California Transparency in Supply Chains Act of 2010

Northrop Grumman Corporation

As a responsible corporate citizen, Northrop Grumman fully supports the elimination of human trafficking and slavery from the supply chain.

Northrop Grumman’s direct suppliers are required both to comply with applicable laws and regulations in providing us manufactured goods and products, and also to adhere to the company’s values and standards of business conduct. Northrop Grumman considers this not only a legal issue but an ethical obligation for everyone associated with Northrop Grumman. Suppliers that fail to adhere to our standards are subject to termination. Northrop Grumman suppliers have access to a toll free open-line that enables them to raise questions and concerns and report violations of laws, regulations and our standards of conduct.

The majority of Northrop Grumman’s business is as a prime contractor or subcontractor to the U.S. Government. As a U.S. Government contractor, Northrop Grumman is governed by and complies with Federal Acquisition Regulation (FAR) 52.222-50, "Combating Trafficking in Persons." Northrop Grumman flows this provision down in its FAR subcontracts. FAR 52.222-50 imposes the U.S. Government's "zero tolerance policy on human trafficking" on its contractors and their subcontractors and prohibits both from utilizing "forced labor" or engaging in "severe forms of trafficking in persons" during the performance of the contract or subcontract. Violations of this FAR provision can result in substantial financial and other penalties.

Northrop Grumman also has a corporate procedure based on FAR 52.222-50 that similarly seeks to combat human trafficking and forced labor. Northrop Grumman employees found to be in violation of this procedure are subject to discipline, up to and including termination.

Northrop Grumman believes that the nature of the business in which Northrop Grumman engages and the regulatory environment in which we operate both mitigate the risk of human trafficking and slavery within our direct supplier base. In keeping with our commitment to ethics, integrity and corporate governance, Northrop Grumman also maintains more broadly based supply chain programs, practices and procedures with the goal of ensuring that our suppliers meet our strong ethical standards and comply with applicable laws and regulations, which include those governing human trafficking and forced labor.

In addition to the specific items identified above that are more focused on combating human trafficking, Northrop Grumman maintains a robust, broad-based ethics and compliance program. This program addresses values, leadership, training, audits, certifications and accountability. This program is intended to ensure compliance with applicable laws and a culture committed to ethics and integrity in all we do.