Leidos, Inc

Based on public information, there is evidence that the Chief Executive Officer has published a statement supporting the ethics and anti-corruption agenda of the company in the Code of Conduct. The company therefore scores 1. To score higher, the company needs to provide evidence of a stronger public stance on anti-corruption or more examples of suchstatements from the last two years.

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 evidence that the company’s Chief Executive Officer demonstrates a personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. The CEO sits on the Ethics Review Board (Executive) and the Ethics Committee (Board). His predecessor also initiated face-to-face meetings with managers to improve company ethics (2011). The CEO also introduces the company’s ethics training.

Based on public information, there is evidence that the company publishes a statement of values or principles representing high standards of business conduct. Leidos states core values as accountability, integrity, respect, responsibility and trust. However, the range of values falls short of the range sought by the question and there seems to be little explanation of why these values matter to the company. The company therefore scores 1.

Based on public information, there is evidence that the company belongs to one or more national or international initiatives. Leidos is a member of IFBEC and DII.

Based on public information, there is evidence that the company has appointed a Board committee with overall corporate responsibility for its ethics and anti-corruption agenda. Leidos has an Ethics and Corporate Responsibility Committee that is comprised of three directors at a minimum.

Based on public information, there is evidence that the company has appointed a named Senior Vice President Ethics and Compliance, Theodore W. Lay. The Senior Vice President Ethics and Compliance is responsible for implementing the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the Ethics and Corporate Responsibility Committee monitors and reviews the performance of the company’s ethics and anti-corruption agenda. Evidence suggests that this review occurs at least annually, as the Committee meets quarterly.

Based on public information, there is evidence of a formal, written plan on which the review of the ethics and anti-corruption agenda by the Ethics and Corporate Responsibility Committee is based. It includes reviewing complaints in regard to compliance violations, overseeing the work of the ethics departments within the company, evaluating compliance policies and procedures, reviewing the ethics and compliance training programmes, and reviewing disciplinary and corrective actions taken by the company. The company therefore scores 1. To score higher the company would need to provide evidence that improvement plans are implemented when issues are identified.

Based on public information, there is insufficient 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. The Ethics Committee has responsibility to monitor and review all ethics and compliance issues, including the review of policies and practices. The link with actual instances of corruption is implicit only.

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

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.

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.

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. Leidos refers third parties to its Code of Conduct. However, it does not mention the consequences of breaches. The company therefore scores 1.

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. The Code of Conduct has an explicit paragraph on “Kickbacks, Fraud, Bribes and Corruption”.

Based on public information, there is evidence of a zero-tolerance policy towards violations of the company’s ethical standards, but not of corruption or bribery specifically. The company therefore scores 1.

Based on public information, there is evidence that the company has an anti-corruption policy that is easily accessible. The Codes of Conduct for both employees and directors are available on the company website. However, these documents only appear to be available in English. The company therefore scores 1.

Based on public information, there is evidence that the company has an anti-corruption policy that is easily understandable and clear to Board members, employees and third parties. There are two separate Codes of Conduct, one for employees and one for directors. Suppliers are referred to the Code of Conduct.

Based on public information, there is evidence that the company has anti-corruption policies that explicitly apply to all employees and members of the Board. There are two separate Codes of Conduct, one for all employees (including executive officers, which is assessed to include executive directors), and a supplementary one for directors (which is assessed to include executive and non-executive directors).

Based on public information, there is evidence that the company has a policy on potential conflicts of interest that applies to both employees and board members.

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. The company therefore scores 1. To score higher, the company would need to provide evidence of a clear set upper limits and of a senior authorisation procedure.

Based on public information, there is no readily available evidence of a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery.

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 regulates and discloses political contributions.

Based on public information, there is evidence that the company has a clear policy on engagement in lobbying activities. The Code of Conduct refers the employees to applicable laws and to coordinate with the Government Affairs Office to ensure proper disclosure. There is also evidence that the company publicly discloses the issues on which it lobbies.

Based on public information, there is some evidence that the company regulates charitable contributions. The Ethics Committee Charter refers to monitoring the company’s policies and practices with respect to contributions to charitable, educational and other tax-exempt organizations. However, the policies are not publicly available. The company therefore scores 1.

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 Corporate Responsibility Report 2012 discusses the e365 campaign where real-life ethics examples are used to illustrate the Code of Conduct. However, there is no other readily available evidence of scenarios or examples to help employees and Board members understand specific policies. The company therefore scores 1.

Based on public information, there is evidence that the company has an ethics training programme. However, it is not explicit with respect to anti-corruption. The company therefore scores 1.

Based on public information, there is evidence that every employee is required to complete biennial ethics training.

Based on public information, there is evidence that the company provides targeted ethics training to members of the Board. This is stated under the Director Orientation and Continuing Educatuion section of the Corporate Governance Guidelines. However, it is not clear how often this training is refreshed or repeated. The company therefore scores 1.

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 no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

Based on public information, there is only evidence that the company may apply disciplinary procedures to employees, Directors and 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. This includes a channel operated by a third party.

Based on public information, there is evidence that the company has whistleblowing channels available to all employees in all geographies – telephone and on-line hotlines plus recourse to management and the Ethics Committee.

Based on public information, there is insufficient evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively. TI notes that the company does have a zero tolerance policy to retaliation and provides reporting channels for anyone wishing to report cases of retaliation. However, there is no readily available evidence of formal mechanisms, such as follow up with individual whistleblowers or analysis of whistleblowing channel usage statistics.

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. Leidos has an Ethics Officer in every business unit each of whom sits on the Employee Ethics Council.

Based on public information, there is evidence of a commitment to non-retaliation for bona fide reporting of corruption. However, although retaliation ‘can result in disciplinary action’, it is not made explicit what the company means by this. The company therefore scores 1.