Ethics & Compliance
We set the highest professional and personal expectations.
We set the highest professional and personal expectations.
Leidos maintains the highest standards of integrity and ethical behavior. Our robust policies, procedures, training, and communications create a comprehensive program, cultivating a culture of integrity that touches every aspect of employee conduct.
For the third consecutive year, the Ethisphere Institute named Leidos one of the World's Most Ethical Companies. This honor underscores our commitment to leading with integrity and prioritizing ethical business performance.
We have a strong history of performance resting on our foundation of integrity. This foundation supports an environment where ethics and compliance is everyone's responsibility. Leidos employees proudly embrace these standards through their work and interactions. Managers at all levels must model the behavior they expect from their teams, and reinforce those values to promote a strong ethical culture within their organizations.
Report an Ethics Concern
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.
The Leidos Ethics and Compliance Program seeks to continuously strengthen our culture of uncompromising integrity by promoting ethics through a variety of initiatives. Ethical business conduct is the responsibility of every employee. In fact, integrity is the first of the six stated Leidos values that employees are expected to emulate and aspire to 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."
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 its reputation.
Code of Conduct
Leidos has a strong culture of ethics and integrity. Our Code of Conduct is a broad statement of principles for conducting business according to the highest ethical standards. It applies to all Leidos subsidiaries and is available in eight languages.
Policies and Procedures
The Code of Conduct (the Code) 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, to comply with the Code, and certify they read and understand the Code as part of their annual required training. The Leidos core values of integrity, inclusion, 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.
Chief Ethics and Compliance Officer Michele Brown 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 Chairman and CEO Roger Krone, Chief Financial Officer, General Counsel, Chief Ethics and Compliance Officer, Chief Human Resources Officer and Head of Business Partnerships, Group Presidents and corporate functional executives.
Corporate Governance and Ethics Committee
Chief Ethics and Compliance Officer Brown reports quarterly to the CGEC of the Leidos Board of Directors. The CGEC charter establishes its oversight of ethics policies and practices, including ethics awareness training, case trends disciplinary actions, and conflicts of interest. In order to provide effective oversight, the CGEC keeps itself knowledgeable about ethics and compliance conditions and trends in the broader industry and within Leidos.
The CGEC 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.
Ethics Training and Communications
The Ethics and Compliance Office promotes a culture of integrity at Leidos and provides ethics and compliance training, communications, and guidance to create a transparent environment and informed employee population.
The Code and annual Ethics Awareness training reinforce Leidos’ core values and provide important information related to many key compliance and risk areas. The Code and ethics awareness training are updated annually, and CEO Krone delivers opening remarks in the training to reinforce our commitment to ethics, integrity, behavior, and accountability. CEO Krone echoes this message in the company’s New Employee Orientation. Ethics Awareness training must be completed annually by all employees, including part-time employees,
Other required annual courses for Leidos employees include labor charging, security awareness, and inclusion acumen training. Employees that work on certain programs and in specific job functions must also complete role-based compliance training. New Leidos employees must complete these required trainings within their first 30 days of employment along with environmental, health, and safety training. Other courses may be required based on an employee's role.
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, which promotes a two-way dialogue and candid conversation.
As part of the office’s continuing efforts to promote transparency and confidence in its robust and independent investigation process, Chief Ethics and Compliance Officer Brown publishes an annual all-employee email titled “Ethics Year in Review.” The email provides an overview of the company’s investigative process and activity from the previous year in an effort to be candid about the office’s efforts to promote a culture of ethics and integrity. The message provides detailed data about ethics-related cases, including the number and nature of cases investigated, the number of employees involved, the substantiation rate, and the remediation taken, including number of terminations.
Further, the Ethics and Compliance Office periodically publishes “Ethics in the News,” highlighting recent, non-Leidos ethics and compliance-related news items. These articles reinforce the importance of Leidos values and acting with integrity at all times. The company encourages employees to use “Ethics in the News” as a resource to facilitate discussions about ethics with their colleagues and others they interact with on a daily basis.
As a companion piece to “Ethics in the News,” the Ethics and Compliance Office publishes a series titled “Let’s Talk Ethics.” The articles feature actual Leidos ethics cases, including any corrective actions, where employees engaged in activities contrary to Leidos policies and the Code. The intent is to highlight and reinforce policies and procedures.
The Ethics and Compliance Office 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; respect human rights; 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.
Reporting Channels and Investigations Case Management
Leidos’ established process for reporting observed or suspected misconduct or any employee grievance is widely advertised and promotes eight separate channels for employees and others to report a concern or simply to ask for guidance. If an individual is uncomfortable coming forward, the individual has the option of reporting anonymously where permitted by law. Any information provided will be kept confidential to the greatest extent possible. The available reporting options are:
- Their supervisor or other individual in the management chain
- Their Group Ethics Director, the Director of Investigations or the Chief Ethics and Compliance Officer
- Their local Human Resources representative, the Workforce Solutions Director or the Chief Human Resources Officer
- The Employee Ethics Council
- The Leidos Hotline, which connects you to an independent third-party provider. You may contact the Hotline by phone or by online submission. Concerns may be reported anonymously.
- The General Counsel or Chief Security Officer.
- The Chairman and CEO
- The Board of Directors via the Lead Director of the Leidos Board of Directors, the Corporate Governance and Ethics Committee Chair or the Audit and Finance Committee Chair.
Consistent with best practices, Leidos has retained a third-party administrator to host its Hotline, which offers a 24/7 call center and accompanying website where employees and others can voice concerns or ask for guidance. The Ethics and Compliance Office is responsible for maintaining this relationship and ensures that the Hotline complies with all relevant laws and regulations in the countries where Leidos operates and that the proper access controls are in place to ensure the information is kept confidential to the greatest extent possible, and accessed by only those with a business need to know. The office has also set up toll-free calling options for U.S.-based callers, and several international locations. Finally, the office ensures that the Hotline phone numbers are posted in common work areas across the enterprise.
The Ethics and Compliance Office maintains an Enterprise Case Management System for documenting and tracking investigations. All key investigative functions, including Human Resources, Ethics and Compliance, Legal, and Security, use this centralized, multifunctional case management system. The company employs a highly collaborative approach to ensure that the most appropriate and independent function investigates each allegation based upon the nature of the underlying concern. All cases are subject to biweekly reviews by Legal, Human Resources, Ethics and Compliance, and Security representatives. Such a high level of collaboration across the enterprise has produced a best-in-class investigative program. Furthermore, Leidos does not close any substantiated case in ECMS until the company has completed all corrective actions.
The company has zero tolerance for retaliation in any form. Leidos supports those who speak up and the company has always encouraged its employees to report any legal or ethical misconduct without fear of retaliation. Additionally, Leidos has established follow-up procedures for closed investigations where there is a heightened risk of retaliation. Those who engage in retaliation will face disciplinary action, up to and including termination of employment. Anyone who asks questions or reports concerns in good faith will be protected. The company is committed to complying with the employee whistleblower protections contained in the Federal Acquisition Regulation (FAR) and the Department of Defense FAR Supplement (DFARS), as well as the anti-retaliation provisions of all applicable laws that prohibit discrimination in the workplace. Employees may also report concerns to an agency’s Office of Inspector General or the Department of Defense (DOD) Hotline.
Ethics Program Assessments and Continuous Improvement
Leidos regularly and comprehensively assesses its Ethics and Compliance program, as well as its culture. The company does this in a number of ways: alignment of the ethics and compliance program to mitigate risks identified during risk assessments, internal reviews of the ethics and compliance program against laws and regulations, audits by internal and external auditors, benchmarking against external best practices, ethical cultural and employee engagement surveys (which includes measuring how comfortable Leidos makes employees feel in reporting misconduct), and reviews by external consultants.
The Leidos foundation was built on a commitment to ethics since the company’s inception in 1969.
Ethical conduct is a hallmark of our business and we commit to corporate integrity and compliance throughout all levels of the company. Leidos established ethics and compliance as a cornerstone of employee behavior by forming the Employee Ethics Council (EEC) in 1984. Comprised of representatives from across the enterprise, the EEC seeks to embed ethics into our business culture. EEC members work closely with line managers to identify and escalate 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.
Leidos pioneered a number of industry best practices in developing its Ethics and Compliance Program. Leidos was one of the early signatories to the Defense Industry Initiative on Business Ethics and Conduct (DII), an organization made up of companies from the aerospace and defense industry whose mission is to promote and advance a culture of ethical conduct among government contractors. Leidos is now considered a leader among the nearly 80 companies that comprise the DII. In 2020, Chairman and CEO Roger Krone was elected to the DII Steering Committee and currently serves as Vice Chair. Chief Ethics and Compliance Officer Michele Brown serves as the Vice Chair of the DII Working Group.
In 1988, the Board of Directors created the Ethics and Corporate Responsibility Committee, currently known as the Corporate Ethics and Governance Committee (CGEC), comprised of board members responsible for reviewing and recommending policies and procedures that maintain a business environment committed to high standards of ethics, integrity, sustainability, and legal compliance. The Board’s close oversight of the company’s Ethics and Compliance Program is now considered to be a best practice in the defense industry.
In 2005, Leidos created a senior management position to oversee the Ethics and Compliance Program. Today, the Senior Vice President, Chief Ethics & Compliance Officer, reports to the Chief Executive Officer and the Board Chair of the CGEC. Through comprehensive training, continuous communications and leadership actions, these efforts help to embed a values-based program into everyday activities across the enterprise.
History of Ethics at Leidos
- Formed Employee Ethics Council - ethics officers responsible for communications, training, and case management to embed ethics into the business culture.
- Early signatory to Defense Industry Initiatives on Business Ethics and Conduct, committing to self-governance in accordance with the highest standards.
- Pioneered board-level oversight by creating the Ethics and Corporate Responsibility Committee.
- Created the position of senior vice president of ethics and compliance (SVP E&C) in response to revised federal sentencing guidelines.
- Federal government ethics officers applaud Leidos’ (legacy SAIC) case resolution process as a best practice. At Leidos (legacy SAIC), ethics cases are assigned to an independent case manager and subject matter expert investigator. Once the investigation is complete, cases are reviewed by an experienced quality assurance team to ensure thoroughness and objectivity.
- Launched the Targeted Compliance Training Program to supplement the Ethics Awareness Program.
- Reconstituted the EEC, which consists of an ethics officer from every business unit and a key corporate functions, as a representative ethics body.
- Recognized by Ethisphere as one of the “World’s Most Ethical Companies” in the aerospace and defense industry.
- Created the Ethics Review Board, which consists of the CEO and an executive team and meets quarterly to review cases, trends, and policies.
- Elevated SVP of Ethics & Compliance (E&C) to report directly to CEO, strengthening commitment to ethics.
- Launched independent, third-party ethics hotline to further enhance reporting confidentiality.
- Launched an Enterprise Case Management System as a customized central repository to document and track investigations, allowing for automated workflow processing, enhanced analytical capability, and more cross-functional collaboration.
- Expanded Ethics and Compliance Program to include group ethics directors, senior investigators, and a dedicated communications lead.
- Strengthened forensic capabilities to better investigate reported cases.
- Implemented root cause analysis as part of every substantiated investigation.
- Created international hotline numbers, with translators available to callers, to support an expanded international presence.
- Launched an enterprise-wide campaign supporting the company’s values-based culture and emphasizing that ethics is not only the responsibility of the (E&C) Office, but also the responsibility of every employee- every employee is an ethics officer at Leidos.
- Promoted quality control and coordinated investigators through bi-weekly meetings with investigators from all investigative functions: Ethics and Compliance, Legal, Internal Audit, Security and Human Resources.
- Recognized three consecutive years (2017-2020) by the Ethisphere Institute as one of the World’s Most Ethical Companies
Code of Conduct
Leidos has a strong culture of ethics and integrity. Our Code of Conduct is a broad statement of principles for conducting business according to the highest ethical standards. It applies to all Leidos subsidiaries and is available in five languages.
Compliance and Audit
The Leidos Internal Audit department regularly audits Leidos programs. The scope of these audits includes assessing compliance with key aspects of the policies and procedures encompassed in the Code. These audits generally include, but are not limited to:
- Compliance with contractual requirements
- Financial performance
- Internal Controls and cultural environment
- Supplier Management
- Prior, recurring and current ethics concerns and investigations
Commitment to International Anti-Corruption and Anti-Bribery
As mandated through Leidos’ corporate core values, the company is committed to maintaining integrity in all of its business operations and requires strict compliance with anti-bribery and anti-corruption laws throughout the world. In accordance with the Code, all Leidos employees are required to keep accurate records, conduct business fairly and honestly and comply with all applicable anti-bribery laws and regulations. Without exception, the company acts in accordance with all of its ethics policies and procedures wherever Leidos operates. Moreover, Leidos also holds its third-party business partners, suppliers, and vendors to the same standards of ethics and integrity.
International Anti-Corruption Policy and Procedures
Through robust policies, procedures and frameworks, the company implements a comprehensive program across our company to ensure compliance with all applicable anti-bribery and anti-corruption laws and regulations. All Leidos personnel and intermediaries that conduct business with Leidos must comply with international Anti-Corruption laws. Key features of the program include oversight of gifts, hospitality, and political and charitable contributions, conducting due diligence merger and acquisition investigations, maintaining accurate books and records, providing accessible general and specific guidance, prohibiting cash and facilitation payments, and requiring employee and third-party training tailored to job function. In addition, Leidos’ International Business policy requires the Leidos International Business Review Board (IBRB) to review international transactions. The IBRB reviewers consist of specialists across the enterprise who review proposed international efforts and provide advice on risk mitigation and contracts procedures in the international environment.
Managing Third-Party Intermediary Risk
The Leidos international anti-corruption program requires close monitoring of third-party intermediaries, including but not limited to:
- Sales representatives,
- Marketing consultants,
- Distributors and resellers,
- Joint venture partners and teaming partners,
- Customs brokers and freight forwarders
- Providers of international sponsorship services, and
- Tax, legal and regulatory advisors representing Leidos in international jurisdiction.
Leidos employs a risk-based model to conduct due diligence reviews and ongoing oversight of third-party intermediaries. Through due diligence reviews, compliance training, and contract terms and conditions, Leidos implements compliance measures commensurate with the particular corruption and bribery risks associated with a business transaction or engagement. Red flags considered in the assessment include:
- Geographical region and country;
- Criminal history (prior convictions, legal enforcement, sanctions, debarment, or penalties);
- Political exposure of the intermediary or parties involved;
- Experience and expertise of the intermediary;
- Degree to which the business activity interaction involves Government Officials;
- Method and amount of compensation (payment to jurisdiction outside the location where services are rendered; transfers to anonymous or numbered bank accounts; cash payments; excessive compensation, fixed retainer payments); and
- Remaining totality of any Red Flags
External Industry Engagement
As mentioned above, Leidos is a member of both the Steering Committee and Working Group of DII, a key industry organization promoting ethical conduct among defense contractors.
Leidos is also a member of The International Forum on Business Ethical Conduct (IFBEC) – a global organization of companies in the aerospace and defense sectors. The IFBEC Global Principles of Business Ethics for the Aerospace and Defense Industry affirm the industry's commitment to ethical business behavior and establishes a uniform set of standards addressing business conduct related to zero tolerance of corruption, use of third-parties, management of conflicts of interest and respect for proprietary information.
Additionally, Leidos is a long-standing member of Trace International, a globally-recognized anti-bribery business association. As a leader in the international business community, Leidos takes its commitment to international anti-corruption and anti-bribery compliance very seriously and is committed to upholding the highest standards and implementing best practices throughout the Leidos compliance program.
Respect for Human Rights
Our mission and our values reflect an unwavering respect for human dignity and fundamental human rights. We condemn human rights abuses and support the United Nations (UN) Guiding Principles on Business and Human Rights. We have a responsibility to respect human rights in the operation of our business, and we adhere to the UN framework to protect and respect human rights and to remedy human rights abuses. We also expect everyone with whom we conduct business to also respect human rights combat human trafficking.
Combating Trafficking in Persons
Consistent with the United Nations Guiding Principles on Business and Human Rights requirements of the Federal Acquisition Regulation Subpart 22.17 and Defense Federal Acquisition Regulation Supplement, the current FAR and DFARS regulations establish general anti‐human trafficking requirements that are applicable to all federal contracts and subcontracts, including the prohibition of specific human trafficking activities and require immediate reporting of such activities to Government authorities. To ensure compliance with these regulations and corporate policies, Leidos implements a compliance plan for the prevention of human trafficking that governs activities under applicable FAR and DFARS contracts.
In accordance with these regulations, Leidos employees, consultants, contractors, subcontractors, and agents performing any work under a federal contract shall not:
Engage in or support trafficking in persons;
Procure commercial sex acts;
Use forced labor in the performance of the contract;
Destroy, conceal, confiscate, or otherwise deny access by an employee to the employee’s identity or immigration documents, such as passports or driver’s licenses;
Use misleading or fraudulent recruitment practices during the recruitment of employees, or misrepresent or fail to disclose information about the key terms and conditions of employment, including wages and fringe benefits, the location of work, living conditions and housing (if housing is provided or arranged), any significant costs to be charged to the employee, and, if applicable, the hazardous nature of the work;
Use recruiters that do not comply with local labor laws;
Charge recruitment fees to employees;
Fail to provide or reimburse return transportation costs upon the end of employment for non-national employees brought into a country for the purpose of working on a U.S. government contract or subcontract;
Provide or arrange housing that fails to meet the host country housing and safety standards; and
Fail to provide a written agreement, if required by law or contract, in the employee’s native language at least five days before the employee departs from his or her country of origin.
Employees, agents, vendors and subcontractors who violate this policy may be subject to disciplinary actions, including but not limited to, removal from the contract, reduction in benefits, or termination of employment or subcontract/agency agreement. Employees, consultants, contractors, subcontractors, and agents working overseas shall also become aware of and comply with that host nation’s laws on this subject.
Any suspected violations must be reported immediately to the Leidos Hotline at 855-753- 4367. Incidents of suspected human trafficking may also be reported to the Global Human Trafficking Hotline at 1- 844-888-FREE and [email protected]. Individuals may freely make such reports without fear of reprisal. Retaliation against individuals for reporting suspected violations is a serious breach of the Leidos Code of Conduct and can result in disciplinary action.