Lockheed Martin Corporation filed a revised policy on hiring foreign business consultants with the US Securities and Exchange Commission in February

Lockheed Martin filed a revised policy on hiring foreign business consultants with the US SEC | Norton Rose Fulbright

March 01, 1999 | By Keith Martin in Washington, DC

Lockheed was enjoined in 1976 from violating the Foreign Corrupt Practices Act.  The filing makes interesting reading for anyone wondering what the US government views as good practices when hiring foreign agents.

For example, Lockheed requires all foreign consultants to sign a written agreement promising to comply with US law on corrupt practices and spelling out what conduct is prohibited.  It does not hire anyone holding a government position, any officer of a foreign political party or any candidate for political office.  It does not hire persons who are linked to a potential customer unless this is allowed by local law and the CEO of the customer consents to the arrangement in writing.  However, it does let its foreign agents pay for meals for foreign officials.

US law makes it a crime for a US national or company to give anything of value to a foreign government official in an effort to win or retain business.

Congress broadened the statute last fall also to outlaw actions “to secure any improper advantage.” It also added employees of international public organizations, like the Asian Development Bank or International Finance Corporation, to the list of persons to whom things of value cannot be given.

Keith Martin