Ethics and integrity

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Ethics and integrity

Ethics and compliance


As a government contractor, compliant and ethical behavior is in our DNA. We’re known as a company that does the right thing and makes the right decisions. This means understanding our compliance policies and procedures and raising concerns when necessary. Whether we’re delivering exemplary services to our customers or acting with respect and integrity when interacting with our peers and partners, our core values drive our behavior every day.

The ethics and compliance office, part of the Office of General Counsel, serves as an independent resource for information, advice and resolution of problems and issues. Perspecta’s chief of ethics and compliance regularly reports on ethics and compliance matters, including ongoing investigations, to our chairman and chief executive officer, the audit committee and the full board of directors.

Reporting concerns


Ethics issues and concerns can be reported in a variety of ways, including anonymously through our ethics helpline. All concerns raised are treated confidentially and Perspecta will never retaliate against any employee who speaks up honestly and in good faith. We expect our employees to behave with integrity and will hold them accountable if we find misconduct.

Our code of conduct, The Standard, is an extension of our values and reflects our continued commitment to ethical business practices and regulatory compliance. We encourage all employees to reach out to their leadership, another manager, human resources, the ethics and compliance team, the Office of General Counsel, or Security for guidance if they ever confront a situation in which they are uncertain. Individuals can also seek guidance or report a concern anonymously by contacting the Perspecta ethics helpline at 1.855.ETHICS0 or 1.855.384.4270 or filing a report online at perspecta.ethicspoint.com.

Inquiries, concerns, or complaints related to the conduct and/or performance of Perspecta Risk Decision Group investigators—including employees, independent contractors and subcontractors—as it pertains to their work on background investigations should be directed to the Perspecta Integrity Assurance and Contract Compliance team at IA.concerns@perspecta.com or fax them anonymously to 866.775.2323 for reporting and resolution.

Training and outreach


Part of building and maintaining an ethical culture is providing employees with the knowledge they need to understand our policies and procedures, and where to go to seek additional guidance. All new hires are required to complete our ethics awareness course upon joining the company, and all employees are required to complete an annual refresher course. Additionally, we provide employees with annual training related to organizational conflicts of interest, labor charging, preventing workplace harassment, cybersecurity and international compliance topics including export control, anti-corruption and anti-boycott.

Beyond annual training, the ethics and compliance office and other compliance functions regularly provide communications to our employees addressing key compliance areas. Members of the ethics and compliance office regularly provide in-person trainings on a variety of topics, in certain cases tailored to the specific needs of a program or function.

International regulatory compliance


Perspecta supports mission-critical, national security objectives for its customers. Fulfilling customer requirements demands compliance with international trade laws and regulations to ensure individual, corporate and national success. That’s why it is Perspecta’s policy to comply with the international trade laws and regulations of the United States (including, but not limited to, the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR)) and each foreign country in which we operate.

Within the ethics and compliance office, Perspecta has established an International Trade Controls and Compliance Office (ITCO), comprised of empowered officials, technology control officers and associated support staff. Perspecta’s ITCO is responsible for administration of our International Trade Controls and Compliance Internal Control Plan, including maintenance of our international trade compliance training program designed to ensure workforce compliance with applicable U.S. trade laws and regulations as well as Perspecta policies and procedures.

We maintain a corporate culture that rewards compliance with applicable international trade laws and regulations and encourages employees to raise compliance concerns to the highest levels of the company without fear of retaliation. Instances of non-compliance may be reported to applicable enforcement authorities when required or appropriate under applicable law and individuals may be subject to corporate imposed additional training and disciplinary action.

Anti-corruption


It is Perspecta policy to conduct every business transaction with integrity, regardless of differing local manners and traditions, and to comply with the laws and regulations of the United States, particularly the provisions of the Foreign Corrupt Practices Act (FCPA), the United Kingdom Bribery Act of 2010 (UK Bribery Act), the laws and regulations of each country and state in which we operate (except to the extent inconsistent with U.S. law), our code of conduct, and other applicable company policies and procedures.

Accordingly, Perspecta employees may not offer, pay, promise to pay, or authorize the provision of anything of value to either a foreign official or any private party for the purpose of obtaining or retaining a business opportunity. We maintain complete and accurate books, records and accounts to ensure that they cannot be used for purposes of bribery (foreign or domestic) or hiding bribery. At Perspecta, failure to comply with anti-corruption laws, including the FCPA and UK Bribery Act, is considered misconduct and may result in immediate termination.

Enterprise risk management and oversight


In order for Perspecta to identify and mitigate risk exposures, we have established an enterprise risk management (ERM) function to identify risks in the strategic, operational, financial reporting and compliance domains and evaluate the effectiveness of existing mitigation strategies, for Perspecta as a whole, as well as for each operating unit.

The ERM function is led by our chief audit executive who reports directly to the audit committee and coordinates and reviews assessments of internal processes and controls for ongoing compliance with internal policies and legal regulatory requirements. The ERM function periodically reports potential areas of risk to the board of directors and its committees.

The Perspecta compliance and risk leadership council empowers our business and functional areas to create a working environment supporting and reinforcing that strong ethics, compliance and risk management is good business.

The council provides cross-business and functional review of and partnership with the activities of the ethics and compliance office and ERM, as well as review of compliance activities of other organizations including human resources, the office of the chief information officer and security. The council is co-chaired by the chief ethics and compliance officer and chief audit executive, and the executive sponsor of the council is the chief financial officer. Participants in the council include the general counsel, chief human resources officer, chief of staff, chief information officer, chief information security officer, corporate controller and selected senior representatives from our business and functional groups.

Corporate governance


The board of directors adheres to governance principles designed to ensure excellence in the execution of its duties and regularly reviews the company’s governance policies and practices. These principles are outlined in our corporate governance guidelines, which, in conjunction with our articles of incorporation, bylaws, code of conduct, board committee charters and related policies, form the framework for the effective governance of Perspecta. For full details regarding Perspecta’s corporate governance, see our proxy statement.

Guidelines and policies


View our guidelines and policies.

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