Whereas: Raytheon Technologies Corporation (Raytheon) is exposed to significant actual and potential adverse human rights risks. The use of its defense products and services may violate the rights to life, liberty, personal security, and privacy. The UN Guiding Principles on Business and Human Rights (UNGPs) constitute the global authoritative framework outlining human rights responsibilities of states and businesses, and expectations are heightened for companies with business activities in conflict-affected and high-risk areas.1 Companies’ human rights responsibilities are independent of the State’s export licensing determinations, as reiterated in a recent United Nations note.2
Raytheon’s Human Rights Policy is not aligned with the UNGPs, and investors lack evidence it is effectively implemented across business functions. An Amnesty International report found Raytheon is not meeting its human rights responsibilities despite severe, irremediable impacts.3 For example, Raytheon’s products have been directly linked to human rights violations in Yemen. The Companywas most recently connected to 80 civilian deaths in a 2022 airstrike by the Saudi-led coalition,potentially amounting to war crimes.4 Raytheon also sells weapons to Israel,5 which are used tomaintain the system of apartheid.6 Furthermore, Raytheon has annual contracts worth $542 millionin nuclear weapons, which are illegal under international law.7 The Company may be required todisclose more about its nuclear weapons involvement to avoid prosecution or legal proceedings.
Despite Raytheon’s stated compliance to US export licensing, a recent United States GovernmentAccountability Office report highlights the US’ failure to monitor whether its weapons have beenused by the Saudi-led coalition to attack civilians.8 This further emphasizes why Raytheon mustconduct its own independent, robust human rights due diligence. The Company faces increasingmaterial legal risk, as a group of Yemeni nationals sued Raytheon and peer defense contractors inMarch 2023 for their complicit role in war crimes in Yemen.9
Raytheon is the subject of multiple divestment campaigns related to its poor human rights trackrecord.10 Raytheon is additionally exposed to increasing regulatory risk due to President Biden’s newConventional Arms Transfer policy, which establishes new restrictions for arms sales that would"more likely than not" be used to commit serious human rights or international humanitarian lawviolations.11
New guidance from the American Bar Association explains how human rights risk assessments canreduce material risks, including divestment, export bans, and civil liability.12 An HRIA can mitigateRaytheon’s continuity risks as increased federal oversight on customer end-use may limit or cancelexisting or future contracts.