You must be fair and impartial in all business dealings.
Our policies prohibit both an actual conflict of interest and activities that create the appearance of a conflict of interest. Avoid situations in which your personal interests might conflict, or appear to conflict, with Lockheed Martin interests.
Never use your contacts or position in the Corporation to advance outside or personal interests.
Do not use our Corporation’s property, information or opportunities for personal gain.
You must provide
of actual or potential conflicts of interest.
Why We Do It
We are committed to the highest standards of ethical business conduct. We expect this of our employees,
agents and Board of Directors.
We have a responsibility to our shareholders to act in the best interests of the Corporation.
The internal disclosure process reinforces our intention to conduct business with integrity.
What is a Personal Conflict of Interest?
A personal conflict of interest exists when you have divided loyalties — when you have a direct or indirect personal interest in a transaction or matter such that it might reasonably appear to affect the judgment you exercise on behalf of Lockheed Martin, influence your actions or lead you to neglect Lockheed Martin business interests.
Our Conflict of Interest policy covers many situations, including these examples:
Personal interest in our Corporation’s transactions —
Having a personal interest or potential for gain in any of our Corporation’s transactions.
Owning a, or having a substantial interest in, a company that is a customer, competitor or a supplier.
Family members —
Doing business with a firm owned or controlled by a Lockheed Martin employee or their family.
Family relationships with persons employed by a supplier or competitor.
Our Conflict of Interest policy covers many situations, including these examples.
Gifts — Acceptance of gifts, payments or services from those seeking to do business with Lockheed Martin. Consult CPS-008 for further guidance about acceptance of gifts.
Outside business interests — Owning your own business or working for another business while employed by Lockheed Martin, using the same or similar professional skills or training used in the course of your employment.
Multiple roles — Acting as an independent consultant to a Lockheed Martin customer or supplier, while employed by Lockheed Martin.
Using assets for personal gain — Using our assets, intellectual property or proprietary information for personal gain.
Subordinate employees — Having a close, personal relationship with a subordinate employee.
Charitable endeavors — Using work time selling products to benefit charitable organizations or soliciting donations for such organizations.
Government employees — Discussing employment with government employees, giving them gifts in violation of applicable laws or regulations or assigning off-limits roles to Lockheed Martin employees who are former government employees.
We comply with all laws and regulations covering employing or acquiring the services of government employees.
We avoid conflicts of interest in connection with employing or acquiring the services of current or former government employees. This includes current or former military personnel and other government employees.
Why We Do It
Our continued success and ability to compete in the marketplace depend on ensuring that we do not hire or work with current or former government employees in a manner that creates a real or perceived conflict of interest.
Apply to contact or negotiations with current government employees to discuss their potential employment by the Corporation or their use as consultants or subcontractors
May restrict the roles and responsibilities that former government employees may perform on our behalf after joining the Corporation
Can be complex. Always consult Lockheed Martin policy and seek the advice of Human Resources or the Legal Department
We identify and avoid or mitigate organizational conflicts of interest (OCI) within Lockheed Martin.
We abide by OCI restrictions.
Why We Do It
Early identification and timely communication of potential conflicts of this nature:
Allows Lockheed Martin to continue to participate in new business opportunities
Prevents disqualification and loss of business
Builds customer trust
What is an OCI?
An OCI could occur if Lockheed Martin is unable or potentially unable to render impartial assistance, service or advice to a customer. The rules are intended to prevent both unfair competitive advantage and conflicting roles that might bias a company’s judgment.
When do you have to disclose an OCI?
Situations requiring disclosure are outlined in