Ethics and Compliance

At Elbit America, our risk management procedures include various policies and procedures that identify, monitor and mitigate risks throughout the organization. Our Risk Issue and Opportunity Management manual provides details needed to implement Program Risk, Issue and Opportunity (RIO) Management using ARM, a tool that identifies risks and opportunities for all projects. We engage in responsible and compliant trading practices by implementing a risk framework and internal controls that demand accountability, transparency and auditability.

We do our due diligence in preventing corruption and bribery within our business. We conduct an annual US Foreign Corrupt Practices Act (FCPA)/Anti-Bribery training with relevant employees and contractors selected for their function’s likelihood of exposure to transactions that could involve corruption. Our anti-corruption and anti-bribery practices are guided by our Prohibition of Fraud Bribery and Corruption Policy. The purpose of this Policy is to assist employees, officers, directors, agents and representatives of the company and our business partners, in identifying fraud, bribery and corruption related issues and in understanding and complying with applicable company standards. Elbit America complies with the FCPA as well as applicable international conventions including the Organization for Economic Co-operation and Development (OECD) Convention and the United Nations Convention Against Corruption.

To prevent corruption and bribery, Foreign Representatives are responsible for interacting with buyers in the foreign market. We hold our representatives to the same expectations as our domestic employees. Our business development team liaises with the representatives to ensure they comply with all of Elbit America’s polices. We have a detailed Foreign Rep Agreement required for all instances of foreign representatives’ partnerships that is updated every 2-3 years. Our representatives are run through a series of background checks prior to onboarding and are required to take annual anti-bribery training as part of their certification. Our Ethics and Compliance Department maintains oversight of representatives to prevent bribery and corruption.

Elbit America maintains a rigorous Anti-Harassment Policy that covers all employees and outlines escalation procedures for reports of misconduct. As part of our commitment to doing the right thing, we do not tolerate discrimination or harassment of any sort in the workplace. Elbit America requires that all employees be treated with dignity and respect and extends these requirements to suppliers, contractors and consultants. Accordingly, we will not tolerate instances involving threats of violence, corporal punishment or various forms of harassment whether based on gender, race, color, religion, ethnicity, age, sexual orientation, national origin, disability or any other legally protected characteristic.

Our Non-Retaliation and Whistleblower Policies are outlined in our Employee Handbook, Employee Code of Conduct, and Supplier Code of Conduct. We host Ethics Group town hall meetings to explain resources and how to reach out regarding ethics concerns. Our third-party helpline can be used by any employee or contractor and can be anonymous by request. Our Director of Ethics is informed whenever a case is initiated and determines the next steps to handle and violations. Our Board Ethics Committee is apprised of all ethics investigations and discusses ethics trends quarterly. The metrics from Ethics Helpline, including how many cases, duration and type, are tracked and reported an internal site. Elbit America has a non-retaliation clause in most procedures listed in the Code of Conduct.

Conducting our business ethically is one of Elbit America’s core values. As part of our ongoing Ethics and Compliance program, and consistent with applicable legal requirements, we are pleased to share our Code of Business Ethics and Conduct as approved by Elbit America’s Board of Directors. Because of the importance we place on conducting our activities in an ethical manner, our employees, officers and directors are committed to following the Code as well as our other ethics and compliance related procedures and policies. We also expect our supply chain to meet our ethical standards in all of their activities with us, as reflected in our Supplier Code of Conduct.

We are committed to respecting human rights and human dignity as outlined in our Human Rights Policy. We comply with all applicable laws pertaining to fair employment practices, as well as laws prohibiting forced and compulsory labor, child labor, employment discrimination and human trafficking. We strive to do business only with suppliers and business partners who share our commitment to the highest standards of ethical business conduct. We will not tolerate the abuse of human rights.

Trade Compliance, Ethics and Security training is mandatory and considered of the utmost importance for employees. Select contractors are required to take annual anti-bribery training and all Foreign Representatives are required to take annual anti-bribery training as part of the TRACE certification.