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J u n e 2 0 1 5 • n a t i o n a l D e f e n s e 9 Ethics Corner By Sandra Evers-\fanly Anyone involved in ethics and compliance within the defense ind\fstry sho\fld know that to be tr\fly effective\b a corporate ethics program req\fires more than a “check the box” approach. The challenge is to develop a vibrant program that resonates with employees in a manner that ca\fses them to take tr\fe ownership of ethics within their area of responsibility. Over the years we\b along with peer companies\b and often in collaboration with the National Defense Ind\fstrial Association and the Defense Ind\fstry Initiative (DII)\b have shared best practices within ind\fstry in the interests of men and women in \fniform. Northrop Gr\fmman has always endeavored to meet the req\firements of applicable laws\b b\ft it has resolved to take the c\flt\fre beyond that by making its ethics program more rob\fst\b proactive and holistic. In 2007\b it decided to establish a direct reporting relationship to both the CEO and the board of directors. This led to the formation of an office of corporate responsibility\b which not only oversees the traditional ethics and compliance f\fnctions\b b\ft also diversity and incl\fsion\b Eq\fal Employment Opport\fnity compliance\b work- place accommodations\b an employee assistance program\b corporate citizenship and the Northrop Gr\fmman Fo\fndation. This new str\fct\fre helps ens\fre that the heart of o\fr program is abo\ft establishing the right c\flt\fre and good corporate citizenship. The right c\flt\fre not only fosters ethical behavior\b it also extends beyond traditional ethics and compli- ance. This more holistic integration has greatly contrib\fted to the contin\fed s\fccess of the c\frrent program. Openly sharing best practices among all defense contractors has allowed the company to discover and apply new ways to strengthen programs and otherwise achieve effectiveness. Two key takeaways from o\fr membership in DII are the impor- tance of val\fes-based ethics programs and the concept of “tone at the top.” The leadership team strives to p\ft ethics at the forefront whether speaking to employees\b ind\fstry and govern- ment leaders\b or making decisions abo\ft what is best for the company. As important as “tone at the top” is critically important\b b\ft so too is the challenge of reaching o\ft to all employees\b to incl\fde knowing and \fnderstanding the “mood in the middle” and the “b\fzz at the bottom.” The ethics program is greatly enhanced by the b\fsiness cond\fct officer network of 120 dedicated employees\b who closely monitor the “middle mood” and “bottom b\fzz.” We also maintain an OpenLine system administered by a third party service provider to facilitate 24/7 reporting\b thereby empowering all employees\b incl\fding those who otherwise may not feel comfortable reporting potential ethics violations. We also endeavor to invigorate and thereby maintain a vibrant ethical c\flt\fre by periodically rebranding the ethics program to keep it fresh in the minds of the employees. In 2015\b Northrop Gr\fmman \fnveiled “Ethics: Own it\b Live it\b Lead it.” How does it work?

Own it: We own ethical c\flt\fre not only by knowing the r\fles\b reg\flations\b policies and proced\fres to perform o\fr jobs\b b\ft also by establishing the right environment and creating an organization of tr\fst. Employees\b at all levels m\fst actively seek to own and establish an ethical c\flt\fre. Company val\fes pro- vide the fo\fndation for everyone to take that ownership.

Live it: We endeavor to live high ethical standards in accor- dance with the val\fes the company holds dearly\b to incl\fde standards of b\fsiness cond\fct and other established r\fles. Each of \fs also seeks to make s\fre the Northrop Gr\fmman val\fes are central to every decision and action we take. The ethics program is there to spell o\ft and help \fs better \fnderstand what that means or looks like\b and otherwise provide g\fidance for those who are \fns\fre abo\ft how to act.

Lead it: Leading ethical behavior m\fst take place at every level. We enco\frage open\b honest comm\fnica- tion and an environment where we can challenge one another\b and contrib\fte to an incl\fsive c\fl- t\fre where all q\festions\b ideas\b and concerns of any nat\fre are openly shared and welcome. Nor is a vice president or manager title in front of a name req\fired in order for an employ- ee to be an effective leader. Everyone sho\fld be enco\fraged to “lead from where yo\f are.” An ethics award\b “The High Road\b” established in 2012\b spotlights employees who show ethical leadership from wherever they sit in the company.

Any ethics program that s\fcceeds in evolving in all the right ways beyond the basic minim\fm req\firements m\fst also be open to change\b whether that be thro\fgh new campaigns\b slo- gans\b logos and themes or thro\fgh organizational re-alignments.

The company has a “best in class” ethics program\b b\ft that means little if employees aren’t well-served by the c\flt\fre\b and by leaders who c\fltivate tr\fst\b initiatives\b training\b b\fsiness cond\fct officers and fo\fndational policies. By doing what is best for the workforce\b and letting employees know they are respected\b val\fed and “heard\b” when it comes to establishing a c\flt\fre of ethical best practices\b they become a force m\flti- plier. They m\fst always feel free to challenge others whenever they have q\festions\b to feel incl\fded in their organizations and know they can bring their a\fthentic selves to work each and every day. In order to see ethics and integrity thro\fgho\ft an organization\b it m\fst be owned\b lived and led by everyone. While Northrop Gr\fmman knows that maintaining constant vigilance is a m\fst\b it is very pro\fd every day to witness men and women owning\b living and leading the way in choosing what is right over what may sometimes appear to be more expedient. Sandra Evers-Manly serves as Northrop \frumman’s v\bce pres\bdent global corporate respons\bb\bl\bty and pres\bdent of the Northrop \frumman Foundat\bon. An Eth\bcal Culture: Own \bt, L\bve \bt, Lead \bt J u n e 2 0 1 5 • n a t i o n a l D e f e n s e 9 “Employees, at all levels must actively seek to ow\f a\fd establish a\f ethical cultu\be.” Copyright ofNational Defenseisthe property ofNational DefenseIndustrial Association and its content maynotbecopied oremailed tomultiple sitesorposted toalistserv without the copyright holder'sexpresswrittenpermission. However,usersmayprint, download, oremail articles forindividual use.