Ethics Program Structure

 
 

Corporate Responsibility

Ethics Program Structure

Ethics Program Structure Update

The Leidos ethics program seeks to continuously strengthen our culture of uncompromising integrity through the support, education, and promotion of ethics, employing a variety of initiatives.

Combining policies, procedures, training and communications, the Leidos ethics and compliance program is comprehensive and touches every aspect of employee conduct.

Policies and Procedures

Our Standards of Business Ethics and Conduct is the foundational policy upon which the Leidos ethics and compliance program is built. Our Ethics Review Board (ERB), an executive management committee, meets quarterly, in conjunction with an Audit Review Board, to review significant enterprise ethics and compliance matters and strengthen the ability to review risk across the company. Members of the ERB include the CEO, chief financial officer, general counsel, chief Human Resources officer, group presidents and corporate executive vice presidents.

The ERB provides senior managers with methodical and direct oversight of our Ethics and Compliance Program. The scope of its reviews include significant ethics cases, trends, disciplinary actions, remedial measures, compliance risks, policy issues, training, communications, and new developments and initiatives.

Independent case management of every assigned ethics and compliance case is crucial to the successful execution of the program's goals. This bedrock concept ensures that all issues are methodically investigated and impartially adjudicated and that whistleblowers are fully protected from retaliation. Before closure, all reported cases are thoroughly reviewed by an appropriate subject matter expert who is independent and objective.

Ethics and Corporate Responsibility Committee

The Ethics and Corporate Responsibility Committee (ECRC), a standing Leidos Board of Directors committee, meets quarterly and is responsible for reviewing the ethical and administrative policies, procedures and responsibilities of Leidos employees and consultants under our Code of Conduct. The ECRC recommends agreed-upon enhancements to such policies and procedures to the broader Board and executive management.

The ECRC reviews policies and practices in the areas of corporate responsibility, including the safety and protection of the environment; charitable contributions; and political, social and environmental issues that may affect the company's business operations, performance, public image or reputation. The ECRC also reviews enterprise cases brought to its direct attention, in addition to a summary of reported cases. Lastly, the ECRC provides recommendations to management on the Leidos Ethics and Compliance Program, policies and procedures.

Employee Ethics Council

The Employee Ethics Council (EEC) continues to be an important resource and a strong part of the Leidos Ethics and Compliance organization. The EEC comprises representatives from each group in the enterprise, who work closely with line managers to identify and resolve ethics and compliance issues in their organization. EEC members also serve as the front line for employee reporting. EEC members take their responsibilities seriously and are a key component of our Ethics and Compliance Program. The EEC meets regularly to exchange information, discuss best practices and present concerns of interest to the enterprise.

Ethics Communications

To be effective, an Ethics and Compliance Program has to be understood and accepted by employees. Key to this effort at Leidos is a robust annual employee communication and engagement plan. The program routinely provides ethics and compliance-related information on the the Leidos intranet. Policy updates are disseminated regularly, via the company intranet, and we also communicate changes to the Code of Conduct as well as current training requirements through a number of vehicles. Articles and announcements posted to the intranet include comment sections for employees and managers at all levels.

Reporting Channels

One of the keys to the strong Leidos ethics program are the eight ways employees can report suspected violations of the Code of Conduct or any ethics concern. Leidos encourages employees to use any of the eight channels listed below to voice an ethics concern (many with anonymous options).

  1. Their supervisor or other individual in the management chain.
  2. Their Human Resources representative, the Director of Workplace Relations or the executive vice president for Human Resources.
  3. The Leidos Hotline at 855-7-LEIDOS (855.753.4367), which connects employees to an independent third-party provider, EthicsPoint, or by online submission of their concern at https://leidos.ethicspoint.com.
  4. The Employee Ethics Council.
  5. The general counsel; senior vice president for Ethics and Compliance (E&C); or chief security officer.
  6. The CEO or chairman of the Leidos Board of Directors.
  7. The Ethics and Corporate Responsibility Committee (ECRC) or the Audit Committe Chair of the Leidos Board of Directors.
  8. The Board of Directors or Lead Director.

Ethics Program Update

In addition to our Values, Beliefs & Expectations, action, accountability, and assistance are included in the Leidos Code of Conduct, which each employee must read to earn their annual certification. Required annual ethics training consists of a values-based, CEO-led ethics introduction video to kick off the rules-based online training to address key risk areas.

Ethical business conduct and compliance is the responsibility of every employee. Leidos encourages manager-led discussions on core values cascade down from the CEO to each manager and then to their direct reports. Key to this effort are scenarios highlighting the importance of each core value. These scenarios enable managers to discuss the importance of doing the right thing, how to report concerns, and help reiterate our zero tolerance of retaliation.

Our goal every year is a Code of Conduct certification and Ethics Awareness Training completion rate of 100 percent, which we achieved in 2015. This exceptionally high rate demonstrates our focus and attention on employee ethics training. We also continue to enhance our ethics case process, ensuring thorough training and objective investigation through corrective and disciplinary action follow-up.

Leidos continues an ongoing ethics and awareness campaign to focus all employees on the necessity of ethical behavior and to emphasize our commitment that ethics concerns will reach the right people, that swift corrective action will be taken in valid ethics cases, and that we have zero tolerance for retaliation.

The campaign message is simple and clear: Protect Leidos and customer assets; foster a safe and healthy work environment; deal fairly and honestly with customers, third parties and public officials; conduct international business properly; report misconduct; and protect colleagues from retaliation. In sum, do the right thing every day. Leidos leadership and the Ethics and Compliance Office remains focused on increasing employees' understanding of how our Code of Conduct translates into day-to-day work experience.

Continued success depends on directly challenging employees to be constant defenders of doing what's right and to follow the guiding principles that give employees a sense of direction - philosophical beliefs, moral compasses, Leidos policies, and the laws of our nation and the nations we support.