Adding Engagement to Your Code of Conduct

November 7, 2014

Tara Mancinelli & Lynn Hamilton – Lockheed MartinElaine Ott – NYSE Governance Services

©2014 Lockheed Martin Corporation

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› 200+ year history of governance leadership

› 16+ years in Compliance & Ethics space

› 4,600 Codes/policies reviewed

› 225+ Codes of Conduct written

› Thought leadership/research

About NYSE Governance Services

Code Update Project Goals• Reflect Changes in Law, Regulation and Policy

• Redesign for Engagement– Same Key Messages Less Words

– Link to Supplementary Resources

• Explain “Why”– Less Legalese

– Code is a Resource, not Repeat of Policy

• eBook Delivery for Majority– PDF and Hard Copy Versions Available

Current, Digital, and Interactive

Major Change Takes Time

Getting Buy In from Stakeholders Early OnGetting Buy In from Stakeholders Early OnGetting Buy In from Stakeholders Early On

OLDP Benchmarking

February 2013

Team Kickoff

July 2013

Final Product

June 2014

The Team• Ethics Core team

• Graphics/Technical team

• Employee Focus groups

• Security Engineering

• Human Factors Engineering

• Command Media (policies)

• Human Resources

• Legal

• EEO

• Contracts

• Privacy

• Learning & Development

• Information Security

• Safety

• International Ethics

• Security

• Sustainability

• Washington Operations

• Labor Relations

• Several employees who helped with proofing

Code Creation Roadmap

Project Initiation1 Week – 6 Months

Code Text Authoring4 Months – 1 Year (+)

› Establish Code communication style goals

› Create Code outline› Draft Code text› Host review sessions

throughout› Host focus groups (if

desired)

Code Design & LayoutAdditional 6 Weeks – 4 Months following text completion

› Define Creative vision› Establish Code presentation

composition› Pair sample with Code draft

text for review team› Layout text following Code

completion› Launch

› Assemble Code team› Host project launch meeting› Define end-user needs and

experience goals› Perform data analysis Current code review Peer benchmarking Policy content and gap

evaluation

Code Team Makeup

Lean Approach

› Compliance Project oversight

Primary drafter or primary reviewer

› Legal Subject matter expert review

› Human Resources Subject matter expert review

Communications and launch assistance

› Communications Content review for readability, tone and organizational “voice”

Design and Layout lead or reviewer

Code Team Makeup

Robust Team Approach

› Project Leadership Compliance Lead

Project Manager

› Subject Matter Experts Compliance (Domestic and

International)

Corporate Social/Sustainability Responsibility

Finance

Human Resources

Information Security

Internal Audit

Labor Relations

Legal

- Risk area specific expertise

Procurement

Risk Management

Safety

Technology

› Additional Content Review Communications/Marketing

Department/Division Managers

Employee Focus Groups

Third Party Assistance (Consultative and/or Outside Counsel)

Key Content Changes

• Significant New Content– Sustainability

– Security

– Retaliation: Definition and New Whistleblower Protection Law

– Drug Free Workplace: Marijuana

– Labor: Right of Free Association, Wage/Hour Laws and Benefits

– Prohibition on Trafficking in Persons

• Added “Interactive” Supplemental Content– Policies can be updated in both internal and external eBook

– Supplemental material can be kept fresh/current

Code Review and Updating

Launch New Code

One Year Later

Review content for policy, procedure and regulatory

updates

Update as needed (minor)

Two Years Later

Review updated best practices to determine if edit or rewrite is

needed. If only an edit is needed, update content as appropriate,

include new comprehension aids and design.

Three Years Later

Launch refreshed Code with updated training and related communication

materials

Code of Conduct eBookwww.lockheedmartin.com/us/who-we-are/ethics/code-of-ethics.html

Major Milestones

Milestone Date

Kickoff 7/16/2013

Face to Face Meeting 11/12-13/2013

Coding 11/18/2013-2/28/2014

Test Readiness Review 3/26/2014

Test/Corrections 4/4-6/23/2014

Operational Readiness Review (ORR) 6/24/2014

Ethics Committee Approval 6/25/2014

Course Code in Catalog 6/25/2014

Board of Directors Approves Resolution 6/26/2014

Production Deployment – Internal/External 6/26/2014

Initial LM News Communications 6/27/2014

Course code shows in Learning Plan 6/30/2014

UAT and Performance Test Results

UAT

• 15 functional test cases

• Cumulative Discrepancies:– 333 Functional Discrepancy Reports

– 8 high, 301 medium, 11 low

– 190 Technical Errors

– 143 Text/Language corrections

Performance

• Load testing was performed with concurrent user base of 1500 users

Devices/Browsers

• Android phone

• Chrome

• Firefox

• IE10

• IE8

• iPad Company

• iPad mini GOOD

• iPad mini Personal

• iPad Personal

• Safari Personal

• Samsung tablet

• iPad through LM Passage

• iPod Touch

• Macbook Safari

• iPhone Company Safari

• iPhone Personal

Mobile View

• Testing Results changed roll-out plan

• Mobile view worked, but…– Not ideal for certification process mainly due to font size

– Works to certify through “deep link” to MyLearning but clunky

• Intended as a reference tool after certification

NYSE GS – Key Issues to Consider

› Which parties need to approve the updated Code (including direction, content and design?) Individual Stakeholder(s)

Compliance and Ethics Committee

Works Councils

Board of Directors (or BOD committee)

› Does the content in the updated Code text align with published policies and procedures?

› If minor changes are needed, do you have authority to update as needed without BOD approval? Policy name updates

Contact information updates

› How are stakeholders going to utilize the Code and related documents? Offline employees

Translations

Employee populations that may benefit from a “pocket guide”

Internal or External?

Internal

› Drafting internally› Lead and manage reviews› Lead and negotiate discussions on best

practices and content decisions› Streamline content written by numerous

SMEs to harmonize language and flow› Utilize internal resources for design and

layout› Create communication materials and

manage print production

External

› Drafting externally› Lead and manage reviews (internal)› Third party can assist internal

discussions on best practices and content decisions

› Leverage external expertise to streamline content for consistent voice and flow

› External design expert creating design and layout

› Communication materials and launch plan created externally for internal action

Translations• Arabic

• Dutch

• Chinese (Simplified)

• Chinese (Traditional)

• French

• German

• Hebrew

• Spanish

• Indonesian

• Japanese

• Korean

• Malay

• Portuguese

• Romanian

• Turkish

NYSE GS – Translations Benchmarking

Communications

• LM News announcement – 6/27

• Leaderlink – 7/8

• HRlink – 7/9

• ePostcard – 7/15-17

• Leader Toolkit – 7/29

• Follow-up ePostcard – 9/7

Rolling Out the New Code

Follow-on Items

Action Item #

Description ECD

1 Website metrics Monthly

2Create web clip for mobile devices

7/31

3 Survey Plan 7/11

4 Gifts Decision Tree (TBD) TBD

5 Print versions expected to be mailed 7/14

6 Post audio version 7/10

7 Post translated versions 7/30

8 Update policy links and add award info 10/31

9 Update template to include feedback button 10/31

Employee Feedback

“Well structured with each success-oriented objective and "Why we do it" discussion.”

“…I felt the material was intended for a professional "adult" audience.

“Very refreshing.”