ManTech International Corporation

Based on public information, there is evidence that the company publishes a single statement from the Chairman and Chief Executive Officer, and the Executive Team, supporting the ethics and anti-corruption agenda of the company. 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 addresses the company’s strong stance against corruption.

Based on public information, there is evidence that an external facing commitment to the ethics and anti-corruption agenda of the company is delegated to other individuals. The General Counsel has attended a whistleblowing event, the Executive Director of Services has attended an anti-fraud event, and the Vice President of Industry Compliance has attended an Ethics, OCI and Compliance event. The Excutive Director of Services, Jim Butterworth, maintains certification as a Certified Fraud Examiner (CFE). The company therefore scores 1. To score higher the company would need to provide evidence that the Chief Executive Officer or the Chair of the Board has demonstrated such external facing commitment.

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 trust, integrity, honesty, and accountability. These values are briefly explained in the Standards of Ethics and Business Conduct and on the company’s website.

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 signficiant focus on anti-corruption.

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 Compliance Officer with responsibility for implementing its ethics and anti-corruption agenda. The individual is identified as Terry Myers.

Based on public information, there is some evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. The Code of Business Conduct is reviewed periodically by Audit Committee. However, it is unclear how often this review process takes place. 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, or 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 update its policies and practices in response to actual or alleged instances of corruption. TI notes the Audit Committee has responsibility to oversee the Standards of Ethics and Business Conduct, but there is no clear process for such update.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. It is unclear if risk assessment processes apply to anti-corruption, and there is no evidence of corresponding mitigation plans. TI notes the risk declaration in the Form 10-K declaration.

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 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 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.

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 gifts and facilitation payments.

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 commitment to apply 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 accessible to Board members, employees, and third parties. The company’s policy is available online on the company website and the policies are also outlined on the company’s intranet.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear to Board members, employees and third parties. The policy is witten in accessible, comprehensible language and can be easily understood by a non-legal audience.

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

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

Based on public information, there is some 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 giving and receiving of gifts is limited and there are clear thresholds for gifts related to US government employees. For some gifts to federal employees and state or local government employees, the company requires a Corporate Compliance Department approval. The company therefore scores 1. To score higher the company would need to provide evidence that it sets upper limits for gift exchange with all individuals, not just US government employees.

Based on public information, there is some evidence of 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. The company limits giving hospitality and sets clear upper limits for hospitality. However, these limits only apply to hospitality exchange with US government employees. The company therefore scores 1. To score higher the company would need to provide evidence that it sets upper limits for hospitality exchange with all individuals, not just US government employees.

Based on public information, there is some evidence that the company has a policy that explicitly prohibits facilitation payments. However, the company provides no guidance or supplementary information on how the policy is to be implemented in practice. The company therefore scores 1.

Based on public information, there is some evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent. The company states that employees need prior approval from the Corporate Legal Department before engaging in political activities. However, political contributions are not publicly declared and guidelines on the application of the regulation are not clear. The company therefore scores 1.

Based on public information, there is some evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent. Employees require prior approval from the Corporate Legal Department before engaging in lobbying. The company therefore scores 1. To score higher the company would need to provide evidence of the specific guidelines of this policy and that it publically discloses the issues on which it lobbies.

Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent. TI notes that there is limited evidence that the company declares charitable contributions.

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 provides a number of scenarios to aid understanding of the company’s Code.

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.

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. Employees are asked to report the conflicts of interest to their supervisor or to the Corporate Compliance Department. In particular, personal conflicts of interest are generally prohibited and any exceptions must be approved in writing by the Chief Compliance Officer.

Based on public information, there is evidence that the company will apply disciplinary procedures to employees and Directors found to have violated the Code of Conduct.

Based on public information, there is evidence that employees can report concerns or instances of suspected corrupt activity using multiple, well-publicised channels. Employees are able to report concerns to the Corporate Compliance Department, the Audit Committee or the Ethics Helpline. The Ethics Helpline is an independent channel that allows anonymous reporting online or by phone.

Based on public information, there is evidence that across geographies, all employees have access to more than one whistleblowing channel. This includes the Ethics Helpline, as well as local and group-wide compliance and ethics officers.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, or that whistleblowers are treated supportively.

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. Employees are able to contact a supervisor, group management contacts, group compliance officers, and the Ethics helpline. Additional guidance is available on the Ethics Programme page on the company intranet.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. The company therefore scores 1. To score higher the company would need to provide evidence that disciplinary measures are applied to employees who breach this policy.