CACI International Inc.

Based on public information, there is evidence that the company has published one statement from the Chief Executive Officer in February 2013, promoting the ethics agenda in the preface of the Standards of Ethics and Business Conduct. The company therefore scores 1. To score higher the company would need to provide evidence of at least two other such statements from the last two years, or one statement from the last two years that specifically supports the company’s strong stance against corruption.

Based on public information, there is evidence that the company’s Chairman demonstrates 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 Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including accountability, integrity, and honesty. The company explains these values and standards in detail, and demonstrates that they are translated into company policies and codes.

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, there is evidence that the company’s Audit Committee is responsible for compliance with the Code of Conduct and other compliance policies. The company’s Corporate Governance Guidelines also indicate that the Board has ultimate oversight over the company’s compliance with ethical standards.

Based on public information, there is evidence that the company has appointed the Director of Business Operations with responsibility for administering the Standards of Ethics and Business Conduct. The individual is named as Steven H. Weiss.

Based on public information, there is evidence that the Audit Committee assists the Board in ensuring compliance with the company’s ethical standards and with their review. However, there is no readily available evidence that this equates to monitoring and review of the company’s whole ethics and anti-corruption agenda. The company therefore scores 1.

Based on public information, there is no readily available evidence of a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management 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 anti-corruption risk assessment procedure implemented enterprise-wide. TI notes the work and responsibilities of the Security and Risk Assessment Committee, but has found no explicit statement on anti-corruption risk assessment procedures.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

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. TI notes that some evidence suggests that the company regulates relationships with consultants, but this appears to not include agents and only appears to apply to US government contracting.

Based on public information, there is no readily available evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance. TI notes that the website has a supplier portal, but this can only be accessed via password.

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 a policy prohibiting corruption in its various forms.

Based on public information, there is evidence that that company has a zero tolerance policy towards bribery.

Based on public information, there is evidence that the company’s Standards of Ethics and Business Conduct and Directors Code of Business Ethics and Conduct are easily accessible to Board members, employees, and all other affiliated organisations through their website in English. However, there is no evidence that they are available in other languages. The company therefore scores 1.

Based on public information, there is evidence that the company’s Standards of Ethics and Business Conduct is comprehensive and the language used is largely clear.

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 policy on potential conflicts of interest, which applies to employees and Board members. This policy includes 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, specifically advising against them and calling for disclosure if above a set upper limit.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality, specifically advising against it and calling for disclosure if above a set upper limit.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is evidence that the company has a policy that prohibits political contributions.

Based on public information, there is evidence that the company has a clear policy on engagement in lobbying activities. However, it is not clear that the company discloses the issues on which it lobbies. The company therefore scores 1.

Based on public information, there is evidence that the company regulates charitable contributions. However, the only reference to such contributions relates to charities with which a Director is affiliated. The company therefore scores 1.

Based on public information, there is some evidence that the company provides written guidance to help Board members and employees understand and implement the ethics and anti-corruption agenda. The company has an internal Manual providing more information, but the Standards of Ethics and Business Conduct do not contain examples or detailed guidance. The company therefore scores 1.

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 the company provides anti-corruption training 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 anti-corruption training to members of the Board.

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

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest. Evidence suggests that employees are simply referred to the Legal Division for guidance.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary measures to those employees found to have engaged in corrupt activities. However, the company does not have a similar explicit commitment for Board members found to have engaged in corrupt activities. The company therefore scores 1.

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 Hotline is operated independently by a third party and facilitates anonymous reporting.

Based on public information, there is evidence that across geogrpahies all employees have access to the hotline. The company therefore scores 1. To score higher the company would need to provide evidence that across geographies all employees have access to more than one reporting channel.

Based on public information, there is evidence that the company provides a useful FAQ for those with questions about the whistleblowing process and it is clear that the company seeks not to deter potential whistleblowers. However, there is no readily available evidence of formal mechanisms to ensure that whistleblowers are treated supportively, for example by using an independent employee survey or analysis of whistleblowing data.

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. However, there is no evidence that disciplinary measures are applied to those breaching this commitment. The company therefore scores 1.