1. 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

2. 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

3. 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

4. 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

5. 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 Q4 2010 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 20102011201220132014 2015Ongoing Conduct country reviews with FCPA focus “Well Controlled” Audit of 2012 Self- Assessment process