Ethics and Compliance
Elbit America is dedicated to conducting business ethically. We focus on compliance and avoidance of conflicts of interest. Our vetting and regulatory oversight process ensures that the end-users of our products are Democratic, sovereign countries that have treaty alliances with the United States (US) Our program is guided by the Code of Conduct and Business Ethics. Trade Compliance, Ethics and Security training is mandatory and considered of the utmost importance for employees.
Key Highlights
Business Ethics
We remain committed to our well-developed ethics program and have expanded our ethics office presence in all facilities. At each of our sites, we celebrate Compliance Week every November which focuses on engaging and educating employees on all elements of compliance. Site liaisons serve as extensions of the ethics and compliance program across all geographies and functions in the organization above a certain headcount, where we do not otherwise have ethics and compliance personnel. Our Board Ethics Committee discusses ethics, compliance, and Ethics Helpline trends quarterly and regularly provide guidance on ethics cases. We have established an Ethics Award, the Real Madore Award, to honor an employee that has been recognized as demonstrating above and beyond commitment to ethical business practices.
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.
Cyber Security
Our people are dedicated to protecting and constantly improving the company’s cyber security program. The cyber security policies and procedures put in place provide a compliance framework to protect the company. We understand that investing in cyber security is not a cost, but critical to our growth. Our cyber experts brief the Board every quarter on cyber security and ransomware from a Governance, Risk and Compliance perspective using a data dashboard. Currently, we maintain 15 policies tied to National Institute of Standards and Technology (NIST) controls for cyber security and information technology. We have also integrated ISO 27001 controls into our security plan which consisted of 3 enclaves: commercial, federal and development.
The quality and integrity of our cybersecurity governance processes are imperative to the success of the company. Cybersecurity governance provides the framework for defining and managing all other cybersecurity policies, plans and procedures. Our Information Governance Board assists Elbit America in developing and implementing a framework to ensure information is readily available to those that need it while still meeting existing compliance requirements. Their mission is to improve the creation, accuracy, availability and use of Elbit America’s information. Additionally, our Cybersecurity Governance Policy applies to all business processes and data, information systems and components, personnel and physical areas of Elbit America. The policy applies to all employees, contractors and other individuals with authorized access to Elbit America’s information system.
Our Technology Control Plan (TCP) delineates Elbit America’s policies and internal controls to ensure that no unauthorized transfer of Classified Information takes place and that any transfer is limited to what is authorized by license or other approval from the US government. It serves as a guidebook for providing protection for internationally shared information and products and is required by NISPOM (NISP).
The IT Disaster Recovery plan aims to protect corporate resources and employees, to safeguard the company’s vital records of which the data center has become the custodian, and to guarantee the continued availability of essential IT services. The Plan outlines the actions to implement a sufficient set of procedures for responding to a disaster that involves our data centers and their services.
The quality and integrity of Elbit America’s risk assessments are used to determine the likelihood and magnitude of harm that affect an information system and ultimately, the company itself in the event of a security breach. By determining the amount of risk that exists, we are in a better position to determine how much of that risk should be mitigated and what controls should be used to achieve that mitigation. Without risk assessments, the potential exists that the organization can leverage security controls to protect information systems. Every quarter, our cyber security experts brief the Board on how we are doing in terms of Governance, Risk, and Compliance (GRC) and cyber security.
We use a third-party software to conduct an annual Security Awareness Training, which is deployed companywide each October during National Security Awareness Month. The training is mandatory for all employees and helps them learn to identify security threats. Additional mandatory cyber security training is also given annually to the “Cleared” Employees. We test our employees using simulated phishing campaigns. These campaigns are delivered corporatewide and run for a week at a time.
Hazardous Waste Management
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Awards and Recognition
Elbit America was named one of the 2024 World’s Most Ethical Companies by the Ethisphere Institute. The Ethisphere Institute highlighted our collective efforts supporting “integrity, sustainability, governance, and community,” marking the sixth time we have earned this distinction, having also been named a World’s Most Ethical Company in 2014, 2015, 2018, 2022 & 2023.
“This recognition underscores our employees’ continuous commitment to operate with integrity and do what’s right for our customers.”
- Luke Savoie, President and CEO Elbit America
Corporate Governance
In every area of our business, we prioritize acting with transparency and accountability. Strong corporate governance is a foundational pillar to these values and to how we operate. Our Board and management team are committed to effectively mitigating corporate risk to create sustainable long-term value.
Special Security Agreement
Elbit America has operated under a US Department of Defense Special Security Agreement (SSA) for over 30 years. Elbit America’s SSA mitigates the potential impact of Foreign Ownership, Control, or Influence (FOCI), and allows Elbit America and its subsidiaries to bid on classified contracts and continue to grow our portfolio. There is a robust mitigation structure including:
- No parental governance clauses in SSA
- Separate physical and network infrastructure
- Robust visitation and communications controls and procedures
- All Elbit America senior officers are security-cleared US citizens