7/28/2019 Raytheon-State Department Settlements Summary

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RAYTHEON - DIRECTORATE OF DEFENSE TRADE CONTROLS (DDTC)SETTLEMENTS COMPARISON/SUMMARY

(As of 7/6/2013)

ITEM# SUMMARY

SETTLEMENTSApr 2013 * Feb 2003 Oct 1999

1 Alleged Violations/Number of Charges 125 26 112 Maximum Civil Fine Could Have Been $62,500,000 $13,000,000 $5,500,0003 Actual Total Civil Fine $8,000,000 $5,000,000 $550,0004 Actual Civil Fine per Violation $64,000 $192,308 $50,0005 Portion of Civil Fine Suspended $4,000,000 $2,000,000 $50,0006 Percentage of Actual Fine Suspended 50% 40% 10%7 Debarment No8 Voluntary Disclosures Numerous

None Noted2

9 Directed Disclosures 1 Noted10 Consent Agreement Term 4 Years 3 Years

GENERAL REMEDIAL MEASURES

11 Measures Incorporated in BusinessAcquisitions X

12 ** Sales or Merger Purchaser orMerging Party Notified in Writing

X

13 ** Ensure Adequate Resources X14 ** Internal Review X15 ** Status Reports to the DDTC X16 ** Special Compliance Officer (SCO) 2 Years 1 Year17 ** Internal SCO 2 Years18 Employee Reporting Mechanism X19 ** Comprehensive Automated Export

Compliance System

X

20 Policies, Procedures and Trainingof ITAR-Controlled Technical Data(TD) Transferred Electronically

X

21 Feasibility Study to MaximizeAutomation of Identification andTracking of ITAR-Controlled TD

X

22 ** 5 Year Jurisdiction Review X23 Outside Audits & Audit Plans 2 Required24 Legal Department Oversight/Support X25 Written Certification to the DDTC X

26Arrange/Facilitate DDTC MinimumAdvance Notice Reviews/Audits

X

27 Enforce & Adopt Policies &Procedures to Ensure Compliance

X

28 Compliance Restructuring X

NOTES: * This is a Global settlement with another $20,000,000 paid to the US Customs Service.** These measures specifically apply to all operating divisions, subsidiaries and business units.

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