Risk Assessment & Sustainment Process
Raytheon’s risk assessment and sustainment process is designed to ensure that Raytheon and each individual Raytheon business: (i) has an unwavering commitment to the highest standards of ethical business conduct, (ii) demonstrates that commitment through a resolute tone at the top, and (iii) maintains effective internal controls, education, policies and procedures that appropriately deter and detect violations of the Foreign Corrupt Practices Act (FCPA) and other applicable anti-corruption laws.
The Anti-Corruption & International Agreements (ACIA) group reports to the Chief Ethics and Compliance Officer (CECO) within the Office of the General Counsel. ACIA maintains/encourages anti-corruption compliance through written communication (emails, blogs, Codebreakers/Codechampions, etc. ), video-based training (FCPAware, EthicSpace, and EthicSketch), and annual live training (ACT With Integrity) required of all employees, and targeted online and F2F training for high risk personnel, with messages encouraging employees to identify issues, ask questions and raise concerns without the fear of retaliation, emphasizing the importance of training, and providing guidance on areas of particular concern to help all employees understand key anti-corruption responsibilities and their personal role in guaranteeing compliance with anti-corruption laws.
ACIA also ensures that Raytheon’s international business development partners receive regular anti-corruption training and that all third-parties agree to abide by all applicable anti-corruption laws, rules, and regulations and uphold Raytheon’s Values.
ACIA also participates in a biweekly meeting of the Compliance Sustainment Team (CST), which is led by the CECO. The CST is a cross‐functional (representatives from Legal, Ethics, Finance, HR, Supply Chain, Business Development, and Global Trade) and cross‐Business Unit team, that is charged with generating and implementing improvements to Raytheon’s anti-corruption policies, training, controls, monitoring, self‐assessments, progress against goals, and lessons learned. The CST reports to the Public Policy & Corporate Responsibility Committee (comprised of members from the Board of Directors) on a quarterly basis. The Public Policy & Corporate Responsibility Committee oversees and guides the overall direction of the company’s anti-corruption program and reports to the Board of Directors on an annual basis.
The CST utilizes a remediation log to track progress of issues through closure. Significant issues are factored into the annual risk assessment process.
On a continuous basis, Internal Audit prepares and updates a risk-based audit plan which takes into account specific risks and opportunities within the Company, including risks for corruption. The Audit Plan includes as appropriate risk based audits of anti-corruption related processes, controls, sites, and transactions. The anti-corruption related portion of the Audit Plan is reviewed with the CECO and approved by the Audit Committee (comprised of members from the Board of Directors) on an annual basis.
Anti-corruption related Internal Audit reports are distributed to the CECO and the ACIA group as appropriate following the conclusion of the audit to ensure that audit results and recommendations are documented and shared. The reports include findings, recommendations for resolution, and an overall opinion. Internal Audit follows up with responsible personnel on any identified findings to ensure completion of remediation.