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.
Summaries of these policies, which typically discuss a wider range of processes in addition anti-corruption measures, are also provided below.
3-RP: Business Travel, Meeting, Entertainment, and Miscellaneous Expenses
The travel policy is designed to strike a balance between protecting the interests of our employees and shareholders by ensuring the safety and well being of traveling employees while being fiscally responsible. Raytheon’s Business Travel, Meeting, Entertainment, and Miscellaneous Expenses Policy strives 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. It applies to all organizations and subsidiaries within Raytheon and outlines employee responsibilities and limitations when planning, expensing, and reporting all business costs.
17-RP: Cost Recording Integrity Standards
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 purpose of Raytheon’s Cost Recording Integrity Standards Policy is to define the Company’s integrity standards regarding cost recording to contracts; to independent research, independent development, and bid proposal projects; and to indirect cost objectives. The policy identifies the importance of accurate, complete and timely recording of authorized cost transactions.
21-RP: International Sales Representative and Consultant 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.
24-RP: 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.
32-RP: 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.
56-RP: 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. 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.
58-RP: 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. 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. pursuant to our 261-RP policy, which is also summarized in this listing.
63-RP: Reporting Political Contribution, Fees, and Commissions Involving Foreign Sales of Defense
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.
part 130.6 Political contribution - definition
Political contribution means any loan, gift, donation or other payment of $1,000 or more made, or offered or agreed to be made, directly or indirectly, whether in cash or in kind, which is:
To or for the benefit of, or at the direction of, any foreign candidate, committee, political party, political faction, or government or governmental subdivision, or any individual elected, appointed or otherwise designated as an employee or officer thereof; and
For the solicitation or promotion or otherwise to secure the conclusion of a sale of defense articles or defense services to or for the use of the armed forces of a foreign country or international organization. Taxes, customs duties, license fees, and other charges required to be paid by applicable law or regulation are not regarded as political contributions.
part 130.5 Fee or commission - definition
Fee or commission means any loan, gift, donation or other payment of $1,000 or more made, or offered or agreed to be made directly or indirectly, whether in cash or in kind, and whether or not pursuant to a written contract, which is:
(1) To or at the direction of any person, irrespective of nationality, whether or not employed by or affiliated with an applicant, a supplier or a vendor; and
(2) For the solicitation or promotion or otherwise to secure the conclusion of a sale of defense articles or defense services to or for the use of the armed forces of a foreign country or international organization.
The term fee or commission does not include:
(1) A political contribution or a payment excluded by part 130.6 from the definition of political contribution;
(2) A normal salary (excluding contingent compensation) established at an annual rate and paid to a regular employee of an applicant, supplier or vendor;
(3) General advertising or promotional expenses not directed to any particular sale or purchaser; or
(4) Payments made, or offered or agreed to be made, solely for the purchase by an applicant, supplier or vendor of specific goods or technical, operational or advisory services, which payments are not disproportionate in amount with the value of the specific goods or services actually furnished.
67-RP: International Procurement
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 Procurement policy mandates thorough due diligence of all significant foreign suppliers. The level of due diligence depends of the supplier's and transactional risk profile. 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.
74-RP: 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 and mandates that those found to have engaged in retaliation will be subject to discipline, up to and including, termination.
93-RP: Wire Transfer Requests – Including All U.S. Dollar Wires, Foreign Currency Wires & Foreign Currency
Raytheon’s Wire Transfer Requests – Including All U.S. Dollar Wires, Foreign Currency Wires & Foreign Currency Drafts Policy establishes guidelines involving the electronic payment of all U.S. wires, foreign currency wires and foreign currency. The policy applies to all U.S. based organizations within Raytheon Company and certain foreign based Raytheon locations.
94-RP: Bank Account Authorizations Policy
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, investments as well as zero-balance accounts for controlling business cash flows, etc. 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 the Legal department’s review.
96-RP: Handling of Checks, Hard-Currency and Coins by Raytheon Office Locations
The purpose of Raytheon’s Handling of Checks, Hard-Currency and Coins by Raytheon Office Locations policy is to establish guidelines for the handling of hard-currency and coins at petty cash office locations, as well as the mailing of any checks between Company locations and banks. The policy applies to all organizations within Raytheon Company.
97-RP: Offering and Accepting Business Courtesies, Gifts and Other Gratuities
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. 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.
109-RP: 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. 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.
117-RP: 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.
124-RP: 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, consultants and representatives must act fairly, impartially, and never place personal interests over their obligations to Raytheon. Directors, employees, consultants and representatives 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, consultants, and representatives. Raytheon’s Conflict of Interest policy requires company directors, employees, consultants, and representatives 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.
128-RP: Export, Reexport and Import Control
Raytheon is committed to long-term growth, including expansion of its international activities. In conducting such activities, Raytheon will comply with the export, reexport and 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, Reexport and Import Control 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.
138-RP: Internal Control Over Financial Reporting Policy
The purpose of maintaining a system of internal control over financial reporting is to foster the preparation of reliable financial statements. Reliable financial statements must be materially accurate. 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 SEC reporting requirements.
156-RP: Purchasing Card Program Policy
The company’s Purchasing Card program is designed to complement other procurement systems, and provides authorized employees a method for purchase and payment of direct and indirect items subject to Business limitations and other certain limitations within the policy. Raytheon’s Purchasing Card Program policy sets forth the limits, examples of authorized uses and unauthorized uses as well as documentation and approval requirements.
197-RP: Federal Lobbying Activities – Reporting and Disclosure
This policy 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 – 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.
215-RP: Corporate Card Program Policy
The Company’s Corporate Card program is designated as the method of payment for all business travel and appropriate miscellaneous expenses (where the card is accepted). Raytheon’s Corporate Card Program provides management reports to monitor controls and program effectiveness; it also 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 uses and unauthorized uses as well as documentation and approval requirements. It also forth monitoring requirements which direct that management takes an active role in monitoring the card activity of their direct reports.
247-RP: General Ledger Requirements
The company’s books, records, accounts, and financial statements must be maintained in reasonable detail, must appropriately reflect the company’s transactions and must conform both to applicable legal requirements and to the Company’s system of internal controls. 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.
251-RP: Due Diligence for International Parties and Transactions
Raytheon’s Due Diligence for International Parties and Transactions policy sets forth the disciplined due diligence that must be performed for all international parties including: customers, suppliers, JV partners and offset service providers; 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.
261-RP: Hiring Process for Non – U.S. Citizens, Local National and Third Country National Employees
It is Raytheon policy to have a consistent talent acquisition process for all hires when filling available openings. Key steps in the hiring of Local National and Third Country National citizens are to include appropriate background screening and International Conflict of Interest (ICOI) reviews. These steps apply to all final candidates, subject to applicable local labor and privacy laws.
293-RP: Authorization, Processing, and Monitoring of International Business Development Partner Agreements
This policy outlines Raytheon's process for engaging and monitoring international business development partners including representatives, consultants and business advisors. (Note that offset providers are covered in 251-RP above). Raytheon has a centralized and rigorous due diligence process for international business development partners. 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 auditing rights and contractual rights to enforce our anti-corruption standards. 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.