Ethics & Compliance
At Raytheon Technologies, we are inspired and guided by our values: Trust, Respect, Accountability, Collaboration and Innovation. By relying on these values, we make a deliberate choice to focus on what is important to us. Our values should always inform our thoughts, words and actions. In that way, they help us create the future we want to experience — and the culture we need to get us there. By committing to a set of shared values, we also promote a more cohesive and supporting organization.
Our Code of Conduct
Raytheon Technologies Code of Conduct
Ethics resources and initiatives
Raytheon Technologies strives to earn the respect of our customers and shareholders based on the quality of our products and services as well as how we do business. We face a wide range of business and compliance risks, including those associated with corruption.
It is the policy of Raytheon Technologies to ensure compliance by its leaders, employees and covered persons, including representatives, consultants and other contracted third parties, with the Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act and all other relevant anti-corruption laws. Raytheon Technologies has a zero-tolerance policy for corrupt behavior.
Our commitment to anti-corruption includes the following:
- Winning Business Solely on the Merits: Raytheon Technologies conducts all of its business solely on the merits. We will not bribe anyone to obtain or retain business or secure any other advantage, nor allow anyone to do so for our benefit, in any market — public or private — anywhere. As a general rule, employees cannot seek or accept any payments from anyone doing business with or seeking to do business with Raytheon Technologies.
- Books and Records: Raytheon Technologies maintains fully accurate and transparent books and records. All assets, liabilities and transactions must be promptly and accurately reflected, and no Raytheon Technologies employee must ever make a deliberately false or misleading entry — no matter how small or immaterial — in our books and records. Raytheon Technologies maintains a robust audit program to ensure that all of our businesses are upholding these non-negotiable requirements.
- Third-Party Intermediaries: Our third-party intermediaries are subject to similar rules and will be selected after a robust due diligence process aimed at confirming their good business practices. Once on board, they will be trained and monitored. Intermediaries engaged in advocacy and sales on our behalf have limited-term contracts, which cannot be renewed without a refreshed assessment.
- Support of Industry Best Practices: Raytheon Technologies has a demonstrated commitment to various global anti-corruption initiatives, including the Global Principles of Business Ethics for the Aerospace and Defense Industry, the International Forum on Business Ethical Conduct (IFBEC) and the Defense Industry Initiative (DII). These initiatives and industry organizations focus on sharing best practices and enhancing ethics and business conduct among defense and aerospace companies.
- Training: Every Raytheon Technologies employee receives annual ethics and compliance training. Anti-corruption compliance is shared through written communication, video-based training, live training, and targeted online and in person training for high-risk personnel with messages encouraging employees to identify issues, ask questions and raise concerns without the fear of retaliation, emphasizing the importance of training, and providing guidance on areas of particular concern to help all employees understand key anti-corruption responsibilities and their personal role in guaranteeing compliance with anti-corruption laws.
- Assessment: Raytheon Technologies regularly assesses and reviews the implementation and sustainment of its anti-corruption controls and continually reviews and assesses our anti-corruption policies, training and practices.
- Reporting and Investigations: In conducting investigations, Raytheon Technologies is objective, thorough and balanced. In managing risk, Raytheon Technologies is conservative and data-driven. We communicate lessons learned from Investigations and apply robust processes and practices for continuous improvement and risk reduction.
In standing by our principles and values, we fight corruption and support the global development of fair markets. Our success relies on abiding by our core principles — regardless of what might be seen as customary or acceptable in a given market.
Raytheon Technologies promotes behaviors that build trust, respect and accountability. When employees, contractors and partners observe or suspect something that conflicts with our values, we encourage them to speak up and report it. Those who speak up to protect our company will be protected in return. Our Code of Conduct and policies reinforce our long-standing commitment to a safe reporting environment that is free of fear, bullying and other negative consequences. Raytheon Technologies has zero tolerance for retaliation and activities that impact good-faith reporting — and anyone engaging in retaliatory behavior is subject to disciplinary action, up to possible termination. Employees should feel confident asking questions or raising concerns directly with their supervisor, a human resources manager, an Ethics & Compliance Officer or the Office of General Counsel.
How to Ask a Question or Raise a Concern
The Ombudsman Program: Now Available to all Raytheon Technologies Employees and External Parties
The Ombudsman Program allows employees and others to ask a question or raise concerns in complete confidence. For additional details on the Ombudsman Program or to speak to an Ombudsman, please visit https://ombudsman.confidential.rtx.com. To contact an Ombudsman by phone:
From within the United States, Canada and Puerto Rico, call 800-871-9065.
When calling from outside the United States, you must first dial the pertinent AT&T Direct access number which can be found at http://www.business.att.com/bt/access.jsp. Listen for a prompt (voice or tone), and then dial the toll-free number for an Ombudsman. Interpreters will be provided through the Ombudsman if English is not your preferred language.
All translators used by the Ombudsman program are retained to work for the Ombudsman and under contract are also obligated to protect confidentiality. Confidential Ombudsman information is secured and accessible only by Ombudsman personnel.
Note: Under French law the Ombudsman Program is limited to (a) accounting, financial, banking and auditing matters; (b) bribery and corruption matters; (c) anti-competitive matters; (d) harassment and discrimination; (e) health, hygiene and security in the workplace; (f) protection of the environment; and (g) internal processes and controls related to (a), (b), (c), (d), (e) and (f) above. For more information regarding the Ombudsman Program in France, please click here.
EthicsLine: Currently Available to Legacy Raytheon Company Employees and External Parties (additional anonymous reporting channels for all Raytheon Technologies employees will be announced in the coming months)
The Ethics Office has a toll-free EthicsLine at 800-423-0210, available for those wishing to raise a concern, seek advice or report alleged misconduct or violation of company policy, government law or regulation. Anonymous reports may be made through written communication or by calling the toll-free corporate EthicsLine, which does not have a caller identification feature, or through our web-based Ethics Check Line. Reports submitted to the Ethics Office will be investigated in the ordinary course by the company’s Ethics Office and, if substantiated, resolved through appropriate corrective action.
Additionally, you may contact the Ethics Office at [email protected].
Accounting, Internal Controls or Auditing Matters
If you wish to raise questions or concerns about company accounting, internal accounting controls or auditing matters (confidentially or anonymously if preferred), you may do so through the Ombudsman Program as outlined above. Please check the appropriate box when submitting your inquiry. All such inquiries will be tracked and investigated and referred to the Board's Audit Committee, unless otherwise instructed by the Committee. You may also communicate to the Audit Committee (confidentially or anonymously if preferred) by writing to:
Raytheon Technologies Corporation Audit Committee
c/o Ethics and Business Conduct
Raytheon Technologies Corporation
870 Winter Street
Waltham, MA 02451-1449
Contact the Board of Directors
If you have a comment or concern which is not more appropriately addressed by the Audit Committee or management of the company, you may communicate with our Board through our Lead Director. Such communications relating to issues within the purview of the Board will be referred to the Lead Director and will be tracked by the Corporate Secretary’s office. You may convey your comment or concern electronically or by writing to:
Raytheon Technologies Corporation Board of Directors
c/o Corporate Secretary
Raytheon Technologies Corporation
870 Winter Street
Waltham, MA 02451-1449
If you provide us with contact information, you will receive written acknowledgement of your communication. You can communicate anonymously or confidentially, if you wish.
At Raytheon Technologies, we aim to be world-class in everything we do — including our compliance with U.S. and other national laws. Every employee is responsible for ensuring that our business is conducted in compliance with these laws and with our Code of Conduct. Our Enterprise Risk Management assessments measure compliance risks, deploy risk mitigation plans and track implementation for five key areas:
Antitrust
Raytheon Technologies has an aggressive antitrust compliance program that promotes and protects competition. We prohibit actions and behavior that support a company’s monopoly or unreasonably restrains competition.
Corruption
Raytheon Technologies does not offer or accept bribes, kickbacks, facilitating payments or anything of value that could improperly influence — or appear to influence — a business decision. Doing so is in direct conflict with our commitment to fair competition. We compete on the merits of our products, services and people each and every day.
Data Privacy and Security
Raytheon Technologies is committed to protecting the personal and proprietary information of Its customers, employees, contractors and business partners.
Government Contracts
Raytheon Technologies focuses on competing fairly, delivering quality products and services, adhering to government accounting and pricing requirements, and the timely and accurate submission of data to the government.
Global Trade Compliance (GTC)
As a leading U.S. importer and supplier of controlled products and technologies to the U.S. Department of Defense, other national defense establishments, and various domestic and international customers, Raytheon Technologies is committed to conducting business in full compliance with all U.S. and other national laws and regulations governing exports, imports, anti-boycott, economic sanctions and embargoes.
Raytheon Technologies strives to earn the respect of our customers and shareholders based on the quality of our products and services as well as how we do business. We face a wide range of business and compliance risks, including those associated with corruption.
It is the policy of Raytheon Technologies to ensure compliance by its leaders, employees and covered persons, including representatives, consultants and other contracted third parties, with the Foreign Corrupt Practices Act (FCPA), the U.K. Bribery Act and all other relevant anti-corruption laws. Raytheon Technologies has a zero-tolerance policy for corrupt behavior.
Our commitment to anti-corruption includes the following:
- Winning Business Solely on the Merits: Raytheon Technologies conducts all of its business solely on the merits. We will not bribe anyone to obtain or retain business or secure any other advantage, nor allow anyone to do so for our benefit, in any market — public or private — anywhere. As a general rule, employees cannot seek or accept any payments from anyone doing business with or seeking to do business with Raytheon Technologies.
- Books and Records: Raytheon Technologies maintains fully accurate and transparent books and records. All assets, liabilities and transactions must be promptly and accurately reflected, and no Raytheon Technologies employee must ever make a deliberately false or misleading entry — no matter how small or immaterial — in our books and records. Raytheon Technologies maintains a robust audit program to ensure that all of our businesses are upholding these non-negotiable requirements.
- Third-Party Intermediaries: Our third-party intermediaries are subject to similar rules and will be selected after a robust due diligence process aimed at confirming their good business practices. Once on board, they will be trained and monitored. Intermediaries engaged in advocacy and sales on our behalf have limited-term contracts, which cannot be renewed without a refreshed assessment.
- Support of Industry Best Practices: Raytheon Technologies has a demonstrated commitment to various global anti-corruption initiatives, including the Global Principles of Business Ethics for the Aerospace and Defense Industry, the International Forum on Business Ethical Conduct (IFBEC) and the Defense Industry Initiative (DII). These initiatives and industry organizations focus on sharing best practices and enhancing ethics and business conduct among defense and aerospace companies.
- Training: Every Raytheon Technologies employee receives annual ethics and compliance training. Anti-corruption compliance is shared through written communication, video-based training, live training, and targeted online and in person training for high-risk personnel with messages encouraging employees to identify issues, ask questions and raise concerns without the fear of retaliation, emphasizing the importance of training, and providing guidance on areas of particular concern to help all employees understand key anti-corruption responsibilities and their personal role in guaranteeing compliance with anti-corruption laws.
- Assessment: Raytheon Technologies regularly assesses and reviews the implementation and sustainment of its anti-corruption controls and continually reviews and assesses our anti-corruption policies, training and practices.
- Reporting and Investigations: In conducting investigations, Raytheon Technologies is objective, thorough and balanced. In managing risk, Raytheon Technologies is conservative and data-driven. We communicate lessons learned from Investigations and apply robust processes and practices for continuous improvement and risk reduction.
In standing by our principles and values, we fight corruption and support the global development of fair markets. Our success relies on abiding by our core principles — regardless of what might be seen as customary or acceptable in a given market.