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FLUOR 14/10/06 HTTP://WWW.FLUOR.COM/PAGES/DEFAULT.ASPX

FINAL ASSESSMENT

FLUOR CORPORATION

The following pages contain the detailed scoring for your company based on

public information.

The following table represents a summary of your scores:

Topic Number of

questions

% score based

on public

information

Leadership, Governance and

Organisation

10 90%

Risk Management 5 70%

Company Policy and Codes 12 83.3%

Training 5 90%

Personnel and Helplines 7 78.6%

Total 39 83.3%

TI understands that the company is not involved in offsets and has therefore removed the two relevant

questions (A13a and A13b).


A1:

Does the company publish a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company?

Score:

2

Comments:

Based on public information, there is evidence available of several strong statements from the Chairman and CEO supporting the company’s ethical culture and strongly advocating against corruption and unethical practices across the company. These include video statements addressing the CEO’s personal support of and investment in the ethics/anti-corruption agenda.

References:

Public:

Sustainability Report (2012), Message from Chairman and CEO:

‘While it’s important for our business conduct to be defined by “doing things right,” it’s

essential that our business conduct be known for “doing the right things.” Fluor’s history is

built on adherence to strong ethics, compliance and business practices— it is a critical

element of the Fluor culture. We have willingly accepted highly visible, global leadership

roles in promoting and improving ethical standards and work everyday to improve

transparency and eliminate corrupt practices broadly across industries and geographies.’

http://www.fluor.com/SiteCollectionDocuments/2012-fluor-sustainability-report.pdf

Partnership Against Corruption Initiative website, Statement by Chairman and CEO:

‘Corruption cannot be addressed solely by Governments and NGOs. We believe

international business must play a decisive role, which is why the company is a global leader

in battling the bribery and corruption that unfortunately still permeate much of the

engineering and construction industry.’

http://www.weforum.org/issues/partnering-against-corruption-initiative


http://www.weforum.org/issues/partnering-against-corruption-initiative


2013, Letter of support for the UN’s Global Compact:

‘Our commitment to transparency is outlined each is Fluor’s sustainability report…’.

http://www.fluor.com/SiteCollectionDocuments/Fluor-UN-Global-Compact-CEO-

Commitment-of-Continued-Support.pdf

2013, Code of Business Conduct and Ethics, p.5: a letter addressed to "Colleagues"

http://www.fluor.com/sustainability/ethics_compliance/Pages/the_code.aspx

Code of Business Conduct and Ethics (October 2014):

Letter from the Chief Executive.

http://www.fluor.com/SiteCollectionDocuments/HR700.pdf

http://www.fluor.com/SiteCollectionDocuments/Fluor-UN-Global-Compact-CEO-Commitment-of-Continued-Support.pdf





A2:

Does the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company?

Score:

2

Comments:

Based on public information, there is evidence that the Chairman and CEO demonstrates a strong external facing commitment to ethics and corruption. He is a member/chair of initiatives for anti-corruption and has also written and spoken about promoting anti-corruption measures and practices in various public forums, such as the PACI initiative, WEF’s anti-corruption initiative. Video statements illustrating the CEO’s personal commitment to the anti-corruption agenda are also available.

References:

Public:

Fluor Website, Leadership Profiles:

‘As chief executive officer, Mr. Seaton is committed to maintaining Fluor's commitments in the areas of ethics and compliance, integrity and anti-corruption. He is an active leader and board member of the World Economic Forum's Partnering Against Corruption Initiative, the co-chair of the Forum's Global Agenda Council on Corruption, and the chairman of the PACI Vanguard initiative.’

http://www.fluor.com/about_fluor/leadership/Pages/LeaderDetailPage.aspx?leaderID=11

‘During 2012 I was honored to co-chair the B20 Task Force on Improving Transparency and

Anti-corruption. Fluor remains committed to active leadership and participation with the

B20 executive leaders from the international business community to advise and recommend

concrete actions the government leaders of the G20 summits can take to combat

corruption.’


Blogs and write ups by CEO on corruption:

‘Are we making a difference against corruption’




http://forumblog.org/2013/01/are-we-making-a-difference-against-corruption/

Video Blog on anti-corruption forum:

http://www.weforum.org/videos/dalian-2011-david-seaton-fluor-corporation

Speech and Discussion on anti-Corruption at PACI 2014:

‘Designing Corruption out of the system’

http://www.youtube.com/watch?v=hzgs0MxrAY4

Video statements from Chairman/CEO:

http://www.fluor.com/sustainability/ethics_compliance/Pages/ethical-leadership.aspx

http://forumblog.org/2013/01/are-we-making-a-difference-against-corruption/

http://www.weforum.org/videos/dalian-2011-david-seaton-fluor-corporation

http://www.youtube.com/watch?v=hzgs0MxrAY4

http://www.fluor.com/sustainability/ethics_compliance/Pages/ethical-leadership.aspx


A3:

Does the company’s Chief Executive Officer demonstrate a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the CEO demonstrates a strong internal commitment to the anti-corruption agenda, for example direct involvement with staff, speaking at training events, etc. The Sustainability reports do mention a comprehensive internal communications programme; however, they do not directly mention the CEO – only, in case of the 2010 report, ‘executives’. The Fluor CEO and Chairman does publish a letter addressed to ‘Colleagues’ which is included in the company ethics handbook; however, this type of involvement is not assessed to be sufficiently active.

References:

Public:

TI notes:


Letter from the Chief Executive


Fluor Compliance and Ethics Hotline:

https://secure.ethicspoint.com/domain/media/en/gui/35334/index.html

Fluor Sustainability Report (2012), p.25:

‘Our culture of integrity is smong ourmost valuable assess. Therefore sustaining a comprehensive communications program for both internal and external audiences is essential. Company leadership stressed the importancs of ethics to our employees through a variety of communications channels during 2010, including face-to-face meetings, web confernces and Fluor’s robust intranet site for our employees worldwide.’

http://www.fluor.com/SiteCollectionDocuments/2010_Fluor_Sustainability_Report.pdf





Sustainability Report (2012), p.12:

‘Our culture of integrity is among our most valuable assets. Therefore sustaining a comprehensive communications program for both internal and external audiences is essential. Company leadership stressed the importancs of ethics to our employees through a variety of communications channels during 2010, including face-to-face meetings, web confernces and Fluor’s robust intranet site for our employees worldwide.


Code of Business Conduct and Ethics (2013), p.5: a letter addressed to "Colleagues" http://www.fluor.com/sustainability/ethics_compliance/Pages/the_code.aspx




A4:

Does the company publish a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability?

Score:

2

Comments:

Based on public information, there is evidence that the company publishes statements representing its values, ethics and belief in a transparency and ethics in business. It also re-enforces the same with specific statements on anti-corruption.

References:

Public:


‘our strong commitment to ethics throughout our business helps drive responsible behavior, maintain our corporate reputation and enhance our financial performance”

We use a comprehensive ethics and compliance program that guides our employees, business partners, suppliers and subcontractors. This dynamic program involves leadership and oversight, risk assessments, policies and procedures, extensive communication and training programs, monitoring, reporting and other initiatives. We continually improve and enhance our ethics and compliance program by monitoring our company, industry and the global business community.’


Fluor Company Website:

‘Fluor's objective is to create value for all of its stakeholders, including shareholders, clients, employees, and the communities where Fluor employees live and work. Good corporate governance standards that promote the principles of integrity, transparency, and accountability will protect and likely enhance Fluor's stakeholder value. Fluor believes good business practices, transparency in corporate financial reporting, and the highest levels of corporate governance are essential components of the company's success.’

http://www.fluor.com/sustainability/corporate_governance/Pages/default.aspx


http://www.fluor.com/sustainability/corporate_governance/Pages/default.aspx


‘Fluor strives to move beyond compliance with laws and regulations, approaching ethics issues proactively. We continually improve and enhance our ethics and compliance program by monitoring evolving risks and benchmarking best practices in our company, our industry and the global business community.

Fluor believes collective action is critical to affect positive change. Fluor takes a leadership role in external initiatives focused on eliminating corruption and bribery, creating a level playing field for business and engaging governments through collective action.

Fluor holds itself to high standards of ethics going beyond compliance with the law. Fluor's commitment is simply this: to do the right thing. Fluor has developed standards, including the Code, and works to ensure that its employees have the tools, knowledge, and resources to adhere to them.’

http://www.fluor.com/sustainability/ethics_compliance/Pages/default.aspx

http://www.fluor.com/sustainability/ethics_compliance/Pages/default.aspx


A5:

Does the company belong to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company is a member of several initiatives promoting anti-corruption and ethics in business. The initiatives are UN Global Compact, Global Reporting initiatives, Founding the World Economic Forum’s (WEF’s) Partnering Against Corruption Initiative (PACI), and the company Chairman is also co-chair of the B20 task force in Improving Corruption & Transparency.

References:

Public:


Gives membership and partnerships with anti-corruption initiatives: PACI, UN Global

Compact




A6:

Has the company appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda?

Score:

2

Comments:

Based on public information, there is evidence that the company has appointed an Ethics and Compliance Committee that reports directly to the Board on matters of ethics and corruption.

References:

Public:

Fluor, Corporate Governance Guidelines:

Roles and responsibilities of the Board:

‘Overseeing the companies integrity & ethics, and compliance with laws’

Compliance and Ethics Committee Charter:

‘The Compliance and Ethics Committee shall: • Facilitate the development, implementation and operation of an effective compliance and ethics program; • Promote an organizational culture that encourages law abiding and ethical conduct; and • Consider and resolve any issues of interpretation regarding any aspect of the compliance and ethics

program.’

http://www.fluor.com/sustainability/ethics_compliance/documents/charter_committee.pdf

Detailed structure of Ethics and Compliance on company website:

http://www.fluor.com/sustainability/ethics_compliance/Pages/fluors_compliance_ethics_program_structure.aspx






A7:

Has the company appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board?

Score:

2

Comments:

Based on public information, there is evidence that the company has appointed the Vice President of Corporate Compliance as the person responsible for implementing the company’s ethics and anti-corruption agenda. This person responsible also has a direct line reporting to the Board and is identifiable by name, as illustrated below.

References:

Public:

Detailed structure of Ethics and Compliance on company Website:


Company Website, Details about Fluor Leadership Team:

‘Wendy Hallgren serves Fluor Corporation as its vice president of Corporate Compliance. Her responsibilities include planning, directing, and managing the company’s comprehensive compliance and ethics program, including its Code of Business Conduct and Ethics, corporate policies and compliance with applicable law. She also has responsibilities relating to the integrity of the company’s financial statements, including acting as a member of Fluor’s Disclosure Committee and supporting the Audit Committee of the company’s Board of Directors.’






A8:

Is there regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda?

Score:

2

Comments:

Based on public information, there is evidence that the company has a formal Board level process of reviewing and updating the company’s ethics codes and agenda. TI has concluded that the Ethics Committee and the Audit Committee review the Code of Conduct annually and propose any major changes to the Board.

References:

Public:

Compliance and ethics committee charter (2014):

’Audit and monitor adherence to the Company compliance and ethics-related policies and

procedures, including, but not limited to, reviewing the Company’s Business Ethics and

Conduct certification process.’

‘Monitor developments in applicable legal and regulatory standards, industry practice, and

general best practices relating to compliance and ethics programs.

• Review effectiveness of the compliance and ethics program under applicable legal and

regulatory standards, including the effectiveness of policies and procedures, training,

auditing, monitoring, reporting, investigations, discipline, disclosure, and the awareness and

promotion of an ethical culture in the organization.

• Evaluate the sufficiency of the Ethics Hotline, including reviewing the performance of, and

selecting, the outsourced organization used to manage the program and the communication

of its availability to employees.’

‘The Compliance and Ethics Committee shall report to the Chief Executive Officer and to the

Audit Committee, at least quarterly, by describing:

• the operation, contents and effectiveness of the compliance program;’


‘The Compliance and Ethics Committee shall report to the Chief Executive Officer and to the Audit Committee, at least quarterly, by describing…the operation, contents and effectiveness of the compliance program, and alleged compliance and ethics violations…’

http://www.fluor.com/sustainability/ethics_compliance/Documents/charter_committee.pdf

Audit Committee Charter (2007), p.4:

The Charter states that one of the Committee’s tasks is to ‘Review and assess the Company's codes of conduct and ethics that are applicable to employees and management, at least annually, and recommend proposed material changes to the Board of Directors for approval.’

http://www.fluor.com/sustainability/ethics_compliance/Documents/cg_audit_committee_charter.pdf

Company Website Section on Program Structure of Ethics & Compliance Initiative:

‘Fluor's Board of Directors is committed to Fluor maintaining an effective compliance and

ethics program. They delegated Board oversight to the Audit Committee, executive

oversight to Fluor's Chief Financial Officer, and appointed a Vice President of Corporate

Compliance to oversee the day-to-day activities of the program. The Vice President of

Corporate Compliance meets with the Board and Audit Committee on at least a quarterly

and annual basis to provide updates on the program. A Compliance and Ethics Committee

was formed to provide assistance to the company's management and the Audit Committee

to enable Fluor to continue to operate according to the highest ethical business standards

and in accordance with applicable laws.’


Annual Report (2013), p.52:

‘Fluor Code of Ethics

We have long maintained and enforced a Code of Business Conduct and Ethics that applies to all Fluor officers and employees, including our chief executive officer, chief financial officer, and principal accounting officer and controller. A copy of our Code of Business Conduct and Ethics, as amended, has been posted on the ‘‘Sustainability’’ — ‘‘Compliance and Ethics’’ portion of our website, www.fluor.com.

We have disclosed and intend to continue to disclose any changes or amendments to our code of ethics or waivers from our code of ethics applicable to our chief executive officer, chief financial officer, and principal accounting officer and controller by posting such changes or waivers to our website.’

http://phx.corporate-







http://phx.corporate-ir.net/External.File?item=UGFyZW50SUQ9MjI0OTYxfENoaWxkSUQ9LTF8VHlwZT0z&t=1


ir.net/External.File?item=UGFyZW50SUQ9MjI0OTYxfENoaWxkSUQ9LTF8VHlwZT0z&t=1



A8(a):

Is there a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and evidence of improvement plans being implemented when issues are identified?

Score:

2

Comments:

Based on public information, there is evidence that the company has a Board level process of reviewing and updating the company’s ethics codes which is based on a written plan specifying factors to be take into consideration.

References:

Public:

Company Website Section on Program Structure of Ethics & Compliance Initiative:

‘Fluor has a multi-faceted Ethics and Compliance Program that guides our employees, joint venture partners, suppliers and subcontractors and other business partners. This dynamic program involves leadership and oversight, risk assessments, policies and procedures, communication and training programs, monitoring, reporting, and other initiatives. Fluor strives to continually improve and enhance our ethics and compliance program by monitoring our evolving risks including any strategic changes (e.g., new markets, businesses, etc.) and benchmarking best practices in our company, our industry, and the global business community.

Fluor's Board of Directors is committed to Fluor maintaining an effective compliance and ethics program. They delegated Board oversight to the Audit Committee, executive oversight to Fluor's Chief Financial Officer, and appointed a Vice President of Corporate Compliance to oversee the day-to-day activities of the program. The Vice President of Corporate Compliance meets with the Board and Audit Committee on at least a quarterly and annual basis to provide updates on the program. A Compliance and Ethics Committee was formed to provide assistance to the company's management and the Audit Committee to enable Fluor to continue to operate according to the highest ethical business standards and in accordance with applicable laws.’





Ethics and Compliance Committee Charter, p.2:

‘Review results of investigations regarding alleged compliance and ethics violations, and determine any new or changed controls to better detect, and prevent reoccurrence of, similar future violations.’

‘Evaluation of program effectiveness

Monitor developments in applicable legal and regulatory standards, industry practice, and general best practices relating to compliance and ethics programs.

Review effectiveness of the compliance and ethics program under applicable legal and regulatory standards, regulating the effectiveness of policies and procedures, training, auditing, monitoring, reporting, investigations, discipline, disclosure, and the awareness and promotion of an ethical culture in the organization.

Evaluate the sufficiency of the Ethics Hotline, including reviewing the performance of, and selecting, the outsourced organization used to manage the program and the communication of its availability to employees.’



‘We continually improve and enhance our ethics and compliance program by monitoring our evolving risks and benchmarking best practices in our company, industry and the global business community’.






A9:

Does the company have a formal process for review and where appropriate update its policies and practices in response to actual or alleged instances of corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company has a process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

References:

Public:

Compliance and ethics committee charter:

‘The Compliance and Ethics Committee shall report to the Chief Executive Officer and to the Audit Committee, at least quarterly, by describing:

• the operation, contents and effectiveness of the compliance program; and

• alleged compliance and ethics violations as set forth in the Fluor Corporation Audit Committee Policy Regarding Receiving Complaints.’

‘Investigations

• Establish procedures to ensure that alleged compliance and ethics violations are appropriately investigated by the proper personnel in accordance with applicable laws and regulations and Company policies and procedures.

Discipline for Violations

• Review results of investigations regarding alleged compliance or ethics violations and discipline taken to ensure the discipline is appropriate to the violation and to maintain consistency.

Disclosure of Violations

• Implement a process to determine if violations of laws or regulations or Company policies or procedures should be reported to appropriate governmental officials, internal committees or the Board.’


‘Review the status and disposition of Ethics Hotline calls, internal management reports regarding compliance and ethical conduct violations, and any other sources from which alleged compliance or ethical conduct violations may result.’

Sustainability report: ‘In all cases where the reports were substantiated, disciplinary and/or corrective actions were taken.’

Compliance and Ethics Council Charter:

‘Reviewing results of investigations regarding alleged compliance and ethics violations, and determine and implement any new changed controls to better detect, and prevent reoccurrence of, similar future violations.’

http://www.fluor.com/sustainability/ethics_compliance/Documents/charter_council.pdf

http://www.fluor.com/sustainability/ethics_compliance/Documents/charter_council.pdf


A9(a):

Does the company have a formal anti-corruption risk assessment procedure implemented enterprise-wide?

Score:

1

Comments:

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise wide. However, there is no readily available evidence of mitigation plans with clear ownership and timelines. The company therefore scores 1.

References:

Public:

Company website:

‘Fluor Ethics and Compliance

Fluor strives to move beyond compliance with laws and regulations, approaching ethics

issues proactively. We continually improve and enhance our ethics and compliance program

by monitoring evolving risks and benchmarking best practices in our company, our industry

and the global business community.’

http://www.fluor.com/sustainability/ethics_compliance/pages/default.aspx


‘Our Management Approach

We use a comprehensive ethics and compliance program that guides our employees,

business partners, suppliers and subcontractors. This dynamic program involves leadership

and oversight, risk assessments, policies and procedures, extensive communication and

training programs, monitoring, reporting and other initiatives.’

(p.13):

‘Fluor employs robust risk-management programs throughout the company to meet the

challenges inherent in an industry with a fluid project base and quickly evolving risks. We

http://www.fluor.com/sustainability/ethics_compliance/pages/default.aspx


utilize a formalized and systematic process for assessing, managing and monitoring the

company’s business risks related to projects, investments and acquisitions. For both our

own company and our clients, the job of managing risk and identifying opportunities begins

when a project is still a prospect. We seek the “root causes” when identifying events that

may go wrong during project execution. We will not pursue a project if we determine it

cannot be executed without violating our ethics and compliance standards . We proactively

develop and monitor mitigation strategies for risks with the potential to affect our

stakeholders.’



‘Assess the risk of non-compliance with applicable laws or regulatoins and of unethical

conduct by employee and third parties, including independent agents, partners,

subcontractors and suppliers.’

http://www.fluor.com/sustainability/ethics_compliance/Documents/charter_committee.pd

f





A10:

Does the company have a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied?

Score:

1

Comments:

Based on public information, there is evidence that the company has a formal process to review risks related to its ethics and compliance codes before implementing a project and prior to engaging with third parties. However, TI assesses that there is limited evidence available concerning the application of this process and in particular the business decisions to which it applies. The company therefore scores 1.

References:

Public:


‘Fluor employs robust risk-management programs throughout the company to meet the

challenges inherent in an industry with a fluid project base and quickly evolving risks. We

utilize a formalized and systematic process for assessing, managing and monitoring the

company’s business risks related to projects, investments and acquisitions. For both our

own company and our clients, the job of managing risk and identifying opportunities begins

when a project is still a prospect. We seek the “root causes” when identifying events that

may go wrong during project execution. We will not pursue a project if we determine it

cannot be executed without violating our ethics and compliance standards. We proactively

develop and monitor mitigation strategies for risks with the potential to affect our

stakeholders.’


Company website:

‘Supplier Expectations

Fluor Expects Its Third Parties to Maintain the Highest Standards of Integrity

Clients depend on us to bring our ethical culture and innovative programmatic solutions to



the delivery of their projects around the world. Fluor engages with Clients, business partners, suppliers, subcontractors, agents and other third parties on ethics and compliance as part of our regular business processes. Fluor seeks to do business with third parties who share our standards and values. We conduct risk-based due diligence when selecting a third party, and monitor red flags during our business relationship. Depending on the type of third party, we embed various requirements and processes to emphasize and mitigate applicable anti-corruption risks.

Fluor limits the number of third party agents by relying primarily on our internal sales staff. We do not have a commission based sales structure, which contributes greatly to the management of corruption risks. We also limit the number of employees who are permitted to have contact with third party agents. Agents are required to certify periodically to their adherence of our anti-corruption requirements.’

http://www.fluor.com/sustainability/ethics_compliance/pages/supplier_expectations.aspx

‘Business Risk Management Framework

Abstract

Fluor's Business Risk Management Framework is a formalized and systematic process for assessing, managing, and monitoring Fluor's business risks. Fluor uses the process to systematically and continuously identify, analyze, and respond to risk and opportunity throughout the project’s life cycle, beginning with the FEED phase through start-up and operation. Fluor has taken its extensive industry experience and proven techniques, established a uniform process, and refined the ability to conduct disciplined reviews for identifying risks, defining mitigation strategies, and managing risks appropriately.

The identified risks are qualitatively rated based on the severity of the potential consequences as well as the likelihood of the event, and prioritized accordingly. Mitigation strategies are researched and evaluated for capability, feasibility, cost effectiveness, and preference. Common mitigation strategies include avoiding, transferring, reducing, and accepting the risk and its consequences. Once the preferred strategies have been selected, cost and benefit opportunities are evaluated, detailed action plans are documented along with due dates and responsible parties, and the plan is reviewed and approved by management. To promote effectiveness, risk data are gathered and analyzed as required to provide updates on a routine basis.’

http://www.fluor.com/about_fluor/corporate_information/technologies/pages/technology-info.aspx?tid=99&bsl=project%20management





A11:

Does the company conduct due diligence that minimises corruption risk when selecting or reappointing its agents?

Score:

1

Comments:

Based on public information, there is evidence that the company does conduct due diligence on appointment with agents. However, it is not clear whether this due diligence is refreshed at least every three years or when there is a significant change in the business relationship. The company therefore scores 1.

References:

Public:

Fluor Company Website, Section on supplier expectations:

‘Fluor seeks to do business with third parties who share our standards and values. We conduct risk-based due diligence when selecting any third party, and continuously monitor red flags during our business relationship. Depending on the type of third party, we embed various requirements and processes to emphasize and mitigate applicable anti-corruption risks.’


Fluor Human Resources Policy, HR 720 (October 2011), Anti-Bribery and Corruption:

‘It is the company's policy to do appropriate due diligence and monitoring of agents [...] before and while conducting business with them’

‘Due diligence and monitoring: it is the company's policy to do appropriate due diligence

and monitoring of agents, joint venture partners, suppliers, contractors and other third

parties before and while conducting business with them. Elements of "appropriate" depend

on the appearance of any "red flags," including but not limited to the location and the

nature of the services provided by Fluor (high risk countries require special diligence);

transactions with foreign governments or their agencies; transactions involving high dollar

value projects; and agents, joint venture partners, suppliers or contractors who are based in

countries that do not prohibit bribery.



The company's law department has established due diligence procedures for agents and joint venture partners, and must review all agreements, The Company's Procurement and Contract functional groups have established due diligence procedures for suppliers and contractors as part of the prequalification of bidders or request for proposal processes. Procurement and Contracts employees must always be involved in any dealings with our suppliers or contractors. The Company requires that all results of due diligence reviews be documented and recorded.’ http://www.fluor.com/SiteCollectionDocuments/in_abac_policy.pdf

http://www.fluor.com/SiteCollectionDocuments/in_abac_policy.pdf


A12:

Does the company have contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company does have processes and also contractual specifications for control and audit of agents with respect to preventing corrupt practices.

References:

Public:

Fluor Company Website, Section on supplier expectations:

‘Fluor seeks to do business with third parties who share our standards and values. We

conduct risk-based due diligence when selecting any third party, and continuously monitor

red flags during our business relationship. Depending on the type of third party, we embed

various requirements and processes to emphasize and mitigate applicable anti-corruption

risks.’


Fluor HR AC policy:

‘Fluor employees [...] and any agents [...] are strictly prohibited from paying a bribe to, or

receiving a bribe from, ANY third party, public or private.’

‘Compliance with this policy is mandatory.’

‘Violations of this policy may result in disciplinary action up to and including termination.’

‘All agents [...] acknowledge an understanding of and agree to comply with applicable anti-

corruption laws and Fluor's Business Conduct and Ethics Expectations for Suppliers and

Contractors. The company should retain the right to terminate its relationship if the third



party is not fulfilling these requirements.’

‘Due diligence and monitoring: it is the company's policy to do appropriate due diligence

and monitoring of agents, joint venture partners, suppliers, contractors and other third

parties before and while conducting business with them. Elements of "appropriate" depend

on the appearance of any "red flags," including but not limited to the location and the

nature of the services provided by Fluor (high risk countries require special diligence);

transactions with foreign governments or their agencies; transactions involving high dollar

value projects; and agents, joint venture partners, suppliers or contractors who are based in

countries that do not prohibit bribery.

The company's law department has established due diligence procedures for agents and

joint venture partners, and must review all agreements, The Company's Procurement and

Contract functional groups have established due diligence procedures for suppliers and

contractors as part of the prequalification of bidders or request for proposal processes.

Procurement and Contracts employees must always be involved in any dealings with our

suppliers or contractors. The Company requires that all results of due diligence reviews be

documented and recorded.’


A13:

Does the company make clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance?

Score:

2

Comments:

Based on public information, there is evidence that the company does make clear to contractors and suppliers its policies and codes on corruption and also the potential consequences associated with breaching the same.

References:

Public:

Fluor's Business Conduct and Ethics Expectations for Suppliers and Contractors:

‘Fluor maintains zero tolerance for bribery and expects our suppliers and contractors to do the same.’

‘Failure to act in a manner consistent with these expectations may impede our ability to do business again in the future.’

http://www.fluor.com/SiteCollectionDocuments/BRHQ056009_Supplier_Expectations.pdf

Fluor HR AC Policy:

‘All contractors, and suppliers [...] acknowledge an understanding of and agree to comply with applicable anti-corruption laws and Fluor's Business Conduct and Ethics Expectations for Suppliers and Contractors. The company should retain the right to terminate its relationship if the third party is not fulfilling these requirements.’



A13(a):

Does the company explicitly address the corruption risks associated with offset contracting?

Score:

NA

Comments:

The company has informed TI that it does not engage in offset contracting.

References:

NA


A13(b):

Does the company conduct due diligence that minimises corruption risk when selecting its offset partners and offset brokers?

Score:

NA

Comments:

The company has informed TI that it does not engage in offset contracting.

References:

NA


A15:

Does the company have an anti-corruption policy that prohibits corruption in its various forms?

Score:

2

Comments:

Based on public information, there is evidence that the company has an anti-corruption policy. It also provides in details regarding the various forms of bribery to guide employees.

References:

Public:

Code of Business Conduct and Ethics, p.33:

‘Zero Tolerance for Bribery

In many parts of the world, paying bribes to win business contracts is unfortunately both accepted and expected. However, Fluor will not tolerate bribery of any form—with any third party, public or private, whether done directly or indirectly through third parties, even if we lose business or encounter delays because of our refusal to do so.

A “bribe” is an offer or promise to give, or the giving of, or authorizing to give, anything of value or another advantage to improperly influence the actions of a third party, public or private. Bribes may include money, gifts, travel or other expenses, hospitality, below-market loans, discounts, favors, business or employment opportunities, political or charitable contributions, or any direct or indirect benefit or consideration. Improper influence typically involves the intent to secure a quid pro quo to buy the misuse of someone’s position.’




A16:

Is the anti-corruption policy explicitly one of zero tolerance?

Score:

2

Comments:

Based on public information, there is evidence that the company has a detailed zero tolerance policy for bribery. This is made clear to all employees.

References:

Public:



In many parts of the world, paying bribes to win business contracts is unfortunately both accepted and expected. However, Fluor will not tolerate bribery of any form—with any third party, public or private, whether done directly or indirectly through third parties, even if we lose business or encounter delays because of our refusal to do so.

A “bribe” is an offer or promise to give, or the giving of, or authorizing to give, anything of value or another advantage to improperly influence the actions of a third party, public or private. Bribes may include money, gifts, travel or other expenses, hospitality, below-market loans, discounts, favors, business or employment opportunities, political or charitable contributions, or any direct or indirect benefit or consideration. Improper influence typically involves the intent to secure a quid pro quo to buy the misuse of someone’s position.’




A17:

Is the company's anti-corruption policy easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company?

Score:

2

Comments:

Based on public information, there is evidence that the company policies and codes related to corruption are easily accessible to employees and also contracted staff by being easily available on the website.

References:

Public:

Code of Business Conduct and Ethics:


Hotline on Business of Ethics:

http://www.fluor.com/sustainability/ethics_compliance/Pages/compliance_ethics_hotline.aspx

Expectations from suppliers and third parties:







A17(a):

Is the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties?

Score:

2

Comments:

Based on public information, there is evidence that the company’s policies are understandable and clear for all employees as well as third parties.

References:

Public:



Hotline on Business of Ethics:


Expectations from suppliers and third parties:







A18:

Does the anti-corruption policy explicitly apply to all employees and

members of the Board?

Score:

2

Comments:

Based on public information, there is evidence that the company’s Code containing its policy on anti-corruption is applicable to all employees worldwide. The same is also applicable for members of the Board.

References:

Public:


‘Who Must Follow Our Code? All employees of Fluor Corporation and its subsidiaries worldwide must adhere to our Code at all times.’


HR Policy:

‘All officers, directors and employees are strictly prohibited from paying a bribe to, or receiving a bribe from, ANY third party, public or private’

http://www.fluor.com/sitecollectiondocuments/in_abac_policy.pdf




A20:

Does the company have a policy on potential conflicts of interest, and does it apply to both employees and board members?

Score:

2

Comments:

Based on public information, there is evidence that the company has a clear policy on potential conflicts of interest. This is also supported by details of scenarios where such conflicts of interest may arise and what the employees are supposed to do in such instances.

References:

Public:


‘A conflict of interest occurs when your personal or financial interests interfere with your ability to make sound and objective business decisions on Fluor’s behalf. You need to avoid any situation that creates even the appearance of this kind of bias. A perceived conflict of interest that calls into question our business integrity can be as damaging to our reputation and business as the existence of an actual conflict.’

‘BOARDS OF DIRECTORS

While Fluor supports outside activities that benefit our communities and profession, you must exercise caution when accepting outside appointments, such as serving on a board of directors of another organization. This may raise a conflict of interest or even a legal issue. In particular, serving on the board of, or otherwise advising, a Fluor competitor, supplier, contractor, agent or client, or any company that has direct commercial dealings or competes with Fluor or a client, may be problematic. Fluor officers are required to obtain approval from the Chief Legal Officer before serving on any board, including nonprofit and community boards.’




A21:

Does the company have a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery?

Score:

1

Comments:

Based on public information, there is evidence that the company has a policy for giving and receiving of gifts. The company does place limits on the value of gifts, but these apply to specific projects and are not company-wide. It is not clear whether all projects have a gift value ceiling and how the ceilings are arrived at. The company therefore scores 1.

References:

Public:


‘To build goodwill with potential and existing clients and other business partners, exchanging gifts and entertainment as business courtesies is accepted business practice. However, we must be cautious when exchanging business courtesies to avoid a conflict of interest or the appearance of one. In addition, we need to take steps to ensure that any gifts and entertainment are not and will not be seen as bribes meant to improperly influence business decisions. If others believe that a business decision was made because of a gift or business courtesy and not purely on the basis of merit and sound business judgment, our reputation will be harmed.’

‘The gift or entertainment:

Is not intended to improperly secure something in return.

Is reasonable and not excessive for the industry, your function, and your position.

Does not violate Fluor's or the third party's applicable standards or law.

Is not in cash.

These rules apply to gifts, favours, meals and entertainment involving your close family members as well.’

‘If you receive an inappropriate gift from a supplier, contractor or other business partner, you must return the item with a tactful yet clear explanation that the gift violates Fluor's


gifts and entertainment policy and let your supervisor know.’


Joint venture between Fluor and Sinclair Knight (Australia), p.4:

The document establishes the maximum value of gifts which do not need to be registered as AUD 100; gifts worth more need to be approved by the manager/programme director and registered.

http://www.fastjv.com.au/docs/Business%20Conduct%20and%20Ethics%20Policy.pdf




A22:

Does the company’s anti-corruption policy include a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery?

Score:

1

Comments:

Based on public information, there is evidence that the company has a policy for giving and receipt of hospitality. The company does place limits on the value of hospitality, but these apply to specific projects and are not company-wide. It is not clear whether all projects have a hospitality value ceiling and how the ceilings are arrived at. The company therefore scores 1.

References:

Public:



Bribes may include money, gifts, travel or other expenses, hospitality, below-market loans, discounts, favors, business or employment opportunities, political or charitable contributions, or any direct or indirect benefit or consideration.’


‘To build goodwill with potential and existing clients and other business partners, exchanging gifts and entertainment as business courtesies is accepted business practice. However, we must be cautious when exchanging business courtesies to avoid a conflict of interest or the appearance of one. In addition, we need to take steps to ensure that any gifts and entertainment are not and will not be seen as bribes meant to improperly influence business decisions. If others believe that a business decision was made because of a gift or business courtesy and not purely on the basis of merit and sound business judgment, our reputation will be harmed.’

‘The gift or entertainment:

Is not intended to improperly secure something in return.


Is reasonable and not excessive for the industry, your function, and your position.

Does not violate Fluor's or the third party's applicable standards or law.

Is not in cash.

These rules apply to gifts, favours, meals and entertainment involving your close family members as well.’

‘If you receive an inappropriate gift from a supplier, contractor or other business partner, you must return the item with a tactful yet clear explanation that the gift violates Fluor's gifts and entertainment policy and let your supervisor know.’


Joint venture between Fluor and Sinclair Knight (Australia), p.4:

The document establishes the maximum value of gifts which do not need to be registered as AUD 100; gifts/hospitality worth more need to be approved by the manager/programme director and registered.





A23:

Does the company have a policy that explicitly prohibits facilitation payments?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company explicitly prohibits facilitation payments. TI notes that the company prohibits facilitation payments in general but allows these in certain circumstances. The circumstances are clearly defined and elaborated upon.

References:

Public:


‘FACILITATING PAYMENTS

At Fluor, facilitating payments are prohibited, unless they are:

• Pre-approved in writing by the Law Department;

• Allowed under all applicable anticorruption and local laws; and

• Properly and accurately accounted for in our company’s records

A “facilitating payment” is a small payment given to a government employee, usually in cash, to expedite or secure the performance of a routine process such as to expedite utility services, provide needed police protection or approve the granting of a work permit or visa. Anti-corruption and local laws often prohibit facilitating payments.

If there is an immediate and credible threat to an employee’s physical safety or security and it is not reasonably possible to get advance approval for a proposed payment demanded, the payment may be made without prior approval but must be promptly reported in writing to the Law Department.’


Fluor Human Resources Policy HR 720 (October 2011): Anti-Bribery and Corruption, pp. 3-4:




Company website, Code of Business Conduct and Ethics:

‘Beyond the Code, Fluor has more detailed policies and practices for its higher risk areas. Fluor’s Anti-Bribery and Corruption Policy prohibits bribing, or receiving a bribe from, any third party. Facilitating payments are prohibited.’





A24:

Does the company prohibit political contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent? Does the company record and publicly disclose all political contributions?

Score:

2

Comments:

Based on public information, there is evidence that the company prohibits political contributions.

References:

Public: Code of Business Conduct and Ethics, p.45: ‘Fluor participates in the political process in order to help governments better understand certain issues that are important to the company. However, there are stringent legal restrictions on what we can contribute to elected officials and members of their staff. For this reason, you may not give or offer company funds or other company assets (directly or indirectly) as any form of political contribution without preapproval of the head of Government Relations. “Political contributions” are defined broadly and can even include buying tickets for or loaning corporate resources to a political fundraising event. Remember, a political contribution could also be construed as a bribe if it is given with the intent of influencing a government official.’ ‘Keep in mind that you cannot use company time, property or equipment for your personal political activities.’


Anti-corruption policy document HR720: ‘Political and charitable contributions: Contributions to political parties, party officials, candidates, organizations or individuals engaged in politics, or charities or sponsorships, whether direct or indirect, must not be a subterfuge for bribery or contrary to applicable law. As always, employees should consult with the Company's Government Affairs and Community Relations functional groups before proceeding to make any political or charitable contributions on behalf of the company, respectively. Proper recording and accounting of contributions is essential.’



A25:

Does the company have a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies?

Score:

2

Comments:

Based on public information, there is evidence that the company has a clear policy on engagement in lobbying activities and guidelines for the same. There is also evidence that the company publically discloses the issues on which it lobbies.

References:

Public: Code of Business Conduct and Ethics, p.45:

‘Lobbying

In many countries, strict rules govern corporate lobbying activities. Lobbying requires disclosure to the government and covers many kinds of activities. In certain countries, lobbyists must be registered. You may be deemed to engage in lobbying if your work involves:

• Contact with legislators, regulators, executive branch officials or their staff

• Making or negotiating sales for government contracts

• Efforts to influence legislative or administrative action

Before engaging in any activities that could be considered lobbying or political activity, contact Fluor’s head of Government Relations.’


US Senate website: Lobbying Report

‘2014’

‘Fluor Corporation’

‘16. Specific lobbying issues

Issues related to ongoing projects and financing including TIFIA loans.

Issues related to surface transportation reauthorization’.



http://soprweb.senate.gov/index.cfm?event=getFilingDetails&filingID=b7b2f5f8-2c66-4f85-8abb-a3f058e8e5d2&filingTypeID=51




A25(a):

Does the company prohibit charitable contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent?

Score:

2

Comments:

Based on public information, there is evidence that the company has a policy on charitable contributions. There are regular publicly available reports on the company’s community impact with highlights of the company efforts, partnerships, supported projects and scorecards on the status of involvement.

References:

Public: Anti-corruption policy document HR720: ‘Political and charitable contributions: Contributions to political parties, party officials, candidates, organizations or individuals engaged in politics, or charities or sponsorships, whether direct or indirect, must not be a subterfuge for bribery or contrary to applicable law. As always, employees should consult with the Company's Government Affairs and Community Relations functional groups before proceeding to make any political or charitable contributions on behalf of the company, respectively. Proper recording and accounting of contributions is essential.’ http://www.fluor.com/SiteCollectionDocuments/in_abac_policy.pdf Fluor, ‘Giving’: The website describes some initiatives the company contributes to and provides some statistical data. http://www.fluor.com/sustainability/community/fluor_giving/pages/default.aspx Community Impact Report Q3 (2014): http://www.fluor.com/sustainability/community/Pages/fluor-community-impact-report.aspx Community Impact Report Q1 (2014): http://www.fluor.com/SiteCollectionDocuments/fluor-community-impact-report-q1-2014.pdf


http://www.fluor.com/sustainability/community/fluor_giving/pages/default.aspx

http://www.fluor.com/sustainability/community/Pages/fluor-community-impact-report.aspx

http://www.fluor.com/sustainability/community/Pages/fluor-community-impact-report.aspx

http://www.fluor.com/SiteCollectionDocuments/fluor-community-impact-report-q1-2014.pdf



Community Impact Report Q2 (2014): http://www.fluor.com/SiteCollectionDocuments/fluor-community-impact-report-q2-2014.pdf Global Community Relations Scorecard (2014).




A26:

Does the company provide written guidance to help Board members and

employees understand and implement the firm’s ethics and anti-corruption

agenda?

Score:

2

Comments:

Based on public information, there is evidence that the company’s policies and codes regarding corruption include a number of clear definitions and examples.

References:

Public: Anti-corruption policy document HR720: http://www.fluor.com/SiteCollectionDocuments/in_abac_policy.pdf






A27:

Does the company have a training programme that explicitly covers anti-corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company has a specific anti-corruption training programme directed at all employees and directors.

References:

Public:

2012 Sustainability Report, p.14:

‘Training is one of the most critical components for the success of any ethics and compliance program. Fluor’s comprehensive training program has a multi- topic curriculum to ensure employees understand the risks that apply to their positions and comply with the related Fluor policies and practices.

One hundred percent of Fluor’s salaried employees have received Code training, with emphasis on our anti-corruption program and other key risk areas. In 2012 we completed development of a new Code training course and launched a pilot of the new course e to 800 employees. We intend to roll it out to all salaried employees in 2013.

Additionally, more than 8,000 employees participated in specialty, web-based training modules in 2012 Face-to-face training classes included project-specific, anti-corruption training, as well as other classes focused on ethics and compliance risk areas for targeted employees and directors.’




A28:

Is anti-corruption training provided in all countries where the company operates or has company sites?

Score:

2

Comments:

Based on public information, there is evidence that the company provides training to all its salaried employees in all geographies.

References:

Public:


‘One hundred percent of Fluor’s salaried employees have received Code training, with emphasis on our anti-corruption program and other key risk areas.’




A29:

Does the company provide targeted anti-corruption training to members of the Board?

Score:

1

Comments:

Based on public information, there is evidence that the company does provide some level of training to Board members. However, it is not clear if they are retrained at least every three years. The company therefore scores 1.

References:

Public:


‘Face-to-face training classes included project-specific, anti-corruption training, as well as other classes focused on ethics and compliance risk areas for targeted employees and directors.’




A30:

Does the company provide tailored ethics and anti-corruption training for employees in sensitive positions?

Score:

2

Comments:

Based on public information, there is evidence that the company does provide specifically tailored anti-corruption training for employees in high risk positions.

References:

Public:


‘Face-to-face training classes included project-specific, anti-corruption training, as well as other classes focused on ethics and compliance risk areas for targeted employees and directors.

For example we implemented a targeted anti-corruption training campaign for employees in high-risk positions or locations.’




A31:

Does the company have a clear and formal process by which employees declare conflicts of interest?

Score:

2

Comments:

Based on public information, there is evidence that the company has a formal and clear process by which employees can declare conflict of interests to supervisors or HR. Company procedure explicitly states that conflicts of interest should be disclosed in writing.

References:

Public:


‘A conflict of interest occurs when your personal or financial interests interfere with your ability to make sound and objective business decisions on Fluor’s behalf. You need to avoid any situation that creates even the appearance of this kind of bias. A perceived conflict of interest that calls into question our business integrity can be as damaging to our reputation and business as the existence of an actual conflict.’

‘BOARDS OF DIRECTORS

While Fluor supports outside activities that benefit our communities and profession, you must exercise caution when accepting outside appointments, such as serving on a board of directors of another organization. This may raise a conflict of interest or even a legal issue. In particular, serving on the board of, or otherwise advising, a Fluor competitor, supplier, contractor, agent or client, or any company that has direct commercial dealings or competes with Fluor or a client, may be problematic. Fluor officers are required to obtain approval from the Chief Legal Officer before serving on any board, including nonprofit and community boards.’

‘To determine whether you have a conflict of interest exists, you should ask yourself:

-Does this situation make me feel uncomfortable?

-Would the action have the potential to affect my ability to make sound business decisions?

...

If you answered "yes" to any of these questions, you should discuss the activity, financial


interest, or relationship with your supervisor or your Human Resources manager immediately.’


Code of Business Conduct and Ethics (October 2014), p. 31:




A32:

Is the company explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities?

Score:

1

Comments:

Based on public information, there is evidence that the company makes clear the consequences and disciplinary actions that may be taken when employees engage in corrupt activities in violation of the company’s code of conduct. However, it is not clear that discipline will be taken in each case. The company therefore scores 1.

References:

Public:


‘Who Must Follow Our Code? All employees of Fluor Corporation and its subsidiaries worldwide must adhere to our Code at all times.’

‘What are the Consequences of Violating Our Code? Violations of our Code can result in disciplinary action, up to and including termination. In appropriate cases, Fluor may also refer misconduct to appropriate authorities for prosecution. This may subject the individuals involved to civil and/or criminal penalties.’


Human Resources Policy HR 720 (October 2011), p. 1:

‘All officers, directors and employees are strictly prohibited from paying a bribe to, or receiving a bribe from, ANY third party, public or private’





A33:

Does the company have multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity?

Score:

2

Comments:

Based on public information, there is evidence that the company does provide a well-publicised channel through its Fluor Hotline to report suspected corrupt activities. The hotline is managed by an independent party and there are strong guarantees of anonymity for those who report infractions (information is only disclosed on a ‘need to know’ basis).

References:

Public:

Fluor Hotline website:


https://secure.ethicspoint.com/domain/media/en/gui/35334/faq.html

Fluor Hotline poster and numbers for multiple countries:

http://www.fluor.com/SiteCollectionDocuments/in_hotline_english.pdf

Fluor Hotline describing and giving details of what to do in case an employee wants to report something and also details of subject matter experts for various issues like bribes, facilitation payments, Gifts and Entertainment, etc.

https://secure.ethicspoint.com/domain/media/en/gui/35334/help.pdf

The Code of Business Conduct and Ethics, pp.15 & 49:








A33(a):

Are the whistleblowing channels available to all employees in all geographies?

Score:

2

Comments:

Based on public information, there is evidence that the company’s whistle blowing channels are available to all employees in all geographies with respective country contact numbers and languages.

References:

Public:



Flour Hotline poster and numbers for multiple countries:


Information on NAVEX Global:

‘NAVEX Global is an independent third party provider to Fluor. Fluor has contracted with NAVEX Global to provide the Fluor Compliance and Ethics Hotline. The NAVEX system is a comprehensive and confidential reporting tool to assist management and employees in working together to address any potential violations of the Fluor Code of Business Conduct and Ethics, company policy or law. You can also seek guidance or ask a compliance and ethics related question through this system.’


The Code of Business Conduct and Ethics, p.49:




https://secure.ethicspoint.com/domain/media/en/gui/35334/code.pdf


https://secure.ethicspoint.com/domain/media/en/gui/35334/help.pdf:



A33(b):

Does the company have formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively?

Score:

0

Comments:

Based on public information, there is evidence that the company creates an encouraging atmosphere for whistle blowing and they are treated supportively. However, it is not clear that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, such as ways to follow up with whistleblowers and monitor their experience.

References:

Public:

TI notes:






‘It is of the highest importance to Fluor that employees are able and willing to readily report concerns about suspected unethical behavior. In addition to having the opportunity to speak with their immediate supervisor, other in management, Human Resources or an investigating department, our company has in place an anonymous, toll-free Compliance and Ethics Hotline, including website-reporting mechanisms, to facilitate employee reporting around the globe Clients, partners, suppliers and subcontractors also are encouraged to use Fluor’s Compliance and Ethics Hotline to report any suspected misconduct involving Fluor.’






A34:

Does the company have well-publicised resources available to all employees where help and advice can be sought on corruption-related issues?

Score:

2

Comments:

Based on public information, there is evidence that the company has well publicised channels to report and seek advice on corruption from trained practitioners.

References:

Public:






‘It is of the highest importance to Fluor that employees are able and willing to readily report concerns about suspected unethical behavior. In addition to having the opportunity to speak with their immediate supervisor, other in management, Human Resources or an investigating department, our company has in place an anonymous, toll-free Compliance and Ethics Hotline, including website-reporting mechanisms, to facilitate employee reporting around the globe Clients, partners, suppliers and subcontractors also are encouraged to use Fluor’s Compliance and Ethics Hotline to report any suspected misconduct involving Fluor.’






A35:

Is there a commitment to non-retaliation for bona fide reporting of corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company has a commitment to non-retaliation for reporting corruption and it states that it will strongly discipline those who retaliate against whistleblowers.

References:

Public:


‘What If I Am Concerned about Retaliation? Fluor will not tolerate any form of direct or indirect retaliation that arises from reporting suspected illegal or unethical conduct in good faith. If a report is made in good faith, you will be protected even if the concern turns out to be unsubstantiated. If you suspect you are experiencing retaliation, you should contact Human Resources or Fluor’s Compliance and Ethics Hotline. Retaliating against someone who makes a report in good faith will result in prompt and strong disciplinary action, up to and including termination.’




Information Sources:

Company website:

www.fluor.com



Code of Business Conduct and Ethics (2013):


Letter of Support for UN Global Compact

http://www.fluor.com/SiteCollectionDocuments/Fluor-UN-Global-Compact-

CEO-Commitment-of-Continued-Support.pdf

2010, Fluor Sustainability Report:


2012, Fluor Sustainability Report:




Audit Committee Charter:


http://www.fluor.com/















2013 Annual Report:


Fluor Human Resources Policy: Anti-Bribery and Corruption:




