Political Activities
Leidos believes that responsible corporate citizenship demands a strong commitment to a healthy and informed democracy through civic and community involvement. With a focus on delivering mission-critical solutions, we generated 87% of revenues for the fiscal year ending December 29, 2023, from U.S. government contracts funded by appropriations enacted by Congress. Furthermore, the business is subject to extensive laws and regulations at the international, federal, state, and local levels. Changes to such laws can significantly affect our business and operations. Given the potential impact public policy can have on our businesses, employees, and customers, Leidos engages with policymakers to advance and protect the company’s and our stockholders’ long-term interests. Consequently, our employees are required to familiarize themselves with, and complete proper training for, applicable laws regarding gifts and lobbying. Employees must also coordinate with the Leidos Government Affairs (LGA) office to support proper disclosure.
Leidos complies with all federal, state, and local laws regarding contributions to political candidates. Leidos has policies and procedures in place, and conducts extensive oversight, to make certain that our political activities and lobbying expenditures are conducted in a legal, ethical, and transparent manner. Under federal law, Leidos is prohibited from making direct political contributions to candidates running for federal office or national political committees. In addition, personal contributions to state and local candidates by Leidos employees, and certain family members, must be approved by Leidos Government Affairs and disclosed in accordance with Leidos policy.
All our political activities, including financial contributions, are made in support of Leidos’ objectives. They are not based on the personal preferences of individual employees, executives, or board members.
Lobbying Activities
In accordance with internal policy regarding lobbying and political activities (reviewed on an annual basis), Leidos Government Affairs leads the company’s engagement in complex federal policy matters, while maintaining the company’s commitment to being a thoughtful and constructive participant in the public policy process.
LGA represent Leidos’ business interests before the U.S. Congress, the Executive Branch, state legislatures, and industry associations to educate, inform, and advocate on behalf of the company, our employees, and our stockholders. This outreach is regulated by federal, state, and local laws. Accordingly, in compliance with the Lobbying Disclosure Act of 1995, as amended, Leidos’ lobbying activities and expenses are disclosed to the U.S. Congress on a quarterly basis. Federal reports disclosing lobbying activity and expenses are available to the public via the Office of the Clerk of the U.S. House of Representatives at lobbyingdisclosure.house.gov.
Leidos Political Action Committee (LPAC)
Leidos provides an opportunity for our employees to voluntarily participate in the political process by joining the LPAC. This non-partisan political action committee keeps employees aware of important issues and decisions made by government officials that can affect our business. It also allows our employees to pool their financial resources to support political candidates, campaigns, and committees to promote the best interests of the company, our stockholders, and employees. Under the Federal Election Campaign Act, Leidos may use its general treasury funds to pay the establishment, administration, and fundraising costs of the LPAC but does not contribute funds to LPAC’s disbursement account. Members of the LPAC may choose to direct their contributions to a specific political party. If the LPAC member has no political preference, their contributions will be allocated according to the bipartisan LPAC Candidate Giving Criteria.
LPAC Governance
In accordance with its bylaws, the LPAC is overseen by a Board of Directors appointed by the Chief Executive Officer consisting of no fewer than seven (7) senior company leaders representing all aspects of the company. The Board of Directors approves contributions to candidates and committees based on the LPAC Candidate Giving Criteria and reviews all contributions periodically for violations of the criteria. The Board of Directors also ensures all contributions made by the LPAC are reported to the Federal Elections Commission in accordance with LPAC bylaws and federal law. Those reports can be reviewed at fec.gov.
The LPAC Candidate Giving Criteria include, but are not necessarily limited to:
- The integrity and character of the candidate
- The candidate’s position and voting record on business-related issues and/or economic questions of national and international importance
- Whether or not the candidate holds a leadership or policy-shaping position in his or her party on a legislative committee or is likely to hold such a position in the future
- The nature and strength of the candidate’s opposition in the primary or general elections
- Financial need and other sources of financial assistance available to the candidate
- The candidate represents a jurisdiction in which Leidos has facilities, business interests, or employees
In the event of a violation of the integrity and character criterion, contributions to candidates may be paused according to the following process:
As part of our commitment to full transparency, a detailed list of LPAC disbursements to candidates, parties and committees is available here:
Leidos does not use any LPAC or corporate funds to contribute to 527 groups, such as governors associations and super PACs, or make independent political expenditures in direct support of or opposition to political campaigns. In addition, Leidos does not use any LPAC or corporate funds to make any contributions to state or local candidates and does not make payments to influence the outcome of ballot measures.
Voluntary Political Participation by Employees
Leidos values the right and responsibility of our employees to participate in the political process. Such participation is entirely a matter of personal choice. Employees are free to engage in the political process in a variety of ways, such as through personal contributions or by volunteering their personal time to candidates or organizations of their choice. These activities, however, must not suggest Leidos’ support, be conducted on company time, or involve the use of any company resources, such as telephones, computers, supplies, or other employees’ time. In addition, employees may not make or commit to political contributions on behalf of Leidos. The company will not reimburse or otherwise compensate an employee for their personal political contributions. While Leidos encourages employees to voluntarily engage in the political process, they must notify Leidos Government Affairs before running for political office or accepting an appointment to any government office.
Participation in Trade Associations
Leidos belongs to several trade associations. These trade associations advocate on major public policy issues of importance to the company and our employees. Our participation as a member of these associations comes with the understanding that we may not always agree with all the positions of an association or its other members, and that we are committed to voicing our concerns as appropriate through Leidos Government Affairs and Leidos leaders who interact with these associations. The Leidos Government Affairs team regularly evaluates our trade association memberships to ensure our participation in these organizations is consistent with our corporate values and business interests on key issues. We also publish a list of member organizations where our dues and other contributions exceed $50,000.
Our trade association policy can be found here:
Board’s Role in Oversight of Political Activities
The Leidos Board of Directors reviews company political engagement and the operations of the Leidos Political Action Committee (LPAC) at least annually. In addition, the Corporate Governance and Ethics Committee of the Board, which is comprised exclusively of independent directors, reviews our political engagement efforts, including political contributions and trade association spend, to ensure alignment with Company policy and our overall values. The Committee also reviews the Company’s policies, guidelines and compliance with respect to political activities.