Anti-Corruption Compliance

Northrop Grumman Corporation 

Achieving global security requires high performance, cutting edge solutions, transparency and strong business ethics. At Northrop Grumman, we commit to living our values, acting with integrity in all that we do and expecting the same commitment from the partners we do business with across the world.

Wes Bush

Wes Bush
Chairman and Chief Executive Officer
Northrop Grumman Corporation


Northrop Grumman conducts its business consistent with high ethical standards and in full compliance with applicable anti-corruption laws. We believe that a strong stance against bribery and corruption supports the values and culture of our Company and is a critical enabler for us to achieve our business objectives.

Northrop Grumman does not tolerate and explicitly prohibits offering bribes, paying bribes or providing other improper things of value, directly or indirectly, in connection with our government or commercial business. Northrop Grumman prohibits our employees from accepting bribes or other improper things of value from any person or entity to, for example, induce or reward them for performing or failing to perform a function or activity.

Our Anti-Corruption Compliance Program is comprised of the following principal elements:

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

Risk Assessment: We conduct internal risk assessments and evaluate the strength of our Anti-Corruption Compliance Program against standards informed by government authorities and industry best practices.

Employee Engagement: We believe that anti-corruption compliance is the responsibility of all Northrop Grumman employees, and in meeting this obligation each employee is expected to:

  • Complete required anti-corruption training
  • Be aware of and alert to the potential for corruption risk factors in the transactions and business relationships they handle for the Company
  • Take appropriate measures to ensure that all contracts and business records that they are involved in accurately reflect the true nature of each transaction and the relationship of the parties involved, and
  • Promptly report any potential or suspected violations, unethical, or illegal activity in accordance with Company policies and applicable law

Due Diligence: We evaluate and carefully select third parties with whom we do business, and clearly communicate our expectations that these third parties share our commitment to the highest level of ethics, integrity, and compliance with applicable laws, rules and regulations, including those related to anti-corruption.

Policies & Procedures: In addition to our Northrop Grumman Standards of Business Conduct and Supplier Standards of Business Conduct, we maintain a comprehensive set of policies and procedures which support our commitment to anti-corruption compliance. Recognizing that the risk of corruption can arise in connection with many different business activities, the Company’s Anti-Corruption Compliance Program includes both broad-based components and more targeted policies and procedures aimed at particular areas of risk.

Business Courtesies
Northrop Grumman has procedures for employees to follow with guidelines for whether and how one can provide or accept business courtesies to or from customers, agents, consultants, suppliers and other non-employee business associates.
Third Parties
Northrop Grumman maintains a robust procedure to ensure that appropriate risk-based due diligence is conducted, and periodically refreshed, on third parties providing goods or performing services on behalf of the company.
Offsets
Northrop Grumman requires a risk based due diligence review of proposed offset (industrial participation) agreements and transactions prior to making any binding commitments.
Prohibition of Facilitating Payments
Northrop Grumman prohibits facilitating payments. Only in the event of a threat to an individual’s life, health or safety may a personal safety payment be made and in that case the facts and circumstances of the payment must be reported.
Employment Conflicts
Northrop Grumman has 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 an improper business advantage to the Company.
Charitable Donations
Companies often participate in charitable giving programs, especially to give back to the communities in which they operate. However, due care must be taken to ensure that program is a bona fide giving program, and, accordingly, Northrop Grumman seeks to ensure that the organization has a reputation for honesty and fair dealing and that the donation will not create a conflict of interest with regard to business that the Company is seeking or currently engaging in.
Political Donations
Northrop Grumman seeks to ensure that any political activity in which we engage is consistent with our high ethical standards and in full compliance with applicable law.

Training: Northrop Grumman's anti-corruption training program includes an array of training resources, both online and in-person. Northrop Grumman personnel are required to complete training requirements relative to their job function and level of involvement with international business. Anti-corruption training is provided for newly hired employees, employees transferred or promoted into a new job function, to employees traveling overseas on business, and periodically as a refresher.

Reporting Obligations: In accordance with Company policies and applicable law, it is the responsibility of all Northrop Grumman personnel immediately to report concerns regarding corruption or the Company's compliance program to the Law Department, the cognizant Business Conduct Officer, their management, HR or via the Company’s OpenLine at http://www.northropgrumman.com/CorporateResponsibility/Ethics/Pages/default.aspx.

We Don’t Retaliate: Northrop Grumman encourages employees to ask questions or raise concerns on ethics and compliance issues that could negatively impact our business. Our policy regarding retaliation is very clear: Northrop Grumman will not tolerate retaliation against an individual who seeks to observe our Standards of Business Conduct by sharing or reporting genuine concerns and issues. Anyone found to have taken part in retaliatory acts against someone who has reported genuine concerns in good faith faces serious disciplinary consequences, up to and including termination.

Industry Engagement: Northrop Grumman is a signatory to the Defense Industry Initiative on Business Ethics and Conduct (DII) and a member of the International Forum on Business Ethical Conduct (IFBEC).

For questions concerning Northrop Grumman's Anti-Corruption Compliance Program, please contact us at: NGIL@ngc.com

OpenLine

Northrop Grumman OpenLine

(800) 247-4952
Toll-free, anonymous
Available 24 hours a day, 7 days a week

Link: Web Reporting

International Open Lines

Australia:​ 1-800-07-9315
Belgium:​ 800-100-10 ID (844) 286-0069
Denmark:​ ​800-100-10 ID (844) 286-0069
France: ​0041 43 300 6805
Germany: ​0041 43 300 6805
Italy: ​0041 43 300 6805
Netherlands: ​0041 43 300 6805
Norway: ​800-12049
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