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The cornerstone to L-3 Communications operating philosophy is our integrity in how we conduct ourselves with our customers, co-workers, and competition. We believe firmly in "doing the right thing" at all times and have enthusiastically endorsed the many L-3 Communications initiatives on its Code of Ethics and Business Conduct.
These codes provide all of our employees with a framework on how we should conduct ourselves with our business partners and each other. We expect our leadership and front-line employees to adopt these principles in spirit and in action. With professional services being the core of our operation, our people are the lifeblood of our business. Ethical conduct by all employees is imperative if we are to maintain a reputation that supports our growth plans and helps us to achieve our financial success.
Statement of Policy
It is L-3 Communications' standard of conduct and express policy that all dealings with our customers, suppliers, competitors, and co-workers will be conducted with the highest level of ethical behavior and in complete compliance with the spirit and the letter of the applicable laws and regulations. Improper activities, or even the appearance of impropriety, could result in serious consequences to the company and to those involved in such activities.
No one shall, on behalf of L-3 Communications, engage in any conduct that violates any law or is otherwise inconsistent with the highest levels of honesty and integrity. L-3 Communications also expects you to deal fairly with our customers, suppliers, competitors, and co-workers. You should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair practice.
The environment in which L-3 Communications does business is governed by complex laws and regulations. This Code of Ethics and Business Conduct outlines key aspects of those laws and regulations, as well as associated L-3 Communications policy. Unless otherwise specified, the provisions of this Code apply to all employees, officers and members of the Board of Directors, as well as to consultants and others who act on behalf of L-3 Communications. If at any time you are in doubt about any aspect of your compliance responsibilities, you should contact your manager, supervisor, designated contact person or use other resources described later to address your concern. Individuals may require additional training in certain areas to ensure compliance.
The Code of Ethics and Business Conduct addresses a number of topics including:
- Reporting Environment
- Protection from Retaliation
- Compliance with Insider Trading Laws
- Implications of Violating the Policy
- Reporting Violations
You are required to report all violations and are encouraged to report suspected violations of this Code or applicable laws and regulations to your manager, supervisor or designated contact person; to anyone in your management organization; to the location's Ethics Officer; the Corporate Ethics Officer; or by using the HelpLine. L-3 Communications maintains a Corporate HelpLine that is answered by a firm hired by L-3 Communications to provide employees with a means to report violations or possible violations of this Code or of the laws and regulations governing L-3 Communications' business. Corporate HelpLine 800 324-6653. If you prefer, you may report such information to the L-3 Communications' Corporate Ethics Officer by mail at the following address: 600 Third Avenue New York, NY 10016, or by email at ethics@l-3com.com. All reports and complaints concerning questionable accounting, internal accounting controls or auditing matters, including those regarding circumvention or attempted circumvention of internal accounting controls or that otherwise would constitute a violation of L-3 Communications' accounting policies, may be reported to the Corporate Ethics Officer, the Corporate HelpLine or to the Board of Directors' Audit Committee. Any reports or complaints sent to the Audit Committee should be sent to: L-3 Communications Attention: Audit Committee 600 Third Avenue New York, NY 10016
The Code also includes commentary on the following 3 broad areas:
Corporate Responsibility which details:
- Work Environment
- Training
- Reporting Environment
- Protection from Retaliation
Your Responsibility which details:
- Corporate Policies
- Seeking Guidance
- Reporting Violations
- Avoidance of Conflicts of Interest
- Company Property
- Confidentiality
- Compliance with Insider Trading Laws
- Reporting of Labor Charges
- Accuracy of Documentation
- Responsibility in Reporting
- Producing Quality Products
- Entertainment, Gifts and Gratuities
- Special Requirements in Dealings with Government Representatives
- Following Security Guidelines
- Marketing Activities
- Procurement Integrity
Marketing and Contracting with the Federal Government which details:
- Truth in Negotiations Act (TINA)
- The Anti-Kickback Act
- The False Statements Act
- The False Claims Act
- Use of Suspended/Debarred Individuals and/or Contractors
For the complete version of the Code of Ethics and Business Conduct that includes the details of those items bulleted above, please click on the following link. ( http://www.l-3com.com/supportfiles/ethics.pdf )
Coleman Aerospace
Jeff Strasser
Vice President
Air Launched Programs
Ethics Officer
jeff.strasser@l-3com.com
Ethics Hotline: 407-370-0625
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