Science Applications International Corporation (SAIC)

Based on public information, there is evidence that the company has published a statement from the Chief Executive Officer supporting the ethics and anti-corruption agenda of the company. However, this statement does not indicate a strong stance against corruption specifically. The company therefore scores 1.

Based on public information, there is evidence that the Chief Executive Officer demonstrates a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. TI also notes that the individual responsible for ethics and compliance, Laura Kennedy, also demonstrates a personal commitment in this regard.

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 or principles representing high ethical standards of business conduct, including honesty, trust, openness, transparency, integrity and accountability. The company clearly demonstrates that these values are translated into company policies and codes.

Based on public information, there is 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. Specifically, 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 a Board committee with overall corporate responsibility for its ethics and anti-corruption agenda. Specifically, the Ethics and Corporate Responsibility Committee has this role; the Committee’s duties and responsibilities are fully publicly available.

Based on public information, there is evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda. This individual is named: Laura Kennedy, Senior Vice President of Ethics and Compliance.

Based on public information, there is evidence that there is regular Board level monitoring and review of the company’s ethics and anti-corruption agenda. This is carried out by Ethics and Corporate Responsibility Committee. In particular, the Senior Vice President, Ethics and Compliance, or the General Counsel communicates to the Committee no less than annually on the implementation and effectiveness of the company’s compliance and ethics program. The company therefore scores 2.

Based on public information, there is some 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. The plan includes evaluating complaints regarding compliance violations, reviewing the compliance policies and procedures, determining the effectiveness of the ethics and compliance training programme, and reviewing disciplinary and corrective actions taken by the company. The company therefore scores 1. To score higher the company would need to provide further evidence of the formal, written plan, as well as the implementation of improvement plans 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.

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 some evidence that the company makes clear to suppliers, through policy terms, its stance on bribery and corruption. However, it is not clear that the consequences of breaches to this stance are made clear. 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.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is explicitly one of zero-tolerance.

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible via the company’s website. However, TI does note that the policy is only available in English and the company is understood to operate internationally. The company therefore scores 1.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear.

Based on public information, there is evidence that the company’s anti-corruption policy, contained with the Code of Conduct, applies to all employees and executive officers. The Board of Directors have a separate Code of Conduct.

Based on public information, there is evidence that the company has clear policies on potential conflicts of interest applying to 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. However, the information available about this policy is limited and no reference is made to upper limits or the requirement for senior authorisation. The company therefore scores 1.

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. TI notes that reference is made to gifts and gratuities, but these statements are not understood to cover hospitality.

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 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 and disclosure, in order to prevent undue influence or other corrupt intent.

Based on public information, there is insufficientevidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent.

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. However, only a limited number of the relevant documents are publicly available. The company therefore scores 1.

Based on public information, there is evidence that the company has an ethics and compliance training programme; however, it is not clear that this explicitly covers anti-corruption. The company therefore scores 1.

Based on public information, there is evidence that employees receive ethics training. However, evidence does not show that this training is available in all countries where the company operates. The company therefore scores 1.

Based on public information, there is evidence that the company provides training on ethics and the Code of Conduct to members of the Board; however, it is not clear how often this training is refreshed. 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 in writing.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to employees found to have engaged in corrupt activities. However, the same commitment is only made with reference to conflicts of interest in the Code of Business Conduct of the Board of Directors. 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 (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity. These channels include an online channel maintained by an independent third party.

Based on public information, there is evidence that the company has whistleblowing channels available to all employees in all geographies.

Based on public information, there is evidence that the company encourages whistleblowing but there is no readily available evidence of formal and comprehensive mechanisms to ensure that whistleblowing by employees is not deterred. Such mechanisms could include analysis of whistleblowing data, employee surveys or follow up with individual whistleblowers.

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 there is a commitment to non-retaliation for bona fide reporting of corruption. The company also makes clear the consequences of breaching this commitment.