Leidos Holdings Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Leidos indicates it has oversight structures for aligning its engagement activities with its climate strategy, including the Government Affairs Committee, which "supports this engagement for compliance with applicable federal, state, and local laws and ensures all activities are consistent with our overall business strategy, including our climate change strategy." The Corporate Governance and Executive Committee (CGEC) "is responsible for reviewing practices and policies in the areas of corporate responsibility, including safety and protection of the environment," and the Sustainability Working Group (SWG) "establishes strategic guidance for corporate sustainability programs and coordinates with internal stakeholders to promote a consistent sustainability message and strategy." However, we found no evidence of a process for aligning indirect lobbying, and the company does not disclose a public commitment to conduct its engagement in line with Paris Agreement goals, stating "No, and we do not plan to have one in the next two years." While these bodies provide some oversight of direct lobbying alignment, the absence of details on monitoring procedures, criteria for trade association engagement, and a public policy commitment limits the transparency of Leidos’s climate lobbying governance. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Leidos indicates it has oversight structures for aligning its engagement activities with its climate strategy, including the Government Affairs Committee, which "supports this engagement for compliance with applicable federal, state, and local laws and ensures all activities are consistent with our overall business strategy, including our climate change strategy." The Corporate Governance and Executive Committee (CGEC) "is responsible for reviewing practices and policies in the areas of corporate responsibility, including safety and protection of the environment," and the Sustainability Working Group (SWG) "establishes strategic guidance for corporate sustainability programs and coordinates with internal stakeholders to promote a consistent sustainability message and strategy." However, we found no evidence of a process for aligning indirect lobbying, and the company does not disclose a public commitment to conduct its engagement in line with Paris Agreement goals, stating "No, and we do not plan to have one in the next two years." While these bodies provide some oversight of direct lobbying alignment, the absence of details on monitoring procedures, criteria for trade association engagement, and a public policy commitment limits the transparency of Leidos’s climate lobbying governance.

View Sources

Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Leidos provides only limited insight into its climate-related lobbying. The company does identify one concrete legislative vehicle—the “Transportation, Housing and Urban Development, and Related Agencies Appropriations Bill, 2024,” where it supported continued funding for the FAA’s Terminal Flight Data Manager programme—with the stated intent of cutting aviation emissions by keeping aircraft at the gate rather than idling on the taxiway. It acknowledges that it “lobbied Congress” on this matter, giving a single example of both its mechanism (direct lobbying) and its target (the U.S. Congress). Beyond this instance, the disclosures do not name any other climate policies, detail additional lobbying channels such as letters, meetings or trade-association activity, or spell out further policy positions or objectives. As a result, while the company confirms one specific engagement and the environmental outcome it seeks, it leaves the breadth of its climate-policy lobbying, the range of mechanisms used and additional goals largely unexplained.	D