Ethics & Compliance
We set the highest professional and personal expectations.
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.
Leidos is known throughout industry for maintaining the highest standards of integrity and ethical behavior. The combination of robust policies, procedures, training and communications creates a comprehensive program, touching every aspect of employee conduct.
We have a strong history of performance that rests on our foundation of integrity. This foundation supports an environment where ethics and compliance is everyone's responsibility. Leidos employees proudly reflect 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.
Leidos has placed ethics at the forefront since its founding in 1969.
Ethical business 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 each group across the enterprise, the EEC seeks to embed ethics into our business culture. It is an important resource and a strong part of the Leidos Ethics and Compliance Program. The EEC exchanges information, discusses best practices, and presents concerns of interest to the enterprise. 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. As one of the early signatories to theDefense Industry Initiative on Business Ethics and Conduct (DII), Leidos is now considered a leader among the nearly 80 companies that comprise the DII. Leidos is also unique in its long history of Board-level ethics oversight. In 1988, the Board of Directors created the Ethics and Corporate Responsibility Committee (ECRC), a committee of board members responsible for reviewing and recommending policies and procedures that maintain a business environment committed to high standards of ethics and 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.
Leidos created a senior management position to oversee the Ethics and Compliance Program in 2005. Today, the Senior Vice President, Chief Ethics & Compliance Officer, reports to our CEO and the Chair of the ECRC. Through comprehensive training, continuous communications and leadership actions, these steps helped to embed our values-based program into everyday activities across the enterprise.
The Leidos Ethics and Compliance Program continuously strengthens 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 worked tirelessly to establish 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 (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 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 Chief Executive Officer, 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 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) is 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 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 our Code 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.
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 directly to employees via email and the Leidos intranet. Employees are encouraged to provide comments and feedback on the intranet announcements and articles to promote a two-way dialogue.
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:
- Their supervisor or other individuals in the management chain
- Their Human Resources representative, the Workforce Solutions Director, or the Chief Human Resources Officer
- The Employee Ethics Council representatives
- The Leidos Hotline at 855-7-LEIDOS (855.753.4367), or by online submission at https://leidos.ethicspoint.com, which connects individuals to an independent third-party provider, EthicsPoint
- The General Counsel, Chief Ethics and Compliance Officer; or Chief Security Officer
- The CEO and Chairman of the Leidos Board.
- The Ethics and Corporate Responsibility Committee (ECRC) Chair or the Audit Committee Chair of the Leidos Board of Directors.
- 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 Leidos values that guides employee behavior. 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 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 include an opening statement from the CEO delivering a strong message on 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 educate 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: do the right thing, every day. Pillars of the campaign include protecting Leidos and customer assets; fostering a safe and healthy work environment; dealing fairly and honestly with customers, third parties, and public officials; conducting international business properly; reporting misconduct; and protecting colleagues from retaliation. Leidos leadership and the Ethics and Compliance Office remain focused on increasing employees' understanding of how the Code translates into day-to-day work experiences.
We integrate privacy into our Code of Conduct and employee training programs.
We integrate privacy protection into our Code of Conduct and customer programs. Protecting information is a commitment we make to our customers and it is an essential part of doing business. Improperly handling sensitive information, even by a single individual, can have serious consequences for our employees, our company and our customers.
The Leidos Information Protection Council (IPC) includes subject matter experts from several corporate functions, including Security, Information Technology, Legal, Export Control, Program Execution, and Communications, as well as from our line businesses. The IPC promotes compliance with laws and regulations, helps protect information from unauthorized disclosure and modification, and promotes collaboration across the enterprise on information security and privacy issues. Our efforts resulted in continuous improvement programs and awareness products such as security, privacy, and Health Insurance Portability and Accountability Act (HIPAA) training modules; and an enterprise communication campaign focused on individual responsibility to protect several categories of sensitive information
History of Ethics at Leidos
- Formed Employee Ethics Council (EEC) - ethic 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
Federal government ethics officers applaud Leidos (legacy SAIC) case resolution process as a best practice. At Leidos (legacy SAIC), ethics cases are assigned and independent case manager and subject matter expert investigator and 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 date repository 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 and ability callers to request a translator 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.