Jay B. StephensWelcome!  As Raytheon continues to grow internationally, it is incumbent upon our employees and representatives to conduct foreign business with the highest ethical standards, comply with U.S. laws and regulations, and adhere to Raytheon’s internal policies and procedures.  We created the Foreign Corrupt Practices Act (FCPA) information and resource portal to support these business objectives.

Here, you can learn about the FCPA, understand the various components of Raytheon’s FCPA Education Program, and learn how you can stay connected with FCPA developments outside of Raytheon.

Jay B. Stephens
Senior Vice President,
General Counsel and Secretary

What is it?

The Foreign Corrupt Practices Act (FCPA) criminalizes certain conduct committed by or on behalf of U.S. companies. The FCPA prohibits corrupt payments or bribes to foreign government officials, establishes accounting rules that require us to maintain accurate books and records of all transactions, and requires effective internal controls around the expenditure of funds.
 

Why is it important?

It's important that we conduct business lawfully around the world. Understanding the FCPA and its implications helps us do that. The Securities and Exchange Commission (SEC) and Department of Justice (DOJ) have increased their scrutiny and prosecution of companies who have purposefully or inadvertently violated the law. The FCPA is designed to drive integrity and fair dealing in global business competition.

 


 

Key Messages

Transparency – Accurately recording and reviewing all expenditures in books and records.

Compliance – Adhering to all components of FCPA.

Internal Controls - The Business Courtesy Approval Request (BCAR) is a vital part of the compliance program and must be used in all relevant instances.

Personal Responsibility – Be aware of the law, follow protocol and raise your concerns to Legal or Ethics.

 


 

Education Program

FCPA Aware Video Modules – A series of video modules that raise awareness about key aspects of the FCPA: due diligence, gifts and gratuities, offsets, and books and records.

FCPA Function-Specific Education – A series of function-specific online modules that provide detailed FCPA information and highlight function-specific, real-world FCPA scenarios.

LT Instructor-Led Sessions – Forums for the business leadership teams or extended leadership teams to receive additional FCPA information, reinforce video or other educational messages and encourage dialogue about critical issues.

Online Compliance Modules – Topics in our library of online ethics and compliance modules include: Global Bribery and Corruption, Understanding the FCPA, and the UK Bribery Act.

 

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