Ethics & Business Integrity

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 sought to embed ethics into our business culture. EEC members worked closely with line managers to identify and escalate ethics and compliance issues in their organization. EEC members also served 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 Programs. 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 former CEO Roger Krone was elected to the DII Steering Committee and served as Vice Chair. The Chief Compliance Officer served 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 Chief 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.

Leidos’ Ethics and Business Integrity Office is responsible for administering the Ethics and Compliance Program. The 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. 

Access the Code of Conduct

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.

The Chief 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 Compliance Officer, Chief Human Resources Officer and Head of Business Partnerships, Sector Presidents and corporate functional executives.

Corporate Governance and Ethics Committee

The Chief Compliance Officer 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 Business Integrity 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 our CEO delivers opening remarks in the training to reinforce our commitment to ethics, integrity, behavior, and accountability. 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 diversity, equity and inclusion 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 Business Integrity 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, The Chief Compliance Officer 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 Business Integrity 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 Business Integrity 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 Business Integrity 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 Business Integrity 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 seven 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:

1. Their supervisor or other individual in the management chain
2. Their Sector Ethics Director, the Director of Investigations or the Chief Compliance Officer
3. Their local Human Resources representative, the Workforce Solutions Director or the Chief Human Resources Officer
4. The Leidos Helpline, which connects you to an independent third-party provider. You may contact the Helpline by phone or by online submission. Concerns may be reported anonymously.
5. The General Counsel or Chief Security Officer.
6. CEO
7. 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 Helpline, which offers a 24/7 call center and accompanying website where employees and others can voice concerns or ask for guidance. The Ethics and Business Integrity Office is responsible for maintaining this relationship and ensures that the Helpline 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 Helpline phone numbers are posted in common work areas across the enterprise.

The Ethics and Business Integrity Office maintains an Enterprise Case Management System for documenting and tracking investigations. All key investigative functions, including Human Resources, Ethics and Business Integrity, 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 Business Integrity, 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.