final assessment kbr, inc. - transparency internationalcompanies.defenceindex.org/pdf/kbr.pdf ·...

KBR, INC. 11/06/14 WWW.KBR.COM

FINAL ASSESSMENT

KBR, INC.

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 70%

Risk Management 5 60%

Company Policy and Codes 12 66.7%

Training 5 50%

Personnel and Helplines 7 78.6%

Total 39 66.7%

TI has found no evidence that the company is 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:

0

Comments:

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or Chair of the Board supporting the ethics and anti-corruption agenda of the company. TI notes a Chief Executive Officer statement on the Sustainability Story that supports the Code of Business Conduct. However, this is assessed to be insufficiently strong to score on this question.

References:

Public:

TI notes:

Built on Values – Our Sustainability Story (2014), p.5:

‘At KBR, our values are our company culture, emphasized in our Code of Business Conduct and the ethics training in which all our employees participate annually. Rather than simply being part of our history, our values guide us daily and are an integral part of the work we perform around the world.’

http://www.kbr.com/Newsroom/Publications/Brochures/KBR-Sustainability-Report-2014.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:

1

Comments:

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. However, there is evidence that this commitment has been delegated to the company’s Director of Compliance. The Director of Compliance Julia Symon has attended many panel discussions in relation to anti-corruption. The company therefore scores 1. To score higher the company would need to provide evidence that the Chief Executive Officer or the Chair of the Board demonstrates such commitment.

References:

Public:

The Oil & Gas Anti-Corruption & Compliance Congress: The Preeminent FCPA Enforcement and Compliance Benchmarking Event for the Oil and Gas Industry (September 2013), p.1:

‘Take part in specifically focused compliance roundtable discussions on:

• The top 5 FCPA compliance challenges facing the oil and gas industry

• Risk-based third-party vetting, screening and monitoring strategies for partners, vendors, contractors, brokers and agents

• Updating global corporate compliance policies for effectively managing gifts, entertainment and hospitality in the current enforcement environment

• Tackling unique compliance challenges associated with the training and management of foreign employees

• Effective remediation strategies for updating your global corporate compliance program post-investigation.’

http://momentumevents.com/wp-content/uploads/2013/04/111W13_HOU_OilGas_053013_v4.pdf

Supply Chain Brain website: KBR Share Insight at the 2nd Annual Oil and Gas Supply Chain




Compliance Meeting

‘KBR Share Insight at The 2nd Annual Oil and Gas Supply Chain Compliance Meeting

March 08, 2012

In recent months, the sentencing of KBR employees signals just how serious the threat of prosecution and conviction is for breaching the FCPA. With the prison sentences ranging from 30 months to 21 months, the consequences of not complying with anti-bribery and corruption legislation is clear.

The 2nd Annual Oil & Gas Supply Chain Compliance conference aims to give attendees the tools prevent breaches, avoid prosecution and ultimately ensure ethical best practive accross the supply chain. Taking place on the 26th - 28th June 2012 in Houston, you'll hear from KBR themselves, as Julia Symon, Director of Compliance will presents about 'Assessing Actions and Breaches that Lead to Prosecution Under the FCPA'.

This invaluable insight will be provided as part of in in-depth two day forum for the industry which has a strong focus on inter-organisation best practice sharing for compliance in th the oil and gas supply chain.

Presenting alongside KBR at the meeting include compliance and legal experts from the following companies:

- Noble Energy Inc - Ensco- Parker Drilling Company- DHL Global Forwarding - BP - Dresser - Rand - Berkeley Research Group - Hercules Offshore, Inc - ENI S.p.A - Weatherford International -H2M Hill - Ethisphere Institute - Flowserve Corporation - Baker Hughes - tomfoxlaw.com - Miller & Chevalier - Amber Road

For more detailed information about the meeting, including detailed agenda, and full speaker faculty, you can download the brochure from the meeting website: www.oilandgas-compliance.com/download-brochure.’

http://www.supplychainbrain.com/content/latest-content/single-article/article/kbr-share-insight-at-the-2nd-annual-oil-and-gas-supply-chain-compliance-meeting/

8th Annual FCPA and Anti-Corruption Compliance Conference (June 2012), p.3:

‘5:20 Working with Compliance Monitors to Offset Possible Conflicts

• Performing due diligence on suggested monitors to select the best option for your organization

• Assessing what information to have ready for the monitor to help ease the process

• Setting a budget for the monitor beforehand to regin in reckless actions

• Having a plan for what they will look into to establish reporting requirements

• Establishing expectations early on to manage deliverables

• Training staff on how to deal with a monitor and their requests

Julian C. Symon, Director of Compliance Legal Department

KBR Inc.’

http://www.conferensum.com/files/4276/CHC445_MB_FCPA.pdf





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 Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company.

References:

Public:

NA


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 a statement of values, including integrity, transparency and accountability. The company clearly explains the importance of these values, while also referencing openness and honesty.

References:

Public:

Built on Values – Our Sustainability Story (2014):

‘Table of Contents

Commitment

Letter from the CEO

Integrity

7 - Who We Are

7 - Sustainable Leadership

8 - Ethics

8 - Health and Safety

9 - Environment

10 - Diversity

10 - Corporate Citizenship

Transparency

13 - Safety Programs

17 - Environmental Initiatives

20 - The KBR Workforce

20 - Employee Engagement

20 - Employee Development and Well-Being

22 - Corporate Giving and Volunteerism


Accountability

27 - Certification Systems

29 - Prominent Sustainability Awards

Responsibility

31 - Kellogg Joint Venture Gorgon (KJVG)

32 - Ichthys LNG

33 - Aspire Defence (Capital Works)

34 - Palm Beach Renewable Facility Unit 2

35 - Escravos GTL

36 - Hallett Wind Farms

36 - Duke Medicine Cancer Center

37 - Climate Change Adaptation Study for Five Pacific Island Nations

37 - Research and Academic Center at Lake Nona

38 - Kitimat LNG

39 - Pacific NorthWest LNG

40 - USAREUR Support Contract II

40 - South Carolina 787 Facility Expansion

41 - DuPont – LaPorte, Texas

41 - Eastern Creek Environmental Impact Statement

Global Report Initiative (GRI) 3.1 Table 5.’

Code of Business Conduct (2012), p.3:

‘However, for purposes of clarity and to ensure compliance with Section 406, this Code of Business Conduct as it applies to these listed officers is designed to deter wrongdoing and promote:

1. honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;

2. full, fair, accurate, timely, and understandable disclosure in reports and documents that the Company files with, or submits to, the SEC and in other public communications made by the Company;

3. compliance with applicable governmental laws, rules and regulations;

4. the prompt internal reporting of violations of the Code to an appropriate person or persons identified in the Code; and

5. accountability for adherence to the Code.’

http://www.kbr.com/About/Code-of-Business-Conduct/Translations/English/COBC_English_FullCode.pdf

(p.4): ‘Beyond legal compliance, all Directors, Employees and Legal Agents are expected to observe high standards of business and personal ethics in the discharge of their assigned duties and responsibilities. This requires the practice of fair dealing, honesty and integrity by




Directors, Employees, and Legal Agents in every aspect of dealing with Company Employees, the public, the business community, shareholders, customers, suppliers, competitors and governmental and regulatory authorities. Directors and Employees when acting on behalf of the Company shall not take unfair advantage through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or other unfair-dealing practices.’

(p.10): ‘Purpose

This Policy establishes guidelines and procedures related to keeping books and records that in reasonable detail accurately and fairly reflect the Company’s transactions and dispositions of assets. The Company shall maintain a system of internal accounting controls to ensure reliability and adequacy of its books and records and proper recording of all transactions including dispositions of assets.’

5. Internal Controls.

A system of internal accounting controls will be maintained that is sufficient to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles or any other criteria applicable to such statements and includes those policies and procedures that:

a. Pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Company;

b. Provide reasonable assurance that transactions are executed in accordance with management’s general or specific authorization; and

c. Provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the Company’s assets.‘

Company website: Mission, Vision and Values

‘Mission, Vision and Values

KBR’s core values drive everything we do. Incorporating these core values in our daily work, and making them an integral part of our culture, is key to our future success. Our values solidify who we are and what we believe.

KBR’s values are:

• Uncompromising commitment to Quality, Health, Safety and Environment

• An open relationship with our employees based on mutual trust, respect and success

• Transparency, Accountability and Discipline in our business

• Best in class Risk Awareness

• Integrity in all we do

• Financial Responsibility to our stakeholders’

http://www.kbr.com/About/Mission-Vision-and-Values/

Company website: Compliance and Ethics



‘Compliance and Ethics

Compliance and integrity are at the core of everything we do at KBR. Our Code of Business Conduct (COBC) establishes KBR's commitment to these principles. The COBC contains specific policies regarding the legal and ethical standards of conduct required of KBR's directors, employees, and agents.

KBR policy prohibits unlawful discrimination against employees, shareholders, directors, officers, customers or suppliers on account of race, color, age, sex, religion or national origin. All persons shall be treated with dignity and respect and shall not be unreasonably interfered with in the conduct of their duties and responsibilities.’

http://www.kbr.com/Social-Responsibility/Diversity-and-People/Compliance-and-Ethics/



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 signatory of the Defense Industry Initiative (DII) and subscribes to the Common Industry Standards.

References:

Public:

DII website: Signatories

http://www.dii.org/signatories



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 the Audit Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Audit Committee is expected to advise the board in regards to Code of Business Conduct and establish procedures for the receipt, retention and treatment of complaints. The General Counsel reviews the Ethics agenda periodically and makes recommendations to the Board.

References:

Public:

Audit Committee Charter (December 2013):

‘Code of Business Conduct and Compliance

-Obtain reports from management, the Corporation’s senior internal auditing executive and the independent auditors that the Corporation’s subsidiary/foreign affiliated entities are in conformity with applicable legal requirements and the Corporation’s Code of Business Conduct and Corporate Governance Guidelines.

-Advise the Board with respect to the Corporation’s policies and procedures regarding compliance with applicable laws and regulations and with the Corporation’s Code of Business Conduct and Corporate Governance Guidelines.

-Establish procedures for the receipt, retention and treatment of complaints received by the Corporation regarding accounting, internal accounting controls or auditing matters, and the confidential, anonymous submission by employees of the Corporation of concerns regarding questionable accounting or auditing matters.

-Discuss with management and the independent auditor any correspondence with regulators or governmental agencies and any published reports that raise material issues regarding the Corporation’s financial statements or accounting policies.

-Review with the Corporation’s General Counsel legal matters that may have a material impact on the Corporation’s financial statements, the Corporation’s compliance policies and


any material reports or inquiries received from regulators or governmental agencies.’

http://www.kbr.com/About/Corporate-Governance/Board-Committees/Audit-Committee-Charter.pdf


‘The Code of Business Conduct of the Company shall be administered as follows:

1. Scope of Code of Business Conduct.

The General Counsel shall, periodically, in light of the experience of the Company, review the Code of Business Conduct, and when necessary or desirable, make recommendations to the Board of Directors: (i) to ensure its continued conformance to applicable Laws; (ii) to ensure that it meets or exceeds industry standards; and (iii) to ensure that any weaknesses revealed through monitoring, auditing and reporting systems are eliminated or corrected.

2. Allocations of Responsibility.

The Board of Directors shall be responsible for the administration of the Code of Business Conduct. The Board of Directors shall establish such procedures as it shall deem necessary or desirable in order to discharge this responsibility. Such procedures shall provide for obtaining advice of legal counsel where appropriate. In discharging these responsibilities, the Board of Directors may delegate authority to such committees, officers and other Employees and may engage such consultants, experts and advisors as it shall deem necessary or desirable.

3. Delegation of Substantial Authority.

No Director or Employee of the Company shall delegate substantial authority to any individual whom such Director or Employee knows, or through the exercise of due diligence should know, has engaged in illegal activities or other conduct inconsistent with an effective compliance and ethics program.

a. For this purpose, persons with “substantial authority” include (i) High Level Personnel, (ii) individuals who exercise substantial supervisory authority, such as a plant manager or a sales manager, and (iii) any other individuals who, although not a part of the Company’s management, nevertheless exercise substantial discretion when acting within the scope of their authority (for example, an individual with authority to negotiate or set price levels or an individual authorized to negotiate or approve significant contracts).

b. The Board of Directors, in administering the Code of Business Conduct, shall consider, adopt and promulgate guidelines for background checks on individuals who are being delegated substantial authority.

4. Communication of Policies.

To ensure the continued dissemination and communication of the Code of Business Conduct, the Board of Directors shall take, or cause to be taken, reasonable steps to communicate effectively the standards and procedures included in the Code of Business Conduct to Directors, Employees and Legal Agents.

5. Monitoring and Auditing.

The Board of Directors shall take reasonable steps to monitor and audit compliance with the Code of Business Conduct, including the establishment of systems that are reasonably designed to detect conduct in violation of the Code of Business Conduct by Directors,




Employees and Legal Agents.

a. To the extent so directed by the Board of Directors, the information developed by the Company’s independent accountants in performing their engagement by the Company and by its internal auditors in the performance of their assigned responsibilities shall be made available to the Board of Directors in its capacity as administrator of the Code of Business Conduct as a means of monitoring and auditing compliance with the Code of Business Conduct.

b. To the extent so directed by the Board of Directors, the results of the periodic health, safety and environmental audits, anti-corruption audits and export administration audits of the Company’s facilities shall be made available to the Board of Directors in its capacity as the administrator of the Code of Business Conduct as a means to monitor and audit compliance with the Code of Business Conduct.

6. Board Committees.

The General Counsel shall report to the Audit Committee of the Board of Directors, at least once each year, regarding the general effectiveness of the Code of Business Conduct. Any such report will also be provided to the Company’s principal Audit Services executive. The Chief Corporate Social Responsbility Officer shall report to the Corporate Social Responsibility Committee of the Board of Directors at least once each year regarding the environmental, health and safety performance of the Company as it relates to the Code of Business Conduct.

7. Reporting Systems.

Directors, Employees, and Legal Agents are both encouraged and obligated to promptly report any violations of the Code of Business Conduct. The Board of Directors shall establish a reporting system that will allow violations of the Code of Business Conduct to be reported and acted upon by Directors, Employees, and Legal Agents of the Company with sufficient authority to deal objectively with the reported matters. The existence and nature of the reporting system shall be communicated to all Employees and, to the extent appropriate, to Legal Agents. The reporting system shall include an Ethics Hotline, which shall allow anonymous reporting. If in doubt about the person to contact, reports should be made to the Ethics Hotline, the General Counsel or any representative of the Law Department. It shall be a violation of this Corporate Policy to intimidate or impose any form of retribution on any Employee or Legal Agent who utilizes such reporting system in good faith to report suspected violations (except that appropriate action may be taken against such Employee or Legal Agent if such individual is one of the wrongdoers).

8. Investigation of Violations.

If, through operation of the Company’s compliance monitoring and auditing systems or its violation reporting systems or otherwise, the Company receives information regarding an alleged violation of the Code of Business Conduct, the person or persons authorized by the Board of Directors to investigate alleged violations of the Code of Business Conduct shall, as appropriate, in accordance with procedures established by the General Counsel:

a. evaluate such information as to gravity and credibility;

b. initiate an informal inquiry or a formal investigation with respect thereto;

c. prepare a report of the results of such inquiry or investigation, including

recommendations as to the disposition of such matter;


d. make the results of such inquiry or investigation available to the Board of Directors for

action (including disciplinary action by the Board of Directors); and

e. recommend changes in the Code of Business Conduct necessary or desirable to

prevent further similar violations.

The Company may disclose the results of investigations to law enforcement agencies.’


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 General Counsel, Andrew Farley, has responsibility for implementing the company’s ethics and anti-corruption agenda.

References:

Public:


‘2. Allocations of Responsibility.

The Board of Directors shall be responsible for the administration of the Code of Business Conduct. The Board of Directors shall establish such procedures as it shall deem necessary or desirable in order to discharge this responsibility. Such procedures shall provide for obtaining advice of legal counsel where appropriate. In discharging these responsibilities, the Board of Directors may delegate authority to such committees, officers and other Employees and may engage such consultants, experts and advisors as it shall deem necessary or desirable.’

(p.5): ‘The Code of Business Conduct of the Company shall be administered as follows:


The General Counsel shall, periodically, in light of the experience of the Company, review the Code of Business Conduct, and when necessary or desirable, make recommendations to the Board of Directors: (i) to ensure its continued conformance to applicable Laws; (ii) to ensure that it meets or exceeds industry standards; and (iii) to ensure that any weaknesses revealed through monitoring, auditing and reporting systems are eliminated or corrected.’

Company website:

‘Andrew Farley, Executive Vice President and General Counsel’

http://www.kbr.com/newsroom/press-releases/2013/09/26/united-states-district-court-

http://www.kbr.com/newsroom/press-releases/2013/09/26/united-states-district-court-awards-kbr-465-million-in-arbitration-against-pep/


awards-kbr-465-million-in-arbitration-against-pep/

http://www.kbr.com/newsroom/press-releases/2013/09/26/united-states-district-court-awards-kbr-465-million-in-arbitration-against-pep/


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 of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. The General Counsel reports to the Audit Committee at least annually regarding the effectiveness of the Code of Business Conduct. The Committee itself reviews the company’s compliance policies and procedures, as well as any complaints received. Evidence suggests this occurs at least anually, as the Committee meets quarterly. The company therefore scores 2.

References:

Public:





(p.5): ‘6. Board Committees.

The General Counsel shall report to the Audit Committee of the Board of Directors, at least once each year, regarding the general effectiveness of the Code of Business Conduct. Any such report will also be provided to the Company’s principal Audit Services executive. The Chief Corporate Social Responsbility Officer shall report to the Corporate Social Responsibility Committee of the Board of Directors at least once each year regarding the environmental, health and safety performance of the Company as it relates to the Code of Business Conduct.’

Audit Committee Charter (2013), p.2:


‘The Committee will meet as often as the members shall determine to be necessary or appropriate, but at least four times during each year.’

(p.6): ‘Code of Business Conduct and Compliance

- Obtain reports from management, the Corporation’s senior internal auditing executive and the independent auditors that the Corporation’s subsidiary/foreign affiliated entities are in conformity with applicable legal requirements and the Corporation’s Code of Business Conduct and Corporate Governance Guidelines.

- Advise the Board with respect to the Corporation’s policies and procedures regarding compliance with applicable laws and regulations and with the Corporation’s Code of Business Conduct and Corporate Governance Guidelines.

- Establish procedures for the receipt, retention and treatment of complaints received by the Corporation regarding accounting, internal accounting controls or auditing matters, and the confidential, anonymous submission by employees of the Corporation of concerns regarding questionable accounting or auditing matters.

- Discuss with management and the independent auditor any correspondence with regulators or governmental agencies and any published reports that raise material issues regarding the Corporation’s financial statements or accounting policies.

- Review with the Corporation’s General Counsel legal matters that may have a material impact on the Corporation’s financial statements, the Corporation’s compliance policies and any material reports or inquiries received from regulators or governmental agencies.’

Proxy Statement (2014), p.14:

‘The Audit Committee also receives reports from management regarding compliance risks and Code of Business Conduct matters. The Audit Committee also reviews at least annually KBR’s policies and guidelines that govern the process by which risk assessment and enterprise risk management is undertaken.’

http://investors.kbr.com/files/doc_financials/2014/KBR2014_PXY_Track1_HD-WebHosting.pdf




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:

1

Comments:

Based on public information, there is limited evidence of a formal, written plan on which the review of the ethics and anti-corruption agenda by the Audit Committee is based. The Committee reviews reports on compliance by the company’s foreign entitities, advises the board in regard to compliance policies and procedures, manage procedures to receive complaints, and review any specific legal matters with the General Counsel. To score higher the company would need to provide further evidence of the formal, clear, written plan, as well as the implementation of improvements plans.

References:

Public:






The General Counsel shall report to the Audit Committee of the Board of Directors, at least once each year, regarding the general effectiveness of the Code of Business Conduct. Any such report will also be provided to the Company’s principal Audit Services executive. The Chief Corporate Social Responsbility Officer shall report to the Corporate Social Responsibility Committee of the Board of Directors at least once each year regarding the environmental, health and safety performance of the Company as it relates to the Code of


Business Conduct.’

Audit Committee Charter (2013), p.2:

‘The Committee will meet as often as the members shall determine to be necessary or appropriate, but at least four times during each year.’

(p.6): ‘Code of Business Conduct and Compliance

- Obtain reports from management, the Corporation’s senior internal auditing executive and the independent auditors that the Corporation’s subsidiary/foreign affiliated entities are in conformity with applicable legal requirements and the Corporation’s Code of Business Conduct and Corporate Governance Guidelines.

- Advise the Board with respect to the Corporation’s policies and procedures regarding compliance with applicable laws and regulations and with the Corporation’s Code of Business Conduct and Corporate Governance Guidelines.

- Establish procedures for the receipt, retention and treatment of complaints received by the Corporation regarding accounting, internal accounting controls or auditing matters, and the confidential, anonymous submission by employees of the Corporation of concerns regarding questionable accounting or auditing matters.

- Discuss with management and the independent auditor any correspondence with regulators or governmental agencies and any published reports that raise material issues regarding the Corporation’s financial statements or accounting policies.

- Review with the Corporation’s General Counsel legal matters that may have a material impact on the Corporation’s financial statements, the Corporation’s compliance policies and any material reports or inquiries received from regulators or governmental agencies.’


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 formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption. The General Counsel and Audit Committee are able to make recommendations to the Board of Directors when necessary.

References:

Public:






The General Counsel shall report to the Audit Committee of the Board of Directors, at least once each year, regarding the general effectiveness of the Code of Business Conduct. Any such report will also be provided to the Company’s principal Audit Services executive. The Chief Corporate Social Responsbility Officer shall report to the Corporate Social Responsibility Committee of the Board of Directors at least once each year regarding the environmental, health and safety performance of the Company as it relates to the Code of Business Conduct.’

(p.5): ‘8. Investigation of Violations.


If, through operation of the Company’s compliance monitoring and auditing systems or its violation reporting systems or otherwise, the Company receives information regarding an alleged violation of the Code of Business Conduct, the person or persons authorized by the Board of Directors to investigate alleged violations of the Code of Business Conduct shall, as appropriate, in accordance with procedures established by the General Counsel:

a. evaluate such information as to gravity and credibility;

b. initiate an informal inquiry or a formal investigation with respect thereto;

c. prepare a report of the results of such inquiry or investigation, including

recommendations as to the disposition of such matter;

d. make the results of such inquiry or investigation available to the Board of Directors for

action (including disciplinary action by the Board of Directors); and

e. recommend changes in the Code of Business Conduct necessary or desirable to

prevent further similar violations.’


‘The Audit Committee also receives reports from management regarding compliance risks and Code of Business Conduct matters. The Audit Committee also reviews at least annually KBR’s policies and guidelines that govern the process by which risk assessment and enterprise risk management is undertaken. The Audit Committee also receives in-depth periodic reports from management regarding specific processes designed to monitor and manage risk, such as project estimation procedures and foreign exchange risk management. The Audit Committee conducts private sessions with KBR’s Chief Financial Officer, Vice President of Internal Audit and General Counsel at each regular meeting and with KBR’s independent auditors at each meeting prior to the release of quarterly and annual results. The Audit Committee Chairman gives a report of the Audit Committee’s activities to the full Board at each regular meeting and in this manner the entire Board is informed of matters that the Audit Committee determines warrant full Board discussion.’


A9(a):

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

Score:

2

Comments:

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The Audit Committee is responsible for risk-assessment procedures and mitigation plans, and there are clear guidelines on how this responsibility is applied.

References:

Public:

Proxy Statement (2014), pp.14-15:

‘Risk Oversight Role Of The Board Of Directors

KBR’s Board of Directors considers risk oversight to be an integral part of its role, and discussions regarding risks faced by the company are part of its meetings and deliberations throughout the year. Furthermore, at least twice each year, the entire Board receives a report from management regarding significant strategic, operational, financial, and hazard risks determined by management to have a potential significant impact on the company as a whole. The risk report involves both current and emerging risks and is the culmination of a process involving input from all business groups and executive leadership. The risk report includes specific strategic, operational, financial and hazard risks, the perceived trend for each of those specific risks — whether increasing, decreasing or stable — and the measures being taken to monitor and mitigate those risks. In addition to the enterprise risk management process described above, the Board of Directors also engages in risk oversight in the area of project revenues. At each meeting, the Board reviews aggregated KBR project revenues measured by type of contract — fixed-price or reimbursable — by country, client and project backlog. In this manner, the Board is informed of the overall risk profile of KBR’s project revenues. The Board also engages in risk oversight through the project approval process, whereby projects reaching a threshold level of expected revenues require Board approval. Fixed-price contracts have a lower threshold level than reimbursable-type contracts because of their potential price and financial risks. In reviewing projects, the Board is presented with management’s assessment of a particular project’s cost exposure associated with operations risk, liabilities and funding risks, - 2014 Proxy Statement 15


Corporate Governance among others. In this manner, KBR’s Board is engaged in risk oversight at the outset of the largest projects, which could have a material effect on KBR’s operations.

The Board is also engaged in risk oversight through regular reports from its Audit Committee. The Audit Committee is charged with reviewing with management the company’s major financial risk exposures, as well as others areas of risk exposure if requested to do so by the Board, and the steps management has taken to monitor and mitigate those exposures. The Audit Committee receives periodic reports from management on these areas of potential exposure, including litigation, liquidity and capital resources, financial reporting and disclosures, regulatory and tax risks, among others. The Audit Committee also receives reports from management regarding compliance risks and Code of Business Conduct matters. The Audit Committee also reviews at least annually KBR’s policies and guidelines that govern the process by which risk assessment and enterprise risk management is undertaken. The Audit Committee also receives in-depth periodic reports from management regarding specific processes designed to monitor and manage risk, such as project estimation procedures and foreign exchange risk management. The Audit Committee conducts private sessions with KBR’s Chief Financial Officer, Vice President of Internal Audit and General Counsel at each regular meeting and with KBR’s independent auditors at each meeting prior to the release of quarterly and annual results. The Audit Committee Chairman gives a report of the Audit Committee’s activities to the full Board at each regular meeting and in this manner the entire Board is informed of matters that the Audit Committee determines warrant full Board discussion. Finally, the Corporate Social Responsibility Committee has the responsibility for the oversight of KBR’s activities in managing its major risk exposures within the health, safety and sustainable development areas. The Corporate Social Responsibility Committee receives periodic reports from KBR’s Chief QHSE Officer relating to these risk exposures and the company’s efforts to mitigate those risks.’


Annual Report (2012), p.24:

‘We are subject to certain U.S. laws and regulations, which are the subject of rigorous enforcement by the U.S. government.

To the extent that we export products, technical data and services outside of the United States we are subject to laws and regulations governing trade and exports, including but not limited to, the International Traffic in Arms Regulations, the Export Administration Regulations and trade sanctions against embargoed countries, which are administered by the Office of Foreign Asset Control within the Department of the Treasury. A failure to comply with these laws and regulations could result in civil and/or criminal sanctions, including the imposition of fines upon us as well as the denial of export privileges and debarment from participation in U.S. government contracts. Additionally, we may be subject to qui tam litigation brought by private individuals on behalf of the U.S. government under the Federal False Claims Act, which could include claims for treble damages. U.S. government contract violations could result in the imposition of civil and criminal penalties or sanctions, contract termination, forfeiture of profit and/or suspension of payment, any of




which could make us lose our status as an eligible U.S. government contractor and cause us to suffer serious harm to our reputation. Any suspension or termination of our U.S. government contractor status could have a negative adverse impact to our business, financial condition or results of operations.

We are subject to anti-bribery laws in the U.S. and other jurisdictions, violations of which could include suspension or debarment of our ability to contract with the United States, state or local governments, U.S. government agencies or the U.K. MoD, third party claims, loss of customers, adverse financial impact, damage to reputation and adverse consequences on financing for current or future projects.

The Foreign Corrupt Practices Act (“FCPA”) in the U.S., the U.K. Anti-Bribery Act and similar anti-bribery laws in other jurisdictions generally prohibit companies and their intermediaries from making improper payments to non-U.S. officials for the purpose of obtaining or retaining business. Our policies mandate compliance with these anti-bribery laws. We operate in many parts of the world that have experienced governmental corruption to some degree and, in certain circumstances, strict compliance with anti-bribery laws may conflict with local customs and practices. We train our staff concerning FCPA issues, and we also inform our partners, subcontractors, agents and other third parties who work for us or on our behalf that they must comply with the requirements of the FCPA and other anti-corruption laws. We also have procedures and controls in place to monitor internal and external compliance. We cannot provide complete assurance that our internal controls and procedures will always protect us from the reckless or criminal acts committed by our employees or third parties working on our behalf. If we are found to be liable for violations of these laws (either due to our own acts or our inadvertence, or due to the acts or inadvertence of others), we could suffer from criminal or civil penalties or other sanctions which could have a material adverse effect on our business.’

http://investors.kbr.com/files/doc_financials/2012/KBR%202012%20Annual%20Report.pdf



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:

0

Comments:

Based on public information, there is no readily available evidence that the company has 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. TI notes that the company has a risk assessment procedure for new projects, but these are related to potential price and financial risk, not to corruption risk.

References:

Public:

TI notes:

Proxy Statement (2014), pp.14-15:

‘KBR’s Board of Directors considers risk oversight to be an integral part of its role, and discussions regarding risks faced by the company are part of its meetings and deliberations throughout the year. Furthermore, at least twice each year, the entire Board receives a report from management regarding significant strategic, operational, financial, and hazard risks determined by management to have a potential significant impact on the company as a whole. The risk report involves both current and emerging risks and is the culmination of a process involving input from all business groups and executive leadership. The risk report includes specific strategic, operational, financial and hazard risks, the perceived trend for each of those specific risks — whether increasing, decreasing or stable — and the measures being taken to monitor and mitigate those risks. In addition to the enterprise risk management process described above, the Board of Directors also engages in risk oversight in the area of project revenues. At each meeting, the Board reviews aggregated KBR project revenues measured by type of contract — fixed-price or reimbursable — by country, client and project backlog. In this manner, the Board is informed of the overall risk profile of KBR’s project revenues. The Board also engages in risk oversight through the project approval process, whereby projects reaching a threshold level of expected revenues require Board approval. Fixed-price contracts have a lower threshold level than reimbursable-type contracts because of their potential price and financial risks. In reviewing projects, the


Board is presented with management’s assessment of a particular project’s cost exposure associated with operations risk, liabilities and funding risks, among others. In this manner, KBR’s Board is engaged in risk oversight at the outset of the largest projects, which could have a material effect on KBR’s operations.’


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 conducts due diligence that minimises corruption risk when selecting or reappointing agents. However, there is no evidence that the company refreshes the due diligence at least every 3 years and/or when there is a significant change in the business relationship. The company therefore scores 1.

References:

Public:


‘Purpose

This policy provides requirements related to business relationships entered into or involving activities outside of the United States (“International Business Relationships”) that pose potential risk under the U.S. Foreign Corrupt Practices Act (“FCPA”) or other

applicable anti-corruption Laws due to the interactions of Employees, Directors, Legal Agents, Third Parties and Partners with Foreign Officials. This policy sets forth the circumstances that trigger the requirement of prior review and approval of an International Business Relationship in order to ensure that the Company has relationships with qualified and ethical individuals and entities

Definitions

“International Commercial Intermediary” (“ICI”) means:

i. any commercial agent, sales representative, sponsor, consultant or other Third Party retained to assist the Company in obtaining or promoting business outside the United States regardless of how that Third Party is compensated (e.g., fixed fee, “success fee,” hourly rate);

ii. any Third Party working as a lobbyist to perform advocacy or interact with a non-U.S. government official, employee or entity on behalf of the Company. Included in this definition of ICIs are International Commercial Agents or ICAs under the Company’s prior policies.

“International Services Intermediary” (“ISI”) means:


i. any Third Party that assists the Company with obtaining a regulatory approval (such as a license, permit or customs clearance) from a non-U.S. government entity, including but not limited to customs brokers, visa expeditors, freight forwarders and importers/exporters;

ii. any Third Party that assists the Company with the resolution of a dispute, claim or debt involving a non-U.S. government entity, including but not limited to tax and financial advisors, debt collectors, and lawyers; and

iii. any Third Party not identified above as an ICI or included in i) or ii) above that interacts on behalf of the Company with non-U.S. government officials, employees or entities, including government-owned or controlled companies, who have some discretionary authority over a matter that could impact the Company’s existing or potential business.

This could include contractors, subcontractors, real estate or property agents, brokers or appraisers, travel agents, and scientific or technical consultants. This would not include Third Parties who prepare marketing studies for an international project but who will not interact with any Foreign Official on KBR’s behalf.

Included in this definition of ISIs are International Non-Commercial Agents or NCAs under the Company’s prior policies.’

(p.16): ‘1. International Commercial Intermediaries, International Services Intermediaries, Partners, and Business Transactions with Foreign Officials shall be subject to careful consideration after an inquiry, appropriate under the circumstances, with respect to

such parties and the proposed arrangements with such parties. No part of the Company, including subsidiaries of the Company may join in these types of International Business Relationship without prior review and approval by appropriate management of the Company and the Company’s Law Department as described below.

2. All prospective ICIs and Partners, except those qualifying for an exception established by the Director of Compliance, must be reviewed in accordance with the Procedures for Implementation of KBR’s Anti-Corruption Policies and approved by the “International Business Relationships Committee” (“IBRC”).

3. All prospective ISIs must be reviewed and approved in accordance with the Procedures for Implementation of KBR’s Anti-Corruption Policies.

4. No ICI, ISI or Partner may be approved unless and until a determination is made that: (i) the proposed International Business Relationship complies with all applicable Laws; and (ii) the review conducted is sufficient to provide the Company with a reasonable level of assurance that the ICI, ISI or Partner will not violate the FCPA or any other applicable anti-corruption law.

5. No work or service may be performed by any new ICI, ISI or Partner with which the Company wishes to join in an International Business Relationship and no promise by Company personnel to pay for such work or service or payment may be made unless and until the proposed relationship has been approved by the Company and a written agreement has been executed by the Company and the ICI, ISI or Partner.

6. The IBRC shall approve standard contract provisions regarding anti-corruption compliance for use in all agreements with ICIs, ISIs and Partners. The Director of Compliance shall ensure that all ICIs, ISIs and Partners are provided with the Code of Business Conduct for International Business Relationships and a summary of International Anti-Corruption Laws


at the time of execution of the agreement between the Company and the ICI, ISI or Partner. All such ICIs, ISIs or Partners receiving these documents shall be asked to sign a certification acknowledging receipt of the documents, affirming comprehension of the materials, and agreeing to comply with the Code of Business Conduct for International Business Relationships and with International Anti-Corruption Laws.’


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 has contractual rights and processes for the behaviour, monitoring, control and audit of agents with respect to countering corruption. Agents are expected to commit to compliance of the company’s Code of Business Conduct and the Anti-Corruption Laws. There is evidence that agents are monitored and in case of violations the contracts are terminated.

References:

Public:


‘“Third Party” means any individual not employed by or entity not owned, even in part, by the Company, retained by the Company to provide services or engage in business activities on behalf of the Company and whose activities are wholly or partly outside the United States, including but not limited to commercial agents, sponsors, advisors, consultants, contractors, subcontractors, and other service providers.’

(p.16): ‘6. The IBRC shall approve standard contract provisions regarding anti-corruption compliance for use in all agreements with ICIs, ISIs and Partners. The Director of Compliance shall ensure that all ICIs, ISIs and Partners are provided with the Code of Business Conduct for International Business Relationships and a summary of International Anti-Corruption Laws at the time of execution of the agreement between the Company and the ICI, ISI or Partner. All such ICIs, ISIs or Partners receiving these documents shall be asked to sign a certification acknowledging receipt of the documents, affirming comprehension of the materials, and agreeing to comply with the Code of Business Conduct for International Business Relationships and with International Anti-Corruption Laws.’ Proxy Statement (2014), p.20: ‘KBR has adopted a “code of ethics,” as defined in Item 406(b) of Regulation S-K. KBR’s code of ethics, known as its Code of Business Conduct, applies to all directors, officers and


employees of KBR, including its principal executive officer, principal financial officer, principal accounting officer and controller, and also applies to all employees of KBR and KBR’s agents. KBR has posted its Code of Business Conduct on its website, www.kbr.com. In addition, KBR intends to satisfy the disclosure requirements regarding any amendment to, or waiver from, a provision of the Code of Business Conduct that relates to any element of the definition of code of ethics set forth in Item 406(b) of Regulation S-K, including the requirements of Item 5.05 of Form 8-K, by posting such information on its website, www.kbr.com.’ (p.24): ‘We train our staff concerning FCPA issues, and we also inform our partners, subcontractors, agents and other third parties who work for us or on our behalf that they must comply with the requirements of the FCPA and other anti-corruption laws. We also have procedures and controls in place to monitor internal and external compliance.’ (p.58): ‘Commercial Agent Fees Prior to separation, it was identified by our former parent in performing its investigation of anti-corruption activities that certain of these agents may have engaged in activities that were in violation of anti-corruption laws at that time and the terms of their agent agreements with us. Accordingly, we ceased the receipt of services from and payment of fees to these agents. In September 2010, we executed a final settlement agreement with one of our agents in question after the agent was reviewed and approved under our policies on business conduct. Under the terms of the settlement agreement, the agent had, among other things, confirmed their understanding of and compliance with KBR’s policies on business conduct and represented that they have complied with anti-corruption laws as they relate to prior services provided to KBR. We negotiated final payment for fees to this agent on several projects in our Hydrocarbons segment resulting in an overall reduction of estimated project costs of approximately $60 million in 2010. We released the remaining agent fee accruals in 2011 on the Bonny Island project which resulted in an increase of $4 million to operating income. ‘

http://www.kbr.com/


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:

1

Comments:

Based on public information, there is evidence that the company communicates its ethics and anti-corruption agenda down the supply chain. Third parties must ascribe to the standards set in its Code of Business Conduct and refrain from paying bribes. However, there is no evidence that the company has contractual rights to apply sanctions in the event of a breach of its contract. The company therefore scores 1.

References:

Public:


‘“Third Party” means any individual not employed by or entity not owned, even in part, by the Company, retained by the Company to provide services or engage in business activities on behalf of the Company and whose activities are wholly or partly outside the United States, including but not limited to commercial agents, sponsors, advisors, consultants, contractors, subcontractors, and other service providers.’

(p.3): ‘The Code of Business Conduct establishes a common set of ethical standards and legal principles that the Company expects all Directors, Employees and Legal Agents to exhibit when dealing with clients, the community and each other. The Company also expects that

Third Parties will also ascribe to these same ethical standards.’

(p.12): ‘Policy

1. The Company will conduct its business in compliance with all applicable Laws and in accordance with ethical standards. The Company prohibits all Directors, Employees, Legal Agents and Third Parties acting on behalf of the Company from paying, offering, promising or authorizing any bribe, kickback or other similar unlawful payment of money or anything of value to any public official or government employee, political party or party official,


candidate for public office or other individual, in any country.

2. More specifically, the Company requires its Directors, Employees, Legal Agents, and Third Parties acting on behalf of the Company to comply at all times with the U.S. Foreign Corrupt Practices Act (“FCPA”) and other applicable anti-corruption laws.’

(p.13): ‘11. All Third Parties who may interact with Foreign Officials on behalf of the Company shall agree in writing to follow all applicable portions of this Policy.’

(p.16): ‘6. The IBRC shall approve standard contract provisions regarding anti-corruption compliance for use in all agreements with ICIs, ISIs and Partners. The Director of Compliance shall ensure that all ICIs, ISIs and Partners are provided with the Code of Business Conduct for International Business Relationships and a summary of International Anti-Corruption Laws at the time of execution of the agreement between the Company and the ICI, ISI or Partner. All such ICIs, ISIs or Partners receiving these documents shall be asked to sign a certification acknowledging receipt of the documents, affirming comprehension of the materials, and agreeing to comply with the Code of Business Conduct for International Business Relationships and with International Anti-Corruption Laws.’


A13(a):

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

Score:

NA

Comments:

Based on public information, there is no readily available evidence that the company engages in offset contracting.

References:

Public:

NA


A13(b):

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

Score:

NA

Comments:

Based on public information, there is no readily available evidence that the company engages in offset contracting.

References:

Public:

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 that prohibits corruption in its various forms, including the giving and receiving of bribes and kickbacks.

References:

Public:

Code of Business Conduct (2012), pp.8-9:

‘Policy

1. The Company prohibits conflicts of interest unless specifically approved by the Chief Executive Officer or his or her designee as provided below since Directors and Employees have a duty to the Company to advance the Company’s legitimate interests when the opportunity to do so arises.

(p.12): ‘Policy

1. The Company will conduct its business in compliance with all applicable Laws and in accordance with ethical standards. The Company prohibits all Directors, Employees, Legal Agents and Third Parties acting on behalf of the Company from paying, offering, promising or authorizing any bribe, kickback or other similar unlawful payment of money or anything of value to any public official or government employee, political party or party official, candidate for public office or other individual, in any country.

2. More specifically, the Company requires its Directors, Employees, Legal Agents, and Third Parties acting on behalf of the Company to comply at all times with the U.S. Foreign Corrupt Practices Act (“FCPA”) and other applicable anti-corruption laws.

3. The FCPA prohibits companies and individuals from corruptly offering, promising, authorizing or giving anything of value to a Foreign Official for the purpose of influencing any act or decision of such Foreign Official in his or her official capacity or in violation of his or her lawful duties in order to secure any improper advantage in order to obtain or retain business or direct business to any person.


4. Because many improper payments are made through intermediaries rather than employees of the Company that desire the business or advantage, the FCPA also prohibits the offering or paying of anything of value to any person if it is known that all or part of the payment will be offered, given or promised to a Foreign Official for the improper purposes discussed above.

5. Any payment to a Foreign Official, including excessive entertainment, travel, gifts of significant value could be considered as a payment of something of value to obtain or retain business or unduly influence some behavior in favor of the Company and therefore could be a violation of the FCPA or other applicable anti-corruption law. Accordingly, extravagant or frequent business courtesies are prohibited. To provide further guidance, the Corporate Policy Regarding the Provision of Business Courtesies to Foreign Officials specifies the circumstances in which gifts may be given or hospitality provided to a Foreign Official.

6. Depending on the circumstances, donations to charitable organizations or community organizations could be considered something of value to a Foreign Official that could be an Improper Payment. The Charitable Contributions policy addresses the approval required for a Foreign Charitable Contribution, and the Foreign Community Contributions policy addresses the approval required for a contribution to an organization or entity that supports a community outside of the United States that is not covered by the Charitable Contributions policy.’

(p.12): ‘9. The Company and its Directors, Employees, Legal Agents and Third Parties acting on its behalf will not make ‘facilitating’ or expediting payments to a Foreign Official, the purpose of which is to expedite or to secure the performance of non-discretionary routine governmental action by such Foreign Official, except in accordance with the Company’s Faciliation Payments Policy.’

(p.14): ‘1. The Company prohibits Directors, Employees, Legal Agents and other third persons as described below from making bribes, kickbacks and other payoffs and benefits to suppliers or customers.

The Company also prohibits Directors, Employees, Legal Agents and other third persons as described below from receiving, directly or indirectly from a third party, anything of a significant value (other than salary, wages or other ordinary compensation paid by the Company) in connection with a transaction entered into by the Company.’


A16:

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

Score:

1

Comments:

Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. However, the company has a zero tolerance policy of violations of the Code of Business Ethics and Conduct, as shown by its explicit commitment to disciplinary procedures in the event of a violation by any employee or director. The company therefore scores 1.

References:

Public:


‘9. Disciplinary Measures.

Directors, Employees and Legal Agents will be held accountable for failure to adhere to the Company’s Code of Business Conduct. The Company shall promptly and consistently enforce its Code of Business Conduct through appropriate means of discipline. Pursuant to procedures adopted by it, the Board of Directors or its designee shall determine whether violations of the Code of Business Conduct have occurred. If the violation involves a Company Employee or Legal Agent, the Board of Directors or its designee shall determine the disciplinary or other measures to be taken against such Employee or Legal Agent. If the violation involves a Director, the violation will be reported to the Board of Directors and the Board of Directors shall determine the disciplinary measures to be taken against such Director.

The disciplinary measures which may be invoked include, but are not limited to, counseling, oral or written reprimands, warnings, probation or suspension without pay, demotions, reductions in salary, termination of employment and restitution.

Persons subject to disciplinary measures shall include, in addition to the violator, others involved in the wrongdoing such as: (i) persons who fail to use reasonable care to detect a violation; (ii) persons who if requested to divulge information withhold material information regarding a violation; and (iii) supervisors who approve or condone the violations or attempt to retaliate against Employees or Legal Agents for reporting violations or violators.’

(p.12): ‘1. The Company will conduct its business in compliance with all applicable Laws and


in accordance with ethical standards. The Company prohibits all Directors, Employees, Legal Agents and Third Parties acting on behalf of the Company from paying, offering, promising or authorizing any bribe, kickback or other similar unlawful payment of money or anything of value to any public official or government employee, political party or party official, candidate for public office or other individual, in any country.

2. More specifically, the Company requires its Directors, Employees, Legal Agents, and Third Parties acting on behalf of the Company to comply at all times with the U.S. Foreign Corrupt Practices Act (“FCPA”) and other applicable anti-corruption laws.’

(p.14): ‘1. The Company prohibits Directors, Employees, Legal Agents and other third persons as described below from making bribes, kickbacks and other payoffs and benefits to suppliers or customers.

The Company also prohibits Directors, Employees, Legal Agents and other third persons as described below from receiving, directly or indirectly from a third party, anything of a significant value (other than salary, wages or other ordinary compensation paid by the Company) in connection with a transaction entered into by the Company.’


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’s anti-corruption policy is easily accessible to Board members, employees and third parties. The Code of Business Conduct has been translated into multiple languages and is available online.

References:

Public:

Company Website: Code of Conduct in English


Company Website: Code of Business Conduct available in Albanian, Arabic, Chinese, English, French, Indonesian, Polish, Portugese, Russian and Spanish

http://www.kbr.com/About/Code-of-Business-Conduct/Translations/





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 anti-corruption policy is easily understandable and clear to Board members, employees and third parties. The company’s policy is assessed to be understandable to a non-legal audience.

References:

Public:


‘Purpose

This Policy prohibits Directors, Employees, Legal Agents, and Third Parties from making, offering or promising to make or authorizing the making of any Improper Payments, and requires that all transactions are executed, and access to assets is permitted, only in accordance with management’s authorization. For purposes of KBR policy, the term “Improper Payments” is used to describe a broad range of unlawful payments of money or anything of value that are usually in the nature of kickbacks, bribes or payoffs made in order to influence favorably some decision affecting a company’s business or for the personal gain of an individual. These types of payments are illegal and unethical. Because actions of Third Parties, like actions of Employees, can create liability for the company and damage its reputation, all Third Parties who may interact with Foreign Officials (as defined in Code of Business Conduct Policy 3-0001 and discussed more fully in Code of Business Conduct Policy 3-0007) on behalf of the Company shall agree in writing to follow all applicable portions of this Policy.

Definition

“Foreign Charitable Contribution” means any contribution to Charitable Organizations outside the United States, or to Charitable Organizations in the United States but for ultimate use outside of the United States.

“Foreign Official” means any:

• officer or employee of a non-U.S. government or public international organization, or any department or agency of such a government or organization;


• officer or employee of a non-U.S. government-owned or controlled company;

• non-U.S. political party;

• non-U.S. political party official;

• candidate for non-U.S. political office; or

• anyone acting in an official capacity on behalf of any of the foregoing (whether paid or unpaid).

Some examples of Foreign Officials include employees of national oil or other state-owned companies, members of royal families, employees of state-owned universities, employees of the World Bank or United Nations, and immigration and customs officials.

Policy






6. Depending on the circumstances, donations to charitable organizations or community organizations could be considered something of value to a Foreign Official that could be an Improper Payment. The Charitable Contributions policy addresses the approval required for a Foreign Charitable Contribution, and the Foreign Community Contributions policy addresses the approval required for a contribution to an organization or entity that supports a community outside of the United States that is not covered by the Charitable Contributions policy. ‘


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 anti-corruption policy explicitly applies to all employees and Board members.

References:

Public:


‘The Code of Business Conduct establishes a common set of ethical standards and legal principles that the Company expects all Directors, Employees and Legal Agents to exhibit when dealing with clients, the community and each other. The Company also expects that Third Parties will also ascribe to these same ethical standards.’

(p.12): ‘This Policy prohibits Directors, Employees, Legal Agents, and Third Parties from making, offering or promising to make or authorizing the making of any Improper Payments, and requires that all transactions are executed, and access to assets is permitted, only in accordance with management’s authorization.’


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 policy on potential conflicts of interest for employees, Directors and senior management. The company policy gives examples of potential conflicts of interest.

References:

Public:


‘Policy

1. The Company prohibits conflicts of interest unless specifically approved by the Chief Executive Officer or his or her designee as provided below since Directors and Employees have a duty to the Company to advance the Company’s legitimate interests when the opportunity to do so arises.

2. The Company has always been concerned with outside business interests of its Directors and Employees that might possibly conflict with the interests of the Company. An adequate definition of what constitutes a conflict of interest is most difficult.

However, the Company expects and requires Directors and Employees to be honest and ethical in the handling of actual or apparent conflicts of interest between personal and business relationships. The minimum standard is that required by law.

There are certain situations which the Company will always consider to be conflicts of interest. These occur if the Director or Employee, or any other person having a close personal relationship with the Director or Employee:

a. obtains a significant financial or other beneficial interest in one of the Company’s suppliers, customers or competitors without first notifying the Company and obtaining written approval from the Chief Executive Officer or his or her designee;

b. engages in a significant personal business transaction involving the Company for profit or gain, unless such transaction has first been approved in writing by the Chief Executive Officer or his or her designee;

c. accepts money, gifts of other than nominal value, excessive hospitality, loans, guarantees


of obligations or other special treatment from any supplier, customer or competitor of the Company (loans from lending institutions at prevailing interest rates are excluded);

d. participates in any sale, loan or gift of Company property without obtaining written approval from the Chief Executive Officer or his or her designee;

e. learns of a business opportunity through association with the Company and discloses it to a third party or invests in or takes the opportunity personally without first offering it to the Company;

f. uses corporate property, information, or position for personal gain;

g. competes with the Company; or

h. engages a significant amount of time in an outside business or other transaction or activity that diverts attention from the execution of an Employee’s responsibilities to the Company during normal working hours.

“Person having a close personal relationship with the Director or Employee” refers to the Director’s or Employee’sspouse, parents, children, siblings, mothers- and fathers-in-law, sons- and daughters-in-law, brothers- and sisters-inlaw,any person living in the same home with the Director or Employee or any business associate of the Director orEmployee.

Outside directorships may create a conflict of interest situation. The Company’s policy concerning outsidedirectorships is stated in Corporate Policy P-GL-KBR-AF-0018 or its successor.

The use of Company property or obtaining of Company services for personal benefit may create a conflict of interestsituation. The Company’s policy on these matters is stated in Corporate Policy No. P-GL-KBR-IT-0855 or itssuccessor.

3. As an enhanced conflict of interest provision, the Company prohibits personal loans or extensions of credit by the Company toDirectors and executive officers of the Company to the extent such loans are not directly related to and in the ordinary courseof the Company’s business.

4. If any Director or the Chief Executive Officer of the Company has a possible conflict of interest, the situation should be promptly and fully disclosed to the Audit Committee of the Company. If any other Employee has a possible conflict of interest, the situation should be promptly and fully disclosed to his or her manager or supervisor. It is the responsibility of the manager or supervisor to obtain the approval of the Chief Executive Officer or his or her designee as required by this Policy.

5. The Company shall have on file a statement of compliance from each key Employee who can direct or influence the use or disposition of any significant amount of funds or other assets of the Company. The disclosure of a financial or other beneficial interest does not mean that the Company will deem it significant or substantial enough to be prohibited. Each case will be decided on an individual basis.

6. The Chief Compliance Officer of the Company will ensure that all Employees subject to this requirement submit annually a completed copy of a statement of compliance. The Chief Compliance Officer will also be responsible for notifying the Chief Executive Officer and the Audit Committee of the Board of Directors that such statements are on file as well as for notifying theChief Executive Officer and the Committee when significant exceptions are reported.’


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 of a company policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. The giving and receiving gifts is regulated, but the company does not set clear upper limits or a specific threshold for senior authorisation. The company therefore scores 1.

References:

Public:


‘There are certain situations which the Company will always consider to be conflicts of interest. These occur if the Director or Employee, or any other person having a close personal relationship with the Director or Employee:

(p.8): ‘c. accepts money, gifts of other than nominal value, excessive hospitality, loans, guarantees of obligations or other special treatment from any supplier, customer or competitor of the Company (loans from lending institutions at prevailing interest rates are excluded);

d. participates in any sale, loan or gift of Company property without obtaining written approval from the Chief Executive Officer or his or her designee.’

(p.13): ‘5. Any payment to a Foreign Official, including excessive entertainment, travel, gifts of significant value could be considered as a payment of something of value to obtain or retain business or unduly influence some behavior in favor of the Company and therefore could be a violation of the FCPA or other applicable anti-corruption law. Accordingly, extravagant or frequent business courtesies are prohibited. To provide further guidance, the Corporate Policy Regarding the Provision of Business Courtesies to Foreign Officials specifies the circumstances in which gifts may be given or hospitality provided to a Foreign Official.’

(p.14): ‘Purpose


This Policy prohibits the payment or transfer of Company funds or assets to suppliers or customers in the form of bribes, kickbacks or other payoffs and prohibits Directors, Employees, Legal Agents and other third persons as described below from participating in such schemes.

Policy

1. The Company prohibits Directors, Employees, Legal Agents and other third persons as described below from making bribes, kickbacks and other payoffs and benefits to suppliers or customers.

2. The Company also prohibits Directors, Employees, Legal Agents and other third persons as described below from receiving, directly or indirectly from a third party, anything of a significant value (other than salary, wages or other ordinary compensation paid by the Company) in connection with a transaction entered into by the Company.

3. Bribes, kickbacks and payoffs include, but are not limited to:

a. gifts of other than nominal value;

b. cash payments by Directors, Employees, Legal Agents or other third persons such as commercial agents, suppliers, customers or consultants, who are reimbursed by the Company;

c. the uncompensated use of Company services, facilities or property except as may be authorized by the Company; and

d. loans, loan guarantees or other extensions of credit (except from lending institutions at prevailing rates).

4. This Policy does not prohibit expenditures of nominal amounts for meals and entertainment of suppliers and customers which are an ordinary and customary business expense, if they are otherwise lawful. These expenditures should be included on expense reports and approved under standard Company procedures.’

(p.26): ‘9. Federal, state and local laws restrict the offering of Gifts to Public Officials. Directors, Employees and Legal Agents are, therefore, generally prohibited from offering anything of value to Public Officials or employees. Directors, Employees and Legal Agents must refer to other relevant policies listed under “Other References” and seek prior approval from the Director of Government Relations and Director of Compliance before offering or agreeing to provide Gifts to any Public Official or employee.’

Company website: Ethical Business Practices

‘Improper Payments

Company policy prohibits its Directors, Employees, Legal Agents and Third Parties who may interact with Foreign Officials on behalf of the Company from making Improper Payments. If such a transaction occurs, the Company and its Directors and Employees directly involved may be subject to fines, imprisonment and civil litigation.

The term "Improper Payments" is commonly used to describe a broad range of business dealings generally considered to be either illegal, unethical, immoral or to reflect adversely on the integrity of the Company. These payments are usually in the nature of kickbacks, gifts of significant value, bribes or payoffs made to favorably influence some decision affecting a


company's business or for the personal gain of an individual. These transactions may result in violation of various laws, including the United States Foreign Corrupt Practices Act (the "FCPA") and similar laws of other countries.

Company policy and the FCPA prohibits the Company and its Directors, Employees and Legal Agents from corruptly offering or giving anything of value to:

An officer or employee of a non-U.S. government or public international organization, or any department or agency of such a government or organization;

An officer or employee of a non-U.S. government-owned or controlled company;

A non U.S. political party official, political party, or candidate for political office; or

Anyone acting in an official capacity on behalf of any of the above.

directly or indirectly, for the purpose of influencing any act or decision of these officials in their official capacity or in violation of their lawful duties or to secure any improper advantage in order to help the Company obtain or retain business or direct business to any person.

Employees of government-owned companies, such as national oil companies, are considered to be Foreign Officials.

Company policy prohibits any Director, Employee Legal Agent, or Third Party who may interact with Foreign Officials on behalf of the Company from making any payment or engaging in any transaction that is prohibited by the FCPA.

Excessive or lavish gifts and hospitality to Foreign Officials can be violations of the FCPA and similar laws such that approvals must be obtained in accordance with the policy regarding Provision of Business Courtesies to Foreign Officials.

Facilitating payments that are small payments to secure or expedite the performance of a routine non-discretionary action by a government official must be strictly controlled and every effort must be made to eliminate or minimize such payments. Facilitating payments, if required, will be made only in accordance with the Company's Facilitating Payments Policy which requires multiple levels of advance written approval. All facilitating payments must be recorded accurately as facilitating payments in the accounting records of the Company.’

http://www.kbr.com/About/Code-of-Business-Conduct/Summary-of-the-Code/Ethical-Business-Practices/Improper-Payments/




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 some evidence of a company policy for the giving and receipt of hospitality to ensure that such transactions are bona fide and not a subterfuge for bribery. The company states that hospitality for suppliers or customers needs prior approval according to Company procedures. However, aside from this there appears to be no reference to set upper limits or a threshold for senior authorisation. The company therefore scores 1.

References:

Public:


‘There are certain situations which the Company will always consider to be conflicts of interest. These occur if the Director or Employee, or any other person having a close personal relationship with the Director or Employee:’

(p.8): ‘c. accepts money, gifts of other than nominal value, excessive hospitality, loans, guarantees of obligations or other special treatment from any supplier, customer or competitor of the Company (loans from lending institutions at prevailing interest rates are excluded);’

(p.13): ‘5. Any payment to a Foreign Official, including excessive entertainment, travel, gifts of significant value could be considered as a payment of something of value to obtain or retain business or unduly influence some behavior in favor of the Company and therefore could be a violation of the FCPA or other applicable anti-corruption law. Accordingly, extravagant or frequent business courtesies are prohibited. To provide further guidance, the Corporate Policy Regarding the Provision of Business Courtesies to Foreign Officials specifies the circumstances in which gifts may be given or hospitality provided to a Foreign Official.’


(p.14): ‘4. This Policy does not prohibit expenditures of nominal amounts for meals and entertainment of suppliers and customers which are an ordinary and customary business expense, if they are otherwise lawful. These expenditures should be included on expense reports and approved under standard Company procedures.’


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 has a clear policy that explicitly prohibits facilitation payments. TI notes that the company states that it will try to minimise facilitation payments and that they require prior approval.

References:

Public:

TI notes:


‘9. The Company and its Directors, Employees, Legal Agents and Third Parties acting on its behalf will not make “facilitating” or expediting payments to a Foreign Official, the purpose of which is to expedite or to secure the performance of nondiscretionary routine governmental action by such Foreign Official, except in accordance with the Company’s Facilitating Payments Policy.’


‘Facilitating payments that are small payments to secure or expedite the performance of a routine non-discretionary action by a government official must be strictly controlled and every effort must be made to eliminate or minimize such payments. Facilitating payments, if required, will be made only in accordance with the Company's Facilitating Payments Policy which requires multiple levels of advance written approval. All facilitating payments must be recorded accurately as facilitating payments in the accounting records of the Company.’





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:

1

Comments:

Based on public information, there is evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent. Political contributions are subject to authorisation from the General Counsel and a review by the Director of Government Relations and Director of Compliance. The company therefore scores 1. To score higher the company would need to provide evidence that it publically declares the recipients of political contributions.

References:

Public:


‘Policy

1. The Company will conduct its business in compliance with all applicable Laws and in accordance with ethical standards. The Company prohibits all Directors, Employees, Legal Agents and Third Parties acting on behalf of the Company from paying, offering, promising or authorizing any bribe, kickback or other similar unlawful payment of money or anything of value to any public official or government employee, political party or party official, candidate for public office or other individual, in any country.’

(pp.25-26): ‘Policy

1. The Company will comply with applicable Laws regulating political influence and campaign contributions.

2. The Company believes strongly in the democratic political process and that its Directors, Employees and Legal Agents should take an active interest in fostering principles of good government in the nations, states and communities in which they live. Directors and Employees may spend their own time and funds supporting political candidates and issues, but they will not be reimbursed by the Company in any way for such time or their funds used for political contributions, nor may they use any Company assets. Directors, Employees


and Legal Agents are urged to be sure that their personal political contributions and activities are in compliance with applicable Laws. For example, persons who are not United States citizens are not permitted to make political contributions to candidates in federal, state or local elections in the United States. Other countries also have Laws regulating political contributions.

3. No Director, Employee, Legal Agent or other third person who represents the Company in political and governmental matters shall apply any pressure, direct or implied, on any Employee that infringes upon an individual’s right to decide whether, to whom and in what amount a personal political contribution is to be made or for whom to vote.

4. Directors, Employees, Legal Agents and other third persons who represent the Company in political and governmental matters must comply with all Laws that regulate corporate participation in public affairs. Under various statutes, certain conduct, which is permitted and encouraged for individuals, is prohibited on the part of corporations. It is the Company’s policy to comply fully with these prohibitions.

5. No contribution of Company funds, property or services can be made, or use of the Company name or logo, in support of any political candidate for elective office, or political cause or any political party or party official in the United States (either at the state or federal level) or in any other country by the Company, or in the name of the Company, except where permitted by law and in accordance with a plan approved by the Chief Executive Officer or his or her designee. Such approval is subject to the General Counsel’s approval and review by the Director of Government Relations and Director of Compliance who will verify that the proposed contribution is legal and proper under applicable Laws, including the FCPA.

6. When permitted by applicable Laws and authorized by the Chief Executive Officer or his or her designee and subject to review by the General Counsel and Director of Government Relations, Company funds and facilities may be used to provide the needed administrative support for the operation of Political Action Committee(s) (PAC) or political action programs, the purposes of which include the disbursement of financial contributions made by certain Employees, shareholders and/or others to political parties or candidates.

7. When permitted by applicable Laws, and authorized by the Chief Executive Officer or his or her designee and subject to review by the General Counsel and Director of Government Relations, expenditures of Company funds may be made to inform or influence the voting public on an issue of importance to the business of the Company and its shareholders.

8. To avoid any legal violations by the Company and to ensure proper regulatory disclosures are filed for the Company and/or its employees, all Political Activities on behalf of the Company require pre-approval by the Company’s Government Relations office. Please note that some Employees may be otherwise subject to a more restrictive policy for their business or corporate unit within the Company.

9. Federal, state and local laws restrict the offering of Gifts to Public Officials. Directors, Employees and Legal Agents are, therefore, generally prohibited from offering anything of value to Public Officials or employees. Directors, Employees and Legal Agents must refer to other relevant policies listed under “Other References” and seek prior approval from the Director of Government Relations and Director of Compliance before offering or agreeing to provide Gifts to any Public Official or employee.’



‘The Corporate Social Responsibility Committee’s responsibilities include, but are not limited to:

• reviewing KBR’s political and charitable contributions as well as any trade organization memberships.’


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:

1

Comments:

Based on public information, there is some evidence that the company has a policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent. The company states that it follows all relevant laws and regulates lobbying by requiring a pre-approval from the Company’s Government Relations office when employees engage in political activities, including lobbying. However, the guidelines on the application are not clear and the company does not publically disclose the issues on which it lobbies. The company therefore scores 1.

References:

Public:


‘Purpose

The Company encourages participation in the political process. The United States federal government, states, localities, and some other countries have, however, enacted Laws regulating Political Contributions, Political Activities and Gifts in order to prevent improper influencing of Public Officials. Moreover, the U.S. Foreign Corrupt Practices Act (“FCPA”) and similar laws of other countries prohibit bribing foreign political parties, foreign political party officials, and candidates for foreign political office, among others. Political Contributions to such individuals or entities could be deemed to be improper payments under the FCPA or anti-corruption laws of other countries. Participating in Political Activities at the international, of U.S. federal, state or local level may raise legal implications and liability for the Company. For these reasons, Employees should become familiar with relevant laws and always consult the Government Relations department before engaging in activities discussed in this Policy. This Policy sets forth certain rules regarding Company and Employee activities as they relate to Public Officials, Political Contributions, and Political Activities.

Definition

“Legal Agent” means any individual or entity acting on behalf of the Company with authority


to bind the Company.

“Public Official” means an elected or appointed federal, state or local government official and his or her employees.

“Political Activities” include but are not limited to:

i. Making corporate Political Contributions, or soliciting Political Contributions from individuals, or using Company funds or resources (such as facilities or personnel), hosting fundraisers, serving as an advisor or having a formal role in a campaign, political party or political committee, or volunteering personal services during Company time on behalf of a candidate campaigning for public office, a political party committee or political committee;

ii. Lobbying or seeking to influence Public Officials to take action on matters over which they have decision making authority, including attempts to influence legislation, agency rulemaking, or awarding of government contracts. Lobbying has specific definitions within a given jurisdiction; please consult the Government Relations Department for further information.

iii. Seeking, accepting or holding any political office associated with the government, including any government board, commission or other similar organization.

“Political Contribution” means a monetary or in-kind contribution to a foreign or U.S. Public Official, a foreign or U.S. federal, state or local candidate, political party, political action committee, section 527 organization or 501(c)(4) organization.

“Gift” means anything of value including meals, transportation, hospitality and entertainment, but does not mean Political Contributions.

Policy

1. The Company will comply with applicable Laws regulating political influence and campaign contributions.

2. The Company believes strongly in the democratic political process and that its Directors, Employees and Legal Agents should take an active interest in fostering principles of good government in the nations, states and communities in which they live. Directors and Employees may spend their own time and funds supporting political candidates and issues, but they will not be reimbursed by the Company in any way for such time or their funds used for political contributions, nor may they use any Company assets. Directors, Employees and Legal Agents are urged to be sure that their personal political contributions and activities are in compliance with applicable Laws. For example, persons who are not United States citizens are not permitted to make political contributions to candidates in federal, state or local elections in the United States. Other countries also have Laws regulating political contributions.

3. No Director, Employee, Legal Agent or other third person who represents the Company in political and governmental matters shall apply any pressure, direct or implied, on any Employee that infringes upon an individual’s right to decide whether, to whom and in what amount a personal political contribution is to be made or for whom to vote.

4. Directors, Employees, Legal Agents and other third persons who represent the Company in political and governmental matters must comply with all Laws that regulate corporate participation in public affairs. Under various statutes, certain conduct, which is permitted and encouraged for individuals, is prohibited on the part of corporations. It is the Company’s policy to comply fully with these prohibitions.


5. No contribution of Company funds, property or services can be made, or use of the Company name or logo, in support of any political candidate for elective office, or political cause or any political party or party official in the United States (either at the state or federal level) or in any other country by the Company, or in the name of the Company, except where permitted by law and in accordance with a plan approved by the Chief Executive Officer or his or her designee. Such approval is subject to the General Counsel’s approval and review by the Director of Government Relations and Director of Compliance who will verify that the proposed contribution is legal and proper under applicable Laws, including the FCPA.

6. When permitted by applicable Laws and authorized by the Chief Executive Officer or his or her designee and subject to review by the General Counsel and Director of Government Relations, Company funds and facilities may be used to provide the needed administrative support for the operation of Political Action Committee(s) (PAC) or political action programs, the purposes of which include the disbursement of financial contributions made by certain Employees, shareholders and/or others to political parties or candidates.

7. When permitted by applicable Laws, and authorized by the Chief Executive Officer or his or her designee and subject to review by the General Counsel and Director of Government Relations, expenditures of Company funds may be made to inform or influence the voting public on an issue of importance to the business of the Company and its shareholders.

8. To avoid any legal violations by the Company and to ensure proper regulatory disclosures are filed for the Company and/or its employees, all Political Activities on behalf of the Company require pre-approval by the Company’s Government Relations office. Please note that some Employees may be otherwise subject to a more restrictive policy for their business or corporate unit within the Company.

9. Federal, state and local laws restrict the offering of Gifts to Public Officials. Directors, Employees and Legal Agents are, therefore, generally prohibited from offering anything of value to Public Officials or employees. Directors, Employees and Legal Agents must refer to other relevant policies listed under “Other References” and seek prior approval from the Director of Government Relations and Director of Compliance before offering or agreeing to provide Gifts to any Public Official or employee.

Procedure

If an Employee, Director or Legal Agent is requested to make a political contribution or to provide assistance on behalf of the Company, whether personal or corporate, and such Employee, Director or Legal Agent has any questions regarding this Policy or applicable Laws, the Employee, Director or Legal Agent should consult with the Director, Government Relations or the Law Department.’


A25(a):

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

Score:

1

Comments:

Based on public information, there is some evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent. The company states that an approval is required for foreign community contributions and that the company only approves charitable contributions to organisations that meet certain criteria. However, there is no readily available evidence that the company publically declares the recipients of such contributions. The company therefore scores 1.

References:

Public:


‘6. Depending on the circumstances, donations to charitable organizations or community organizations could be considered something of value to a Foreign Official that could be an Improper Payment. The Charitable Contributions policy addresses the approval required for a Foreign Charitable Contribution, and the Foreign Community Contributions policy addresses the approval required for a contribution to an organization or entity that supports a community outside of the United States that is not covered by the Charitable Contributions policy.’


‘The Corporate Social Responsibility Committee’s responsibilities include, but are not limited to:

• reviewing KBR’s political and charitable contributions as well as any trade organization memberships.’

Company Website: Charitable Giving Guidelines

‘Charitable Giving Guidelines

In determining eligibility for making a charitable contribution, KBR will only consider an organization, a program or an activity that meets the first three criteria and at least one of


the additional ones:

- Must be a US 501(c)3 organization, school or educational institution or vetted charity internationally

- Meets one or more of KBR’s focus areas of education, environment and health - Directly impacts or benefits communities around the world where KBR has a

permanent office or project site - Demonstrates a specific need for support and has sound financial management - Provides for KBR employee volunteer involvement opportunities - Is recognized as a model program and has potential for replication - Can serve as a catalyst for support from other corporations and foundations - Has measureable results or criteria for evaluation - Completed application must be received by KBR by July 31 of the present year to be

considered for grants/donations/sponsorships, etc., for the following year.

KBR will NOT consider support to:

- Capital campaigns - Individuals - Organizations in the United States without federal tax-exempt status as US 501 (c) 3

nonprofits or educational institutions - Organizations outside the United States that are not approved charities in the

selected country or are not completely vetted for compliance with United States guidelines, laws and regulations

- Organizations located where KBR does not have offices other than selected international, national and regional programs

- Political, labor, fraternal organizations or civic clubs and all organizations which carry on propaganda or otherwise attempt to influence legislation

- Athletic or sporting event sponsorships unless US 501 (c) 3 nonprofits or educational institutions and for charitable purposes

- Religious organizations (e.g., churches or organizations directly tied to a place of worship) as determined at the sole discretion of KBR

- Development or production of books, films, videos or radio or television programs - Advertising in programs or journals unless associated with a KBR supported activity,

event or funded program - Support of school activities, clubs and events unless it involves science, technology,

engineering or math education’

http://www.kbr.com/social-responsibility/community/corporate-giving/charitable-giving-guidelines/




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:

1

Comments:

Based on public information, there is some evidence that the company provides written guidance to help Board members and employees understand and implement its ethics and anti-corruption agenda. The company provides definitions for the terms it uses in its policy, including definitions for gift, political contributions, improper payments and different actors, such as foreign officials. The company therefore scores 1. To score higher the company would need to provide evidence of written guidance that contains illustrations of particular situations in which employees might encounter corruption, to enhance understanding of company policies.

References:

Public:


‘Purpose

This Policy prohibits Directors, Employees, Legal Agents, and Third Parties from making, offering or promising to make or authorizing the making of any Improper Payments, and requires that all transactions are executed, and access to assets is permitted, only in accordance with management’s authorization. For purposes of KBR policy, the term “Improper Payments” is used to describe a broad range of unlawful payments of money or anything of value that are usually in the nature of kickbacks, bribes or payoffs made in order to influence favorably some decision affecting a company’s business or for the personal gain of an individual. These types of payments are illegal and unethical.Because actions of Third Parties, like actions of Employees, can create liability for the company and damage its reputation, all Third Parties who may interact with Foreign Officials (as defined in Code of Business Conduct Policy 3-0001 and discussed more fully in Code of Business Conduct Policy 3-0007) on behalf of the Company shall agree in writing to follow all applicable portions of this Policy.

Definition


“Foreign Charitable Contribution” means any contribution to Charitable Organizations outside the United States, or to Charitable Organizations in the United States but for ultimate use outside of the United States.

“Foreign Official” means any:

• officer or employee of a non-U.S. government or public international organization, or any department or agency of such a government or organization;

• officer or employee of a non-U.S. government-owned or controlled company;

• non-U.S. political party;

• non-U.S. political party official;

• candidate for non-U.S. political office; or

• anyone acting in an official capacity on behalf of any of the foregoing (whether paid or unpaid).

Some examples of Foreign Officials include employees of national oil or other state-owned companies, members of royal families, employees of state-owned universities, employees of the World Bank or United Nations, and immigration and customs officials.

Policy






6. Depending on the circumstances, donations to charitable organizations or community


organizations could be considered something of value to a Foreign Official that could be an Improper Payment. The Charitable Contributions policy addresses the approval required for a Foreign Charitable Contribution, and the Foreign Community Contributions policy addresses the approval required for a contribution to an organization or entity that supports a community outside of the United States that is not covered by the Charitable Contributions policy.

7. Improper Payments may result in violation of United States federal laws such as the FCPA and the anti-corruption laws of other countries, as well as domestic anti-bribery laws, mail fraud and wire fraud statutes, and anti-racketeering statutes. If violations occur, the Company and its Directors, Employees, Legal Agents, and Third Parties may be subject to fines, imprisonment and civil litigation. Directors and Employees who make or offer Improper Payments or engage in conduct prohibited by the FCPA or other applicable anti-corruption laws also are subject to disciplinary action by the Company, including termination.

8. Prior to acquiring a new company or other entity or purchasing an equity interest in an existing company or other entity, the Company will conduct a review to the extent possible under the circumstances to determine whether there is any credible evidence that the company or other entity to be acquired has engaged or appears likely to engage in Improper Payments.

9. The Company and its Directors, Employees, Legal Agents and Third Parties acting on its behalf will not make “facilitating” or expediting payments to a Foreign Official, the purpose of which is to expedite or to secure the performance of nondiscretionary routine governmental action by such Foreign Official, except in accordance with the Company’s Facilitating Payments Policy.

10. All transactions should be accurately, transparently, and timely recorded in the Company’s books and records with sufficient detail and documentation to support the transactions pursuant to Code of Business Conduct Policy 3-0004 and in accordance with the Accounting for Compliance Sensitive Payments policy.

11. All Third Parties who may interact with Foreign Officials on behalf of the Company shall agree in writing to follow all applicable portions of this Policy.

12. The Director of Compliance shall be responsible for establishing the procedures necessary to implement this Policy.’

(p.25): ‘Definition

“Legal Agent” means any individual or entity acting on behalf of the Company with authority to bind the Company.

“Public Official” means an elected or appointed federal, state or local government official and his or her employees.

“Political Activities” include but are not limited to:

i. Making corporate Political Contributions, or soliciting Political Contributions from individuals, or using Company funds or resources (such as facilities or personnel), hosting fundraisers, serving as an advisor or having a formal role in a campaign, political party or political committee, or volunteering personal services during Company time on behalf of a candidate campaigning for public office, a political party committee or political committee;


ii. Lobbying or seeking to influence Public Officials to take action on matters over which they have decision making authority, including attempts to influence legislation, agency rulemaking, or awarding of government contracts. Lobbying has specific definitions within a given jurisdiction; please consult the Government Relations Department for further information.

iii. Seeking, accepting or holding any political office associated with the government, including any government board, commission or other similar organization.

“Political Contribution” means a monetary or in-kind contribution to a foreign or U.S. Public Official, a foreign or U.S. federal, state or local candidate, political party, political action committee, section 527 organization or 501(c)(4) organization.

“Gift” means anything of value including meals, transportation, hospitality and entertainment, but does not mean Political Contributions.’


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 training programme that explicitly covers anti-corruption. The company states that it provides training related to the Code of Business Conduct, as well as a separate anti-corruption training programme.

References:

Public:


‘Policy

1. Directors, Employees and Legal Agents have the responsibility to read, understand, and comply with the Code of Business Conduct and to participate in any Company-mandated training relating to the Code of Business Conduct.’


‘Ethics

The KBR Code of Business Conduct (COBC) is a collection of 17 corporate policies that guide the behavior we expect of employees every day at our workplace. The COBC applies to every employee and those we hire to perform work on our behalf, from upper management to all full-time employees, and from craft/hourly employees to subcontractors. At KBR, the COBC is not just a document— it is an active part of our daily work. It showcases our values that are so much a part of our company’s culture. It is how we present ourselves to the world and build our strong reputation for professionalism and fair, ethical behavior toward all. Put simply, it’s how our global team does business. Each employee is required to become familiar with the COBC upon hire. To demonstrate our commitment to maintaining an outstanding workforce, KBR employees are required to refresh their ethics training with an annual course’

(p.58): ‘All KBR employees are required to complete Code of Business Conduct (COBC)


training annually, and KBR also has an extensive training program focused specifically on anti-corruption that includes live and online training.’


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 anti-corruption training is provided in all countries where the company operates or has company sites.

References:

Public:


‘Policy

1. Directors, Employees and Legal Agents have the responsibility to read, understand, and comply with the Code of Business Conduct and to participate in any Company-mandated training relating to the Code of Business Conduct.’


‘Ethics

The KBR Code of Business Conduct (COBC) is a collection of 17 corporate policies that guide the behavior we expect of employees every day at our workplace. The COBC applies to every employee and those we hire to perform work on our behalf, from upper management to all full-time employees, and from craft/hourly employees to subcontractors. At KBR, the COBC is not just a document— it is an active part of our daily work. It showcases our values that are so much a part of our company’s culture. It is how we present ourselves to the world and build our strong reputation for professionalism and fair, ethical behavior toward all. Put simply, it’s how our global team does business. Each employee is required to become familiar with the COBC upon hire. To demonstrate our commitment to maintaining an outstanding workforce, KBR employees are required to refresh their ethics training with an annual course.’


A29:

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

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

References:

Public:

NA


A30:

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

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

References:

Public:

NA


A31:

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

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest. TI notes that employees are required to disclose conflicts of interests to a manager. However, there is no evidence that this disclosure is conducted in writing.

References:

Public:

TI notes:


‘4. If any Director or the Chief Executive Officer of the Company has a possible conflict of interest, the situation should be promptly and fully disclosed to the Audit Committee of the Company. If any other Employee has a possible conflict of interest, the situation should be promptly and fully disclosed to his or her manager or supervisor. It is the responsibility of the manager or supervisor to obtain the approval of the Chief Executive Officer or his or her designee as required by this Policy.

5. The Company shall have on file a statement of compliance from each key Employee who can direct or influence the use or disposition of any significant amount of funds or other assets of the Company. The disclosure of a financial or other beneficial interest does not mean that the Company will deem it significant or substantial enough to be prohibited. Each case will be decided on an individual basis.

6. The Chief Compliance Officer of the Company will ensure that all Employees subject to this requirement submit annually a completed copy of a statement of compliance. The Chief Compliance Officer will also be responsible for notifying the Chief Executive Officer and the Audit Committee of the Board of Directors that such statements are on file as well as for notifying the Chief Executive Officer and the Committee when significant exceptions are reported.

Procedure

1. A completed statement of compliance will be obtained annually from all key Employees


subject to this requirement. In any instance where the number of key Employees makes this requirement burdensome, statements may be obtained from key Employees during the months which include their employment anniversary dates or on such other schedule as may be approved in writing by the Chief Executive Officer.

2. The completed statements will, subject to the Company’s policy on document retention, be retained on file in hard copy, electronic format, microfilm or other media as directed by the Chief Compliance Officer.

3. Statements of compliance will be completed by all Employees upon becoming subject to the standard stated in Policy paragraph 5 above. Supplemental and annual reports for such Employees will be obtained as set forth in Procedure paragraph 1 above.

4. The statement of compliance selection and reporting process will be reviewed annually by the principal Audit Services executive for adequacy and compliance with this Policy.

5. Results of the reporting process and the nature of significant exceptions, if any, will be communicated annually to the Chief Executive Officer and to the Audit Committee of the Board of Directors by the principal Audit Services executive no later than the first Audit Committee meeting of the following year.’


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:

2

Comments:

Based on public information, there is evidence that the company will apply disciplinary procedures to employees and Directors found to have violated the Code of Conduct. The company states that employees will be held accountable for failure to adhere to the company’s Code.

References:

Public:


‘9. Disciplinary Measures.

Directors, Employees and Legal Agents will be held accountable for failure to adhere to the Company’s Code of Business Conduct. The Company shall promptly and consistently enforce its Code of Business Conduct through appropriate means of discipline. Pursuant to procedures adopted by it, the Board of Directors or its designee shall determine whether violations of the Code of Business Conduct have occurred. If the violation involves a Company Employee or Legal Agent, the Board of Directors or its designee shall determine the disciplinary or other measures to be taken against such Employee or Legal Agent. If the violation involves a Director, the violation will be reported to the Board of Directors and the Board of Directors shall determine the disciplinary measures to be taken against such Director.

The disciplinary measures which may be invoked include, but are not limited to, counseling, oral or written reprimands, warnings, probation or suspension without pay, demotions, reductions in salary, termination of employment and restitution.

Persons subject to disciplinary measures shall include, in addition to the violator, others involved in the wrongdoing such as: (i) persons who fail to use reasonable care to detect a violation; (ii) persons who if requested to divulge information withhold material information regarding a violation; and (iii) supervisors who approve or condone the violations or attempt to retaliate against Employees or Legal Agents for reporting violations or violators.’


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 employees can report concerns or instances of suspected corrupt activity using multiple, well-publicised channels. Employees are able to report using the anonymous EthicsPoint online reporting tool, the Ethics Hotline or the Code of Business Conduct post office box. Ethicspoint is an independent reporting channel that allows two-way confidential communication. Other channels include the Law Department, Audit Services, HR department, and management.

References:

Public:


‘4. Directors, Employees and Legal Agents must promptly report any suspected violation of the Code of Business Conduct to an appropriate reporting outlet, which may include but is not limited to:

a. www.kbr.ethicspoint.com

b. The Ethics Hotline or Code of Business Conduct post office box

c. The Director of the Code of Business Conduct

d. Appropriate representative of the Law Department, Audit Services, Human Resources,

Health, Safety & Environment or other compliance-related department

e. The Employee’s supervisor or manager

f. Member of the executive senior management’

EthicsPoint Website: KBR EthicsPoint

‘To help us comply with the principles reflected in the Code, KBR has selected EthicsPoint, an independent company that specializes in the handling of confidential and anonymous reporting of workplace and ethical issues and concerns. KBR values and encourages your


input and, as indicated in the Code of Business Conduct, if you are aware of a violation, you must report it.

EthicsPoint will report all information it receives to KBR on a confidential basis. You have the option to submit claims anonymously if you wish. KBR will review every submission received, investigate all complaints, and, where appropriate, implement corrective action.

You may submit a report 4 ways: 1) online; 2) over the phone; 3) via email; or 4) through the Director of Business Conduct PO Box.

To submit a report through this website, start by selecting "File a Report" above and then follow the simple instructions.

To submit a report by telephone from either within the United States or Canada or internationally, follow the simple instructions on the right side of this page.

To submit a report via email, address your concerns to [email protected]

Or write to:

Director of Business Conduct

KBR, Inc.

P.O. Box 2464

Houston, TX 77252-2464

U.S.A

If you have a question about an issue that concerns you, you may select "Ask a Question" above and follow the simple instructions.

For individuals in the European Union, the Hotline only allows you to report concerns related to financial, accounting or auditing practices of the company, fraud or bribery allegations. If your concern pertains to other types of non-compliance issues, you are encouraged to report them to local management.’

www.kbr.ethicspoint.com

EthicsPoint Website: FAQ

‘What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?

When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique user name and are asked to choose a password. You can return to the

EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative and add further information that will help resolve open issues. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into an “anonymous dialogue” where situations are not only identified but can be resolved, no matter how complex.’

https://secure.ethicspoint.com/domain/media/en/gui/31830/faq.pdf

Company website: Confidential Reporting of Alleged Code Violations

‘Confidential Reporting of Alleged Code Violations

http://www.kbr.ethicspoint.com/



If you need advice relating to the Code of Business Conduct, there are a number of sources. You may contact your supervisor, the Law Department, either in person or by telephone, send an e-mail to FHOUKBR - CODE ([email protected]) or a letter to the special post office mailbox noted below. You may also call the Company's Ethics Hotline.’

http://www.kbr.com/About/Code-of-Business-Conduct/Summary-of-the-Code/Confidential-Reporting-of-Alleged-Code-Violations/




A33(a):

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

Score:

2

Comments:

Based on public information, there is evidence that across geographies, all employees have access to more than one whistleblowing channel. This includes the Ethics Hotline, the Director of the Code of Business Conduct, or a representative of a compliance-related department.

References:

Public:

Company website: Code of Business Conduct

‘To report a violation of the law or the Code of Business Conduct you may utilize the KBR Ethics Hotline and Reporting system at EthicsPoint. Available 24 hours a day, 7 days a week, your questions or concerns will be addressed by the Company confidentially and discretely. You may remain anonymous and translators are available.’

http://www.kbr.com/About/Code-of-Business-Conduct/


‘4. Directors, Employees and Legal Agents must promptly report any suspected violation of the Code of Business Conduct to an appropriate reporting outlet, which may include but is not limited to:

a. www.kbr.ethicspoint.com

b. The Ethics Hotline or Code of Business Conduct post office box

c. The Director of the Code of Business Conduct

d. Appropriate representative of the Law Department, Audit Services, Human Resources, Health, Safety & Environment or other compliance-related department

e. The Employee’s supervisor or manager

f. Member of the executive senior management’


http://www.kbr.com/About/Code-of-Business-Conduct/


‘To help us comply with the principles reflected in the Code, KBR has selected EthicsPoint, an independent company that specializes in the handling of confidential and anonymous reporting of workplace and ethical issues and concerns. KBR values and encourages your input and, as indicated in the Code of Business Conduct, if you are aware of a violation, you must report it.






Or write to:


KBR, Inc.

P.O. Box 2464


U.S.A




Company Website: Confidential Reporting of Alleged Code Violations








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:

1

Comments:

Based on public information, there is some evidence that the company has mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively. The company states that discouraging employees from making a report is prohibited and upper management is said to review all alleged violations of the Code of Business Conduct. Additionally, the company publishes whistleblowing data, suggesting that the company analyses such data to discover issues. However, it is not clear what is communicated to employees and if there are other formal mechanisms to ensure that whistleblowing is otherwise not deterred. The company therefore scores 1.

References:

Public:


‘The reporting system shall include an Ethics Hotline, which shall allow anonymous reporting. If in doubt about the person to contact, reports should be made to the Ethics Hotline, the General Counsel or any representative of the Law Department. It shall be a violation of this Corporate Policy to intimidate or impose any form of retribution on any Employee or Legal Agent who utilizes such reporting system in good faith to report suspected violations (except that appropriate action may be taken against such Employee or Legal Agent if such individual is one of the wrongdoers).’

(p.24): ‘5. The Company prohibits retaliation in any form for reporting, in good faith, suspected violations of the Code of Business Conduct. Disciplinary action will be taken against anyone who retaliates directly or indirectly against any Employee who reports actual or suspected violations. Discouraging other Employees from making a report is prohibited and could result in disciplinary action’



‘KBR offers an independently operated, global ethics hotline for reporting possible violations of the KBR COBC or applicable anti-corruption laws. These allegations are investigated to resolve any issues, and KBR takes disciplinary action as needed. Upper management reviews all alleged violations of the COBC. Between 2011 and 2013, the KBR Ethics Hotline received 1,294 calls, of which 330 concerned potential COBC violations.’


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 resources available to all employees where help and advice can be sought on corruption-related issues. Employees are able to contact the Ethics Hotline, the Law Department, the Director of Business Conduct, or the Director of Compliance.

References:

Public:


‘12. Advice and Assistance.

When in doubt about the propriety of a particular course of action, Employees are encouraged to contact the Ethics Hotline, the Law Department or any other person identified in this Code of Business Conduct for advice and assistance, including the Director of Business Conduct and Director of Compliance.’


‘To help us comply with the principles reflected in the Code, KBR has selected EthicsPoint, an independent company that specializes in the handling of confidential and anonymous reporting of workplace and ethical issues and concerns. KBR values and encourages your input and, as indicated in the Code of Business Conduct, if you are aware of a violation, you must report it.







Or write to:


KBR, Inc.

P.O. Box 2464


U.S.A




Company Website: KBR Regional Contacts

http://www.kbr.com/About/Code-of-Business-Conduct/Regional-Contacts/

Company website: Confidential Reporting of Alleged Code Violations









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 bona fide reporting of corruption, with disciplinary measures applied to employees who breach this policy.

References:

Public:


‘5. The Company prohibits retaliation in any form for reporting, in good faith, suspected violations of the Code of Business Conduct. Disciplinary action will be taken against anyone who retaliates directly or indirectly against any Employee who reports actual or suspected violations. Discouraging other Employees from making a report is prohibited and could result in disciplinary action.’


Information Sources:

Company website:

www.kbr.com

KBR Built on Values – Our Sustainability Story (2014):


KBR Annual Report (2012):


KBR Code of Business Principles (2012):


KBR Code of Business Conduct Translations:


KBR Audit Committee Charter (December 2013):


KBR Proxy Statement (2014):


The Oil & Gas Anti-Corruption & Compliance Congress: The Preeminent FCPA Enforcement and Compliance Benchmarking Event for the Oil and Gas Industry (September 2013):


http://www.kbr.com/















8th Annual FCPA and Anti-Corruption Compliance Conference (June 2012):


Supply Chain Brain website: KBR Share Insight at the 2nd Annual Oil and Gas Supply Chain Compliance Meeting


Company Website: Charitable Giving Guidelines


Company website: Mission, Vision and Values


Company website: Compliance and Ethics


DII website: Signatories






EthicsPoint Website: FAQ


Company Website: Confidential Reporting of Alleged Code Violations



















Company Website: KBR Regional Contacts



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