Ethics and Compliance

Recognized as one of

the 2025 World's most

ethical companies

Operate Under A
Code of Conduct and

Business Ethics

Maintain A
Third-Party

Anonymous Hotline

Uphold Human Rights
And Anti-Harassment

Policies

Business Ethics

We are committed to operating a well-developed ethics program across all of Twenty-Six Defense. Site liaisons serve as extensions of the ethics and compliance program across all geographies and functions in the organization above a certain headcount, where we do not otherwise have ethics and compliance personnel.

We have an Ethics Committee who meets regularly to discuss a variety of ethics and compliance topics. To honor an individual annually who excels at ethical practices we recognize their accomplishments by presenting them with our Real Madore Award.

Risk Management

Our risk management procedures include various policies and procedures that identify, monitor and mitigate risks throughout the organization. Our Risk Issue and Opportunity Management manual provides details needed to implement Program Risk, Issue and Opportunity (RIO) Management using ARM, a tool that identifies risks and opportunities for all projects. We engage in responsible and compliant trading practices by implementing a risk framework and internal controls that demand accountability, transparency and auditability.

Anti-Corruption We apply due diligence in preventing corruption and bribery within our business. We conduct annual US Foreign Corrupt Practices Act (FCPA)/Anti-Bribery training with relevant employees and contractors selected for their function’s likelihood of exposure to transactions that could involve corruption. Our anti-corruption and anti-bribery practices are guided by our Prohibition of Fraud Bribery and Corruption Policy. This Policy is designed to assist employees, officers, directors, agents and representatives of the company and our business partners, in identifying fraud, bribery and corruption related issues and in understanding and complying with applicable company standards. Twenty-Six Defense complies with the FCPA as well as applicable international conventions including the Organization for Economic Co-operation and Development (OECD) Convention and the United Nations Convention Against Corruption.

Foreign Representatives To prevent corruption and bribery, Foreign Representatives are responsible for interacting with buyers in the foreign market. We hold our representatives to the same expectations as our domestic employees. Our business development team liaises with the representatives to ensure they comply with all of Twenty-Six Defense's polices. We have a detailed Foreign Representative Agreement required for all instances of foreign representatives’ partnerships that is updated every 2-3 years. Our representatives must complete a series of background checks prior to onboarding and are required to take annual anti-bribery training as part of their certification. Our Ethics and Compliance Department maintains oversight of representatives to prevent bribery and corruption.

Anti-Harrassment As part of our commitment to doing the right thing, we do not tolerate discrimination or harassment of any sort in the workplace. Elbit America requires that all employees be treated with dignity and respect and extends these requirements to suppliers, contractors and consultants. Accordingly, we will not tolerate instances involving threats of violence, corporal punishment or various forms of harassment whether based on gender, race, color, religion, ethnicity, age, sexual orientation, national origin, disability or any other legally protected characteristic.

Ethics Helpline

Our Non-Retaliation and Whistleblower Policies are outlined in our Employee Handbook, Employee Code of Conduct, and Supplier Code of Conduct. We host Ethics Group town hall meetings to explain resources and how to reach out regarding ethics concerns. Our third-party helpline can be used by any employee or contractor and can be anonymous by request. Our Director of Ethics is informed whenever a case is initiated and determines the next steps to handle and violations. Twenty-Six Defense has a non-retaliation clause in most procedures listed in the Code of Conduct.

Code of Conduct Conducting our business ethically is one of Twenty-Six Defense’s core values. As part of our ongoing Ethics and Compliance program, and consistent with applicable legal requirements, we are pleased to share our Code of Business Ethics and Conduct. Because of the importance we place on conducting our activities in an ethical manner, our employees, officers and directors are committed to following the Code as well as our other ethics and compliance related procedures and policies. We also expect our supply chain to meet our ethical standards in all of their activities with us, as reflected in our Supplier Code of Conduct.

Human Rights We are committed to respecting human rights and human dignity as outlined in our Human Rights Policy. We comply with all applicable laws pertaining to fair employment practices, as well as laws prohibiting forced and compulsory labor, child labor, employment discrimination and human trafficking. We strive to do business only with suppliers and business partners who share our commitment to the highest standards of ethical business conduct.

Employee Training Trade Compliance, Ethics and Security training is required for all employees. Select contractors are required to take annual anti-bribery training and all Foreign Representatives are required to take annual anti-bribery training as part of TRACE certification.

Cyber Security

Protecting both Twenty-Six Defense's and our customers non-public information is critical. Our Cyber Security policies and procedures provide a comprehensive compliance framework. We maintain several policies tied to National Institute of Technology (NIST) information security control families and also voluntarily maintain ISO/IEC 27001, 27014, and 27035 compliance in addition to the United Kingdom’s Cyber Essentials Plus certification.

Along with NIST, ISO, and Cyber Essentials controls within our System Security Plans, we've integrated Payment Card Industry Data Security Standard (PCI DSS) requirements.

Cyber Security Governance We interact with stakeholders across all levels of the company. These forums provide stakeholders the opportunity to gain context for cybersecurity policies and to strengthen our cybersecurity initiatives. Our InfoSec team meets regularly with business leaders, corporate IT personnel and with system administrators. Our cybersecurity governance efforts have been recognized by ISO 27001 assessors, Department of Defense cybersecurity assessors, and partner organization compliance teams.

IT Disaster Recovery Plan The IT Disaster Recovery plan aims to protect corporate resources and employees, to safeguard the company’s vital records of which the data center has become the custodian, and to guarantee the continued availability of essential IT services. The Plan outlines the actions to implement a sufficient set of procedures for responding to a disaster that involves our data centers and their services.

Risk Assessments

Elbit America’s risk assessments enable our leaders to make predictive investments in order to mitigate risk of business disruption or data loss. Leveraging a quantitative process, InfoSec determines risks, calculates an associated cost, and conveys the risk along a spectrum of confidence levels. The risk assessment itself results in an intuitively understood chart that over the course of years has demonstrated the ability to manage what has become the most concerning risk to business operations.

Employee Training We implement a multifaceted cybersecurity awareness training program. The annual training is conducted companywide each October during National Security Awareness Month. It is tailored toward identifying the most common security threats. We also routinely test our employee knowledge through simulated phishing campaigns that mirror recent real-world attacks.

Special Security
Agreement

Twenty-Six Defense operates under a US Department of Defense Special Security Agreement (SSA). This SSA mitigates the potential impact of Foreign Ownership, Control, or Influence (FOCI), and allows Twenty-Six Defense and its subsidiaries to bid on U.S. government defense contracts.

A robust mitigation structure exists including:

No parental governance clauses in SSA
Separate physical and network infrastructure
Visitation and communications controls and procedures
All Twenty-Six Defense senior officers are US citizens

Understand
the mission.
Access the capability.

Featured Solutions

Featured Solutions

About Twenty-Six Defense

News

Twenty-Six Defense to Strengthen Innovation and Domestic Manufacturing for America’s Warfighters

Work With Us

Life at Twenty-Six Defense

Do Business With Us

Featured Opportunities

Power Theme
is

ETHICS AND
COMPLIANCE

Highlights

Business Ethics

Cyber Security

Awards
and Recognition

Special Security
Agreement

Understandthe mission.Access the capability.

Featured Solutions

Featured Solutions

About Twenty-Six Defense

News

Twenty-Six Defense to Strengthen Innovation and Domestic Manufacturing for America’s Warfighters

Work With Us

Life at Twenty-Six Defense

Do Business With Us

Featured Opportunities

Power Themeis

ETHICS ANDCOMPLIANCE

Highlights

Business Ethics

Cyber Security

Awardsand Recognition

Special SecurityAgreement

Understand
the mission.
Access the capability.

Power Theme
is

ETHICS AND
COMPLIANCE

Awards
and Recognition

Special Security
Agreement