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 Code of Conduct, policies and procedures.
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, establish accounting rules that require us to maintain accurate books and records of all transactions, and require effective internal controls around the expenditure of funds.
WHY IS IT IMPORTANT?
It's important that we conduct business lawfully, and ethically, 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 anti-corruption laws.
OUR COMPLIANCE PROGRAM – KEY AREAS
Commitment – The CEO and Board of Directors are regularly briefed on Raytheon’s anti-corruption program. Additionally, senior leadership from across the Company’s functions and business units (several hundred leaders) participate in anti-corruption assessments and provide quarterly certifications on their understanding of the anti-corruption policy and their reporting of any matters of concern.
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 are available in multiple languages.
Oversight, Autonomy, and Resources – ACIA sits under the purview of the Chief Ethics and Compliance Officer (CECO) within the Office of General Counsel. The CECO provides an annual anti-corruption program review to the Public Policy & Corporate Responsibility Committee (PPCRC) of the Board of Directors, including updates on significant compliance issues, trends, and risks. The PPCRC oversees and guides the overall direction of the company’s anti-corruption program and reports to the full Board of Directors on an annual basis. The CECO also provides an annual Ethics and Business Conduct review to the full Board of Directors, as well as quarterly program updates, which include anti-corruption updates as appropriate.
Additionally, the Compliance Oversight Team (COT), comprised of the General Counsel, CECO, Chief Financial Officer, President of GBS (Raytheon’s shared services business unit), Vice President of Human Resources & Security, Vice President of Contracts/Supply Chain, and Vice President of Internal Audit, oversees the anti-corruption program and meets at least twice a year to review risks, evaluate program controls and discuss key enhancement initiatives. 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. ACIA has dedicated personnel who 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 has dedicated significant resources to develop a strong due diligence process, which leverages payment controls as a check on potential corrupt activities.
Internal Audits – Internal Audit performs periodic reviews of anti-corruption activities and processes.
Anonymous Reporting – Multiple reporting systems are available to Raytheon personnel and third parties, including the ability to make an anonymous report. Qualified personnel process reports in a timely manner and provide feedback at the conclusion of the investigation. Raytheon maintains a zero tolerance policy toward any act of retaliation against an employee, business partner, or other person 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 and by tracking trends in the volume of reports to Ethics.
Investigations – The Company conducts investigations of suspected corruption, working with relevant personnel from across Raytheon’s programs and functions to complete investigations, identify root causes of anti-corruption related incidents, and take appropriate corrective action. ACIA and the Litigation team of the OGC collaborate with the Office of Ethics and Business Conduct to investigate corruption/bribery related matters, including whistleblower reports, received by Ethics through the reporting channels outlined in the Code of Conduct. Investigation findings and any corrective/remedial actions are documented in ACIA’s case management tool and, where necessary, coordinated with Raytheon’s Litigation and Global Security Services departments to ensure reporting of misconduct to relevant authorities.
The ACIA Senior Director reviews matters of suspected corruption with the CECO, General Counsel, and Corporate Controller & Chief Accounting Officer to ensure timely notification to Management of the investigation and status of remediation. 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 – ACIA and the cross-functional Compliance Sustainment Team (CST) are responsible for testing and reviewing Raytheon’s anti-corruption process and training, and recommend improvements for implementation. The Company accomplishes this in principal part through the assessment of the key controls documented in the Anti-corruption Controls and Monitoring System discussed above.
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. Raytheon also conducts third party due diligence on all prospective joint venture partners.
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 to address emerging risks or new modalities of non-compliance.
Additionally, all employees complete annual ACT with Integrity training, which portrays employees facing ethical dilemmas in the workplace and reinforces the importance of, and avenues for, reporting misconduct.
Raytheon solicits feedback on the effectiveness of training through employee surveys. On at least an annual basis, and as necessary, Raytheon reviews and updates training material to ensure it is accurate and current with known risks, company policies, procedures, laws, and regulations. Raytheon also confirms needed translations – typically several non-U.S. languages and including all principal jurisdictions where Raytheon employees work.
Online Compliance Modules – To augment the several focused and internally–produced training and awareness video vignettes, Raytheon also procures and makes available to all employees a library of on-line training resources. 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 newly-hired Raytheon personnel are required to review Raytheon’s Anti-Corruption policy and Code of Conduct. All existing employees must acknowledge receipt of the Code whenever it is revised, typically every 24 months.
Targeted Training – Raytheon personnel with high-risk job functions are required to take additional anti-corruption training on an at least an annual basis. For example, no employee may obtain a ticket for international travel unless they have completed the annual training. A cross-functional team identifies employees in high-risk positions using objective criteria such as place of employment and job function, and reviews the list annually.
Multifaceted Training Methods – Raytheon personnel with the highest-risk job functions are provided with enhanced multimedia training and in some instances, in-person training.
IBDP Training – Raytheon’s International Business Development Partners (IBDPs) must complete anti-corruption training provided by the Company. At a minimum, IBDPs receive face-to-face training by qualified Raytheon personnel at least every two years. ACIA tracks IBDPs’ completion of anti-corruption training, and Raytheon will not renew an IBDP agreement unless required training is completed. Raytheon assigns additional on-line training modules to the IBDPs on an annual basis.