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  • Cover Page
  • A Message from our President and Chief Executive Officer
    Jim Taiclet CEO President
  • Our Values
    standard integrity stakeholders customers right respect perform
  • We Uphold the Code
    principles ethical business practices employees board of directors consultants contract laborers others laws regulations investigations violations trust stakeholders customers violations disciplinary action termination accountable report question concern waiver board committee Legal Department Ethics Office Security government agency third party conducting investigation suspected violation law destroy alter documents electronic records lie mislead investigator obstruct information legal action agencies investigating violations Code public New York Stock Exchange NYSE Securities and Exchange Commission Sarbanes-Oxley Act of 2002
  • We Report Violations
    action report reporting violations policy contract provision potential violation violations timely reporting failure suspected questionable conduct supervisor human resources ethics legal security EEO Investigations environment safety and health global diversity and inclusion internal Audit Committee guidance information resources concern illicit contact manager Human Resources Business Partner Ethics Officer Security Global Diversity Inclusion employees concerns accounting internal controls auditing matters confidential anonymous Corporate Ethics Office Chair Board
  • We Participate in Training
    training values real-life scenarios workplace violations violation required training compliance ethics awareness training individual employees application
  • We Take Action
    integrity questions actions colleagues corporation values conflicts potential violations law policy leadership personnel voicing our values identify correct problems issues unconscious bias ethical decision-making questions data talk reframe issue techniques
  • We Have Zero Tolerance for Harassment
    tolerance harassment verbal physical conduct abuses intimidates torments degrades threatens person environment psychological verbal harassment abusive conduct team witnesses unwelcome touching assault impeding movements blocking movements accessing transmitting displaying offensive messages images cartoons derogatory comments epithets slurs jokes objects sexual harassment behavior words deeds electronic communication online collaboration tools outside workplace policies conduct off-premises work U.S. law employee rights protections reprisals governmental officials Legal Department Ethics Office gross waste mismanagement abuse authority violations government contracts public health safety
  • We Have Zero Tolerance for Discrimination
    discrimination employees applicants characteristics protected law laws policy policies recruitment selection promotion demotion transfer layoff termination compensation education training disciplinary action diverse talents perspectives solutions value virtue unconscious bias culture performance harassment overt race ethnicity religion color sex pregnancy age veteran status ancestry sexual orientation gender identity expression marital status family structure genetic information mental physical disability legally protected characteristic
  • We Have Zero Tolerance for Retaliation
    zero tolerate retaliation good faith inquiry participates investigation reports misconduct fear employee employees trust reporting termination interactions legally protected reprisals fraud waste abuse government programs inappropriate treatment complaint participating internal investigation ethics-related inquiry truthful
  • We Respect Privacy
    personal information data business purpose authorization privacy dignity individuals safeguard confidentiality employee records externally file transfer trust employees customers protections appropriate email messages social media collaborative workspaces third parties necessary contractual agreements
  • We Use Assets Responsibly
    responsible protecting customers property assets use waste abuse customer company resources entrust entrusted unauthorized third-party information risks financial obligations improper violations violation laws law failure contractual obligations deviations policies unintended individuals misuse U.S. Government federal crime concern using customer contractually allowed authorized sending storing handling sensitive information personal computing device email addresses unapproved electronic items memory sticks data corporate credit card care guard borrow remove permission communication systems resources materials facilities equipment
  • We Keep Accurate Business Records and Communicate Accurately to the Public
    honestly accurately business financial records conduct business transparently compromising proprietary confidential information misrepresent fact falsify records promptly transactions books obligation public stockholders accurate disclosures customers investors maintain processes data accurate records legal regulatory obligations public company trust confidence public disclosures inputs government agencies external communications account costs labor travel material expenses behalf ensure comprehensive fair timely accurate understandable violate policy illegal inaccurate pricing submitted proposals reporting travel expenses labor charging U.S. Federal Acquisition Regulatory Council defense contractor reports documents U.S. Securities and Exchange Committee regulatory authorities presentations
  • We Protect Sensitive and Classified Information
    use store protect sensitive information applicable requirements obtain authorization disclosing receiving recipients classified information security clearance need to know social media responsibly conscious share unapproved generate acquire access valuable customers business technological economic advantages national security interests incident mishandling information damage reputation partners countries proper approval publishing making external presentations country-specific laws regulations import/export issues handling safeguarding requirements data security sensitivity safe colleagues protection engagement ends facilities customer locations working home public remotely Personal Information U.S. Personal Data Non-U.S. Export Controlled Information Proprietary Information Third Party PIRA employees Public Information Release Authorization tool point of contact Communications
  • We Accurately Charge Labor and Other Costs
    business-specific labor recording policies procedures account costs labor travel material improperly charging time customer contracts fraud accountable labor charges accurate recording time excessive online collaboration tools internet non-work purposes labor mischarging violate policy illegal falsifying timekeeping records incorrectly objective approving shifting costs improper accounts appropriately violation ethics case allegation contract work independent research development bid proposal transactions outside individuals organizations generally accepted accounting practices principles United States countries
  • We Avoid Individual Conflicts of Interest
    fair impartial business dealings personal interests interest corporation's business conflicts of interest activities appearance contacts position advance outside personal interests property information opportunities personal gain written disclosure action potential conflicts aware multiple loyalties disclosing potential independent objective assessment mitigating action owning substantial interest customer competitor supplier firm owned controlled employee family relationships persons accepting gifts payments consultant subordinate Conflict of Interest Network Tool COIN
  • We Avoid Conflicts of Interest with Government Employees
    conflicts of interest conflict connection employing acquiring services current former government employees military personnel comply laws regulations success ability compete marketplace hire work current former creates real perceived information competitive advantage individual possesses conflict contacting negotiating potential future employment service consultants subcontractors restrict roles responsibilities perform behalf complex advice legal Human Resources Department U.S. Government government ethics official background
  • We Avoid Organizational Conflicts of Interest
    actively work avoid neutralize mitigate Organizational Conflicts of Interest OCI prevent unfair competitive advantage conflicting roles impair objectivity products services limited government customers employees multiple customer representatives programs conflict government contract compromise failure screen business opportunities disqualification opportunity policies prevent bias judgment report disclosure restrictions supervisors notify prospective relationships impartial assistance advice objectivity screening letter OCI Reporting System
  • We Do Not Engage in Insider Trading
    comply applicable securities laws avoid appearance impropriety possession material nonpublic information company trade company's share tip underlying investor's trust public's trust financial markets depend confidence trades publicly available security trading material nonpublic terms legal definitions contact Legal Department question important related third party general public possibility communicating violate law stock Insider Trading learned stock common preferred restricted units employee options bonds notes debentures options call options instruments transactions securities fund transfers reallocations stock fund savings benefit deferred compensation plans purchase sale of common stock sale shares vested restricted stock units gifts gift tax trades limit orders prior possession material disseminated news official announcement open market privately company plans assimilated general public reasonable investor
  • We Use Artificial Intelligence Responsibly
    Artificial Intelligence AI benefits procurement development use values potential customers operations industry leader revolutionary technology access valuable data high-performance computing unleashed unprecedented opportunities changing companies sectors evolving discipline risks addressed design implementation systems principles concepts Ethical Development Use of Artificial Intelligence U.S. Department of Defense guidance
  • We Value Fair Competition
    fair dealings customers suppliers competitors employees communications representations prospective customer supplier partners accurate truthful contracts compliance laws specifications requirements contract terms conditions request accept use copy distribute information legitimately entitled highest standards integrity procurement processes bidding negotiating contracts essential current future products services activities violate policy illegal discussing using copying distributing unauthorized information pricing bid strategy bids negotiations connection attendance trade industry groups training guidance legal department ethics office discussion agreement competitors markets territories products services report inquiries Legal Department government prosecutors price-fixing bid-rigging written expressed agreement circumstantial evidence suspicious bid patterns travel expense reports prosecute competitor unauthorized legal right copy distribute
  • We Respect Trade Guidelines
    comply export import laws regulations transfer technical data equipment technology countries support restrictive international trade practices boycotts sanctioned U.S. Government U.S. law business violations illegal damage trust transparency transact legitimate long-term customers fair open competition worldwide competitors suppliers written oral request bids proposals red flag reported Element Legal Counsel restrictions sanctions embargoes prohibit activities prohibits interaction identified terrorist states organizations international trade careful inadvertent violations explicit contract language
  • We are Accountable for the Actions of Third Parties
    engage third parties third party conduct business contrary law policies values principles training ethical compliance requirements actions behalf impact reputation improper actions conducted criminal civil liability employee employees accountable conducting business development consultants independent contractors obligations applicable laws regulations acting consultants representatives comply trained clear responsibilities action adherence policies international
  • We Have Zero Tolerance for Corruption and Kickbacks
    tolerance bribery corruption offer give solicit receive bribe kickback business engagement violate anti-corruption law laws Code of Conduct perception impropriety unfair competition cost jeopardizes products services attempt corrupt illegal prosecuted U.S. countries conducting reputational legal harm financial penalties debarment reputation government public officials unusual circumstances questionable compensation accounting invoicing capabilities red flags expressions red flag Legal directly indirectly paying promising giving offering authorizing value influencing person misuse position unlawful illegitimate improper behavior gain advantage bribery fraud extortion theft abuse power money laundering money fee commission credit gift gratuity thing of value loan entertainment service compensation prime contractor employee subcontractor improperly obtaining rewarding favorable treatment prime contract subcontract fact event circumstances information legal compliance illegal unethical conduct corrupt practices non-compliance anti-corruption laws international
  • We Strictly Adhere to All Antitrust Laws
    knowingly business arrangements eliminate discourage competition improper competitive advantage antitrust laws law world-wide protect trade commerce unlawful restraints monopolies unfair business practices protecting partners proposed activity complies Legal department rules engaging activities discussions price fixing boycotting suppliers customers pricing competitor disparaging misrepresenting harassing competitor teaming companies outcomes blocking competitors market entry bribery kickbacks stealing trade secrets agreements market allocating bids contacts territories restricting production sale products lines product service conditioning purchase services requirement seller purchaser
  • We Accept and Provide Only Appropriate Business Courtesies
    favorable treatment received given exchange business courtesies courtesy offered accepted law policy gifts perception favors improperly influence judgment compete merits products services unfair competitive advantage fairly avoid inappropriate relationship rules monetary limits Public Officials guidance Ethics uncertain allowable limits guidelines country value offering giving receiving intent gain illegal unethical fair market value employees Supply Chain Management relations Gifts Decision Tree tangible intangible fair market value recipient international
  • We Maintain a Safe and Healthy Work Environment
    safe healthy work environment operating protects conserves natural resources prevents pollution speak up culture encourage identify unsafe harm home trust workplace company cares welfare report violations posted warnings procedures regulations management accident injury job environmental safety health concern IDEA identify evaluate act
  • We Maintain a Drug-Free Workplace
    hire rehire individuals possess use sell manufacture transfer trafficking under the influence illegal drugs abusive use legal drugs workplace company business prohibit alcohol location behalf comply Drug-Free Workplace Act of 1988 federal state local laws regulations violations criminal drug statutes substance perform ability safely productive security clearance employment U.S. federal contactor drug-free United States state local initiatives legalizing marijuana medical recreational requirement colleague dependency issue advantage resources help risk damage morale productivity public image limit
  • We are Committed to Security
    protect people operations assets mitigate threats employee safety safeguard classified material information entrusted comply exceed customer national security policy requirements dedicated counterintelligence insider threat detection programs objective security investigative process security compliance benefits customers national global stability contract performance products services uncompromised target threat actors gain damage destroy capabilities colleague's behavior suspicious unusual activity inquires request external sources facilities operations programs products report unauthorized assets reported email security threat trick legitimate source partners
  • We are Committed to Sustainability and Responsible Corporate Citizenship
    positive impacts products services environment economy community development infrastructure resilience avoid minimize negative consequences business activities society employees protects conserves natural resources prevents pollution commitments long-term competitiveness sustainability cost risk innovation global policies procedures practices commitment corporate citizenship mission choices
  • We Respect Human Rights
    respect human rights element corporate citizen globe championing diversity inclusion promoting fair responsible employment wage hour practices fair competitive wages prohibiting harassment bullying discrimination child labor forced labor trafficking persons purpose employees suppliers steps supply chain relations stakeholders product services protecting advancing integrity core values satisfaction productivity competitiveness slavery world engage third parties violate principles suspicious behavior violations global history criminal
  • We Support the Political Process
    policy law political processes countries business spirit letter laws participation process contributions gifts lobbying unintended violations opportunities damage reputation civil criminal penalties employees aware action prohibited require caution permitted personal best interests shareholders funds assets facilities benefit political parties candidates world written approval Government Affairs International activities United States countries prohibit corporate contributions donating goods services directly indirectly consultants employee work local state laws
  • Receipt and Acknowledgement
    acknowledge acknowledgement credit receipt receive

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