Business Conduct Compliance Training
Business conduct compliance training educates employees in every country where Lockheed Martin operates about the standards of conduct that apply to their jobs and the potential consequences of violations. Annually, we conduct a mandatory training review with our Subject Matter Experts (SMEs) who assist us with the review of the content, target audiences, and repeat intervals of our Business Conduct Compliance Training.? Results of the annual review are presented to the Risk and Compliance Committee and any significant modifications requested require the committee’s approval.? Employees are also sent a survey after course completions to help measure the overall effectiveness of our business conduct compliance training. In addition, Lockheed Martin regularly identifies the need for and develops focused supplementary training for groups of employees facing increased risk based on geographical location, and Ethics and Compliance training is required and provided on an annual basis to international consultants.? Business conduct compliance training is required in areas that present substantial risk to the Corporation, including the below courses:
Antitrust Compliance?addresses compliance with antitrust laws, including the Sherman Act, which forbids anticompetitive practices such as price fixing, bid-rigging, and market allocation, and the Clayton Act, which prohibits exclusive dealing arrangements and tying arrangements. This course is required to be taken every two years by the CEO/President and Executive Vice Presidents or Company Vice Presidents/General Managers and their direct reports; all senior level employees in LM Government Affairs, Business Development, Contracts, Procurement, Global Supply Chain and Legal; all employees in Ethics and Business Conduct.
Combating Trafficking in Persons?defines human trafficking, helps the audience recognize populations vulnerable to human trafficking, reviews the indicators of human trafficking and encourages taking appropriate action if human trafficking violations or indicators are encountered. This course is required to be taken every four years by all employees.
Contact with Government Employees?increases awareness of policies, procedures, and laws governing the hiring of, or acquisition of the services of, current or former government employees. This course is required to be taken every two years by all employees in leadership positions; all employees in LM Government Affairs, LM International, Talent Acquisition and Ethics and Business Conduct.
Drug-Free Workplace?emphasizes the importance of maintaining a drug-free workplace, describes the company’s policy and what constitutes drug or alcohol abuse in the workplace, and teaches employees how to identify and resolve drug-related work issues. This course is required to be taken every three years by all employees.
Equal Employment Opportunity/Affirmative Action?teaches leaders how to recognize and address situations that could lead to violations of Affirmative Action (AA) or Equal Employment Opportunity (EEO) policies and laws. The course emphasizes leaders’ responsibility for cultivating an inclusive work environment. This course is required to be taken every two years by all leaders/managers and team lead designated employees as well as all employees in Ethics and Business Conduct. Employees outside of the US are excluded.
Gifts and Business Courtesies?covers the giving and receiving of gifts and business courtesies and explains how to comply with anti-kickback and anti-corruption policies, laws and regulations (see also International Business Practices). This course is required to be taken annually by the CEO/President and Executive Vice Presidents or Company Vice Presidents/General Managers and their direct reports; all leader coded employees; all Control Account Managers; all employees in LM Government Affairs, LM International, Global Supply Chain, Legal, Contracts, Procurement and Ethics and Business Conduct.
Harassment in the Workplace?explains how to recognize, prevent, and address harassment in the workplace. This course is required to be taken annually by all employees.
Insider Trading?provides an overview of company policy and U.S. Securities laws as they pertain to the disclosure of confidential information and to trading in securities while in possession of material, non-public information. This course is required to be taken every four years by all employees. Senior level employees are required to take this course annually. Employees in leader coded positions, Corporate Strategy & Business Development, Global Supply Chain, Finance, Fiscal, Legal, Contracts and Procurement are required to take this course every two years.
International Business Practices?teaches employees how to recognize and address situations that could lead to violations of the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and other applicable bribery, anti-boycott, or anti-corruption laws in the U.S. and other countries in which we do business (see also?Gifts and Business Courtesies). This course is required to be taken annually by the CEO/President, Executive Vice Presidents or Company Vice Presidents/General Managers and their direct reports; all employees in Communications, Legal, Business Development, International Human Resources, Finance, Audit, Contracts, Procurement, Global Supply Chain Operations and International tax; employees in Project Management, Shipping and Traffic and Security positions; all employees in Ethics and Business Conduct, LM International and LM Government Affairs; employees whose work location is in a country that scores a 50 or below in the TI Corruption Perceptions Index; and employees who schedule international travel in the company travel system.
Labor Charging?teaches employees the importance of and their responsibility for accurate labor charging, how to charge their time, who to ask when unsure of proper labor charging actions, and how labor charges are audited and addressed. All employees are required to take this course annually.
Security Refresher Training?is an annual requirement for employees who maintain a?United States Government Security Clearance and/or a Sensitive Compartmented Information (SCI) access. The course reviews the proper safeguarding of classified and other sensitive information. Employees who maintain a security clearance and/or SCI access are required to take this course annually.
Sensitive Information and International Trade Compliance?discusses the proper handling and storage of export controlled, proprietary, third party proprietary and personal information, as well as the principles of international trade compliance and risks of cyber-attacks or other intelligence threats. All employees are required to take this course annually.
Truth in Negotiations Act?reviews the provisions of the Truth in Negotiations Act (TINA), which governs the conduct of people involved in the development or negotiation of contract proposals for the government or with a prime contractor. At the Corporate level, this course is required to be taken every two years by the CEO/President, Executive Vice Presidents or Company Vice President/General Manager and their direct reports; senior level employees in Business Development, Legal, Contracts, Procurement, Global Supply Chain Operations and Ethics and Business Conduct; and employees who provide cost estimating input to a proposal. Employees outside of the US are excluded.