Copyright © 2015 Raytheon Company. All rights reserved. Customer Success Is Our Mission is a registered trademark of Raytheon Company. Fine Tuning Anti-Corruption Initiatives Brian Baldrate Senior Counsel, International and Washington Operations November 19, 2015

RAYTHEON MOST PRIVATE Page 2 Benchmarking Raytheon to DOJ / SEC’s “Hallmarks of Effective Compliance Programs”  In A Resource Guide to the U.S. Foreign Corrupt Practices Act, released November 2012, DOJ / SEC have listed “Hallmarks of Effective Compliance Programs” which they believe should be included in an effective FCPA compliance program  Team compared Raytheon’s current FCPA practices to the list –Raytheon has all policies, processes or procedures expected under the 10 DOJ / SEC Hallmarks DOJ / SEC “HALLMARKS”RAYTHEON POLICIES AND PROCEDURES 1 Commitment from Senior Management and a Clearly Articulated Policy Against Corruption  Tone at the top and commitment to compliance, statements in Company’s Code of Conduct, training programs, ethics policies, etc. 2Code of Conduct and Compliance Policies and Procedures  Code of Conduct and policies and procedures addressing anti-corruption, robust finance policies, processes and internal controls, Contracts and Supply Chain policies and procedures 3Oversight, Autonomy, and Resources  Integrated compliance structure – General Counsel is Chief Compliance Officer 4Risk Assessment  Internal Audit, business process owners and at enterprise level 5Training and Continuing Advice  Annual ethics and compliance education along with function specific FCPA training; on-line and in- person; video vignettes; General Counsel and Ethics as part of integrated compliance structure 6Incentives and Disciplinary Measures  System of reporting for concerns of misconduct with swift disciplinary actions imposed on employees who violate Raytheon’s Code of Conduct or applicable policies 7Third-Party Due Diligence and Payments  Due Diligence performed by General Counsel RWO: International Representatives & Consultants and Offset Providers; international supplier and customer due diligence procedures; due diligence for international transactions 8Confidential Reporting and Internal Investigation  Ethics Hotline, quarterly certifications, investigations, and reporting to senior leadership and the Board of Directors 9Continuous Improvement: Periodic Testing and Review  Internal Audit, FCPA audits, annual self assessments, and quarterly anti-corruption certifications, policies updated taking into account recent developments of anti-corruption laws and regulations 10 Mergers and Acquisitions: Pre-Acquisition Due Diligence and Post-Acquisition Integration  Robust diligence integration procedures related to anti-corruption

RAYTHEON MOST PRIVATE Page 3 INTERNAL AUDIT  Manage location self-assessments  Identify gaps/process improvements  Develop action plans,  Reporting to Anti-Corruption Sustainment Team RESPONSIBILITY Corporate Oversight Team (COT) VP GC, VP CFO, VP HR, VP Contracts/Supply Chain, VP Internal Audit Anti-Corruption Sustainment Team VP Legal International, VP Controller/CAO, Senior Counsel International, Asst. Controller, Director Compliance Contracts/Supply Chain, Mgr. Int’l HR, General Counsel and Controller Representative from each Business Anti-Corruption Business & Functional Structure CEO  Oversee overall direction of Anti- Corruption Program  Communicate lessons learned and best practices  Self-assessment process  Quarterly certifications  Financial and accounting controls  Risk-based assessment to identify/prioritize risk  Anti-corruption policies & internal controls to address/mitigate risk  Function-specific education keyed to policies and controls SAS Legal Finance Contracts/ Supply Chain Human Resources GBS / RII / Corporate Legal Finance Contracts/ Supply Chain Human Resources IDS Legal Finance Contracts/ Supply Chain Human Resources IIS Legal Finance Contracts/ Supply Chain Human Resources MS Legal Finance Contracts/ Supply Chain Human Resources Page 3 Raytheon Anti-Corruption Program Organization  Apprise management of specific FCPA / Anti-Corruption Risks  Participate on Anti-Corruption Sustainment Team  Complete FCPA reviews across Raytheon as part of audit plan  Apprise management of specific FCPA / Anti-Corruption Risks  Participate on Anti-Corruption Sustainment Team  Complete FCPA reviews across Raytheon as part of audit plan

RAYTHEON MOST PRIVATE Page 4  Has an unwavering commitment to the highest standards of ethical business conduct;  Demonstrates that commitment through a resolute tone at the top; and  Maintains effective internal controls, education, policies and procedures that appropriately deter and detect violations of the FCPA and other applicable anti-corruption laws Goal – Ensure that Raytheon and each individual Raytheon business: Raytheon’s Anti-Corruption Sustainment team meets weekly and has focused on  Anti-corruption controls; enhancing certain Company policies and underlying procedures; anti-corruption training and self-assessment process for anti-corruption controls III. Identify Improvement Opportunities II. Review Current Practices I. Identify Best Practices V. Monitor Compliance IV. Implement Changes Goal: Ensure Anti-Corruption Program is Comprehensive and Effective Raytheon’s Anti-Corruption Sustainment Program

RAYTHEON MOST PRIVATE Page 5 Sustainment Team Anti-Corruption Training Compliance Certifications Self-Assessment Process Policies / Processes Internal Audit Cross-functional team created Face to face in- country training Team expanded to include OGC and Finance representatives from each Business FCPA Aware launched Q and refreshed on ongoing basis Expanded criteria for training rqmts Quarterly certification process implemented to ~450 certifiers Completed annually at all Entities IDS Pilot Self-Assessment developed Revision of existing policies (i.e. Proposals, Int’l Procurement, BCAR, Political Contributions, Contributions, Offsets) New: General Ledger Requirements New: Due Diligence for Int’l Parties New: Local Hiring & Overarching Anti- Corruption Quarterly certification of Self-Assessments Core working group weekly meetings Raytheon published external web content Added FCPA Resource Guide training for Acctg. Functional specific training created New: Int’l BD Partner Policy & Monitoring Raytheon’s Continuing Anti-Corruption Journey Raytheon constantly focused on best in class Anti-Corruption program IA Moves into OGC Ongoing Conduct country reviews with FCPA focus “Well Controlled” Audit of 2012 Self- Assessment process