On February 15, 2022 Leidos Holding Inc. (Leidos), a Virginia-based science and technology company, disclosed in a Form 10-K filing with the US Securities and Exchange Commission (SEC) that in late 2021 it had discovered unspecified “activities . . . raising concerns” by its employees, third party representatives, and subcontractors relating to its international operations. Without explaining the nature of these activities in any further detail, Leidos disclosed that it had hired outside counsel to conduct an investigation—overseen by an independent committee of Leidos’ Board of Directors—into whether such activities may have violated the US Foreign Corrupt Practices Act, other potentially applicable laws, or the Company’s Code of Conduct.
Leidos stated that it had voluntarily self-reported the investigation to the US Department of Justice and SEC, and was cooperating with both entities. Finally, Leidos noted that, although it could not anticipate the timing, outcome, or impact of the investigation, “violations of the FCPA and other applicable laws may result in criminal and civil sanctions, including monetary penalties, and reputational damage.”