8-KOther EventsExhibits & Filings

LOCKHEED MARTIN CORP 8-K Report, Corporate Update (Feb 26, 2013)

Filed February 26, 2013For Securities:LMT

Summary

Lockheed Martin Corporation (LMT) filed a Form 8-K on February 26, 2013, to announce an amendment to its internal Corporate Policy Statement CPS-704, now being replaced by Cross Function Procedure CRX-011, concerning the acquisition of international consultant services. This filing is made on behalf of its former subsidiary, Lockheed Corporation, fulfilling a 1976 Consent Agreement with the SEC. The agreement requires LMT to provide advance notice to the SEC before any amendment to policies and procedures related to compliance with the Foreign Corrupt Practices Act (FCPA). While the amendment itself is described as routine and pertains to internal procedures, the significance for investors lies in the ongoing adherence to regulatory commitments. This filing demonstrates the company's continued diligence in maintaining compliance with FCPA-related policies, which is crucial for a global defense contractor like Lockheed Martin. Investors can view this as a positive indicator of corporate governance and risk management, ensuring the company operates within legal and ethical frameworks, particularly concerning international business dealings.

Key Highlights

  • 1Lockheed Martin is amending its internal policy (CPS-704) regarding the engagement of international consultants.
  • 2The updated procedure, CRX-011, replaces the previous policy statement.
  • 3This filing is a requirement stemming from a 1976 Consent Agreement with the SEC made by its former subsidiary, Lockheed Corporation.
  • 4The agreement mandates advance notification to the SEC for any amendments to policies and procedures related to Foreign Corrupt Practices Act (FCPA) compliance.
  • 5The amendment is described as routine and pertains to internal procedures.
  • 6The company is providing this update ten days prior to the proposed effectiveness of the amended policy.

Frequently Asked Questions

The primary purpose of this 8-K filing is to inform the SEC about an amendment to Lockheed Martin's internal corporate policy (CPS-704) concerning the use of international consultants. This update is being made on behalf of its former subsidiary to comply with a long-standing 1976 Consent Agreement.

No, the filing states that the amendment is routine and relates to updating internal procedures. It is being made to satisfy a pre-existing requirement under a 1976 Consent Agreement with the SEC related to Foreign Corrupt Practices Act (FCPA) compliance, rather than being a response to a new regulatory change or enforcement action.

The Foreign Corrupt Practices Act (FCPA) is a U.S. federal law that prohibits U.S. persons and entities from bribing foreign government officials to obtain or retain business. As a major global defense contractor, Lockheed Martin operates in many countries and engages in international business, making adherence to FCPA and related internal policies critically important for compliance and avoiding legal/reputational risks.

The 1976 Consent Agreement with the SEC, entered into by Lockheed Corporation (now part of Lockheed Martin), requires the company to notify the SEC at least ten days before any amendment to its policies and procedures concerning FCPA compliance. This filing is a direct fulfillment of that contractual obligation.