2016 Leader`s Guide (English)

Transcription

OUR VALUES
Do What’s Right - We are committed to the highest standards of
ethical conduct in all that we do. We believe that honesty and integrity
engender trust, which is the cornerstone of our business. We abide
by the laws of the United States and other countries in which we do
business. We strive to be good citizens and we take responsibility for
our actions.
Respect Others - We recognize that our success as an enterprise
depends on the talent, skills and expertise of our people and our ability
to function as a tightly integrated team. We appreciate our diversity
and believe that respect – for our colleagues, customers, partners,
and all those with whom we interact – is an essential element of all
positive and productive business relationships.
Perform With Excellence - We understand the importance of our
missions and the trust our customers place in us. With this in mind,
we strive to excel in every aspect of our business and approach every
challenge with a determination to succeed. We seek not only the
highest accomplishments as individuals, but also seek to help our
fellow team members achieve at the highest levels.
COMMITMENT TO INCLUSION
At Lockheed Martin, we embrace the diverse talents and perspectives
of our people to power innovation and business success.
FULL SPECTRUM LEADERSHIP IMPERATIVES
• Deliver results
• Shape the future
• Build effective relationships
• Energize the team
• Model personal excellence, integrity, and accountability
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Dear Training Leader:
Welcome to “Voicing Our Values” Ethics Awareness Training for 2016.
Use this annual training session to focus yourself and your team on the importance of ethics
and integrity in our work environment. It is important that you review this guide before
facilitating a training session. The guide provides important discussion points for each case
scenario and highlights the various techniques we want everyone to be able to use. Please
use the information to guide your group’s discussion. Ensuring that all employees feel
valued and empowered to bring their best to Lockheed Martin is essential to strengthening
our foundation.
Voicing our values through daily actions reflects Lockheed Martin’s unwavering and longstanding commitment to ethical conduct. We recognize that all employees, and especially
leaders, play an active role in guiding our ethical status.
A key factor is the ability for all employees to talk about and take action for resolution to
conflicts that may arise in our work environment.
Awareness training provides an opportunity for all of us to strengthen the skills we need to
address values conflicts and ethical dilemmas in the workplace. Your role as a training leader
ensures a lively, healthy dialogue on the questions presented and helps others practice
these skills, including taking action.
The case scenarios are based on real-life issues facing employees and reflect the complexities
and realities of our workplace. Each case focuses on how we can address these issues more
successfully when they arise. This year’s case topics include conflict of interest, corruption,
fraud and full spectrum leadership. Issues with supplier relationships and the protection of
sensitive information are also presented, as they affect our ability to perform with excellence
in a global marketplace.
Your role in upholding Lockheed Martin’s commitment to the highest standards of ethical
business conduct is essential. You provide the example to employees that crosses the
boundaries of department, business unit and business area.
Thank you for inspiring our employees to recognize that their obligation to act is a key
component in building our “take action” culture.
Leo S. Mackay Jr.
Vice President, Ethics & Sustainability
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VOICING OUR VALUES 2016
TABLE OF CONTENTS
Thought Starters ................................................................................ i
Preparing to Lead the Session............................................................. 3
Voicing Our Values Techniques............................................................ 4
Before the Session .............................................................................. 6
Leading the Session............................................................................. 6
Case List and Key Issues . .................................................................... 7
Case Summaries and Leader’s Discussion Notes
Case 1 — Take One For The Team................................................. 8
Case 2 — We’re Lucky To Have Them ......................................... 10
Case 3 — Really Eye-Opening...................................................... 12
Case 4 — Didn’t Hear It From Me................................................ 14
Case 5 — Just Get It Done........................................................... 16
Case 6 — It’s The Way We Do Things ......................................... 18
Wrapping Up...................................................................................... 20
Sample Concluding Message.............................................................. 20
Facilitation Do’s and Don’ts .............................................................. 21
Participation & Acknowledgement .................................................. 22
Training Evaluation ........................................................................... 22
Participation & Acknowledgement Form........................................... 23
Quick-Start Guide............................................................................... 24
Timeline for One-Hour Session..............................................Inside Back Cover
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PREPARING TO LEAD THE SESSION
It’s important to review this section before your session.
• Each case scenario presents a situation that involves ethics, inclusion, and Full Spectrum
Leadership issues, and shows the outcome of a values conflict or ethical dilemma in the
workplace. The case scenarios are intended to demonstrate how various techniques may
be used to more effectively address ethical dilemmas or values conflicts that we may
encounter in the workplace.
• You are responsible for understanding these techniques before leading the awareness
training session.
In particular, we are asking everyone to consider how they might use any or all of the
following techniques to more effectively voice their values:
– Ask Questions
– Talk to Others
– Obtain Data
– Reframe the Issue.
Definitions of these techniques are provided on page 4 of this guide with a link to a printable
reference page for use by attendees when discussing the cases.
• For some of the scenarios, there may be a reportable violation. You will have the opportunity
to discuss what may be reportable and when it should be reported. However, a big part of
voicing our values means raising issues and using the techniques outlined above to prevent
a violation from occurring. The case summaries, pages 8 to 19, provide some discussion points
for your use. You should have time for three cases in your one-hour session.
Virtual Groups
Prior planning is essential to ensure virtual sessions are meaningful for all participants. Be
sure in advance that all locations have access to the web-based version of the training or the
training DVD. If you are facilitating a session that includes participants both physically with
you as well as on the phone or other conferencing system, ask all the virtual participants to
mute their phones when playing the video. Ask all participants to share their responses. Be
sure to put the audio systems in your rooms on mute as needed. The discussion is a key
element of this training, so as a leader, please arrange as many sessions as you need to allow
all of your team members to participate fully.
The online version of the training is found at
http://ethics.corp.lmco.com/ethics/awareness_training.cfm;
or http://www.lockheedmartin.com/us/who-we-are/ethics/training.html.
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VOICING OUR VALUES TECHNIQUES
Resolving ethical dilemmas or values conflicts effectively by voicing our values requires
us to recognize that such conflicts are not uncommon in the workplace. You can,
and should, strategize how you might respond if faced with different types of ethical
dilemmas or conflicts. By approaching conflicts in this manner, they become business
problems that can be resolved by using an appropriate strategy, rather than emotional
situations that you feel paralyzed to resolve. Should you be unable to resolve the conflict
using these techniques, or in the event of a compliance breach, you should report the
violation to your manager, Human Resources, the Legal Department, Security, Internal
Audit, the EESH Office, or the Ethics Office.
The following are some of the techniques or actions you should consider using to address
ethical dilemmas or values conflicts:
Ask Questions
• Gather information in a non-threatening way
• Don’t assume you’re right
• Probe for information rather than arguing.
Ask questions that demonstrate that you don’t assume you are right or know everything
about the issue in question. Ask questions designed to gather information and help
everyone involved in the discussion achieve a clearer and more complete picture of the
issue at hand. Asking questions in this manner can help you understand the situation
in a way that resolves your values conflict. Alternatively, it may cause the other person
involved in the conflict to reconsider his or her course of action. For example, you could
ask: “What factors did you consider in deciding XYZ?” or “Could you help me understand
the basis for your decision?”; “Did you consider that your approach could be viewed by
some as high risk?” or “What mitigation plan do we have to address the risk?”
Obtain Data
• Use fact-based data to support your position. Don’t assume that the other person
already knows and is disregarding this data
• Explain how your data leads to a different outcome or conclusion.
Use fact-based logic and data to support your position. Ensure that those who are
proposing actions that are causing you a conflict understand the data that should lead
to a different outcome or conclusion. By voicing your values using data, you will avoid
unnecessarily emotional arguments that likely will place the other person on the defensive.
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Talk to Others
• Identify a network of people with whom you are comfortable
• Look for those who have related experience
• Be honest about your dilemma.
Identify people – your colleagues or leaders – with whom you feel comfortable
discussing ideas and issues. Talk to them about the conflict that you face. Sometimes
just talking over an issue helps you figure out how to handle it. Also, they may have
experienced a similar situation. Find out how they handled it.
Reframe the Issue
• Use neutral language
• Highlight a different perspective
• Present risks of the current course and suggest alternatives.
Speak with the person on the other side of your dilemma. Rephrase the situation and
options in more neutral language or in ways that highlight a different perspective that
suggests an alternate course of action that is more consistent with your values. Reframe
the issue in a manner that shows the other person that you are not questioning his or
her integrity, rather you have a real concern that needs to be resolved for you to feel
comfortable with the action you are being asked to take or the situation in which you
find yourself. For example, a potentially unethical action can be reframed to show how
the action creates a risk that the other person would want to avoid.
NOTE: This information is available online in printable format.
For participants inside the firewall, go to http://ethics.corp.lmco.com/ethics/
awareness_training.cfm and click on “Voicing Our Values Techniques.”
For participants outside the firewall, go to http://www.lockheedmartin.com/us/
who-we-are/ethics/training.html and click on “Voicing Our Values Techniques.”
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BEFORE THE SESSION
Here are some basic steps to take before the training session.
Locate the contact information for your Ethics Officer. You will need this for the closing message
on page 20. You can locate this information on Enhanced White Pages, and it may differ for
employees at different locations. Identify how many people in your organization are to be trained
and schedule enough sessions for training groups of 12–24 people, although the training can be
used for smaller or larger groups. Send participants a meeting notice with the time and place
for the session. Send the notice sufficiently in advance to allow participants time to plan their
schedules. A session is required to last at least one hour. Include directions on how to charge
labor for the session.
Reserve a room with enough tables and chairs for comfortable seating, and connectivity, or a
DVD player if necessary. Test the equipment to make sure it is working. Test the DVD disk in the
machine if you use this option. NOTE: DVDs will not run automatically in most Lockheed Martin
computers. Be sure you know how to activate the DVD for viewing. Refer to “Facilitation Do’s
and Don’ts” on page 22. Familiarize yourself with the cases by reading the summaries in this
Leader’s Guide and by previewing the video.
Select three to four cases that are appropriate for your group, choosing cases that will be the
most relevant and challenging.
LEADING THE SESSION
Distribute to the attendees in your training session copies of pages 4 and 5 in the Leader’s Guide
and “Our Values” both found online at http://ethics.corp.lmco.com/ethics/awareness_training.
cfm; or http://www.lockheedmartin.com/us/who-we-are/ethics/training.html.
Provide directions on how to charge labor for the training session.
Provide directions on how to acknowledge participation.
If any participants are hearing-impaired, click on the “Settings” icon in the video window before
playing the introductory video.
Choose “Subtitles” if using a DVD. If your session includes virtual participants, be sure to start
the video at the same time and ask participants to mute phone lines while the video plays.
Click “Introduction” to play the video segment which includes a message from Chairman,
President and CEO Marillyn Hewson, as well as an overview of how the activity works.
Play a case. Read case summary aloud before playing case.
Discuss the case as a group and answer the questions on the screen.
Click “Continue” to view the second part of the video. At the conclusion of the video, ask for
any additional comments.
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Repeat the process to complete at least three cases (or as many cases as can be covered in the
available time, which should be no less than one hour). A suggested timeline for the session is
located on the inside back cover.
Deliver a concluding message. See page 20.
Note: For virtual session, see page 3.
CASE LIST, KEY TOPICS AND ELT SUMMARY
Case 1 – Take One For the Team
• FSL* - Build Effective Relationships, Misuse of Assets, Safety
Richard H. Edwards, Executive Vice President, Missiles and Fire Control
Case 2 – We’re Lucky to Have Them
• Conflict of Interest, Gifts and Gratuities, Procurement
Richard F. Ambrose, Executive Vice President, Space Systems
Case 3 – Really Eye-Opening
• Expense Reporting, Fraud, International Business
Bruce L. Tanner, Executive Vice President and Chief Financial Officer
Case 4 – Didn’t Hear It From Me
• Sensitive Information Protection, Insider Trading, Conflict of Interest, Privacy
Maryanne R. Lavan, Senior Vice President, General Counsel and Corporate
Secretary
Case 5 – Just Get It Done
• FSL* - Build Effective Relationships, Quality, Fear of Retaliation
Orlando P. Carvalho, Executive Vice President, Aeronautics
Case 6 – It’s The Way We Do Things
• Corruption, Procurement
Dale P. Bennett, Executive Vice President, Mission Systems and Training
* Full Spectrum Leadership
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MAIN
CHARACTERS
CASE 1: TAKE ONE FOR THE TEAM
• Jonathan – LM UK Manager
• Antonio – Visiting LM US Manager
• Sarah – LM UK Employee
• Troy – LM UK Employee
SUMMARY
Jonathan, a UK manager, directs his team, including Troy, to take process and safety shortcuts. He’s
also using company equipment and materials to support a local rugby club. Jonathan intimidates
the workforce and at least one employee, Sarah, is leaving the company as a result. When Antonio,
Jonathan’s US-based leader, comes to visit, Jonathan is evasive and tries to limit Antonio’s interaction
with team members.
Leader’s Note: Here are some notes to help guide the group discussion.
DISCUSSION QUESTIONS This should be an open discussion for the group.
How and by whom were the Lockheed Martin values and the Voicing Our Values techniques
applied in this situation, or how might they be applied?
Thought starters about our Values are on page i.
All of our values may come into play in this scenario, depending on which aspect of the case you are
considering.
While Do What’s Right may lead us to support the community, Jonathan’s charging the customer for
making the goalposts is wrong. He does not Respect Others when his tone with his team members
is forceful and disrespectful nor when he directs Troy to use the forklift without proper training.
Employees are afraid to challenge him even when they know his direction may be improper. Team
morale is affected and additional talented people like Sarah may choose to leave the company. Perform
With Excellence includes all aspects of Full Spectrum Leadership, not just Delivering Results. Jonathan’s
treatment of his team members fails to meet those standards for leaders.
Sarah has attempted to Talk to Others/Report Violations by e-mailing her concern about the goalposts
to Antonio, but he did not attempt to follow up with her to understand and instead forwarded her
message to Jonathan, believing it to be a non-issue. He should have done more, and certainly should
have followed up directly with Sarah. Despite receiving no feedback, Sarah takes the initiative to speak
with Antonio after the all- hands. When presented directly with the issue by Sarah, Antonio listens to
her concern and seeks clarification. (Ask Questions, Reframe the Issue.)
Troy attempts to Reframe the Issue for Jonathan regarding safety and why she shouldn’t be operating
the equipment and she Asks Questions in the all-hands meeting but Jonathan shuts her down and then
attempts to intimidate her. Troy could have taken more direct personal action. While she talked to her
fellow team member, Sarah, in a last minute effort, Troy might have also spoken with a mentor or one of
Jonathan’s peers for advice on how to handle the situation (Talk to Others, Obtain Data). Jonathan might
have considered the impact of his behavior on the team’s productivity had he been approached by a peer,
who could have Reframed the Issue for him. Jonathan’s failure to establish and maintain strong, enduring
and effective relationships is contradictory to the Full Spectrum Leadership attributes of successful
leadership. Actively listening to feedback and ideas from employees helps maintain an open dialogue.
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His actions did not foster an environment in which employees felt comfortable sharing both positive and
negative information.
Either Troy or Sarah could have contacted HR or Ethics regarding Jonathan to discuss his behavior and
the issue regarding the goalposts. (Report Violations) Their fear of retaliation seems to be the reason
they have not done so, but Lockheed Martin does not tolerate retaliation and their concerns would
have been fully addressed.
How might similar situations occur in our own work area and how can we avoid them?
This should be an open-ended conversation about how the concepts in this scenario might apply to
those in the training session.
A potential negative occurrence might be considered unlikely by some and highly probable by others
on the same team. When that is the case, we should not intentionally withhold potentially negative
information. A leader could encourage team members to be open and honest about any concerns and
enlist their assistance in resolving an issue.
How can leaders demonstrate that they are willing to hear and act on employee concerns
without retaliation?
Trust among team members is crucial to accomplishing our tasks in an effective and efficient manner.
It’s appropriate to bring possible solutions or mitigations forward at the same time an issue is raised, but
leaders should remind the team that it is not a precondition to reporting a concern. Employees might
avoid reporting bad news to their supervisor unless the leader has made it clear in advance that he or she
really wants to hear it. Asking for negative reports on just one occasion may not achieve the goal; it takes
repetition. Employees watch carefully what happens to their peers who report bad news, and even one
incident that is perceived as “punishing the messenger” may keep others from speaking up.
Following the discussion, the group watches the second half of the video.
Closing remarks on this case:
It is important to adhere to all safety requirements and these should not be bypassed for any reason,
including schedule pressures.
We should be respectful, open and honest in all of our business interactions. In particular, our team
relationships should reflect the highest levels of respect. In this case, Jonathan’s lack of respect for his
own team members was a significant issue and it masked additional problems. Possible misconduct
by an employee’s supervisor or manager should
be reported to their Ethics Officer or Human
RELEVANT POLICIES:
Resources Business Partner.
CPS-001 Ethics and Business Conduct
Confirmed mischarging may result in disciplinary
action up to and including termination of
employment. A U.S. Government contractor, as
well as individuals employed by the firm, may be
debarred or suspended from contracting with
the federal government for a knowing failure to
promptly disclose to the government credible
evidence of a Reportable Violation in connection
with the performance of a contract or subcontract.
For more information, see CPS-718 Disclosures to
the United States Government. In other countries,
including Australia, Canada and the United
Kingdom, local laws and regulations apply.
CPS-002 Quality, Mission Success and Safety
CPS-004 Political Activity
CPS-007 Personal Use of LM Assets
CPS-008 Gifts, Hospitality, Other Business
Courtesies, Sponsorships
CPS-021 Good Corporate Citizenship and
Respect for Human Rights
CPS-564 Harassment-Free Workplace
CPS-718 Disclosures to the U.S. Government
CRX-251 Charitable Contributions
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MAIN
CHARACTERS
CASE 2: WE’RE LUCKY TO HAVE THEM
• Ricardo – LM Employee
• Tony – Supplier
• Traci – Ricardo’s wife
• Natalie – LM Manager
• Maura – Tony’s wife (not seen)
SUMMARY
Ricardo, an employee, and Tony, a supplier, are close friends. Over the years the relationship has
blurred the lines between business and friendship. They are both traveling to an upcoming overseas
conference. Tony provides hardware that may be defective. In trying to help each other, they may
create issues involving a significant quality escape and improper acceptance of a business courtesy.
considering.
Ricardo’s friendship with supplier Tony becomes a problem when Ricardo fails to exercise due
diligence in the sourcing of items to meet the project’s needs. Although he is trying to Perform with
Excellence by ensuring he can deliver the product, he is taking shortcuts that actually undermine that
performance. In addition, his failure to disclose the potential conflict of interest is a serious issue (Do
What’s Right).
Ricardo’s close association with Tony interferes with Ricardo clarifying the procedures he should be
following to properly source materials (Obtain Data, Ask Questions.) He should have checked with the
Global Supply Chain Organization regarding the proposed procurement of the alternate video cards and
with the Legal Department on his possible conflict of interest due to his friendship with Tony.
Natalie Asks Questions of Ricardo in order to help him understand the importance of following the
correct procedures to source materials. She tries to Reframe the Issue for him by mentioning possible
counterfeiting and the rack work that could have been an in-house sourcing solution – but that
conversation occurs after the decisions have already been made. Now that Natalie has made him aware
of the potential problems, Ricardo might Do What’s Right and Obtain Data to confirm the scope of his
responsibilities. Either he or Natalie could take action to Report Violations.
Tony’s providing Ricardo with the use of a hotel room during the conference becomes a greater
conflict of interest concern with Tony’s firm having received a contract through Ricardo. The soundness
of Ricardo’s actions is called into question, especially given that he did not follow the approved
procurement processes.
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If the group is involved in procurement, or in make-or-buy decisions, the issues presented are directly
relevant. Other groups may discuss what types of process shortcuts someone might be tempted to take
or how a personal conflict of interest could occur in their work group.
What issues might arise when an employee, or a family member, has a close relationship with a
supplier? How is such an issue best handled?
Family and friends may be employees in businesses that supply materials and/or services to
Lockheed Martin. Depending on one’s role in working with such a business, this could create a
conflict of interest that unintentionally clouds judgment in making decisions relative to that supplier,
interfering with our following government requirements for fair competition. There are many
possible consequences: we may end up procuring unapproved items that will fail prematurely in
service or contain counterfeit components in violation of law and regulation. We could even end up
overpaying for something that initially seemed like a good buy.
Filing a conflict of Interest disclosure form allows Legal to look at the relationship(s) involved and
provide direction that will prevent even the appearance of a conflict of interest.
Actual or potential conflicts must be disclosed in accordance with CRX-014 Individual Conflict
of Interest.
All of our business practices are to be conducted in a thorough and impartial manner, with fair
competition. Selecting suppliers based on personal relationships undermines this process. In this
case, Ricardo’s personal friendship with Tony has led him to giving Tony what could be construed as
preferential treatment. Gifts and business courtesies may be a particular issue with new suppliers
who are not familiar with our policies. A U.S. Government contractor, as well as individuals employed
by the firm, may be debarred or suspended from contracting with the federal government for a
knowing failure to promptly disclose to the government credible evidence of a Reportable Violation in
connection with the performance of a contract or
subcontract. In other countries, including Australia,
RELEVANT POLICIES:
Canada and the United Kingdom, local laws and
regulations apply.
Deciding whether to make or buy certain hardware
can have broad reaching implications beyond
the purchase price. By following the established
CPS-113 Acquisition of Goods and Services
processes for this, we can ensure that all relevant
CPS-718 Disclosures to the United States
factors are considered.
Government
CRX-014 Individual Conflict of Interest
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MAIN
CHARACTERS
CASE 3: REALLY EYE-OPENING
• Joseph – New LM employee
• Gita – LM employee
• Stelio – International consultant
• Sharon – Gita’s and Joseph’s manager
SUMMARY
Co-workers Gita and Joseph meet with consultant Stelio for drinks after a promising customer meeting.
Joseph is concerned that they may have “oversold” the technology they are showcasing. He is also
concerned about properly expensing the alcohol, but Stelio dismisses this concern. With their business
concluded, Gita invites a friend to join her for a couple of days of vacation. Gita’s manager Sharon finds
out that the charges Gita is expensing may not be business-related.
considering.
Gita and Stelio are not respectful of the customer nor of new employee Joseph (Respect Others).
Joseph Asks Questions but the others deflect and make fun of him rather than responding with valid
answers. As the senior team members, they are providing the new employee with poor examples of
how to Do What’s Right and Perform with Excellence. In addition to appropriate training and briefings,
a new team member should be provided with appropriate mentoring and leadership guidance.
Sharon only discovered by happenstance the concern with Gita’s time charging and expense reporting.
As Gita’s manager, she should have been monitoring Gita’s attendance and expense reports, paying
attention to odd details that could have surfaced these issues earlier (Perform with Excellence.)
Joseph tries to Ask Questions of Gita and Stelio about the behavior and procedures he witnesses. His
concern for policy being violated is dismissed by the others (Do What’s Right). Gita blatantly states that
she does not need to concern herself with a mischarging concern because the consultant will cover
her. Due to their influence, Joseph may believe that he doesn’t have to Obtain Data, because he sees
that the policies do not appear to apply to his team – but he could certainly Talk to Others, perhaps his
manager Sharon, about what he observed, including his conversation with Gita after she returned.
Sharon should act on the information that came to her in the conversation with Joseph about
Gita’s vacation.
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New employees may need specific training and mentoring to fully understand the scope of their
responsibilities, their tasks, and relevant policies. Leaders should check in with them regularly regarding
their work and progress. It is unclear whether Sharon, Joseph’s manager, has provided this level of
support; but leaders in all organizations should have an onboarding plan for new team members.
Employees with concerns should use the Voicing Our Values techniques to Talk to Others, Ask Questions,
Obtain Data and help team members Reframe the Issue in order to prevent misconduct from occurring. If
team members are acting inappropriately, employees can raise the issue to their manger or to their next
level leader. Unethical behavior may cause concerns in any environment; domestic or international, in
the office or on the shop floor. Possible misconduct should be reported to the Human Resources Business
Partner, the Legal Department, Security, Internal Audit or the Ethics Office.
At any point did Joseph have an obligation to report a concern? Why or why not?
Yes he did. While Joseph did the right thing by Asking Questions of his team members, when he
became concerned about possible discrepancies between the policies and his team members’ actions,
he should have raised an alarm. You are responsible for reporting a violation or suspected violation. An
illegal or unethical action is not permitted, even if it appears to benefit the Corporation or is directed by
a higher authority in the organization.
Gita and Stelio openly collaborated to defraud the Corporation. Stelio’s offer to handle the translations
suggests that he would use the opportunity to benefit beyond the scope of his consulting agreement.
At the same time, the two conspirators distort Joseph’s perspective on the ethical business model that
Lockheed Martin strives to maintain. Had Joseph not been made aware of their improper behavior through
the disciplinary action, his future work decisions and conduct could have been skewed, jeopardizing the
Corporation and his career.
Mischarging puts business at risk and results in costly business and, at times, personal criminal and civil
penalties. Reputational risks cannot be measured. Laws can be complex, particularly when working with
international governments, consultants and suppliers. Lockheed Martin would rather walk away from
business than risk violating U.S. or other countries’ law or our Code of Conduct, and Lockheed Martin
has so walked away. All employees engaged in international business should be familiar with the relevant
policies, and have received appropriate compliance training before performing international businessrelated services on behalf of Lockheed Martin.
There is a time charging issue depicted in this case because
Gita has improperly accounted for her time while working
on a government contract. In other countries, different
disclosure statements or cost accounting standards may
apply. A government contractor, as well as individuals
employed by it, may be debarred or suspended from
contracting with the government for a knowing failure to
promptly disclose to the government credible evidence of a
Reportable Violation in connection with the performance of
a contract or subcontract.
RELEVANT POLICIES:
CPS-007 Personal Use of Lockheed
Martin Assets
CPS-008 Gifts, Hospitality, Other
Business Courtesies, Sponsorships
CPS-718 Disclosures to the United
States Government
CPS-730 Compliance with AntiCorruption Laws
CRX-011 International Consultants
CRX-325 Business Travel
CRX-534 Absence from Work
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MAIN
CHARACTERS
CASE 4: DIDN’T HEAR IT FROM ME
• Linna – Employee
• Shon – Supervisor
• Natalie – Facility Manager
• Ryan – Employee
SUMMARY
Linna is dating another employee and the relationship sours. Her friend Shon, a supervisor, offers her
some words of consolation. In the process, Shon may violate the privacy policy regarding employee
personal information and also release sensitive pre-decisional information relating to a possible
facility closure, even though Facility Manager Natalie has strongly cautioned her team to protect that
information. Linna’s co-worker Ryan considers trading stock based on that information.
considering.
Shon was privy to proprietary and personal information that he was responsible to protect (Do What’s
Right). However, he failed to Perform with Excellence when he hinted at that information in his
conversations with team members. Shon, Linna and Ryan all failed to Respect Others in discussing
Nathan’s job assignment and move.
Through Shon’s insinuations, Ryan and Linna incorrectly determined and acted on the belief that the
facility was being closed.Unfortunately, their mistake spiraled out of control and into the community
when Ryan called her uncle in local government. Either of them might have Talked to Others and
Obtained Data internally to better understand the process for making a plant closure decision (even
though they would not be able to get specific information about the current assessment.) They could
have also Obtained Data about our policy on Insider Trading. Linna does appear to Ask Questions of
Natalie, perhaps for the wrong reasons - but the conversation is cut short. Natalie might double back
to finish that conversation with Linna and also follow up with the small team aware of the facility
assessment to reinforce the need to limit that information to those with a need to know (Talk to
Others.)
Conversations with a friend or co-worker can be misinterpreted and result in a rumor’s rapid development
and spread. This may disrupt productivity by creating unnecessary distractions and may even promote
disagreements between co-workers. Rumors, should they spread into the local community, may cause
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problems that negatively affect the Corporation. Reputational risks to the Corporation cannot be
measured. When a rumor surfaces it is best to deal with it promptly to avoid misinformation from building
into an issue that spreads animosity among co-workers or in the community.
Communications are vital to a successful work environment. By asking questions and responding factually
to questions asked, or stating clearly that they cannot answer, all employees may contribute to avoiding a
disruptive rumor from becoming counter-productive.
What are the potential ramifications of Linna, Shon and Ryan mishandling proprietary and
personal information?
In this case, Linna and Ryan build rumor and bits of facts into disruptive speculation about what they
believe is an imminent facility closure. The commotion goes beyond the workplace when Ryan calls her
uncle who is in local government, informing him of this potentially significant economic impact to the
community. Such a rumor could create concern that negatively affects the Corporation’s reputation.
Factual news about such a serious development should come from the Corporation’s local or regional
leadership. Additionally, the closing of a facility may entail legal requirements. In this scenario, if the
assessment does in fact result in a recommendation to close the facility, but the information has
already been leaked, the situation may require the effort of Legal staff to untangle it. Linna and Ryan
further extend the damage caused by their out-of-control rumor when considering trading shares of
stock acting on nonpublic information. From their conversation, it sounds as if a facility closure would
have a material impact to Suborne, the electronics distributor. Trading stock in this situation would
violate CPS-020 Fair Disclosure of Material Information, our policy governing the use of information
that has not been disclosed previously by Lockheed Martin and broadly disseminated to the public.
Additionally, their trading would be a violation of law, subjecting them to criminal prosecution.
Conflicts of interest can be complex, particularly when working with friends and family. Gossip can
be damaging. Shon’s allusions to Linna’s former boyfriend and his future work status were, while
well-intentioned to help his friend move on from the failed relationship, outside his boundaries in the
handling of personal information. For example, a manager would be remiss to share an employee’s
salary or medical information with other employees. Although Shon did not divulge specific personal
information, he did receive a verbal reprimand for his lack of discretion. His personal friendship with
Linna and Ryan nearly undermined the proper handling of information. Privacy laws and regulations
vary among countries, including Australia, Canada,
the United Kingdom, and the United States.
RELEVANT POLICIES:
Our policy CPS-201 Release of Information details
how, and by whom, company-related information is
to be publicly released, including use of the Internet
and social media. Lockheed Martin encourages
communication and collaboration among its
employees, customers, partners, and others. Social
media supports these goals, but all who use it
must understand that online activities can have
far-reaching and lasting consequences. Information
you post ultimately may reach a different or wider
audience than intended or expected.
CPS-020 Fair Disclosure of Material
Information
CPS-201 Release of Information
CPS-722 Compliance with U.S. Securities Law
CRX-014 Conflict of Interest
CRX-015 Protection of Sensitive Information
CRX-015A Personal Information
CRX-016 Privacy – United States
CRX-017 Personal Data Protection
CRX-253 Social Media
15
MAIN
CHARACTERS
CASE 5: JUST GET IT DONE
• Patrick – Shop technician
• Deepti – Shop technician
• Jamison – Manager
SUMMARY
Jamison, the manager, is pressuring team members Deepti and Patrick to perform, but he is not listening
to their feedback. He also mocks their support of a company-sponsored charity event. Patrick, a
technician, tries to satisfy Jamison’s demands and improve the team’s output by using a technique that is
outside standard processes. Incorrectly drilled holes result and Jamison covers up the mistakes.
considering.
Patrick held back negative information from his manager Jamison by not speaking up about his actions
involving use of alternative production methods. He may have been trying to Perform with Excellence
by trying to meet the schedule, but he misses the mark regarding both that value and Do What’s Right.
Patrick shared information (Talk to Others) with his co-worker, Deepti. He also tried unsuccessfully to talk
with Jamison. With no help from Jamison, Patrick could, but does not, Talk to Others like Quality, Human
Resources or the Ethics Office for guidance that could help identify a proper solution. He uses an unapproved
quick fix, rather than bringing the issue forward via a channel other than his manager. Deepti takes the
initiative and when she realizes that Patrick has inappropriately drilled the parts, she Asks Questions and
tries to Reframe the Issue for him, asking if he wants to be responsible if the parts fail in the field. She might
also Talk to Others, if not Jamison directly, then his leadership or other organizations, when she realizes
that Patrick is not going to speak up. Unfortunately, Deepti did not take the action of Reporting a Violation;
rather, she deferred to Patrick stating it was his responsibility. Given the gravity of the situation in this case –
the production of parts for flight use – the issue should have been reported at any point by either of them.
Jamison is clearly most interested in getting parts through the system to avoid a negative effect on his
record. He jettisons our value of Do What’s Right in a mistaken attempt to meet deadlines. In contrast
to a core value – Respect Others – Jamison demotivates his team by casting aspersions on their
charitable efforts as well as their work performance. He continues to demand their action without Asking
Questions that might lead to the real issue and a viable solution. Jamison might also Talk to Others
among his leadership or other organizations to seek alternative approaches to motivate the team to
reach the desired goals. Jamison’s failure to establish and maintain enduring and effective relationships
is contradictory to the Full Spectrum Leadership imperatives of successful leadership. His actions did not
foster an environment in which employees felt comfortable sharing negative information. Jamison might
benefit from an open dialogue in which he listens to feedback from the team and considers potential
solutions rather than seeking to place blame.
16
This should be an open-ended conversation about how the concepts in this scenario might apply to those in
the training session.
Deadline pressure can cause tension that quickly spreads among team members. Rash statements could
be made that lack respect, thus causing others to feel insulted or shamed. The time spent to choose
the words best suited for the moment can make the difference between a dynamic team and a poorly
performing team. Communication is a vital component to a successful team. In the instance when harsh
words may be spoken, it is best to clear the air promptly and avoid resentment that could build among
team members. Unreasonable demands can raise the fear of retaliation, prompting some team members
to withhold information that could prove vital to a successful organization or team performance. We
should be open and honest about the issues at hand and enlist assistance in resolving problems. It’s
appropriate to bring possible solutions or mitigations forward at the same time an issue is raised, but that
is not a precondition to reporting an issue.
How can a leader under schedule pressure appropriately motivate and inspire the team?
Leaders should help their team members determine the best way to communicate such information. Employees
might avoid reporting bad news to their supervisor unless the leader has made it clear in advance that he or
she really wants to hear it. Asking for negative reports on just one occasion may not achieve the goal; it takes
repetition. Employees watch carefully what happens to their peers who report bad news, and even one incident
that is perceived as “punishing the messenger” may keep others from speaking up.
Use of team meetings to discuss what goals are set along with discussions relevant to lessons learned during the
work process can help to keep the team focused and understand what is expected. Regular, open conversation
about any challenges and how to address them can create an environment in which everyone feels comfortable
contributing. In a situation where there is a potential to miss targets, a process improvement team can research
best practices and develop alternatives.
It is important to adhere to all procedural requirements and these should not be bypassed due to schedule
pressures. It is not acceptable to sign off on work if there is a question as to whether the work has been properly
completed. This includes all aspects of our work, not just our manufacturing operations. For example, the same
principles apply to engineering and financial analyses and reviews, procurement packages, and waste material
disposal. While retaliation is not explicitly shown in this case, Patrick exhibits a fear of retaliation if he “snitches.”
Whether overt or subtle, retaliation against anyone who makes an inquiry, participates in an investigation or
reports misconduct in good faith is not tolerated at Lockheed Martin and should be reported immediately.
Information on retaliation is covered in CPS-001 Ethics and Business Conduct and in “Setting the Standard,”
Lockheed Martin’s Code of Conduct.
We should be respectful, open and honest in all of our business interactions. Our workplace relationships should
reflect the highest levels of respect. Jamison’s lack of respect for his own team members was a significant issue.
It cost him his employment, as he chose to leave the company in
lieu of termination of his employment. Had his team members
RELEVANT POLICIES:
asked for assistance from the Ethics Office or others, including a
senior leader or HR Business Partner, it may have been helpful for
CPS-002 Quality, Mission Success and
all. An employee who self-reports may still face disciplinary action.
System Safety
It is important to remind session attendees that treating people
CPS-021 Good Corporate Citizenship
with respect and dignity ensures the long-term sustainability and
and Respect for Human Rights
competitiveness of our business.
17
MAIN
CHARACTERS
CASE 6: IT’S THE WAY WE DO THINGS
• Rafael – Employee
• Jason – Project Lead
• Ed – Supplier
SUMMARY
A new operation at a small site results in Rafael being tasked with hazardous material disposal.
His discussion with Jason, the project lead, indicates that competitive sourcing is required. Rafael
opts to circumvent the competitive sourcing process. Ed, a possible waste disposal supplier, offers
inappropriate incentives (kickbacks) to close the deal.
considering.
Rafael’s attempts to resolve his dilemma with sourcing a supplier run counter to our values and he does
not use the Voicing our Values techniques effectively to reach a solution.
Jason Reframes the Issue for Rafael by noting that the work associated with this assignment is
similar to other work Rafael has performed and citing some of the special considerations in selecting
a hazardous waste removal supplier. In providing a full view of the process, Jason gives Rafael
information on how to proceed should the availability of a supplier be unique. Jason tries to help Rafael
understand the importance of taking the proper steps to establish a supplier contract.
However, Rafael ignores the core values of Do What’s Right and Perform with Excellence as he appears
to be more concerned with reducing his workload than with following the standard procurement
procedure. He attempts to use a creative, but unauthorized approach. Rafael is receptive to the sales
pitch from Ed, who is a seasoned expert in closing the deal. Rafael does not seem to realize that he
is about to accept a bribe from Ed. Ed, not Rafael, Asks Questions and gains an advantage in the
negotiation. Ed positions himself to promptly close the deal with a bit of additional encouragement.
Rafael might Obtain Data by checking the applicable policies about procurement, Ask Questions of
Jason to better understand what’s expected, and/or Talk to Others, like someone in the Global Supply
Chain organization, about the “deal” that he is discussing with Ed.
When we or our team members are faced with a challenging work assignment it is important to
recognize that the level of effort may be greater than first expected. Cutting corners to avoid an
increased workload is not aligned with our values: Do What’s Right; and Perform with Excellence.
18
Team members and other employees have a wealth of experience and should be readily available to
share the wisdom gained in their respective careers. Those with more knowledge on specific subjects
can provide co-workers with information before being asked. Our projects are best served when we
include a full array of sources, including our team members and others, as we search for information (Ask
Questions, Obtain Data). This ensures a solution to benefit both internal and external stakeholders.
While many people might choose not to get involved, Jason demonstrates how any of us can Take
Action in similar circumstances to help a co-worker who might be struggling with a dilemma.
What are the potential outcomes of Rafael’s decision?
A gift or other business courtesy may influence the receiver to “return the favor” by showing
preference to the giver. In this case, Rafael is being offered discounted rent by Ed in exchange for
placing a contract with Ed’s firm – a bribe.
Additionally, Rafael is circumventing the approved procurement processes, agreeing to possible
additional transactional costs that will increase the price.
Rafael is about to break the law by accepting a bribe. When this is discovered, the company may need
to report the situation to the government and Rafael will likely lose his job, face personal debarment,
and possibly face criminal liability.
Failure to follow proper competitive sourcing requirements can also lead to reporting to the
government, a need to refund any excess costs to the customer, and public embarrassment for
Lockheed Martin. Ed’s company may not even be qualified to perform this work, and improper disposal
of hazardous waste could result in fines and criminal liability for the company.
It’s never too late to Do What’s Right. Thanks to having listened to Jason and taking action accordingly, Rafael
avoided a serious error in procurement through an unscrupulous supplier. Ed’s firm was faced with being
unable to apply for Lockheed Martin contracts and faced potential debarment from all federal contracts.
Jason could have ignored Rafael’s dilemma and not continued to check on his progress and try to help.
However, to do so would be the very inaction our Voicing Our Values training is aimed at overcoming.
There are very limited circumstances in which an employee may accept a gift or business courtesy.
Those situations are described in CPS-008 Gifts,
Hospitality, Other Business Courtesies and
RELEVANT POLICIES:
Sponsorships. Employees in any way involved in
procurement must be even more cautious, and
may only accept unsolicited promotional items
with a fair market value of less than $20.
P-cards may not be used to circumvent the
approved processes for procurement. While
convenient, and appropriate for some types of
purchasing, there are limitations on how and when
these cards may be used.
CPS-113 Acquisition of Goods and Services
We are told that this is a small site. Leaders responsible
for small and remote sites should take extra measures
to ensure that policies are well understood and
followed, and to review the local operating practices.
CPS-716 Compliance with the Anti-Kickback
Act of 1986
CPS-718 Disclosures to the U.S. Government
CPS-730 Compliance with Anti-Corruption
Laws
CRX-014 Individual Conflict of Interest
CRX-156 Purchasing Cards
19
WRAPPING UP - YOUR CONCLUDING MESSAGE
• Thank participants.
• Remind employees to go online to acknowledge completion of the training. (Or make
sure all participants have signed the
participation and acknowledgement sheet if online form is not available.)
• Inform employees that their feedback is important and ask that they complete the
feedback survey for participants that is available online.
– Inside the firewall, go to http://ethics.corp.lmco.com/ethics/awareness_training.cfm.
Click on the “Participant Survey” link.
– Outside the firewall, go to http://www.lockheedmartin.com/us/who-we-are/
ethics/training.html
Click on the “Participant Survey” link.
– Explain that some participants and session leaders will receive an e-mail
with a survey request and encourage employees to participate if asked.
• Provide your concluding message.
SAMPLE CONCLUDING MESSAGE
Thank you for your participation. I want to encourage you all to continue to talk and think
about the importance of taking action and voicing our values. This should not be a once-ayear dialogue. Also, I want to emphasize that as Lockheed Martin employees, we are all
encouraged to seek advice, express concerns, or report violations to the person with whom
we are most comfortable; your manager, the local Ethics Officer, Human Resources, Audit,
the Legal Department, EESH, or the Ethics Office.
Our local Ethics Officer is
Name: [INFORMATION AVAILABLE IN WHITE PAGES OR LMPEOPLE]
Phone: [INFORMATION AVAILABLE IN WHITE PAGES OR LMPEOPLE]
One last note – your feedback on this training program is extremely important. The feedback
survey is online and is part of the online training acknowledgement process at the Corporate
Ethics & Business Conduct website; go to the Corporate Ethics Awareness Training
Resources page at http://ethics.corp.lmco.com/ethics/awareness_training.cfm or
http://www.lockheedmartin.com/us/who-we-are/ethics/training.html.
Please participate if you receive an e-mail with a survey request.
Thank you for participating in today’s program.
20
FACILITATION DO’S AND DON’TS
FACILITATION DO’S
FACILITATION DON’TS
Do send out a meeting notice to all
participants well in advance of the
scheduled session. Include labor
charging direction.
Don’t wait until the last minute
to schedule your session.
Do take the time to review the training
materials, understand the Voicing Our
Values Techniques, and select cases that
are most relevant for your group. Your
Ethics Officer can help you with this.
Don’t wait until you’re in the room to
figure out how to facilitate the training or
use the audio visual equipment.
Do know the name and phone
number of your Ethics Officer.
Don’t forget to encourage employees to
contact their Ethics Officer at any time,
even for advice.
Do use online resources if available.
Don’t overlook the use of online training
in lieu of the DVD.
Do test the DVD in the player/computer you
will use in the session before the meeting
date. 1) Insert the DVD, 2) Press Windows
key and E key, 3) Right click on DVD, 4) Click
on Play.
Don’t wait until the day of your session
to test the DVD in the machine if you use
this option.
Do consider virtual training if your team is
widely distributed (if needed, seek help
from your IT Services).
Don’t forget to involve employees
participating via phone.
Do select a variety of cases, including
those that may be the most challenging or
uncomfortable to discuss.
Don’t select only cases with which you’re
comfortable – you might miss out on
some of the most valuable learning
opportunities.
Do take the initiative to get everyone
involved in the activity and keep the
conversation flowing around the room.
Don’t let people “sit out” the session
without participating, or allow one or two
people to dominate the entire discussion.
NOTE: This page is available
online in printable format.
Internal: http://ethics.corp.lmco.com/ethics/awareness_training.cfm
External: http://www.lockheedmartin.com/us/who-we-are/ethics/training.html
21
PARTICIPATION AND ACKNOWLEDGEMENT
All employees are required to record his or her participation in a training session.
Online: Most business units use the Online Participation and Acknowledgement feature. Visit
either the internal or external LMPeople website and click on “MyLearning” and then on the
“Learning Plan” link. Click on “2016 Ethics Awareness Training” and scroll to the “Self Completion”
section and click on “Take Credit for this Course.” Enter the date you completed your training
and click “Take Credit.”
Manual: For sites not using this online feature, a hard copy of the participation and
acknowledgement form is included in this year’s materials. When the hard copy form is to
be used, the leader of the session should make a sufficient number of copies for all
participants (one form can be used for up to 20 participants). Signed forms are to be
returned to the Ethics Office.
TRAINING EVALUATION FORM
Your feedback is important and we encourage all participants and facilitators to complete a
feedback survey. Inside the firewall, visit http://ethics.corp.lmco.com/ethics/awareness_
training.cfm and click on the appropriate “Survey” link. Outside the firewall, go to
http://www.lockheedmartin.com/us/who-we-are/ethics/training.html and click on the
appropriate “Survey” link.
22
PARTICIPATION AND ACKNOWLEDGEMENT FORM
Note: Use of a hard-copy version of this form may not be required if your business unit
tracks training online.
2016 Ethics Awareness Training
LM Company: ___________________________ Training Leader: _________________________
Facility: ____________________________ Employee Group: ________________________
Session Location: ____________________________ Date: ________________________________
Name
Signature
Employee ID
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Return signed forms to your Ethics Office.
23
QUICK-START GUIDE
Note: This guide is not meant to replace the more detailed instructions in Leader’s Guide.
Before the Session
8 Make sure room is ready and all equipment works.
8 Using Online Resources;
• Internal: http://ethics.corp.lmco.com/ethics/awareness_training.cfm.
• External: http://www.lockheedmartin.com/us/who-we-are/ethics/training.html.
8 Using DVD;
• Load Disk.
• Press Windows key + E key; or click on Start, click on Computer.
• When Computer screen appears, right click on DVD.
• Click on Play.
• Call IT Service Desk at 800-435-7063 if assistance is needed.
8 Select 3-4 appropriate cases. Get familiar with cases by watching video or reading summaries in
Leader’s Guide.
8 Determine if your business unit has Online Acknowledgement option. (If online is not used,
photocopy the participation form on page 23.)
Getting Started
8 Explain using online acknowledgement or have participants sign the printed participation form.
8 Give leader’s introduction and explain how activity works. (Instructions are also in the
introductory video.) Click on “Introduction” to begin the video.
8 Play Introduction video. Use “subtitles” for hearing-impaired participants.
Case Discussion
Select case, read case summary aloud and play video until it stops at Discussion screen.
Discuss case and answer Discussion Questions on screen.
Continue video to end.
Conclude case by reading from Leader’s Guide any perspectives not previously covered. Repeat process for each case. (Do as many cases as can be covered in one hour).
Wrapping Up
8 Thank participants.
8 Remind employees to go online to acknowledge training.
8 Remind employees to provide feedback using the online evaluation form at “Participant Survey.”
8 Read concluding message.
8 Use the online “Facilitator Survey” to provide your feedback.
24
Timeline for One-Hour Session
Welcome (Video runs 4 Minutes)........6 Minutes
Case View/Discuss............................... 16 Minutes
Wrap Up............................................... 6 Minutes
© 2016 LOCKHEED MARTIN CORPORATION

2016 Leader`s Guide (English)

Transcription

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