Raytheon has an overarching anti-corruption policy which articulates our zero tolerance for corruption; this policy appears at the link provided. The anti-corruption policy also describes related policies and procedures, which further detail how the Company's internal controls operate to detect, prevent and correct issues related to this critical area of governance. This policy covers all organizations within Raytheon Company, including direct and indirect subsidiaries other than Forcepoint1 entities, and governs all members of our Board of Directors, all employees, and the parties who work with us, such as business partners, consultants, contractors, lobbyists, and representatives.
Note: 1Forcepoint is a joint venture cybersecurity business that establishes and maintains its own policies and procedures, including a comprehensive anti-corruption policy that is reviewed by Raytheon. Forcepoint has its own governance system for anti-corruption compliance, including the screening and management of third parties, which is designed to support its business model. Forcepoint participates in the bi-weekly Compliance Sustainment Team meetings and has periodic meetings with the Raytheon ACIA Senior Director to discuss Forcepoint’s program and address any issues as required.
Summaries of related Raytheon policies, which typically relate to a wider range of processes in addition to anti-corruption measures, are provided below.
RP-FIN-CFO-001: Business Travel, Meeting, Entertainment, and Miscellaneous Expenses
Raytheon’s Business Travel, Meeting, Entertainment, and Miscellaneous Expenses Policy is designed to ensure the safety and wellbeing of traveling employees while being fiscally responsible, and to ensure that the reporting and accounting for business expenditures are in compliance with all applicable laws and regulations of the United States and other jurisdictions in which Raytheon Company conducts business. The policy also requires that auditable records are maintained. It applies to all businesses within Raytheon Company and other qualifying persons who incur travel and / or business expenses on behalf of all Raytheon organizations and subsidiaries. The policy outlines employee responsibilities and limitations when planning, expensing, and reporting all business costs.
RP-FIN-CAO-008: Cost Recording Integrity Standards
Raytheon’s Cost Recording Integrity Standards Policy defines the Company’s integrity standards regarding cost recording to contracts; independent research, independent development, and bid proposal projects; and to indirect cost objectives. The Company’s cost recording integrity standards are applied to the procedures by which the Company and its employees discharge their responsibilities to ensure proper cost recording and compliance with applicable laws and regulations that relate to customers, suppliers, and the exercise of stewardship responsibilities to stockholders. The policy identifies accurate, complete, and timely cost recording as one of the most important responsibilities assigned to employees, supervisors, and all higher levels of management, and reiterates that it is the Company’s policy that the highest standards of accuracy, integrity, and validity are to be reflected in all entries on recording documents.
RP-OGC-003: International Business Development Partner Costs, Bidding, Accounting and Payment of
The company recognizes the need for international representatives and consultants to complement the company’s business development efforts in achieving a cost-efficient, international marketing network for the company’s products and services. It is company policy to comply with all laws and regulations governing the company’s domestic and foreign operations, and to conduct its international marketing efforts in keeping with the highest moral, legal and ethical standards. Raytheon’s Authorization and Processing of International Representative and Consultant Agreements policy sets forth direction on the appointment and use of International representatives and consultants; provides direction on due diligence review procedures applicable to all international representatives and consultants; and ensures that all international representatives and consultants are fully trained in, and comply with, the company’s Code of Conduct, other applicable policies and procedures, the Foreign Corrupt Practices Act, as amended (FCPA), and all other applicable U.S. and foreign laws. In addition, Raytheon’s International Sales Representative and Consultant Costs, Bidding, Accounting and Payment of policy establishes uniform practices and controls for the bidding, accounting and payment of international sales representative and consultant costs.
RP-OGC-004: Records Management
The company shall create, maintain and retain complete and accurate records, which accurately reflect the underlying transactions of the business in order to operate its businesses; comply with statutory and regulatory recordkeeping and records retention requirements, external financial requirements, contractual requirements and company requirements; preserve its history; and protect intellectual property of the company. Records shall be protected against alteration, deletion or destruction, as well as from unauthorized access and shall remain readable, retrievable and accessible throughout their required retention period. Raytheon’s Records Management policy establishes the requirements for managing company applicable records in a consistent and systematic manner including the minimum retention periods for records to comply with legal and Company requirements; timely disposition of non-records and implement the legal hold process for certain required records.
RP-CON-002: Review of Proposals and Contract Documents
Raytheon applies a consistent approach to the conduct of business through formal reviews of proposals and contract documents by Raytheon’s businesses, corporate staff and executive office utilizing a standard review process. Raytheon’s Review of Proposals and Contract Documents policy outlines the disciplined review and assessment of each requirement’s cost, schedule, performance and other factor’s risk before award, and if successful, grants approval to proceed with contract award. The level of review is determined by factors such as dollar value, risk to the company and strategic importance to the company’s goals. The history of proposal approvals is stored electronically and also maintained in the contract file.
RP-IA-001: Internal Audit
Raytheon’s Internal Audit Policy outlines the roles and responsibilities, procedures and requirements of Internal Audit as well as the roles and responsibilities of those organizations throughout Raytheon as they work with Internal Audit. The Company has established and maintains an Internal Audit organization that is independent and objective. Internal Audit brings a systematic and disciplined approach to monitoring, evaluating and improving the effectiveness of the risk management, financial and operational control, and governance processes throughout Raytheon. Internal Audit functions as an independent appraisal entity to evaluate Company activities and to assist by furnishing analyses, appraisals and recommendations concerning the activities reviewed.
RP-OGC-005: Employment of Current and Former U.S. Government Employees
The Company complies with laws and regulations concerning the employment of current and former U.S. government employees, including restrictions on employment discussions with certain personnel. A legal review is conducted to avoid any conflict of interest in connection with the employment of current or former U.S. government personnel. The legal review determines whether a candidate for employment who is a current or former government employee may be hired by the Company, and, if so, whether any conflict of interest restrictions under various laws and regulations would apply to the job applicant. Similar reviews are conducted for job applicants who are current or former employees of governments other than the U.S.
RP-OGC-006: Reporting Political Contribution, Fees, and Commissions Involving Foreign Sales of Defense Articles / Services under ITAR part 130
Raytheon shall comply with all reporting requirements under ITAR 22 CFR Part 130. Such regulations require that a report be submitted to the U.S. Department of State when Raytheon:
- Applies to the U.S. Department of State for licenses or approvals for the permanent export of defense articles or defense services, valued at U.S. $500,000 or more, in support of international direct commercial sales; or
- Enters into contracts or contract modifications with the Department of Defense (DoD) to supply, pursuant to a foreign military sale (FMS) contract, defense articles or defense services, valued at US$500,000 or more, for the armed forces of a foreign country or international organization.
Raytheon’s Reporting Political Contribution, Fees, and Commissions Involving Foreign Sales of Defense Articles/Services policy establishes the internal guidance and controls to assure compliance with U.S. laws and regulations regarding the prompt reporting of fees and commissions in connection with foreign sales.
RP-SCM-005: Supply Chain Responsibility and Authority, and Authorzed Procurement and Payment Methods
This policy, which applies to all Raytheon organizations and personnel, establishes accepted methods to procure and pay for goods, materials, and services. The policy mandates that Supply Chain is the sole organization authorized to commit Raytheon to buy goods, materials, and services, except for limited, specified categories of expenditures made by Finance and Treasury, Human Resources, Legal, Real Estate, and Meetings, Events, and Trade Shows Planners. Requests for policy exceptions must be approved by the Business Chief Financial Officer, Business Functional Vice President, Business Supply Chain Vice President, and Business Director of Environmental, Health, Safety and Sustainability. Due diligence is performed on suppliers prior to making them active in Raytheon’s Enterprise Supplier Data Master (ESDM) file or in the local vendor master file, and suppliers must be active in ESDM to receive payments from Raytheon. Where a one-time supplier payment outside of ESDM is required, Business Controller approval is required except for merger and acquisition transactions, job applicant out-of-pocket expenses, and legal settlements. In collaboration with Finance, Supply Chain monitors procurement activity and compliance with this policy. For more information regarding Raytheon’s supply chain management, please see the Suppliers section of this website.
RP-SCM-006: International Supply Chain Management
It is the policy of the company to comply with laws and rules governing the export and import of products and technical data, (e.g., International Traffic in Arms Regulations (ITAR), and Export Administration Regulations (EAR)); implement internal FCPA controls designed to prevent and detect unlawful payments to foreign government officials and provide reasonable assurances that disbursements are commensurate with services rendered or goods and materials procured; accurately recorded in company books and records; and made for proper and lawful purposes. Raytheon’s International Supply Chain Management policy mandates thorough due diligence of all foreign suppliers. The level of due diligence depends of the supplier's and transactional risk profile. The due diligence process includes analysis of ownership, to include identification of foreign government/foreign government agency ownership interest, and all parties that are foreign government owned or controlled are subject to enhanced due diligence. The cornerstone of Raytheon’s due diligence process is to ensure that “red flags” are first identified through the diligence process, and then ensure these concerns are addressed — with the assistance of legal counsel as appropriate — in order to mitigate the potential corruption risks. The results of all due diligence reviews are documented and recorded in Raytheon’s 3D database, which provides companywide access to the results of all due diligence for review by all Raytheon employees.
Terms and conditions of international purchase orders require warranties of compliance with applicable anti-corruption laws and breach of these warranties are grounds for cancellation of the purchase order and other remedies. The terms and conditions also include anti-corruption warranties with respect to the supplier’s subcontractors. For more information, please refer to the International General Terms and Conditions of Purchase (TC-004) on the Suppliers section of this website.
RP-OGC-ETH-001: Code of Conduct and Ethics and Business Conduct Program
Raytheon is committed to the highest standards of ethical business conduct in its dealings with employees, customers, communities, suppliers, shareholders and others. Raytheon has issued a Code of Conduct (the “Code”) and established a ethics and business conduct program to assist Raytheon leaders, the Board of Directors, employees, suppliers, agents, consultants, representatives and others in recognizing, understanding and attending to the ethical dimensions of their jobs and in appropriately resolving business conduct issues. Raytheon’s ethics and business conduct program incorporates the compliance standards and principles set forth in the United States Sentencing Guidelines for Organizations, The Defense Industry Initiative on Business Ethics and Conduct, the IFBEC Global Principles of Business Ethics and the Federal Acquisition Regulations. Further, the Code articulates Raytheon’s strong “speak-up” culture and anti-retaliation ethos, outlines reporting avenues, and mandates that those found to have engaged in retaliation will be subject to discipline, up to and including, termination.
RP-OGC-ETH-004: Prevention of Retaliation
Raytheon’s anti-retaliation policy reinforces Raytheon’s longstanding commitment to prevent all forms of retaliation. Raytheon is committed to fostering a free and open atmosphere that encourages employees, business partners and others to make inquiries, express work-related concerns about ethics issues, and/or report violations or suspected violations of laws or regulations, Company policies and procedures, or Raytheon’s Code of Conduct. The policy is intended to encourage employees, business partners, and others to actively participate in any internal investigation without fear of retaliation. The Company also prohibits retaliation against an employee, business partner, or other person who expresses a concern or files a complaint with a regulatory or other governmental agency or court.
RP-FIN-TR-003: E-WIRE Treasury System Wire Transfer Requests – Including All U.S. Dollar Wires, Foreign Currency Wires & Foreign Currency Drafts
Raytheon’s Treasury Wire System Wire Transfer Requests – Including All U.S. Dollar Wires, Foreign Currency Wires & Foreign Currency Drafts policy establishes guidelines involving the electronic approval and payment of all U.S. dollar wires, foreign currency wires, and Foreign Currency Drafts / checks. The policy applies to all U.S. based organizations within Raytheon Company and foreign based Raytheon locations and sets forth authorizations, amounts/limits, separation of duties and approvals.
RP-FIN-TR-004: Bank Account Authorizations
Raytheon’s Bank Account Authorizations policy sets forth guidelines involving bank account authorizations including: opening new accounts; closing accounts; changing signatories to existing accounts; establishing signatory check signing limits; approving and implementing all banking services and related banking fees; and approving all contracts for banking services, in conjunction with Raytheon’s Legal department’s review. Corporate designated bank accounts are opened in order to facilitate the centralized management of the Company’s cash and investments, as needed. These include accounts for payroll, accounts payable, accounts receivable, escrow, and investments.
RP-OGC-ETH-002: Business-Related Gifts, Hospitality and Sponsorships
Business courtesies are occasionally appropriate in building and maintaining business relationships with government and commercial customers. However, when conducting company business Raytheon employees must avoid even the appearance of currying favor, or any other misconduct, that may have an adverse impact on the reputation of Raytheon. Raytheon’s Offering and Accepting Business Courtesies, Gifts and Other Gratuities policy sets forth the process employees must follow before offering, giving, or receiving a business courtesy, gift, or other gratuity. While the dollar limits and approval procedures are set forth in that policy all employees must ensure that any business courtesy: i) is modest and appropriate for the occasion; ii) is necessary for a bona fide business purpose; iii) is in compliance with all applicable laws, policies and regulations. Policy requirements and approval procedures differ depending upon the type of recipient and the nature and/or value of the gift or hospitality. It is never permissible to offer or extend a business courtesy that could be reasonably interpreted as an attempt to obtain or retain an improper business advantage or that could embarrass, or negatively reflect on, Raytheon’s reputation. Where approval of a gift or hospitality is required, such requests and determinations are recorded in an online Business Courtesy Approval Request tool.
RP-BD-004: International Industrial Cooperation (Offsets)
It is the company’s policy to satisfy all of its offset commitments in a manner which enhances the company’s international growth objectives while ensuring reputational and compliance risks are addressed. Raytheon’s International Industrial Cooperation (Offsets) policy sets forth the processes, responsibilities and procedures to satisfy international Offset requirements while complying with applicable laws and rules. Before entering into an offset arrangement, extensive party and transactional due diligence is conducted on all potential offset providers. Higher risk offsets are subject to enhanced due diligence. The cornerstone of Raytheon’s due diligence process is to ensure that “red flags” are first identified through the diligence process, and then ensure these concerns are addressed — with the assistance of legal counsel as appropriate — in order to mitigate the potential corruption risks. The results of all due diligence reviews are documented and recorded in Raytheon’s 3D database, which provides companywide access to the results of all due diligence for review by all Raytheon employees. All Offset Service Agreements and Appendices are approved by the Raytheon Washington Office, Office of General Counsel. Raytheon uses Offset Service Agreement and Appendix templates, which include required anti-corruption provisions. Further, the Global Partnering & Offsets functional organization in Corporate Business Development provides guidance and best practices on Offset issues, and coordinates Offset activities across the Company. Personnel within that function must complete the FCPA Aware anti-corruption training module.
RP-COMM-001: Corporate Contributions, and Matching Gifts Policy
Charitable contributions and gifts of property or services made by the company to non-profit organizations qualified under Section 501(c) of the Internal Revenue Code must be made in accordance with Raytheon policies, applicable legal and ethical standards. Raytheon’s Corporate Contributions, and Matching Gifts policy sets forth the management and approval of charitable contributions and gifts of property or services to non-profit organizations, including grants made at the request of members of the board of directors and corporate management leadership team. For additional details on corporate contributions, please refer to the Corporate Governance section of this website.
RP-BD-002: Domestic Political Contributions, and Activities
Raytheon Company participates in the political process to serve its best interests on behalf of its shareholders and employees. In all such activities, the Company complies with all relevant laws and regulations and adheres to the highest standards of ethical conduct. It is Raytheon policy that Company funds, assets, property, or other things of value will be contributed, loaned, or made available directly or indirectly (i.e., through the use of intermediaries, consultants, subsidiaries, affiliates, or otherwise) to any party, committee, or candidate in the United States only if such activities are permissible under relevant Federal, state and / or local laws and regulations. Where contributions from Company funds are permissible by law, the policy requires any such contribution to have the approval of Raytheon’s Political Expenditure Review Committee. For additional details on political contributions, please refer to the Corporate Governance section of this website.
RP-OGC-ETH-003: Conflict of Interest
It is Raytheon’s policy is to ensure a companywide, consistent approach with respect to the identification, disclosure, and resolution of conflicts of interest. Raytheon is committed to conducting its business with propriety, and our directors, employees, contractors, consultants and international business development partners must act fairly, impartially, and never place personal interests over their obligations to Raytheon. Directors, employees, consultants, contractors, and international business development partners engaged by the company are responsible for recognizing and avoiding activities, investments or relationships which involve or could result in a conflict of interest or the appearance of a conflict of interest. Potential and actual conflict of interest disclosure requirements are imposed to enable the company to independently evaluate and determine whether a conflict of Interest may be properly managed or may disqualify the individual from engaging in specific duties or responsibilities, and to ensure that company standards of ethical conduct are maintained by its directors, employees, contractors, consultants, and international business development partners. Raytheon’s Conflict of Interest policy applies to all Raytheon organizations, including all direct and indirect subsidiaries other than Forcepoint entities, and requires company directors, employees, contractors, consultants, and international business development partners to avoid conflicts of interest, or the appearance of such, between their obligations to the company and their personal affairs and to disclose certain matters identified in the policy should they arise. Raytheon’s Ethics and Business Conduct Office is responsible for reviewing potential conflict of interest submissions, devising mitigation strategies where appropriate, and maintaining such records in a centralized tool. Failure to comply with Raytheon’s Conflict of Interest policy may result in termination of employment or termination of a business relationship with Raytheon.
RP-OGC-GTC-001: Export / Import Controls Compliance
Raytheon is committed to long-term growth, including expansion of its international activities. In conducting such activities, Raytheon will comply with the export / import laws and regulations of the United States and each foreign country in which it conducts business or in which it is located. Raytheon’s Export / Import Controls Compliance Policy provides a framework for achieving effective compliance with the involved regulations and the Company’s growing global business model. All Raytheon employees are accountable for adherence to this policy.
RP-FIN-CAO-024: Internal Control Over Financial Reporting
Raytheon’s Internal Control Over Financial Reporting policy defines the Company’s system of internal control over financial reporting, which is comprised of process and procedures that enable Company management to discharge its stewardship responsibility to stakeholders and helps ensure compliance with the requirements of applicable laws and regulations, including the Sarbanes-Oxley Act of 2002 and Securities and Exchange Commission (SEC) reporting requirements. The Company maintains a system of internal control over financial reporting to provide reasonable assurance regarding the accuracy and reliability of the Company's financial statements and underlying accounting records, as well as to provide for the proper safeguarding of the Company's assets. Our system of internal control is directed at providing reasonable assurance that all Company transactions are fully and accurately reflected in the books and records of the Company; payments from Company funds or other assets are not approved or made with the intention or understanding that any part of such payment will be used for any purpose other than that described by the documents supporting the payment; and procedures and limitations established by management regarding custody of and access to the Company’s assets, including the execution of transactions affecting such assets, are strictly followed. The Company conducts ongoing monitoring of the system of internal control over financial reporting to ensure controls have been appropriately designed, and that they continue to operate effectively.
RP-OGC-011: Federal Lobbying Activities - Unallowability, Reporting, and Disclosure
This policy, which applies to all Raytheon entities and their employees, consultants, and sale representatives, is designed to ensure compliance by Raytheon Company with all laws and ethics regulations applicable to the company’s federal lobbying activities and to ensure complete and accurate reporting of such activities under the Federal Lobbying Disclosure Act (LDA) of 1995, as amended by the Honest Leadership and Open Government Act of 2007. Raytheon’s Federal Lobbying Activities – Unallowability, Reporting and Disclosure policy provides guidance to ensure timely and accurate record-keeping, reporting, and certifications concerning the company's lobbying activities and the giving of gifts and payment of travel expenses of Members of the House or the Senate, all as required by the LDA. For additional details, including lobbying expenditures, please refer to the Corporate Governance section of this website.
RP-FIN-CFO-002: Corporate Card Program
Raytheon’s Corporate Card Policy establishes the requirement for use of the Company’s Corporate Card as the method of payment for all business travel and appropriate miscellaneous expenses (where the card is accepted). Raytheon’s Corporate Card Program provides training, approval processes, reporting, and controls to monitor compliance with Raytheon policies and procedures. The program holds the employee and the approving supervisor accountable for non-compliance with Raytheon policies, Federal Acquisition Regulations, and relevant law. Raytheon’s Corporate Card Program Policy sets forth the limits, examples of authorized and unauthorized uses, and documentation and approval requirements. It also defines the monitoring responsibilities of management to take an active role in monitoring the card activity of their direct reports.
RP-FIN-CFO-004: Corporate Card Use for Goods, Materials and Services Procurement
The Company’s Corporate Card Use for Goods, Materials and Services Procurement Policy establishes the use of the Company’s Corporate Card in specific circumstances to complement other procurement systems by allowing authorized employees to use the corporate card as the method of payment for approved goods, materials, and services. The policy sets forth the limits, examples of authorized and unauthorized uses, and documentation and approval requirements.
RP-FIN-CAO-050: General Ledger Requirements
Raytheon’s General Ledger Requirements policy sets forth the requirement to create and maintain books, records and accounts that are in reasonable detail to accurately and fairly reflect the transactions and dispositions of the assets of the Company. It also sets forth specific requirements for preparers to document each Manual Journal Entry accurately, transparently, and in detail sufficient to reflect the nature and substance of the transaction. Raytheon strictly prohibits entries in the books, records, or accounts of the Company that are false, misleading, incomplete, inaccurate, or artificial. Additionally, the preparation of fictitious invoices, over-invoices, or other misleading documentation is strictly prohibited, The Company’s books, records, accounts, and financial statements are maintained in reasonable detail, appropriately reflect the Company’s transactions, and conform both to applicable legal requirements and to the Company’s system of internal controls.
RP-CON-016: Due Diligence for International Third Parties and Transactions
Raytheon’s Due Diligence for International Third Parties and Transactions policy sets forth the disciplined risk-based due diligence that must be performed for all international parties including: customers, suppliers, JV partners, offset service providers, and other third parties; as well as for international transactions. This policy also provides guidance on doing business with countries under US or other applicable sanctions or restrictions (including requiring senior management review) and incorporates enhanced internal controls to ensure compliance with anti-corruption laws. The cornerstone of Raytheon’s due diligence process is to ensure that “red flags” are first identified through the diligence process, and then ensure these concerns are addressed — with the assistance of legal counsel as appropriate — in order to mitigate the potential corruption risks. The results of all due diligence reviews are documented and recorded in Raytheon’s Due Diligence Database, which provides companywide access to the results of all due diligence for review by all Raytheon employees. Further, the due diligence process on international parties, including offset providers is refreshed frequently as change orders and modifications arise, but in any event, no less than once every two years.
RP-OGC-024: Authorization, Processing, and Monitoring of International Business Development Partner Agreements
This policy, which applies to all Raytheon organizations, wholly-owned subsidiaries and landed companies, and any other entity where Raytheon has a controlling ownership interest, other than Forcepoint entities, outlines Raytheon's process for engaging and monitoring international business development partners (IBDPs) including representatives, consultants and business advisors. (Note that offset providers are covered in RP-CON-016 above). All international business development partner engagements and renewal activities undergo enhanced due diligence conducted by ACIA. The process includes a requirement to document the business need for a third party and dynamic screening during the life-cycle of an IBDP agreement. ACIA’s due diligence includes an in person interview, Restricted Party and Politically Exposed Person screenings, financial records review, key person analysis, review of company background reports from commercial sources, and expanded due diligence for high-risk engagements. Raytheon will not engage an IBDP where Raytheon does not have sufficient information to determine whether there is a foreign government ownership interest. This review and approval process is rooted in the Foreign Corrupt Practices Act and similar anti-corruption laws and aided by the Raytheon Due Diligence Guidebook, the Raytheon Due Diligence Database, the TI Corruption Perceptions Index, Restricted Party Screening, a robust approval matrix, and standardized agreements with anti-corruption terms and auditing rights and contractual rights to enforce our anti-corruption standards. All new IBDPs are approved by the Business Unit Office of General Counsel, ACIA, Raytheon Washington Office General Counsel, Raytheon International, and the Senior Vice-President of Business Development. Further, the due diligence process is refreshed frequently as change orders and modifications arise, but in any event, no less than once every two years. The policy requires that compensation for any IBDP is reasonable, economically justified, commensurate with the services rendered, and in compliance with anti-corruption laws. Raytheon monitors IBDP activities on a periodic basis to ensure compliance with Raytheon requirements and anti-corruption laws and regulations.