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Exhibit 360

Ethics agreement of Mark T. Esper, nominee for Secretary of the Army

Exhibit 360 ยท Correspondence

Ethics agreement of Mark T. Esper, nominee for Secretary of the Army

For a period of one year after my resignation from Raytheon, I will not participate personally and substantially in any particular matter involving specific parties in which I know Raytheon is a party or represents a party

Esper resigns from Raytheon on confirmation, forfeits unvested restricted stock, divests Raytheon stock within 90 days, keeps participation in Raytheon's deferred compensation plan and recuses from matters affecting it, and recuses one year from matters in which Raytheon is a party.

Source
Mark T. Esper to DoD Alternate Designated Agency Ethics Official; posted by U.S. Office of Government Ethics
Date
26 July 2017
Quoted from
Letter p. 1
Grade
Primary record
Document
https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/26BF12099203D918852581710026F5E2/%24FILE/Esper,%20Mark%20T.%20%20finalEA.pdf
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Cited by

Finding DEF-4.7
Primary record Seven officials are documented moving between Defense Department posts and the boards or payrolls of defense contractors in dated steps from 2009 to 2021, under the Obama, Trump and Biden administrations. Five of them (Lynn, Shanahan, Esper, Mattis and Austin) came to senior Pentagon posts from contractor roles, and four (Work, Pawlikowski, Mattis and Austin) took contractor board seats after leaving DoD posts or the armed services.
Finding DEF-4.8
Primary record Four officials who came to the Pentagon from contractor roles stated their recusal terms in their own agreements: Shanahan (Boeing), for the duration of his service; Esper (Raytheon), one year, with a continuing limit tied to his deferred compensation; Mattis (General Dynamics), one year; and Austin (Raytheon Technologies), four years. The DoD Inspector General investigated 2019 allegations that Shanahan promoted Boeing and did not substantiate any of them.