New Lockheed Policy to Prevent Questionable Foreign Marketing Practices

PSAD-77-92: Published: Mar 16, 1977. Publicly Released: Mar 16, 1977.

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Lockheed Aircraft Corporation has taken several actions to remedy earlier management problems of money flowing to unauthorized individuals or organizations in connection with its foreign marketing activities.

The new Lockheed policy and related procedures contain suitable control features over the company's own actions in foreign market dealings. However, there are certain external factors present in the foreign market which are beyond Lockheed's control, and, as such, the Lockheed actions alone will not necessarily preclude the possibility of money flowing to unauthorized foreign governmental, military, or customer officials. Lockheed established a Consultant Review Committee to review the qualifications of international consultants, which are individuals or firms engaged to provide marketing intelligence and marketing related services in foreign countries. The new policy sets out certain qualifications and limitations related to dealings with international consultants. The procedures have control features which provide for a separation of responsibilities and duties between officials proposing the use of consultants and officials approving the selections and payments. Payments to international consultants by all Lockheed divisions and subsidiaries require centralized approval. Lockheed has for the most part followed its new policy and procedures.

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