All Raytheon third-parties must undergo comprehensive, rigorous, and continuous risk-based due diligence screening and monitoring, with high risk transactions and parties receiving enhanced due diligence. Risk-based factors include, for example, the location of the party/transaction, size of the transaction, type of transaction, etc. The Raytheon due diligence process ensures that “red flags” are quickly identified and then ensures these concerns are addressed — with the assistance of legal counsel as appropriate — to mitigate potential corruption and other risks that might affect a relationship with a party generally or in the context of a specific transaction. The due diligence process includes analysis of ownership, to include identification of foreign government/foreign government agency ownership interest. A positive indication of foreign government/foreign government agency ownership interest is considered a “red flag” and escalated to the Office of General Counsel for review. The results of all due diligence reviews are documented and recorded in Raytheon’s Due Diligence Database (3D), which provides companywide access to the results of all due diligence for review and use by all Raytheon employees. Further, due diligence on international parties is refreshed as change orders and contract modifications arise, but no less than every two years.
Our due diligence processes include:
International Party Due Diligence (IPDD) is a focused assessment of each non-U.S. supplier, person, company, representative, consultant, offset service provider, prime contractor, customer, teammate, joint venturer, or other party, affiliated with a transaction in which Raytheon is considering entering into an international contractual relationship (International Party). IPDD focuses on the specific party to identify, resolve, or mitigate (if possible) legal, ethical, reputational, financial, or other risks that may adversely affect the proposed business relationship. IPDD provides reasonable assurances that the Company has adequate information to make an informed decision about the international party before entering into a contractual or business relationship.
International Transactional Due Diligence (ITDD) is an assessment of the entire transaction that “connects the dots,” and ensures an overall understanding of the business deal, including verifying the credibility of the proposed business partner’s claims, flow of funds analysis and the overall business relationship and involving, as appropriate, specialized international tax, human resources, and civil works considerations. ITDD provides reasonable assurances that the company has adequate information to make an informed decision about the overall transaction (of which the international parties are one component part), before entering into the international contractual or business relationship.
Raytheon incorporates strong anti-corruption provisions into its contractual documents. Raytheon also incorporates audit and termination provisions into contractual documents with international representatives and consultants. Third parties must agree to these terms prior to working with Raytheon. The Company’s standard terms and conditions for purchase orders require suppliers to abide by Raytheon’s Code of Conduct or the supplier’s equivalent ethics and conduct standards. Additionally, the terms and conditions require warranties of compliance with applicable anti-corruption laws, and breach of these warranties are grounds for cancellation of the purchase order.
For more discussion of our due diligence process, please see the related policy descriptions on the Anti-Corruption Policies section of this website.
To improve the operation and management of Raytheon’s due diligence activities, Raytheon’s leadership made a significant investment in digitization and automation. The investments will provide an updated and scalable database infrastructure, electronic workflows, enhanced reporting capabilities, and smart logic functions.