It is the policy of Raytheon Company to ensure compliance by its leaders, employees, and covered persons, including representatives, consultants and other contracted third parties, with the Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act, and all other relevant anti-corruption laws. Raytheon has a zero tolerance policy for corrupt behavior.
The company competes based on price, the quality of our products and services, and the skills of our employees and subcontractors, not on the basis of any improper advantage outside the rules establishing fair competition. We take pride in our ethical culture and expect employees to do the right thing. Business objectives cannot be met by sacrificing Raytheon’s integrity. When in doubt, we follow the maxim: “If it’s gray, walk away.” Our Code of Conduct makes clear that anti-corruption compliance is key to upholding our Company values and critical to protecting our reputation in the global business arena. Raytheon reinforces our commitment to integrity in the global marketplace through a comprehensive set of policies, including an overarching anti-corruption policy. For a description of these policies, please see the Anti-Corruption Policies section of this website.
Raytheon’s anti-corruption compliance program is led by the Anti-Corruption & International Agreements (ACIA) group, which reports to the Chief Ethics and Compliance Officer (CECO) within the Office of the General Counsel. ACIA drives anti-corruption compliance through written communication (emails, blogs, Codebreakers/Codechampions, etc. ), video-based training (FCPAware, EthicSpace, and EthicSketch), annual live training (ACT with Integrity) required of all employees, and targeted online and in person training for high risk personnel, with messages encouraging employees to identify issues, ask questions and raise concerns without the fear of retaliation, emphasizing the importance of training, and providing guidance on areas of particular concern to help all employees understand key anti-corruption responsibilities and their personal role in guaranteeing compliance with anti-corruption laws. ACIA also ensures that Raytheon’s international business development partners receive regular anti-corruption training and that all third-parties agree to abide by all applicable anti-corruption laws, rules, and regulations and uphold Raytheon’s values.
Raytheon has a rigorous anti-corruption self-assessment and sustainment process, where we continually review and assess our anti-corruption policies, training, internal controls and practices. Read more about our cycle of continuous improvement.
Raytheon helped draft and was one of the original signatories of the Global Principles of Business Ethics for the Aerospace and Defense Industry. Our support for the Global Principles reinforces our commitment to anti-corruption compliance wherever we do business. Read the Global Principles. Raytheon is a founding member of the International Forum on Business Ethical Conduct (IFBEC) and an original signatory to the Defense Industry Initiative (DII). These industry organizations focus on sharing best practices and enhancing ethics and business conduct among defense and aerospace companies.
Key Elements of Raytheon's Anti-Corruption Sustainment Program