Regulatory and Legal Compliance Key Elements

Management Commitment: The unwavering commitment of our management to a strong culture of integrity lies at the foundation of our ethics and compliance program. Our leadership demonstrates its commitment regularly through communications and actions.

Standards And Policies: Beyond our Standards of Business Conduct, we have a comprehensive set of policies and procedures that clearly establishes and communicates standards to which we hold employees accountable, and establishes roles and responsibilities for strong internal controls.

Oversight And Resources: We use internal teams that work together to provide the needed oversight and resources to drive our compliance program including our Office of the Chief Compliance Officer; Corporate Compliance Council; Law Department; Global Corporate Responsibility; Ethics; and Internal Audit.

Risk Assessment: Our Enterprise Risk Management Council evaluates the significant risks facing our company and the strategies to mitigate and address those risks.

Incentives And Discipline: We publicly recognize employees who do the right thing. We also have effective processes for addressing allegations and disciplining employees who engage in misconduct.

Due Diligence: We devote significant resources to evaluating and carefully selecting third parties, including sales representatives, partners, consultants, suppliers and teammates. We clearly communicate our expectations that these third parties must share our commitment to doing business with the highest levels of ethics and integrity, and in compliance with all applicable laws and regulations.

Review And Audits: Through employee surveys and our well-established corporate audit program, the Corporate Compliance Council, and other feedback channels, we continuously review and identify areas for potential enhancement of our compliance program.

ANTI-CORRUPTION COMPLIANCE

We do not tolerate bribery or corrupt business practices. We conduct our business consistent with high ethical standards and in full compliance with all applicable anti-corruption laws.

We compete in the global marketplace based on the quality of our products and services and the value we create for our customers by offering those products and services at a competitive price. We have zero tolerance for bribes, kickbacks or any other illegal business practices.

We are always mindful that our culture for ethical behavior and reputation is among our most important assets. We maintain vigilance and care for both, avoiding transactions and relationships that could violate the law or otherwise compromise our ethics and integrity. Our ethical culture and reputation are foundational elements of being a trusted supplier for our customers, a reliable performer for our shareholders, and an employer of choice for our talented workforce.

  • Prohibition on Bribery: Our policies prohibit offering or paying a bribe, directly or indirectly, in connection with any business (commercial or government). We also prohibit the acceptance or promise of anything of value from any person or entity as an inducement or reward improperly to perform or fail to perform a function or activity.
  • Management Commitment: Throughout our business and management ranks, our leadership demonstrates a proactive, visible and steadfast commitment to anti-corruption compliance.
  • Risk Assessment: We conduct internal risk assessments and evaluate the strength of our anti-corruption compliance program against standards provided by government authorities and industry best practices.
  • Risk Based Third Party Diligence: We have a dedicated and centralized due diligence collection and analysis organization to conduct risk based vetting of third parties with whom we work.
  • Automation: We use an automated diligence management system to facilitate our third-party diligence processes.
  • INDEPENDENT REVIEW BOARDS: We utilize cross-functional teams for the review and approval of third-party relationships.
  • Employee Engagement: Anti-corruption compliance is the responsibility of all Northrop Grumman personnel, and in meeting this responsibility, our employees are expected to:
    • Complete required anti-corruption training.
    • Be aware of the potential for corruption risk factors in the transactions and business relationships they are involved in on Northrop Grumman’s behalf, such as the perception of corruption in a particular country or organization, adverse information concerning the ethical reputation of our trading partners and other red flags that might arise.
    • Take measures to ensure that all contracts and business records accurately reflect the nature of each transaction and the relationship of the parties involved.
    • Complete an annual conflict of interest disclosure form to ensure job performance is not improperly influenced by outside interests.
    • Promptly report any potential or suspected violations, unethical, or illegal activity in accordance with company policies.
  • Business Courtesies and Charitable Giving: We maintain procedures for employees to follow in order to provide or accept business courtesies to or from non-employee business associates. We also maintain procedures that govern participation in charitable giving to ensure honesty and fair dealing and minimize the risk that a donation will create a conflict of interest with regard to current or potential business.
  • Employment Conflicts: We maintain procedures regarding conflicts of interest that might arise when hiring employees. Decisions regarding hiring an employment candidate may not be used to induce a party to provide any improper business advantage to the company.
  • INTERNAL REPORTING: We expect our leadership to exhibit ethical behavior and to anticipate and respond appropriately to employees seeking to report misconduct. To encourage employees to report potential misconduct, we use management training and “train-the-trainer” modules. This preparation fosters a climate of trust where our employees are more likely to report potential misconduct.
  • Industry Engagement: Northrop Grumman is a long-standing and active member of the Defense Industry Initiative (DII) on Business Ethics and Conduct and the International Forum on Business Ethical Conduct (IFBEC), among other organizations that promote and benchmark best practices.