discrimination, use of child or forced labor, or trafficking in persons for any purpose.
• Trafficking in persons and slavery are issues around the world, and if we are not mindful, we could unwittingly engage with third parties who violate these principles.
What to Watch Out For
• Suspicious behavior or activities may indicate the presence of human rights violations.
- Maintains our commitment to integrity and our core values.
- Promotes employee satisfaction and
productivity.
- Enhances competitiveness of our business.
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
• Employees can exercise their right of free association and to choose or not choose collective bargaining representation.
• Employees and suppliers must take the appropriate steps to ensure respect for human rights in our business.
• We adhere to human rights precepts in our relations with stakeholders and through our products and services.
Political Process
WE SET THE STANDARD
• Follow corporate policy and the law concerning the political process in all countries where we do business.
• Uphold the spirit and letter of all laws relating to our participation in the political process.
• Laws governing political contributions and lobbying are complex.
• Even unintended violations can result in loss of business opportunities, damage to our reputation and civil and criminal penalties.
Why It Matters
What to Watch Out For
Page 31
Lockheed Martin
Code of Conduct
• CPS-004 Political Activity
• CPS-005 International Operations
• CPS-008 Gifts, Hospitality, Other Business Courtesies, and Sponsorships
• CPS-045 Government Affairs
• CPS-730 Compliance with Anti-Corruption Laws
• CRX-251 Charitable Contributions
Policies
• Prohibited
• We Support the Political Process
• Require Caution
• Permitted
X
You are encouraged to:
• Participate in the Lockheed Martin Employees’ Political Action Committee, if eligible.
• Participate personally in civic affairs and the political process on your own time, and at your own expense.
• Support the political parties and candidates of your choice.
Permitted
X
• Using any Lockheed Martin funds, assets or facilities for the benefit of political parties or candidates anywhere in the world without
obtaining prior written approval.
Prohibited
X
• Public Office - Conflicts of interest can arise if you seek or hold public office or serve on
commissions or advisory groups.
• Lobbying - Lobbying can be direct or indirect, but either way, it is highly scrutinized and must follow policy.
• U.S. Congressional and Executive Branch - It is important that Lockheed Martin present a
single, consistent business message to our U.S.-based customer community. Government
Affairs works with business areas to develop a united approach to the Corporation’s U.S.-
based marketing initiatives and policy, regulatory and legislative strategies. To this
end, Government Affairs must authorize any interaction with U.S. Congressional members
or Executive Branch officials in Washington, D.C. or their employees and staff.
• State and Local Governments - Government Affairs must authorize any interaction with state and local government officials on behalf of Lockheed Martin.
• Non-U.S. Governments - Follow policy when engaging with Non-U.S. Government Officials to assure that their activities are permitted and within local laws and regulations.
• Individual Political Contributions - Some state and local laws may restrict, limit or require
disclosure of personal political contributions made by individual employees or their
immediate family members.
Require Caution
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
X
• Many countries, in addition to the United States, may prohibit corporate political contributions. This may include donating
corporate funds, goods or services, directly or indirectly, to political candidates, including through consultants or employee work time.
• Local and state laws may limit corporate political contributions and activities.
We Support the Political Process
Page 32
Lockheed Martin
Code of Conduct
• CPS-004 Political Activity
• CPS-005 International Operations
• CPS-008 Gifts, Hospitality, Other Business Courtesies, and Sponsorships
• CPS-045 Government Affairs
• CPS-730 Compliance with Anti-Corruption Laws
• CRX-251 Charitable Contributions
Policies
800-LM ETHIC (800-563-8442)
International: Dial the United States access code 01 and 800-563-8442
For the Hearing or Speech Impaired: 800-441-7457
Call:
Office of Ethics and Business Conduct
Lockheed Martin Corporation
6801 Rockledge Drive
Bethesda, MD 20817
Write:
corporate.ethics@lmco.com
E-Mail:
Employees may transmit concerns about accounting, internal controls or auditing matters and confidential or anonymous submission of questionable accounting or auditing matters to the Audit Committee of the Lockheed Martin Board of Directors. If you wish to raise a concern to the Audit Committee, you may do so by contacting the Corporate Ethics Office and your concern will be communicated to the Chair of the Audit Committee of the Board.
Audit Committee:
Contact
Receipt and Acknowledgement
You acknowledge that you have read and will abide by Setting the Standard, the Lockheed Martin Code of Ethics and Business Conduct (the Code). You are acknowledging that you understand that each Lockheed Martin employee, member of the Board of Directors, consultant, contract laborer or other agent representing or acting for the Corporation is responsible for knowing and adhering to the principles and standards of the Code. You are also acknowledging that you understand that violations of the Code are cause for corrective action, which may result in disciplinary action up to and including discharge.
To take credit in Atlas Learning, click here and complete
"TAKE CREDIT (STEP 2)".
Receipt and
Acknowledgement
Good Corporate Citizenship
Our Work Environment
Conduct
Business Fairly
Demonstrate
Accountability
Respect
Others
Lead with Integrity
Introduction
• CPS-004 Political Activity
• CPS-005 International Operations
• CPS-008 Gifts, Hospitality, Other Business Courtesies, and Sponsorships
• CPS-045 Government Affairs
• CPS-730 Compliance with Anti-Corruption Laws
• CRX-251 Charitable Contributions
Policies
800-LM ETHIC (800-563-8442)
International: Dial the United States access code 01 and 800-563-8442
For the Hearing or Speech Impaired: 800-441-7457
Call:
Office of Ethics and Business Conduct
Lockheed Martin Corporation
6801 Rockledge Drive
Bethesda, MD 20817
Write:
corporate.ethics@lmco.com
E-Mail:
Employees may transmit concerns about accounting, internal controls or auditing matters and confidential or anonymous submission of questionable accounting or auditing matters to the Audit Committee of the Lockheed Martin Board of Directors. If you wish to raise a concern to the Audit Committee, you may do so by contacting the Corporate Ethics Office and your concern will be communicated to the Chair of the Audit Committee of the Board.
Audit Committee:
Contact
SETTING THE STANDARD
Updated October 2023.
Lockheed Martin Corporation
6801 Rockledge Drive
Bethesda, MD 20817
©1995-2023. Lockheed Martin Corporation. All rights reserved.
1-800-LM ETHIC (1-800-563-8442)
corporate.ethics@lmco.com
Corporate Ethics Office
Lockheed Martin Corporation
6801 Rockledge Drive, MP-211
Bethesda, MD 20817