Booz Allen Hamilton Inc.

Based on public information, there is evidence that the company publishes a statement from the Chief Executive Officer supporting the ethics agenda of the company. TI notes the Chairman’s Letter in the Annual Report, but does not assess this to be sufficiently detailed on ethics and anti-corruption. The company therefore scores 1.

Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including honesty, trust, openness, integrity and responsibility. The company clearly defines these values and demonstrates that they are translated into company policies and codes.

Based on public information, there is evidence that the company is a member of the Defense Industry Initiative on Business Ethics and Conduct (DII).

Based on public information, there is evidence that the company has appointed the Audit Committee with overall corporate responsibility for its ethics and anti-corruption agenda.

Based on public information, there is evidence that the company has appointed the Chief Ethics and Compliance Officer with responsibility for implementing the company’s ethics and anti-corruption agenda. This individual is identified as Gale N. Smith.

Based on public information, there is evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. However, it is not clear how regularly the review is undertaken, nor is the precise scope of the review made clear. The company therefore scores 1. To score higher, the company would have to indicate the scope and the timing of any review.

Based on public information, there is no readily available evidence that there is a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Audit Committee is based, and no evidence of improvement plans being implemented when issues are identified.

Based on public information, there is no readily available evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is no readily available evidence that the company has a formal risk assessment procedure for assessing enterprise-wide anti-corruption risks.

Based on public information, there is evidence that the company has a formal risk assessment procedure, which takes ethics and business conduct into consideration. Only limited details are provided regarding the circumstances under which it should be applied. The company therefore scores 1.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting its agents. However, there is no evidence that this is refreshed every three years and/or when there is a significant change in the business relationship. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption. It is unclear if the consequences of breaches to this stance are made clear. The company therefore scores 1. TI notes the company’s voluntary 'Partner in Ethics Program’, part of a commitment to encourage business ethics throughout its supply chain.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms, including improper payments and conflicts of interest.

Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. However, the company has a zero tolerance policy of violations of the Code of Business Ethics and Conduct, as shown by its explicit stance on disciplinary procedures in the event of a violation by any employee or director. The company therefore scores 1.

Based on public information, there is evidence that the company’s anti-corruption policy is easily available. However, it only appears to be available in English, while information suggests that the company is active in numerous global locations. The company therefore scores 1.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear. TI notes that the language is clear and the company provides useful examples in a Q&A format to assist with understanding.

Based on public information, there is evidence that the company’s anti-corruption policy applies to all employees and members of the Board.

Based on public information, there is evidence that the company has a comprehensive policy on potential conflicts of interest for employees and Board members. The policy contains a definition and examples of potential conflicts of interest.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. However, the full details of the policy are not publicly available. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. However, the full details of the policy are not publicly available. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments. TI notes that the company’s Green Book includes a section prohibiting the payment of contingent fees, but this is not understood to refer to facilitation payments.

Based on public information, there is evidence that the company prohibits political contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent.

Based on public information, there is evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent. All payments to nonprofit/charitable entities are processed via a Contributions Portal through which the Community Partnerships team tracks, reviews and approves them where appropriate.

Based on public information, there is evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. The company’s Green Book is a comprehensive guide to the ethics and anti-corruption agenda and contains useful examples in a Q&A format.

Based on public information, there is no readily available evidence that the company has a training programme that explicitly covers anti-corruption.

Based on public information, there is no readily available evidence that anti-corruption training is provided in all countries where the company operates or has company sites.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board. Although the Corporate Governance guidelines indicate that directors are provided with orientation training, part of which includes training on policies and procedures, there is no evidence to suggest that this includes anti-corruption training.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is evidence that the company has a clear and formal process by which employees declare conflicts of interest. However, this disclosure is made to an employee’s manager in writing, rather than to an independent department. The company therefore scores 1.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is evidence that the company has multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee, to report concerns or instances of suspected corrupt activity. In particular, the EthicsFirst Line is externally operated and facilitates anonymous reporting.

Based on public information, there is evidence that across geographies, all employees have access to more than one whistleblowing channel.

Based on public information, there is evidence that the company supports and encourages whistleblowing. However, it is not clear that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, such as ways to follow up with whistleblowers and monitor their experience. The company therefore scores 1.

Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption within the company. There is also evidence that disciplinary measures are applied to employees who breach this commitment.