: What is the CACI Hotline?: The Hotline is a reporting system that enables an employee to talk confidentially with an independent company, Listen Up about a problem associated with CACI's business practices. Listen Up is a third-party company that is separate and independent of CACI and specializes in running hotline programs for companies throughout the U.S.
Utilizing the Hotline, reports are received, evaluated and, depending on the nature of the report and the channel through which it is made, referred to the General Counsel, the Chairman of the Audit Committee of CACI International Inc's Board of Directors, the Internal Auditor, the Corporate Ombudsman or the Employee Relations Manager for action under CACI's Corporate Compliance Program.
The Hotline provides an opportunity to report compliance issues related to accounting or auditing policies or practices, internal accounting controls, fraud, waste, abuse of authority, gross mismanagement, laws, regulations, CACI's Standards of Ethics and Business Conduct, corporate policy, conflict of interest and security.
: How can I contact the Hotline? : There are two ways
- Call Listen Up at 800-928-3505
- Go to http://www.ListenUpReports.com/, a website managed by SAI Global
: What information should I provide when making a report? : Please be as specific as possible. Your report should provide
- Involved employees' full names, titles and office locations
- What wrongdoing you are reporting
- Why you believe the activity was misconduct
- Specific dates and times
- Specific location where wrongdoing occurred
- How the individual(s) completed the wrongdoing
- Why you believe the individual(s) acted in this manner
: Do I have to identify myself? : While we encourage you to identify yourself, it is not required. It is preferable that you identify yourself so that we may contact you to ask for additional information or clarification of your report so that we have a better opportunity to conduct a meaningful investigation. If you identify yourself to a Hotline investigator your identity will be kept confidential to the extent possible consistent with the obligation to investigate and remediate problems.
: Why can't CACI guarantee that a caller's name will never be known to someone outside of the Hotline program? : There are two reasons why such a guarantee cannot be made
- First, although calls made to the CACI Hotline and the name of the callers will be handled in confidence, the caller's report and name often must be divulged to
those persons responsible for investigating the allegations made, in accordance with CACI's Corporate Compliance Program.
- Second, it is important to understand that, regardless of the measures taken by those investigating a report to keep the caller's name confidential, the fact of
investigating allegations in and of itself could provide an indication as to who made the allegation in the first place.
For example, suppose the administrative assistant to a manager of a five-person team, four of whose members work at remote locations, places an anonymous call to the Hotline alleging that the manager is falsifying timecards.
When the investigation of the allegations comes to the attention of the manager (which it must in the context of a thorough investigation) the manager may be able to deduce who may have made the Hotline call.
We regret the fact that, because of the ability of people to draw inferences from their observations, it is impossible to guarantee that the identity of each Hotline caller will never be guessed. We are committed, however, to the following
- The identity of each Hotline caller, as disclosed to the proper corporate representatives, will be held in confidence.
- We will maintain a strong policy against retaliation. If you have made a Hotline call and suspect that you are the subject of retaliation efforts contact the Ombudsman, the Director of Internal Audit or the General Counsel for assistance.
: What can I expect when I call the Hotline? : A professional interview by the designated GCS investigator. You will be asked to provide information that will help the investigator piece together the facts of the situation (who, what, when, where, why and how) and will help CACI to assess the impact of the alleged wrongdoing. The information you provide will be handled in a confidential manner to the extent possible consistent with the obligation to investigate and remediate problems. All efforts will be made to protect anyone making a report to the Hotline from retaliation.
: How long does it take to conclude action on a Hotline report? : The time required to complete an investigation varies depending on the complexity of the situation and on the amount of additional material or allegations received.
Corporate Compliance Program Frequently Asked Questions
: What is CACI's Corporate Compliance Program? : The Corporate Compliance Program is a set of policies and procedures that provides a systematic means of promoting compliance with our CACI's Standards of Ethics and Business Conduct, laws and regulations. CACI performs substantial work for government agencies and employs a large number of people in interstate commerce. As such, we are subject to a significant amount of oversight aimed at ensuring that we comply with the myriad of laws, regulations and contract terms applicable to our operations. Moreover, because of the serious consequences that accompany a failure to comply with company policy, legal, regulatory and contract requirements, CACI has Standards of Ethics and Business Conduct designed to discover and correct or to prevent compliance failures.
One aspect of the CACI Compliance Program is that we take seriously and investigate any and all allegations of unlawful or improper actions. In this environment it is inevitable that CACI will receive allegations of compliance failures and initiate investigations in accordance with the compliance program. Thus, investigations of alleged wrongdoing are a fact of life in our business and a necessary part of our corporate culture.
Cooperation in any investigation is a requirement for each and every CACI employee as stated in CACI's Standards of Ethics and Business Conduct, and as reflected in CACI Policy and Guidelines, Chapter 3, Section 3013.c(1). Moreover, because investigations are a necessary part of our business, and because in many cases there are legitimate explanations for conduct that appears inappropriate at a distance, we advise employees to cooperate with all investigations and to make efforts not to take personally the allegations that are being investigated.
In the wake of the accounting scandals of 2002, including the Enron and WorldCom matters, it is clear that problems in the areas of accounting policies and practices, internal accounting controls and auditing policies and practices have a unique potential to cause substantial harm. The Hotline provides concerned individuals with assurance that complaints related to such problems receive the special attention of the Audit Committee of the Board of Directors of CACI International Inc.
: Why do we have a Corporate Compliance Program?
: As a publicly owned corporation and government contractor we have an obligation to ensure that our business is conducted in accordance with the highest ethical standards consistent with applicable company policy, laws and regulations, including those related to equal employment and government procurement. The Hotline is the formal, front-end information retrieval system for the Corporate Compliance Program.
: Who is responsible for implementing the Corporate Compliance Program? : The General Counsel, the Internal Auditor, the Employee Relations Director, the Ombudsman and, with respect to accounting and auditing matters, the Audit Committee of our Board of Directors.
: If I am asked to be interviewed am I required to answer questions posed by a representative of the
Corporate Compliance Program?
: Yes. Every employee has an obligation to cooperate and respond fully, promptly and honestly to inquiries made as part of an investigation as stated in CACI's Standards of Ethics and Business Conduct that each employee is required to sign annually.
: Must I report my contact with, or what I said to, a representative of the Corporate Compliance Program to my supervisor or any other management representative?: No.
: Can I voluntarily report my contacts to my supervisor or another management official if I choose? : Yes. You may speak to whomever you choose. Sometimes, however, particularly on sensitive investigations, we will request that you be discrete and that you keep your contact with the Corporate Compliance Program private and confidential.
: What if I am concerned or apprehensive about meeting with a Corporate Compliance Program representative in my office? : If you believe that meeting with a Corporate Compliance Program representative in your office inhibits your ability to cooperate fully or would possibly jeopardize your standing or position with your management the Corporate Compliance Program representative will make arrangements to meet elsewhere.
: How may I report what I perceive to be violation of the Code? : You may report compliance issues in the following ways
- CACI Hotline report by telephone or website
- Telephone or email report to the Employee Relations Director, the Internal Auditor, the Ombudsman or the General Counsel
- Internal memorandum sent to one of the above CACI officials in an envelope marked "confidential"