It is the responsibility of each employee to recognize and avoid any situation involving a business conflict of interest. Employees are expected to promptly disclose any known relationships or activities that may cause a real or perceived business conflict of interest. This information is disclosed to your supervisor/manager via the C-196A process and allows issues to be worked before they develop into a problem. Through this action, an employee protects their own interests as well as Northrop Grumman's. When using this hard copy version of this form, attach additional pages to provide required information.
A Business Associate is any person or entity that has, or is actively seeking to establish, a business relationship with Northrop Grumman, including, but not limited to, a supplier, subcontractor, consultant, customer, team member, or joint venture partner.
If your situation or circumstances are not specific to a question, use Question 7 to disclose your information. No additional research is required in answering the questions. Answer each question to the best of your knowledge.
If you answer YES to Questions 1-4, provide the person's relationship to you; the business entity and location, and their position with that business; provide your Northrop Grumman job responsibilities and state whether you make management decisions, or participate in the selection of or evaluate the performance of any business associate. Indicate if you and the individual named are working on the same contract.
1. Are you an employee, officer, or director for any business associate that does or seeks to do business with Northrop Grumman Corporation or its subsidiaries and affiliates?
2. Do you own, directly or indirectly, a substantial financial interest (as defined in 2A, 2B, or 2C) in any current or prospective business associate’s entity?
A. Ten percent or more of the individual’s net worth, excluding deposits in banks, trust companies, or savings and loan associations
B. At least a five percent interest in a publicly-traded company
C. Any interest in a non-publicly-traded company.
If you answer YES to Questions 3 A-D, provide the information requested above and indicate what was received, the purpose of the business courtesy, and the estimated value.
3. During the last year, have you received, directly or indirectly, from a current or prospective business associate any of the following which have a value in excess of €25 (or equivalent)?
A. Any travel or entertainment?
B. Any gifts, gratuities, or anything of value?
C. Any cash, free or discounted services, or free or discounted use of facilities? Note: This does not include discounted services offered by Northrop Grumman Employee Services.
D. Any compensation, commissions, fees, services, honorariums, or payments of any kind?
If you answer YES to Question 4, provide the information requested above and provide the circumstances of the transaction.
4. Has a debtor/creditor relationship existed at any time in the last year between you and a business associate? (Excludes loan/credit transactions at current market rates).
DISCLOSURE OF CONFLICTS OF INTEREST AND CERTIFICATE OF STANDARDS OF BUSINESS CONDUCT - INTERNATIONAL
5. Have you directly or indirectly revealed company proprietary matters to any unauthorized persons or have you used company proprietary information in any way to promote your own business or personal interests?
If you answer YES to Question 6, explain the information received or revealed, from/to whom, under what circumstances and indicate if you reported this to the Law Department.
6. Have you improperly received or revealed bid and proposal information or proprietary or source selection information pertaining to a competitor of Northrop Grumman?
If you answer YES to Question 7, explain the interest or arrangement and provide a brief description of your Northrop Grumman job responsibilities.
7. Do you have any other interest or arrangement which may violate the Standards of Business Conduct or may otherwise result in an actual or perceived conflict of interest?
CERTIFICATION I have read, understand my responsibilities and have and will comply with the Northrop Grumman Standards of Business Conduct. I will update this information if any situation or fact arises that would make my responses incomplete.
IMMEDIATE MANAGEMENT SIGNATURE IF ANY QUESTION IS ANSWERED YES.