Anti-Corruption

L3 has a comprehensive compliance program with established policies, procedures, training, and internal controls to ensure that its business activities reflect the highest levels of ethical conduct. The policies and procedures are reviewed on an ongoing basis to identify areas in need of improvement, and they are updated as necessary and appropriate. Policies, procedures, training, and related internal controls are also tested on an ongoing basis by Internal Audit and the departments governing the policies. The following overviews describe the spirit of the policies that serve as the foundation for ethical business practices and anti-corruption compliance.

Overview of Company Policies

Corporate Policy 706

This policy requires that risk-based due diligence must be performed on prospective third parties both before and throughout the business relationship. The policy’s related procedures outline the detailed steps used to perform due diligence in an attempt to identify any potential risks and red flags. Red flags are addressed with additional due diligence and/or the assistance of legal counsel in order to mitigate potential corruption risks.

Corporate Policy 709

This policy sets forth the ethical standards of conduct and practices that must be followed by L3 in conducting international business. L3 prohibits public and private sector bribery in accordance with the U.S. FCPA, the UK Bribery Act, and other laws enacted pursuant to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. The policy’s related procedures outline the detailed steps and approvals required for training, hospitality, and appropriate record-keeping. L3 policy prohibits facilitation payments. Anyone that becomes aware of any suspected violation must report it promptly to corporate headquarters. A formal review process exists to ensure any identified control gap or weaknesses are addressed and controls are updated to strengthen the company framework for compliance. Furthermore, internal controls over processing of high risk transactions have been built into the company’s SOX framework.

Corporate Policy 002

This policy requires that L3 transactions are kept free from even the perception that favorable treatment was sought, received, or given in exchange for furnishing or receiving business courtesies. L3 employees are prohibited from giving or receiving business courtesies that constitute, or could be reasonably perceived as constituting, unfair business or a violation of law. Employees must know and understand prohibitions and limitations of the recipient’s organization before offering a business courtesy. Business courtesies must be consistent with marketplace practices, be infrequent in nature, and may not be excessive or lavish.