Anti-Human Trafficking and Slavery Statement
Northrop Grumman Anti-Corruption Compliance
Northrop Grumman is committed to maintaining a strong culture with a deep respect for individuals and human rights. We have adopted company policies, practices and procedures to reflect and implement this broad commitment. The Human Rights Working Group, senior management and our Board of Directors provide oversight to enhance further this Policy and the Company’s commitment to human rights.
Human rights are generally defined as the basic freedoms believed to be inherent to all people. They are outlined in the Universal Declaration for Human Rights, www.un.org/en/documents/udhr.
The Universal Declaration focuses on dignity, respect and equality, without discrimination. These are principles that lie at the core of our Company’s values. We are committed to treating all of our stakeholders – including our employees, customers, shareholders and suppliers, and the communities in which we operate – with dignity, respect and equality, and also to partnering with our stakeholders to help them to do the same.
Although governments have the primary duty to provide and protect human rights, companies share a responsibility to act in ways that support them. The U.N. Guiding Principles for Business and Human Rights, adopted by the U.N. in 2011, offers a source of guidance on how governments, companies, and other parties can address their responsibilities.
Companies can advance human rights through the culture they establish, how they treat their employees and other stakeholders, how they manage their operations and engage in trade, and with the contributions they make to the global communities where they live, work and serve. Northrop Grumman’s commitment to human rights is reflected in each of these areas.
Requirements of our Human Rights Program
The Company’s commitment to human rights starts with the Company’s culture and core values, which form the basis for everything we do. We work hard to foster a culture in which each person can thrive. The Company’s first value provides explicitly: We do the right thing – we earn trust, act with ethics, integrity and transparency, treat everyone with respect, value diversity and foster safe and inclusive environments.
On top of this foundation, our Standards of Business Conduct, policies, procedures and practices set forth specific requirements for how we do business, and what we expect of those with whom we do business. They both reflect and implement the Company’s commitment to human rights. Of particular note, our Standards of Business Conduct, policies, procedures and practices provide for:
- We respect and value the rights of our employees and strive to provide them with a safe and inclusive environment in which they can excel. We treat our employees with respect and dignity, actively protecting and progressing their human rights. We seek to be a preferred place to work, where all are invited to speak up. We realize that the world we serve is diverse in its social customs and cultural traditions, and we respect and embrace those differences. We believe the differing viewpoints that we each bring to the workplace challenge and enable us to think more broadly and allow us collectively to better serve our customers and communities. The company has more than 13 employee resource networks, in which more than 22,000 of our diverse colleagues participate, that inform and implement strategies and initiatives that progress the Company’s business imperatives and values.
- The Company does not tolerate any discrimination in employment based on an individual’s protected status, and strives to ensure equal pay for equal work. We work hard to provide a work environment free from discrimination, harassment and retaliation.
- We treat with dignity and respect not only our employees, but those with whom we do business – including our customers, suppliers, partners and competitors.
- The Company respects the rights of employees to form, join, or not join labor unions. This includes the right to freedom of association and collective bargaining. Additionally we work together and make every effort to reach an agreement through open and constructive negotiations.
- Company employees have the right to fair working conditions, competitive wages and reasonable working hours. Northrop Grumman does not tolerate the use of child labor, forced labor, bonded labor or human trafficking of any kind.
- We provide reasonable accommodations for qualified persons based on disabilities, religious beliefs and pregnancy/childbirth (and related conditions). We strive for our facilities, websites, information, communications and technology to be accessible to all in their audiences.
- We manage our facilities and conduct our operations in a manner intended to protect the health and safety of our employees, and also customers, contractors and any other visitors.
- We respect the privacy of our employees and business partners who trust us with their personal information. The Company has specific policies in place that are designed to safeguard personal information and ensure that personal information is collected, used and shared in an appropriate manner and in conformity with our promises and legal obligations. The Company works to abide by all applicable privacy-related laws and regulations in the countries where it operates.
Our Supply Chain
- Northrop Grumman is committed to high standards of ethical and business conduct as it relates to its procurement of goods and services.
- Northrop Grumman treats its suppliers with respect and integrity and is dedicated to serving as a good partner to the many companies who help us meet our mission.
- We also work with our suppliers to help them to embrace similar values and to further our commitment to human rights. We require suppliers to adhere to a detailed Supplier Code of Conduct, along with relevant terms and conditions. Among other things, that Code sets out requirements related to ethics and integrity, labor and employment practices, protecting human rights, sustainability, and diversity and inclusion. The Code requires our suppliers to protect the rights of workers in our extended supply chain, including with regard to health and safety standards and local wage and hour laws. It prohibits the use of forced labor, child labor or human trafficking of any kind. We specifically require compliance with each of the Federal Acquisition Regulation Combatting Trafficking in Persons, UK Modern Slavery Act, and California Transparency in Supply Chains legislation. We proactively seek to mitigate any risk of conflict minerals both through the Supplier Code and our conflict minerals programs. That program makes clear our expectations that our products will not contain conflict minerals that directly or indirectly finance or benefit armed groups.
- Before entering into supply agreements, we undertake due diligence on potential suppliers to assess whether they will be able to meet our requirements. And during performance on contracts, we further monitor their performance. We take very seriously any issues with human rights or other aspects of labor practices in our supply chain. We investigate allegations of misconduct and take appropriate remedial action, including termination of contracts.
Our Programs and Products
- Northrop Grumman is committed to high standards of ethical and business conduct as it relates to how it develops, offers and provides goods and services.
- The company considers potential risks at different stages throughout the life-cycle of a product. This includes risks to human rights, technical issues, legal requirements, financial considerations or performance obligations, and risks to the company’s reputation, sustainability and long-term value. Northrop Grumman considers potential risks as it assesses how best to design and manufacture products, as well as to whom and under what circumstances they can and should sell them. The company is mindful of how its products might be used over time and potential unintended uses.
- Northrop Grumman has robust processes and procedures in place to help ensure the company does not do business in countries or sell products to customers not properly approved by the US Government. The company has procedures in place to engage in due diligence, to assess and potentially to mitigate risks – including to human rights or, more broadly, the reputation of the company – before undertaking certain business opportunities, even if they are or would be approved. Where the risks of agreeing to such a business opportunity are unacceptable, Northrop Grumman will decline the opportunity regardless whether it is legally permissible.
- Northrop Grumman does not manufacture or sell cluster munitions or components of such munitions as defined in the Convention on Cluster Munitions (“CCM”) issued on May 30, 2008 as initiated at the Oslo Conference in 2007 (“Oslo Conference”).
- Northrop Grumman does not manufacture or sell anti-personnel mines or components of such articles as defined in the Convention on the Prohibition of the Use, Stockpiling, Production and Transfer of Anti-personnel Mines and on their Destruction (“Ottawa Treaty”).
- Northrop Grumman does not manufacture or sell biological or chemical weapons or components of such articles as defined in the “Biological and Toxin Weapons Convention” and “Chemical Weapons Convention.”
- Northrop Grumman does not manufacture or sell white phosphorus weapons or components of such articles.
- The company conducts business globally in a manner consistent with its Values, as well as all applicable laws. Northrop Grumman works to incorporate its environmental, social and governance responsibilities and customer support into decision-making, including the products the company designs, develops, manufactures and sustains.
- For Northrop Grumman, being a good corporate citizen means improving the lives of the people in the communities where we live and work. We invest heavily in our communities, providing funding and other support to a wide range of local, national and international causes, across the globe. Our current efforts are focused on education, advancing diversity and inclusion, STEM, the well-being of our veterans and members of the military (and their families), human dignity and environmental stewardship.
- We are committed to serving as thought leaders and consensus builders in our communities, advancing our values of respect for all individuals, equal opportunity, diversity and inclusion, and protecting our environment.
- We conduct our operations in an environmentally responsible manner, in compliance with all applicable legal requirements. In addition, we establish, implement, monitor and report on progress against specific environmental goals. Those goals are intended to reduce our environmental footprint, reduce the production of waste, reduce our use of scarce natural resources, and protect our global environment.
- We are also working to consider potential environmental impacts as we design and develop manufacturing processes for our products.
- It is important to our Company, our employees, our shareholders and our local communities that the Company is striving proactively to manage our environmental impacts and to continue to enhance the sustainability of our operations.
Our Commitment to Integrity
- Our commitment to integrity lies at the core of our culture. We work every day to ensure an open, inclusive and ethical work environment in which our employees strive to do the right thing to serve our many stakeholders and to ensure the long term success of our enterprise.
Training, Communication and Oversight of the Company’s Human Rights Program
As noted above, Northrop Grumman’s human rights program is founded on our culture and values, and implemented through various policies and procedures, also described above. In addition, the Company is committed to training and communication, and broad oversight to help ensure our human rights program is effective and evolves to reflect learning and best practices.
Training and Communication
Effective training and communication are critical to the success of our human rights program. The Company provides periodic training to all employees on various elements of our human rights program. The Company provides more targeted training to leaders and to employees based on their roles and responsibilities, including under the policies and procedures described in this Policy. For example, we provide additional training to our Business Conduct Officers who are positioned globally and may be called upon to identify and address human rights related concerns.
The Company communicates more broadly with employees about the importance of human rights and the underlying principles of respect, dignity and equality. We communicate through internal communications, leader messages, a robust website and workplace postings among other things.
The Company reports on this human rights program in its Annual Proxy Statement and its annual Sustainability Report.
Reporting, Investigation and Corrective Actions
Any employee who believes there may have been a violation of this Policy should report it through established channels, including to their supervisor, Business Conduct Officer, the law department or human resources, or through the OpenLine. Reports to the OpenLine can be made anonymously if allowed by local law.
Reports of potential violations will be investigated and, if substantiated, remedial action will be taken. Northrop Grumman will not tolerate any retaliatory action against someone who comes forward in good faith to raise concerns about possible violations of this Policy.
We assess potential human rights risks, the severity of the potential risk, and the relevant mitigation measures. We integrate relevant findings into our policies and procedures as needed, based upon assessments. We track various aspects of our progress as part of the Company’s efforts continuously to improve.
We have established a Human Rights Working Group to help ensure this Policy is being implemented effectively and achieving our goals. The Human Rights Working Group considers the effectiveness of the program, the nature of the risk environment, and evolving best practices. As appropriate, the Human Rights Working Group will recommend changes to this program. This team is led by the General Counsel (or designee) and includes senior representatives from, among others, Global Corporate Responsibility, Human Resources, Legal, Global Supply Chain, Investor Relations, Contracts, EHS, Global Business Office, Government Relations, Communications and our Sectors.
The Board of Directors oversees the Company’s commitment to human rights. The Policy Committee of the Board has specific responsibility to provide oversight of the Company’s human rights program, including reviewing and making recommendations for enhancements, as appropriate. The Vice President, Global Corporate Responsibility, and the Chair of the Human Rights Working Group meet at least annually with the Policy Committee of the Board of Directors to provide an update on the Company’s human rights program and to discuss any areas of concern.
The Company may conduct additional audits or assessments, as appropriate, to measure compliance related to various of the above commitments.