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Ethics & Conduct

Conducting our business ethically is one of Elbit Systems’ core values. Our policy is to follow best practice compliance standards applicable to the broad range of our global activities. Because of the significance we place on the transparency of our ethical business conduct, the following codes, policies and procedures are all publicly available as provided below.

 

Code of Business Conduct and Ethics

Conducting our business ethically and consistent with best practices and legal requirements is essential to our success. Attached is our Code of Business Conduct and Ethics, as approved by Elbit Systems Board of Directors.

 

Whistleblower and Investigations Procedure

As part of our business ethics compliance policy, we encourage reporting of suspected violations of our policies, improper conduct and legal non-compliance. We are committed to taking such reports seriously, investigating them in a prompt and discrete manner, and we do not tolerate retaliation against employees who report in good faith. Attached is our Whistleblower and Investigations Procedure, which describes the methods for reporting and the process we follow to investigate such reports.

Anti-Bribery and Corruption Compliance Policy

The international nature of our business and our work with governmental customers and end users around the world, as well as our being a publicly traded company, requires us to follow leading anti-bribery and corruption compliance standards. We have zero tolerance for corruption, and our employees, officers and directors are committed to conducting our business according to applicable anti-bribery and corruption compliance practices. Attached is our Anti-Bribery and Corruption Compliance Policy.

Procedure on Anti-Bribery and Corruption Due Diligence

An important part of our anti-bribery and corruption compliance policy is the due diligence we conduct with respect to third parties with whom we do not business. Attached is our Procedure on Anti-Bribery and Corruption Due Diligence (without Annexes).

Business Entertainment and Gifts Policy

Another important aspect of our anti-bribery and corruption compliance policy, as well as our policy for avoiding potential conflicts of interest, is the way in which we provide and receive business entertainment, hospitality and gifts. Attached is our Business Entertainment and Gifts Policy (without Annexes).

Supplier Code of Conduct

We expect our supply chain to meet our ethical standards in all of their activities with us. Attached is a copy of our Supplier Code of Conduct, which is incorporated into our procurement agreements.

Conflict Minerals Compliance Policy

We support government and industry initiatives to increase supply chain transparency to facilitate the ability of companies to source “conflict-free minerals”. We are also committed to sourcing materials from companies that share our values with respect to conflict minerals, as reflected in our attached Conflict Minerals Compliance Policy. Elbit Systems’ most recent Conflict Minerals Report to the SEC also is attached.

Human Rights Statement

We conduct our business activities in accordance with best practices relating to the human rights of our workforce, our supply chain and our surrounding communities.  We adhere to the UN Guiding Principles on Business and Human Rights.  Our latest Human Rights Statement, as approved by our Board of Directors, is attached.

Compliance with Convention on Cluster Munitions

All of our activities in the area of munitions, Including those of IMI Systems Ltd, are in compliance with the international Convention on Cluster Munitions that entered into force in August 2010.