High Ethical Standards
Raytheon has earned a reputation for excellence in systems, products, and services -- in defense and commercial electronics, engineering and construction, and aviation. This reputation rests on our unwavering commitment to the highest ethical standards.

The company has established a code of conduct, a set of ethical principles, supported by detailed standards of business conduct. The ethical principles of the company (integrity, respect, teamwork, quality, innovation and citizenship) are the foundation for ethical conduct. The company’s Standards of Business Ethics and Conduct booklet provides a clear road map for employees to follow in their daily work. Each employee is a critical link in the chain of excellence and acknowledges his or her responsibility under the code.

Executive Leadership
Since the Company’s founding, management example and continuing diligence has created a company environment of respect and confidence that assures continuing high ethical performance and respect for law. All managers maintain an open door regarding employee questions, including those of business conduct and ethics. Managers investigate any suspicion of unethical activities and call upon the Ethics Compliance Office for assistance.

To ensure continuing attention to matters of ethics and business conduct on the part of all Raytheon employees, the company has designated a corporate director of Ethics Compliance, as well as ethics officers in major business segments. The corporate ethics director reports to the Audit Committee of the Board of Directors and the Corporate Ethics Committee. Each ethics officer is charged with the responsibility for monitoring performance under the Standards of Business Ethics and Conduct and for resolving business conduct and ethical concerns.

Reporting Mechanism
The maintenance of high ethical business conduct is the responsibility of every employee and company representative, agent and consultant. Employees must assure that, not only are their actions of a high ethical standard, but also, that the perception of their activities is at an equally high level. Employees are expected to raise a question of ethical behavior before it happens and to report any conduct which is believed in good faith to be a violation, or apparent violation, of the standards. Every employee’s cooperation is required in assuring that violations of these standards are called to the attention of those in the company who should be informed. The company strongly encourages employees to work with their supervisors in making such reports and in addition, provides employees the right to report such violations directly to the Corporate Ethics Office or to the local ethics officer. Reports are handled as confidentially as possible and no employee will suffer retaliation for reports made in good faith. The Corporate EthicsLine number is:

1.800.423.0210.

Education and Communications
The company provides extensive values-based general ethics education and specific compliance-based training. Managers and employees are encouraged to discuss ethical issues at staff meetings and whenever appropriate to reinforce the company’s commitment to fostering an environment of the highest ethical standards. Approximately 72,000 employees received general ethics education in 2007.

The company also continues an active communications programs to all employees, representatives, agents and consultants, including the dissemination of policies and booklets. The explanatory ethics booklets cover overall standards pertinent to contractual activities, labor reporting, procurement, quality, international business, antitrust and other compliance topics. These have wide distribution to employees and are reviewed by management in sessions with employees.

Self Governance and Audit
Particular attention is paid to self governance by Raytheon to monitor compliance with federal laws and to adopt procedures for voluntary disclosure of violations and of corrective actions taken. Raytheon performs audits to verify the existence of internal control procedures. The Ethics Compliance Office insures a thorough investigation of all reports of violations relating to compliance with all ethical standards and law.

Compliance and Discipline
Though Raytheon is confident that it can count on every member of the company to do his or her part, deviations from our business conduct standards are not tolerated. Disciplinary action is taken against any individual who is found to have authorized, condoned, participated in or concealed actions that violate these standards; against any individual who knowingly falsely accuses another employee of a violation of a law, policy or the Standards of Business Ethics and Conduct or raises any ethical or compliance issue under false pretenses; against any supervisor who disregards or approves a violation, or who fails to prevent or report violations; and against supervisors who retaliate, directly or indirectly, or encourage others to retaliate against an employee who reports a violation of these standards. Because the standards are very important to our corporate values, the only appropriate response to a deviation from these standards may be termination of employment.