Anti-Bribery and Corruption SUSTAINABILITY MANAGEMENT PLAN GOAL Achieve 100% completion of required employee training on gifts and business courtesies and international business practices annually through 2025. 2021 PROGRESS We achieved 100% completion of these two trainings for required employees. At Lockheed Martin, we have zero-tolerance for bribery and corruption. We will walk away from business engagements associated with improper conduct and that would violate U.S. and other applicable anti-corruption laws. Included in our comprehensive approach to anti-corruption compliance are our Gifts and Business Courtesies and International Business Practices business conduct compliance training modules. These courses, required annually for employees with applicable roles and responsibilities, inform and deliver resources to employees about our expectations for ethical business practices, and support employee awareness of, and compliance with, applicable laws. Additional employee engagements about the importance of anti-corruption compliance are provided through a variety of topical spot briefings within functional teams. For example our legal team engages employees several times a year on the history, importance and risks related to corruption during our Doing Business Overseas course. In 2021, we created two high-impact, supplemental modules with specific situational scenarios illustrating corruption risks and behaviors for employee awareness. These included: • Country-specific training: We created country-specific training for certain employee populations and locations, such as Saudi Arabia. We plan to create similar content for additional countries in the future. • “What do you do?” scenario training: This scenario training reflects real-world situations employees may encounter during international field deployments or travel, which may implicate bribe requests, including where personal safety may be at risk. We plan to release these trainings in 2022 through a variety of internal media resources. Our corporate policies Gifts, Hospitality, Other Business Courtesies and Sponsorships and Compliance with Anti- Corruption Laws provide specific guidance and procedures for the company. For example, the first policy outlines thresholds of permissibility, exception request processes and approval responsibilities associated with offering of certain business courtesies. We use an analytics tool to scan company data and flag questionable transactions for review and any policy violations that may occur are reported to business area legal teams for remedial actions, as well as to the Senior Vice President, General Counsel and Corporate Secretary on a quarterly basis. Please refer to the Lockheed Martin Code of Ethics and Business Conduct for more information on our anti-corruption policies. About this Report Our Company Our Sustainability Approach Our Sustainability Priorities Beyond the SMP ESG Performance Index www.lockheedmartin.com 2021 Sustainability Report 42
Lockheed Martin Sustainability Report Page 41 Page 43