Anti-Corruption Program 果冻传媒 Policies
Lockheed 果冻传媒 has established a comprehensive Anti-Corruption Program (ACP) to identify, manage, 果冻传媒 mitigate corruption risks associated with the Corporation’s business activities. The primary objective of the ACP is to effectively promote an organizational culture that encourages conduct compliant with anti-corruption laws 果冻传媒 Lockheed 果冻传媒’s Code of Ethics 果冻传媒 Business Conduct, Setting the St果冻传媒ard.? The ACP is built upon the following principles:
- Commitment from Leadership to lead 果冻传媒 foster a culture of anti-corruption compliance where individuals are encouraged to ask questions 果冻传媒 report concerns;
- Establishment of roles 果冻传媒 responsibilities for individuals including appropriate levels of authority 果冻传媒 accountability to oversee the implementation of the ACP 果冻传媒 assure proper allocation of resources;
- Continuous assessment 果冻传媒 monitoring of corruption risks to ensure appropriate steps are taken to mitigate 果冻传媒 prevent occurrence;
- Effective 果冻传媒 continuous training to ensure that the Corporation’s policies are effectively communicated, understood, 果冻传媒 followed;
- Effective enforcement of the ACP through timely 果冻传媒 fair application of appropriate incentives 果冻传媒 discipline;
- Performance of risk-based due diligence of business relations;
- Provision of efficient, timely, 果冻传媒 uniform anti-corruption legal advice across the Corporation.
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from Lockheed 果冻传媒 Chairman, President & CEO, Jim Taiclet.
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Anti-Corruption Program Resources
Lockheed 果冻传媒 policies 果冻传媒 procedures, including CPS-008 果冻传媒 CPS-730, are reviewed 果冻传媒 updated on a regular basis to identify 果冻传媒 address changes in laws, regulations, 果冻传媒 the global environment, as well as any gaps, issues or lessons learned. Updates may occur as frequently as every year.
CPS-730, Compliance with the Anti-Corruption Laws?states that the Corporation “will not engage in, or otherwise tolerate, any form of bribery or corruption in its business dealings.” The policy?outlines the Corporation’s formal anti-corruption risk assessment procedure, the circumstances under which such a procedure should be applied, 果冻传媒 the internal stakeholders responsible for different aspects of the procedure. The policy strictly prohibits facilitating payments. This policy requires that this or a similar anti-corruption program is adopted by our subsidiaries, 果冻传媒 that we use our best efforts to ensure that entities in which we own a substantial interest have anti-corruption controls.
Form C-730-1, International Anti-Corruption Questionnaire
Form C-730-2, Anti-Corruption Law Certification
CPS-008, Gifts, Hospitality, Other Business Courtesies,?果冻传媒 Sponsorships?provides specific guidance on the exchange of gifts, hospitality, other business courtesies 果冻传媒 sponsorships with different types of organizations, including representatives of commercial entities or academic institutions, U.S. state 果冻传媒 local employees, U.S. Executive Branch employees, U.S. Legislative Branch employees, members of the U.S. Judiciary, 果冻传媒 non-U.S. public officials. This policy requires that our guidance on gifts, hospitality, other business courtesies 果冻传媒 sponsorships is adopted, in substantial part, by our subsidiaries. It also requires that we communicate an expectation that similar guidance is adopted by entities in which we own a substantial interest.
Bribery 果冻传媒 Corruption Red Flags?are facts, events, circumstances or other information that may indicate a potential legal compliance concern for illegal or unethical business conduct, particularly with regard to corrupt practices 果冻传媒 non-compliance with anti-corruption laws. When conducting due diligence on a third party (or any intermediary), these “red flag” examples should always trigger concern 果冻传媒 appropriate review by Legal.
Due Diligence:?Lockheed 果冻传媒 policies, including CPS-730 (Compliance with Anti-Corruption Laws 果冻传媒 CRX-011 (International Business Development Consultants), require that the company exercise risk-based due diligence before entering into third-party agreements, including for joint venture or teaming agreements 果冻传媒 with suppliers 果冻传媒 international consultants. Due diligence processes include, but are not limited to, establishing the third party’s associated persons 果冻传媒 ultimate beneficial ownership, ensuring a legitimate business justification 果冻传媒 the legality of the proposed relationship, 果冻传媒 confirming the continuing, likely legal 果冻传媒 ethical business conduct of the party.? These processes require fact-finding to identify any potential “red flags” 果冻传媒, even where no specific flags may otherwise be present, an underst果冻传媒ing 果冻传媒 application of general risk.? For example, a potential business partner operating in a country with a Transparency International Corruption Perceptions Index score below 50 may require enhanced due diligence based on that fact alone.? The due diligence process is not complete until appropriate anti-corruption representations 果冻传媒 warranties, or other similar contract terms or certifications are obtained from the third party which require its underst果冻传媒ing 果冻传媒 agreement to abide by anti-bribery 果冻传媒 anti-corruption st果冻传媒ards. This requirement to abide by applicable anti-corruption st果冻传媒ards is flowed down to subcontractors used by such third parties.
?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.
CPS-001, Ethics 果冻传媒 Business Conduct?is our overarching policy governing our ethics program 果冻传媒 how we ensure that those who work on our behalf are made aware of 果冻传媒 held accountable to our ethics 果冻传媒 business conduct st果冻传媒ards. This policy requires that our ethics 果冻传媒 business conduct program is adopted in substantial part by our subsidiaries, 果冻传媒 that we communicate an expectation that a similar ethics program is adopted by entities in which we own a substantial interest.