Anti-Corruption Awareness, Compliance & Education

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. and non-U.S. laws and regulations, and adhere to Raytheon’s internal policies and procedures.

ANTI-CORRUPTION

Anti-corruption laws criminalize certain conduct committed by or on behalf of companies. Anti-corruption laws prohibit corrupt payments and/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 anti-corruption laws and their implications helps us do that. Anti-corruption laws are designed to drive integrity and fair dealing in global business competition. Prosecutors across the globe are increasingly coordinating with each other and enhancing scrutiny of companies who have purposefully or inadvertently violated the anti-corruption law.

OUR COMPLIANCE PROGRAM – KEY AREAS

Commitment – The CEO and Board of Directors are regularly briefed on Raytheon’s anti-corruption matters.  Additionally, senior leadership participate in anti-corruption assessments on a quarterly basis.

Code of Conduct and Compliance Policies – Raytheon’s Anti-Corruption policy and Code of Conduct are made available to all employees of the company and available in multiple languages.

Oversight, Autonomy, and Resources – The Anti-Corruption compliance organization sits under the purview of the CEO, General Counsel, and Chief Ethics and Compliance Officer.  Significant investments have been made in personnel and technology to enhance Raytheon’s compliance activities.

Risk-Based Compliance – Personnel, resources, and compliance activities are allocated using a risk-based approach that considers a variety of factors.

Continuous Training and Advice – Raytheon personnel with high-risk positions are provided enhanced multimedia and in-person training by subject matter experts within the company.  Raytheon’s Anti-Corruption group has dedicated personnel that provide advice across the enterprise.

Zero Tolerance – Raytheon has a zero tolerance policy for corrupt behavior.

Third-Party Due Diligence and Payments – Raytheon understands that third-parties pose the biggest anti-corruption risk and have dedicated significant resources to develop an industry-leading due diligence process, which leverages payment controls as a check on corrupt activities.

Internal Audits – Internal Audit performs periodic reviews of anti-corruption activities and processes.

Anonymous Reporting – Multiple anonymous reporting systems are available to Raytheon personnel and third parties and processed in a timely manner.  In support of that commitment, Raytheon maintains a zero tolerance policy toward any act of retaliation against an employee who has raised an issue or filed an internal complaint, or complaint with a regulatory or other government agency, or has participated in the investigation of a complaint.  We assess our employees’ confidence in Raytheon’s non-retaliation commitment through company-wide employee surveys.

Investigations – At least annually, briefings on anti-corruption violations, including results of alleged misconduct investigations, status of investigations, and corrective and disciplinary actions taken, are presented to the Public Policy Corporate Responsibility Committee of the Board of Directors. In addition, anti-corruption investigations and allegations involving significant financial improprieties are reported to the Audit Committee of the Board of Directors.

Continuous Improvement – The Anti-Corruption Working Group is responsible for testing and reviewing Raytheon’s anti-corruption process and training, and recommends improvements for implementation.

Transaction Due Diligence – M&A is a critical part of Raytheon’s business and as such, Raytheon has developed a comprehensive pre-acquisition and post-acquisition anti-corruption compliance process.

 

EDUCATIONAL PROGRAM AND TRAINING

Raytheon Company has a robust anti-corruption training program, including the award-winning FCPA Aware video series, which depicts real life situations and dilemmas. The featured FCPA video, "FCPA Aware: No Envelope, Please," shows a company manager meeting with a potential third-party international business development representative. The third-party representative has not been engaged or directed by the company, but he has already shown corrupt intent to provide an improper business advantage by sharing nonpublic information about a competitor. This training is refreshed on an annual basis.

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

Certifications – All Raytheon personnel are required to comply with Raytheon’s Anti-Corruption policy and Code of Conduct on an annual basis.

Targeted Training – Raytheon personnel with high-risk job functions are required to take additional anti-corruption training on an at least an annual basis.

Multifaceted Training Methods – Raytheon personnel with the highest-risk job functions are provided with enhanced multimedia training and in some instances, in-person training.