Ethics Program Structure

 
 

Ethics & Corporate Responsibility

Ethics Program Structure

  • Compass for Ethics and Compliance
    Compass for Ethics and Compliance
    Compass for Ethics and Compliance

    At Leidos, we take every report seriously and have zero tolerance for retaliation of any kind against individuals who, in good faith, raise questions or report concerns.

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Ethics Program Structure

The Leidos Ethics and Compliance Program seeks to continuously strengthen our culture of uncompromising integrity by promoting ethics through 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. Current employees stand on the shoulders of those who founded the company in 1969 and who established its solid reputation over the decades. The company’s continued success stems from a culture that recruits and retains outstanding individuals committed to preserving our reputation.

Policies and Procedures

The Code of Conduct is the basis of Leidos corporate policies and practices and is designed to promote ethical business conduct and compliance with the law. All employees are required to conduct all business affairs ethically and to comply with the Code. The Leidos core values of integrity, innovation, agility, collaboration, and commitment are emphasized in the Code and are the foundation of our culture.

The Standards of Business Ethics and Conduct at Leidos is the foundational policy of the Ethics and Compliance Program. The Ethics Review Board (ERB), an executive management committee, meets quarterly in conjunction with an Audit Review Board and Enterprise Risk Management Committee, to review significant enterprise ethics and compliance matters and strengthen the ability to review risks across the company.

The Chief Ethics and Compliance Officer reports to the ERB on a range of issues, including significant ethics cases, trends, disciplinary actions, remedial measures, compliance risks, policy issues, training, communications, and new developments and initiatives. Members of the ERB include the CEO, Chief Financial Officer, General Counsel, Chief Ethics and Compliance Officer, Chief Human Resources Executive, Group Presidents and corporate functional executives

Ethics and Corporate Responsibility Committee

The Chief Ethics and Compliance Officer reports quarterly to the Ethics and Corporate Responsibility Committee (ECRC), a long-standing Leidos Board of Directors committee. The ECRC charter establishes its oversight of ethics policies and practices, including ethics training, case trends disciplinary actions, and conflicts of interest. In order to provide effective oversight, the ECRC keeps itself knowledgeable about ethics and compliance conditions and trends in the broader industry and within Leidos.

The ECRC also reviews policies and practices in the areas of sustainability, 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.

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 includes representatives from each group across the enterprise who work closely with line managers to identify and resolve ethics and compliance issues in their organization. EEC members also serve as one of the eight channels for employees to report violations of the Leidos Code of Conduct and other ethics concerns. The EEC discusses best practices and presents concerns of interest to the company. EEC members take their responsibilities seriously and are a key component of our overall Ethics and Compliance Program.

Ethics Communications

The Ethics and Compliance Office promotes a culture of integrity at Leidos. The office provides ethics and compliance training, communications, and guidance to create a transparent environment and informed employee population. Each year, the Ethics and Compliance Office endeavors to find new and innovative ways to underscore the importance of ethical decision-making for all employees. Using robust communications campaigns, the program routinely publishes a variety of ethics and compliance-related information by email directly to employees and also on the Leidos intranet. Articles and announcements posted to the intranet include sections for employees to provide comments and feedback.

Reporting Channels and Case Management

Leidos has an established process for reporting observed or suspected misconduct that is widely advertised and promotes eight separate channels for employees and others to report a concern or simply to ask for guidance. The available reporting options are:

  1. Their supervisor or other individual in the management chain.
  2. Their Human Resources representative, the Workforce Solutions Director or the Chief Human Resources Officer.
  3. The Employee Ethics Council.
  4. 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 (international hotline numbers are available to employees on our Ethics and Compliance intranet hub).
  5. The General Counsel; Chief Ethics and Compliance Officer; or Chief Security Officer.
  6. The CEO or Chairman of the Leidos Board.
  7. The Ethics and Corporate Responsibility Committee (ECRC) Chair or the Audit Committee Chair of the Leidos Board of Directors.
  8. The Board or Lead Director.

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 appropriately investigated and impartially adjudicated. Before closure, all reported cases are thoroughly reviewed by an independent and objective subject matter expert. The company has zero tolerance for retaliation in any form.

Ethics Program Update

Ethical business conduct is the responsibility of every employee. In fact, integrity is the first of the five stated Leidos values that employees both currently emulate and also aspire to further exemplify. Leidos defines this value of integrity as “having the courage to make tough ethical decisions, taking pride in our work, being transparent with our team, and being respectful of everyone.” The Code of Conduct and annual Ethics Awareness training reinforce Leidos’ core values and provides important information related to many key compliance and risk areas. The Code and training are updated annually and Chairman and CEO, Roger Krone, delivers strong messages in both regarding ethical behavior and accountability.

Leidos has consistently achieved a Code of Conduct certification and Ethics Awareness training completion rate of 100 percent. This exceptionally high rate demonstrates the company’s focus on and prioritization of employee ethics training.

Notably, Leidos engages in an ongoing ethics and awareness campaign to focus all employees on the necessity of ethical behavior and to emphasize its commitment that ethics concerns will reach the right people, that swift corrective action will be taken in valid ethics cases, and that the company has zero tolerance for retaliation of any kind.

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 remain focused on increasing employees' understanding of how the Code of Conduct translates into day-to-day work experiences.