Leidos's DEI Employment Practices: What the Company's Own Documents Show — and What They Mean for Employees

Published August 22, 2026 · Last updated August 22, 2026 · By Fett Law — Michigan Employment Discrimination Attorneys

Key facts

Did Leidos tie executive pay to diversity targets?

Yes. In the proxy statement it filed with the Securities and Exchange Commission on March 15, 2023, Leidos Holdings, Inc. told its shareholders that a modifier inside the personal-goals portion of its short-term incentive plan "will be measured against the Company's efforts to increase representation of female and ethnically diverse employees." A year later, the company restated that modifier without the representation measure.

The linkage appears in Leidos's own proxy statement — a document filed with the SEC and mailed to shareholders, under the heading "ESG Role in Annual Cash Incentive":

"The modifier, which is being included as part of the 'personal goals' portion of our short-term incentive plan, will be measured against the Company's efforts to increase representation of female and ethnically diverse employees (measured against the 'Next Level Leidos' goal of a 10% increase by 2030), improve employee retention and engagement metrics, and upskill our technical workforce."

— Leidos Holdings, Inc., 2023 Proxy Statement (DEF 14A, filed March 15, 2023), Proxy Summary, "ESG Role in Annual Cash Incentive" (source)

The same proxy explains the purpose in the company's own words: the changes were intended to "hold our executives accountable for making progress on our commitment to building and reinforcing a strong inclusive culture at Leidos."

In the proxy statement filed the following year, on March 12, 2024, the modifier is described differently. It becomes a "+/- 20% modifier to our short-term incentive plan" that "will be assessed based on personal goals and behaviors," evaluated against "the Company's six core values: integrity, inclusion, innovation, agility, collaboration, and commitment." The representation measure is no longer part of the modifier's stated definition — although the 10%-by-2030 representation goal and the two-diverse-candidates interview goal both still appear in that same 2024 filing's sustainability disclosures.

In plain terms: for the plan year described in the 2023 proxy, part of what senior Leidos executives were paid depended on how the demographic composition of the workforce moved. Executives compensated on that basis set the priorities that recruiters and hiring managers were expected to deliver. How that expectation reached individual hiring and promotion decisions is a question answered by the people who sat in those decisions, not by a filing.

Did Leidos require diverse candidates in hiring and promotion?

Yes. Leidos Holdings, Inc. published a standing enterprise goal to "Interview at least two diverse candidates for all senior management positions" — defined in the company's own footnote as every role classified M3 or higher — and reported its attainment numerically: in 2022, Leidos interviewed two diverse candidates for 237 of 420 such positions.

The goal was one of ten enterprise-wide "Next Level Leidos" 2030 goals adopted in November 2021, and it appears in the company's corporate responsibility and sustainability reporting for four consecutive years, as well as in the proxy statement filed with the SEC in March 2024:

"Interview at least two diverse candidates for all senior management positions**"
"**Senior Management is defined as all roles classified as an M3 or higher in Leidos' job classification system."

— Leidos, 2022 Annual Sustainability Report, p. 22, "Next Level Leidos Progress 2022" and accompanying footnote. The identical goal appears in the 2020 Corporate Responsibility Report, the 2021 Annual Sustainability Report, and the 2024 Proxy Statement (DEF 14A, filed March 12, 2024) (proxy source).

The 2022 report describes the same requirement in expanded form, and adds the protected characteristics explicitly:

"One step on this journey is our goal to interview at least two female and/or ethnically diverse candidates for all senior management positions classified as an M3/P6/T6 or higher to improve representation."

— Leidos, 2022 Annual Sustainability Report, p. 48, "Inclusive hiring and representation."

Unlike most large employers, Leidos published how often the requirement was actually met:

"Leidos interviewed two diverse candidates for 237 out of 420 positions, 56% of positions."

— Leidos, 2022 Annual Sustainability Report, p. 45, "Performance Against Targets." The 2021 report had reported the goal's status as: "We are currently building a roadmap and developing the strategies to meet this goal."

The company also described the tooling built around the goal. Its 2022 report states that Leidos "Provided access to SeekOut, enabling our recruiters to discover talent from underrepresented groups by using diversity filters and a bias reducer to immediately eliminate indicators of race and gender from candidate profiles," and "Continued our women-focused partnership with Fairygodboss, a platform that enhances our searches for female professionals by providing access to a pool of qualified candidates across all industries" (2022 Annual Sustainability Report, p. 48).

Operationally, a two-diverse-candidate interview requirement is a rule about who must appear on an interview list before a senior management role can be filled. Leidos's own numbers say it was applied to 420 senior management openings in a single year and satisfied in 237 of them. Employees and applicants who competed for M3-and-above roles at Leidos during those years were competing inside that rule, whether or not they knew it existed.

Did Leidos set racial or gender representation goals?

Yes. Leidos Holdings, Inc. adopted a public 2030 goal to "Increase representation of women and ethnically diverse employees by 10% by 2030," measured against a fiscal 2021 baseline, and reported annual progress against it. That same goal is the metric named in the 2023 proxy's short-term incentive modifier.

The goal was announced with the Next Level Leidos ESG goal set in November 2021 and published with its baseline definition:

"Increase representation of women and ethnically diverse employees by 10% by 2030*"
"*The baseline for this goal is Fiscal Year (FY) 21 demographics for Leidos employees that identify as female and ethnically diverse."

— Leidos, 2022 Annual Sustainability Report, p. 22 and footnote. The same goal and footnote appear in the 2020 Corporate Responsibility Report, the 2021 Annual Sustainability Report, and the 2024 Proxy Statement (source).

Leidos then reported movement against the goal year by year:

"In 2021, our representation of women was 34%, a 1% increase over calendar year 2020. Representation of ethnically diverse employees was 33.4%, a 1% increase over calendar year 2020."

— Leidos, 2021 Annual Sustainability Report, "Performance Against Targets."

"In 2022, our global representation of women was 35%, a 1% increase from 2021. Representation of ethnically diverse employees in the U.S. workforce was 35%, a 2% increase from 2021."

— Leidos, 2022 Annual Sustainability Report, p. 45, "Performance Against Targets." The report adds that these increases put the company "on track to achieve a 10% increase by 2030" (p. 49).

Two features distinguish this goal from a general aspiration. First, it has a defined numerator, a defined baseline year, and a deadline. Second, the 2023 proxy statement names it as the measure against which part of executive short-term incentive pay was assessed. A numeric demographic goal that is wired to compensation is a target someone is accountable for hitting — and the people best positioned to describe how that accountability was carried into individual decisions are the recruiters, HR staff, and line managers who were given the number.

Did Leidos run programs restricted by race or sex?

Not on the published record reviewed here. Fett Law located no Leidos-published training, mentoring, sponsorship, fellowship, or leadership program whose eligibility was stated to be limited by race or sex. Leidos's own documents describe its employee resource groups and development programs as open, and this page does not claim otherwise.

Leidos's 2022 report describes its nine employee resource groups — among them the African American Leidos Network, the Asian-Pacific Islander Network, the Hispano-Latinx Leidos Asociación, Pride, and the Women's Network — as vehicles through which "all 45,000 global employees" may "participate in professional development and philanthropic opportunities" (2022 Annual Sustainability Report, p. 49). The company's 2019 Corporate Responsibility Report describes the inaugural Women's Leadership Forum hosted by the Women's Network, and records that the organizers "wanted to involve participants from all generations, all levels, and all groups at Leidos," with male executives among the attendees and speakers.

This is stated plainly because the difference matters. Restricted-eligibility programs were one of the four categories of conduct in the IBM settlement, and their absence from Leidos's published record is a real distinction from several other companies documented in this series. It is also a distinction limited to what Leidos chose to publish. Whether any Leidos program, cohort, nomination list, or high-potential slate operated on race or sex in practice is a question about internal records and lived experience, not published reports — and if you were told a Leidos program was not for you, that is worth a conversation.

How Leidos's DEI program changed, 2019–2026

Why these practices matter legally

Title VII of the Civil Rights Act of 1964 prohibits employers from making employment decisions because of race or sex — and it protects every race and both sexes. Practices in which a protected trait operates inside an actual employment decision are what these cases examine.

Two recent Supreme Court decisions sharpened the rule. In Muldrow v. City of St. Louis (2024), the Court held that a plaintiff challenging a discriminatory change in the terms or conditions of employment need show only some harm, not a "significant" disadvantage. In Ames v. Ohio Department of Youth Services (decided June 5, 2025), the Court unanimously rejected the rule that majority-group plaintiffs must clear a higher evidentiary bar to bring a discrimination claim. Separately, 42 U.S.C. § 1981 prohibits race discrimination in the making and enforcement of contracts — including employment — and carries a four-year window with no agency filing requirement. (Statutes: Title VII, § 1981; opinions: Muldrow, Ames.)

For federal contractors there is a second layer. On April 10, 2026, International Business Machines Corporation paid $17,077,043 to resolve allegations — under the Justice Department's Civil Rights Fraud Initiative, in DOJ's first False Claims Act settlement of its kind — that it certified compliance with federal anti-discrimination requirements while operating DEI practices including "a diversity modifier that tied bonus compensation to achieving demographic targets," altered "interview criteria based on race or sex through the use of 'diverse interview slates,'" "race and sex demographic goals for business units," and training, mentoring and leadership programs whose eligibility was "limited on the basis of race or sex" (DOJ press release). DOJ stated that "the claims resolved by the United States in the settlement are allegations only and there has been no determination of liability."

The parallel fact on the nexus side is unusually direct here. Leidos is not a company that happens to hold some federal contracts; it told the SEC that 87% of its fiscal 2025 revenue came from U.S. government contracts. Executive Order 14173, signed January 21, 2025, directs that federal contracts include a term requiring the counterparty "to certify that it does not operate any programs promoting DEI that violate any applicable Federal anti-discrimination laws," and a term making compliance with federal anti-discrimination law "material to the government's payment decisions" for False Claims Act purposes (90 FR 8633).

To be clear about what is and is not established: no court or agency has found that Leidos's practices violated any law, no False Claims Act case or Justice Department inquiry involving Leidos DEI practices has been made public, and the IBM settlement itself resolved allegations without any admission of liability. What can be said is narrower and factual — that three of the four categories of conduct DOJ described in the IBM matter correspond to practices Leidos described in its own SEC filings and published reports. For the complete framework — the four illegal DEI practice categories and when you can sue — see our guide, Is DEI Illegal? 4 Illegal DEI Practices & When You Can Sue.

Were you affected by these practices at Leidos?

If you worked at Leidos Holdings, Inc. — or applied there — between roughly 2019 and 2025, the documented practices above may have touched your career in ways worth examining:

• You were passed over for a senior management role classified M3, P6, or T6 or higher, at a company that required at least two female and/or ethnically diverse candidates to be interviewed for each of those openings and reported meeting that requirement 237 times in a single year.
• You were not advanced from an interview list, or were told a search was being reopened or extended, during years when a published interview-composition requirement applied to the role.
• You were a manager, recruiter, talent-acquisition professional, or HR business partner with first-hand knowledge of how the two-candidate requirement and the 10%-by-2030 representation goal were implemented in actual hiring and promotion decisions.
• You were an executive or people leader whose short-term incentive was assessed, in whole or in part, against progress on increasing representation of female and ethnically diverse employees.
• You were separated or laid off and signed a severance agreement without anyone reviewing whether you were giving up a discrimination claim.

Because Leidos derives the overwhelming majority of its revenue from U.S. government contracts, insiders with knowledge of demographic employment practices during the certification period may also have information relevant to a False Claims Act qui tam claim — a mechanism that lets individuals bring claims on the government's behalf and potentially share in any recovery. Qui tam complaints are filed under seal, so a whistleblower's identity is initially protected. Both Title VII and the False Claims Act prohibit retaliation against people who assert their rights or report violations.

If any of these fits, it costs nothing to find out where you stand — meet our DEI discrimination lawyers, or start below.

What could a claim against Leidos be worth?

Claims arising from practices like those documented at Leidos Holdings, Inc. can carry substantial value: False Claims Act whistleblowers receive 15–30% of any government recovery, individual discrimination cases combine uncapped lost pay with damages that several statutes leave uncapped, and a single companywide policy can support a class action. The figures below are illustrative — not a prediction for any individual case.

Whistleblower rewards under the False Claims Act

Under 31 U.S.C. § 3730(d), a qui tam whistleblower (called a "relator") is entitled to 15–25% of what the government recovers when the Justice Department intervenes, and 25–30% when the relator litigates without government intervention. For scale: on a settlement the size of IBM's $17,077,043, the intervened-case whistleblower share would be roughly $2.6 million to $4.3 million. Because False Claims Act recoveries are built on treble damages plus per-claim penalties, recoveries against very large contractors can run substantially higher.

Damages in individual discrimination cases

Back pay and front pay are uncapped under Title VII. Compensatory and punitive damages under Title VII are capped by employer size — $300,000 for employers with more than 500 employees, the bracket Leidos occupies — but race claims under 42 U.S.C. § 1981 carry no damages caps at all, which is one reason race discrimination cases are often pleaded under it, and many state civil-rights statutes (including Michigan's Elliott-Larsen Civil Rights Act) are likewise uncapped. Prevailing plaintiffs generally recover attorney's fees on top. For a sense of what employment discrimination cases can produce, Fett Law's own results include a $10.5 million race and age discrimination class action against Ford Motor Company, a $1.1 million jury judgment against the Michigan State Police, and a $460,000 reverse-discrimination settlement for three corrections officers. Prior results do not guarantee a similar outcome.

Class action potential

Class actions are built on a single policy applied to many people — and the practices documented above are companywide by design: one interview-composition requirement covering every M3-and-above opening, one enterprise representation goal, one incentive-plan modifier. Historic employment-discrimination class settlements show what such cases can reach: Coca-Cola paid $192.5 million (2000), Texaco $176.1 million (1996), and Novartis $175 million (2010) to resolve class claims.

Every case depends on its own facts — these figures show the range the law makes possible, not a promise of any outcome. The fastest way to learn where your situation falls is to start a confidential intake or request a free consultation.

Frequently asked questions

Sources

Documents below were retrieved and verified in August 2026. Leidos's SEC filings are permanently public on EDGAR. The annual sustainability and corporate responsibility reports are no longer linked from Leidos's own reporting index; copies are held by Fett Law and page citations refer to the PDFs as published.

• Leidos Holdings, Inc., 2023 Proxy Statement (DEF 14A, filed March 15, 2023) — SEC EDGAR
• Leidos Holdings, Inc., 2024 Proxy Statement (DEF 14A, filed March 12, 2024) — SEC EDGAR
• Leidos Holdings, Inc., Annual Report on Form 10-K for fiscal 2025 (fiscal year ended January 2, 2026) — PDF
• Leidos, 2022 Annual Sustainability Report (pp. 22, 45, 48–49) — not currently linked from Leidos's reporting index; copy on file. Publication announcement rehosted at 3BL Media and CSRwire
• Leidos, 2021 Annual Sustainability Report; 2020 Corporate Responsibility Report; 2019 Corporate Responsibility Report — not currently linked from Leidos's reporting index; copies on file
• Leidos, "Leidos announces 2030 sustainability goals" (November 10, 2021) — company page; PR Newswire
• Leidos, "About our Reporting" and the Responsibility & Sustainability hub (current state as of August 2026) — About our Reporting · Responsibility & Sustainability
• Leidos, EEO-1 Employer Information Reports, 2020 and 2024 — linked from the Responsibility & Sustainability page
• U.S. Department of Justice, "IBM Pays $17 Million to Resolve Allegations of Discrimination Through Illegal DEI Practices" (April 10, 2026) — press release
• Executive Order 14173, "Ending Illegal Discrimination and Restoring Merit-Based Opportunity" (January 21, 2025), 90 FR 8633 — Federal Register
• Title VII, 42 U.S.C. § 2000e-2 — statute; 42 U.S.C. § 1981 — statute; False Claims Act, 31 U.S.C. §§ 3729–3733 — statute; qui tam relator shares, 31 U.S.C. § 3730(d) — statute
• Muldrow v. City of St. Louis (2024) — opinion; Ames v. Ohio Dep't of Youth Services (2025) — opinion