Ethics and Compliance at Booz Allen

Our commitment to ethics, integrity and compliance with laws

Booz Allen’s Ethics & Compliance program ensures the firm and our people engage in and promote ethical behavior and comply with laws and regulations in all jurisdictions where we operate. It also helps us drive business objectives and strategies and enhances our reputation as an ethical and socially responsible company. Our Code of Business Ethics and Conduct and Policies and Programs form the foundation of our program and approach to Ethics and Compliance.

As part of our broader enterprise risk and compliance network, the Ethics & Compliance program covers a broad range of topics including:

Anticorruption and Anti-Bribery
Anti-Money Laundering and Counter-Terrorist Financing
Competition and Antitrust
Data Privacy and Protection
Ethics
U.S. Federal Government Contractor Compliance
Information and Corporate Records Management
International Trade Compliance

Our Ethics & Compliance programs share a common framework to help us achieve our objectives:

Driven by accountable leadership and supported across the firm
Our Board of Directors (through the Audit Committee) and the Chief Ethics & Compliance Officer, supported by leadership at all levels, oversee and are accountable for our commitment to compliance and ethical conduct and the Ethics & Compliance program. This includes providing effective tone-at-the top messaging and adequate resources. The Chief Ethics and Compliance Officer reports to and educates the Audit Committee in person twice annually and additionally as needed on our key compliance areas and initiatives, including risk assessment and audit findings.
Informed through regular risk assessments
Ethics & Compliance coordinates with our enterprise risk management and business teams to proactively identify new compliance risks and conduct comprehensive risk assessments and benchmarking exercises regularly for our key and emerging compliance risk areas. This enables us to identify requirements and risk, determine whether the program is designed to address these requirements and risks, and assess whether the program is operating as designed. Risks identified during these assessments are addressed through tailored program enhancements.
Enabled by standards, controls, tools, and technology
We establish clear, specific, and documented codes (including our Code of Business Ethics and Conduct), policies, procedures, and controls for directing employee behavior. We promote, enable, and strengthen compliance with laws, regulations, and company standards. Using new and better tools and technology grounded in existing business processes—such as recruiting and hiring, bidding for work, onboarding suppliers—we operationalize compliance systems and provide employees with resources.
Engagement through training and awareness
We empower our employees to identify, escalate, and mitigate risks through a mix of firmwide and targeted audience training and awareness. We rely heavily on real-world scenarios and regularly adjust our approach based on participant feedback and industry best practices.
Routinely monitored and audited to ensure appropriate response
We conduct regular compliance monitoring activities to systematically evaluate our programs, monitor trends, and provide independent review to ensure appropriate programmatic and specific response.

All Booz Allen employees are required to report legal or ethical concerns through established firm reporting channels. When notified of a concern, the firm follows our detailed investigative protocols to investigate each allegation of misconduct fully and fairly and assesses and imposes discipline for misconduct. Where appropriate, the firm discloses misconduct to regulatory authorities and escalates issues to senior leadership and the Board of Directors.