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Behaving the Atkins way:our code of conduct

Is it secure?

Am I doing the right thing?

Who’s responsible?

Should I report it?

Is it legal?

Is it ethical?

?

Is it safe?

Is it sustainable?

Behaving the Atkins way:our code of conduct

4 Behaving the Atkins way: our code of conduct

Do you need to report an issue or concern?

In the first instance, you should talk to your line manager, but there is further help at hand, including Safecall.

Safecall provides a confidential service for the reporting of any inappropriate behaviour.

For further information on how to report an issue, see page 54 of this code.

Behaving the Atkins way: our code of conduct 5

Do you need to report an issue or concern? See page 54 for details.

Contents

Foreword from our CEO 7

Introduction 8

Section 1: Doing business the Atkins way 13

a. People 15

b. Win work 16

c. Deliver work 17

d. Business operations 17

Section 2: Behaving the Atkins way 19

a. Value people and relationships 22

b. Work ethically 25

c. Build our success 26

- Atkins’ Design Principles 29

d. Be safe and secure 31

- Safe and Secure by Choice 33

- Safety moments 34

e. Take personal responsibility 35

f. Protect information and assets 37

g. Enable a sustainable future 38

- Atkins’ Sustainability Principles 39

Section 3: Putting it into practice 43

Section 4: Reporting an issue or a concern 53

Section 5: Further information 57



Foreword by Uwe Krueger, CEOAtkins is a great place in which to work. I am proud of everything we have already achieved over the years and look forward to the successes yet to come. It is with pride, that I join generations of passionate and brilliant Atkins people in our shared commitment to do the right thing.

It is a mark of our culture that we care about our colleagues, our clients and partners, and the legacy we leave behind for future generations to inherit. We also care about the

reputation we have built for ourselves. Atkins’ continued success depends upon us maintaining that reputation. I want us to set and maintain the highest standards of behaviour and be able to withstand scrutiny – something we can only do if we are clear about what Atkins stands for and the behaviours that underpin it.

What we do and how we do it sends a powerful message to our clients, our business partners, and to prospective Atkins employees. It also distinguishes us from our competitors.

This code sets out what it means to think and behave in the Atkins way. It provides us with a clear framework within which to make decisions, defining what we are all expected to do on a daily basis, and what we can expect from our colleagues.

Irrespective of your job role, functional area, business unit or region, together we are one Atkins. This code applies to everyone in the Atkins Group – employees, temporary staff and associates. It is also a useful reference point for working with our business partners on the standards that we expect.

Please ensure you understand and are familiar with the behaviours and principles set out in this code, and that you reflect them in your work activities. All businesses and employees within the Atkins Group are accountable for their behaviour and I ask for your support and professionalism in making this code truly effective.

I will always support you in doing the right thing. If you are ever in any doubt or have concerns about dishonest, unethical, unacceptable or unsafe behaviour, I encourage you to raise this and challenge anything you feel is inappropriate.

Uwe KruegerChief Executive Officer


IntroductionWhen you join Atkins, you join a business with a proud heritage. It is a business that prides itself on the talents and qualities of its people; qualities that have enabled us to develop lasting and valued relationships with our clients, and an enviable reputation around the world.

We do things the Atkins way. We care and this sits at the heart of our culture, running through the core of everything we do.We care about each other and we care about our clients. We care about the quality of the solutions we deliver, the services we provide, and the world in which we live and work. But above all, we care about our future.

We work hard to protect our reputation and safeguard our future, setting high standards for ourselves in everything we do, every day.



Integrity

Protect information and assets

Deliver work

People Win work

Take personal responsibility

Be safe and secure

Build our success

Work ethically

Enable a sustainable

future

Value people and relationships

Businessoperations

Integrity

Prrotectinformation andd assets

liverDelwork

Peopleple Winork wo


fe Be safureand sec

Build ourBsuccesss

Work ethicallyethically

Enable aa sustainabble

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Value people and relationshipsand relationships

Businnessoperations

This code is structured around our four core business processes, and defines the seven behaviours that wrap around our daily activities.

The diagram below illustrates this relationship, and as you can see, it places integrity at the heart of what we do.

In Section 1, we describe the four processes on which we all focus, while in Section 2, we identify the behaviours we value and expect of all Atkins people. Then, in Section 3, we describe the ways in which we must all apply these behaviours to our daily activities.



Behaving the Atkins way

This code sets out what is expected of you as an Atkins employee, providing explanations and guidance in every section, designed to help you meet those expectations. It also describes what you can expect from Atkins as a company, and what you should expect from each other.

Working within these expectations is crucial to our success, and will ensure our company has a reputation we can all be proud of.

Once you’ve read this code, you will:

• Understand what is expected of you as an Atkins employee• Understand the importance of caring and behaving the

Atkins way • Understand the consequences of not behaving the Atkins way • Know how and when to report any issues that you feel

contravene our behaviours, and feel empowered to do so • Know where to go for further information, advice and support

This code forms part of the Atkins corporate governance framework. In other words, the controls we put in place at every level of our business. For more information about our corporate governance framework, see page 58.



Section 1:

Doing business the Atkins way

In this section, we explore each of our four core business processes and set out:

• A short description of each business process

• The rationale for each business process




Be safe and secure

Build our success

Work ethically


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Deliver work

People Win work

Businessoperations

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Section 1:

Doing business the Atkins wayAt Atkins, our daily activities revolve around four core business processes:

These activities form the foundation upon which we have achieved – and continue to achieve – success. After all, what we do, and how we do it, defines us. It is what attracts clients and talented people to our business.

But in order to achieve success in each of these areas, we must all behave in a way that meets our legal obligations, is ethical and fair, and reflects our culture.

Our approach to developing and supporting our people

Our approach throughout day-to-day business operations

Our approach when delivering work to our clients

Our approach to bidding for and winning work



a. PeopleWhat do we mean by ‘People’?

People are central to us achieving our aims as a business. This includes our colleagues, our clients, our business partners and others we work with.

• We need to attract and retain the very best people to work for Atkins, motivate people to achieve the best, and develop individuals and teams to their full potential

• We need to inspire confidence among those we work with, including demonstrating respect for others – their cultures, customs and traditions – and fostering open and honest communication

• We need to ensure the safety and well-being of everyone.

Why is it important?

People are at the heart of what we do – the services we provide are built around the skills and expertise of our workforce. Our culture and the way we work determine whether clients and partners want to do business with us, and whether talented people choose a career with Atkins.


b. Win workWhat do we mean by ‘Win work’?

To be financially successful, Atkins needs to maintain a constant pipeline of future work. To secure and retain clients, win work and grow our business, we need to conduct ourselves in a professional manner.

This includes:

• Winning new clients• Securing new and additional work with existing clients• Delivering different services and types of work to our

current clients, including opportunities for cross selling• Retaining contracts for services when these are re-tendered• Developing alliances and joint ventures that enable us to win

more work• Opening up new markets through innovation and a fresh

perspective.


We need new and continued sources of revenue to continue to be successful.

“At Atkins, we’re always willing to go the extra mile, to push the technical boundaries and do extraordinary things to deliver innovative solutions.”– Andrew, chief engineer



c. Deliver workWhat do we mean by ‘Deliver work’?

Delivering work describes the way we fulfil our commitments and satisfy the needs of our stakeholders and interested parties (including clients, colleagues and suppliers), as well as meeting our own and industry standards.

We must always strive to show how Atkins can add value over and above the basic requirements of doing a piece of work.


We’re judged by the quality of the work we deliver, as well as our approach to getting things done. The way we deliver work is guided by our culture, which reinforces, strengthens and builds our reputation.

d. Business operationsWhat do we mean by ‘Business operations’?

The term ‘business operations’ describes how we implement the right processes and governance to ensure that we efficiently and effectively fulfil our legal and ethical commitments, and be commercially successful.

Atkins has developed a comprehensive corporate governance framework and Business Management System (BMS) for this purpose.

For details of the framework, please go to page 58 of this code.


We need to operate in a coordinated and consistent manner, with simple and streamlined processes that help us achieve our ultimate goals.



Section 2:

Behaving the Atkins way

In this section, we look at each of our core behaviours – how we work and what we value – and explain:

• What each behaviour means and our expectations of all Atkins people

• Why it’s important to meet these expectations

We also challenge you to look at your own behaviour and ask yourself some important questions.


Section 2:

Behaving the Atkins wayHaving identified the four business processes on which we all focus, every day, we will now detail the seven behaviours that wrap around our processes.



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Work ethically


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The way we behave matters.

Whether we’re meeting with clients, working alongside our colleagues, or attempting to attract new talent to our business, we are all representatives of Atkins.

How we interact with others is what defines us as a company, and each of us has a part to play in maintaining and enhancing our reputation as one of the world’s leading design, engineering and project management consultancies.

We must live up to our core behaviours and be open, honest, honourable and transparent in everything we do. It means:

• Working ethically, ‘doing the right thing’• Taking personal responsibility for the work we do and the way

we do it• Valuing other people and our relationships with them • Looking out for our own safety and security and that of others• Building and maintaining our success• Protecting sensitive information and assets• Considering the impact we have on the environment.

Above all, it means caring about the future of Atkins and behaving with integrity.

These are our core behaviours.


a. Value people and relationshipsWhat do we mean by ‘Value people and relationships’?

Valuing other people and relationships means that we should all:

• Treat others as we would expect to be treated ourselves: openly, with respect for the cultures and customs of our colleagues and clients – respect and embrace our diversity

• Work to earn the trust and confidence of others in order to build lasting professional relationships with a diverse group of people

• Make constructive, two-way communication the cornerstone of our management style, actively listening to and engaging with every member of the team

• Lead by example and be a role model for the behaviours we want others to adopt.




Throughout your career with Atkins, we want you to flourish, to enjoy your work, to have fun, to progress your career and to develop your role. A positive working environment is good for all of us as individuals, good for our teams, and because we all work better when we have a real sense of belonging, it is good for business too.

Professional and meaningful relationships with our colleagues, clients and partners are key to our success.

They make the difference between just doing the work, and doing it well. It is important for each of us to take the time to understand and to value the contribution that others make to the work we are doing.

Ask yourself…

• Do you always respect others, even when they do things differently from you?

• When travelling or seconded internationally, do you understand and respect local cultures?

• What would, could or have you done when others make unprofessional or offensive comments?

• How do you build long-lasting, professional relationships?

“The team culture here has always been a bit special. It’s like a mini family in which people understand, trust and support each other.”– Lucy, senior engineer



b. Work ethicallyWhat do we mean by ‘Work ethically’?

Working ethically means that we should all:

• Obey the law, observe regulations and guidelines and be seen to do so

• Exercise judgement in all our professional relationships and take steps to avoid situations that could compromise us. For example, a conflict of interest with someone we know or something we do outside of work

• Avoid giving or receiving any kind of gift or hospitality that could be seen to influence a business decision. Where any gift or hospitality is given or received, this should always be signed off by your line manager or supervisor. If you are unsure or need advice, contact your local Legal Advisor. For more information go to tinyurl.com/ko8aubr


Our reputation is built on trust. Our clients trust us with critical projects. Our partners trust us with sensitive information. Our employees trust us with their careers. And if we are to maintain that reputation, we all need to play our part and demonstrate that we continue to deserve that trust, every day, in everything we do.

Atkins people are some of the brightest and best. We’re good at what we do, whether we’re planning, designing and enabling complex client projects, solving technical challenges, or delivering project excellence.

From the smallest detail behind the scenes to the highest profile client interactions, we must always be ethical and honest.

Ask yourself…

• Could any of your actions be questioned or misconstrued? • How would you feel seeing your actions reported on the front page

of a newspaper? • Are you complying with the content and the spirit of company

policies and procedures? • Are you confident that you always ‘do the right thing’ at work?• Have you ever taken action to highlight a risk or concern?


c. Build our successWhat do we mean by ‘Build our success’?

Building our success means that we should all:

• Be commercially aware, controlling costs where we can and actively looking for ways to increase revenue across the Atkins Group

• Ensure that our own work is always of the highest standard and expect the same of colleagues

• Be diligent in our approach to all business processes and maintain good discipline in reporting, record keeping and company protocols

• Remember that we are all ambassadors for Atkins and that we share the responsibility to protect and enhance the reputation of the company.


• Our success as a company is based on us delivering value for money to our clients and shareholders. We all have a part to play in maintaining the standards of technical excellence and good governance set out in the Atkins Design Principles; the principles which enhance our worldwide reputation

• When we all understand how our individual roles fit into the bigger picture, we work together more effectively. And that is good for all of us because as long as the company succeeds, we all succeed.



What are Atkins’ Design Principles?

“The design principles give us a common language we can use to discuss both the achievement of brilliance and the avoidance of disasters. Through such conversations we can allow the creativity and talent of Atkins’ designers to flourish.” – Martin Grant, CEO, Energy

Designing and the design process is a journey that turns an aspiration into clear unambiguous information that enables a physical item or system to be created. This may be in the form of:

• Detailed specifications• Manufacturing instructions or drawings • Operating instructions.

Start the job rightDo the job right

Finish the job right


The Atkins Design Principles are fundamental to the design journey and form part of the Atkins Business Management System (BMS). The collective goal of the design principles is that the final design deliverables should represent the best possible solution given the project constraints.



Atkins’ Design Principles

We have fully understood customer requirements, assessed these as being reasonable and translated them into a clear basis of design.

We have assessed what resources (e.g. key people, skills, accommodation and tools) are required and confirmed they are available.

We have understood our scope of work within the project lifecycle and have split this into appropriate phases. The work breakdown structure and deliverables for each phase are well defined.

We have understood and communicated roles and responsibilities for our operations and our customer’s and any third parties such as a regulator.

We have put in place suitable processes for managing change, risk and information flow.

We have put in place suitable processes to ensure that our deliverables meet the design requirements.

We will capture lessons learned during the project and feed these back into our design processes.

Start the job right Do the job right

Finish the job right

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2

3

4

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Ask yourself…

• What would, could or have you done differently to contribute further to the success of Atkins?

• Could you collaborate more with colleagues to cut costs or cross-sell services?

• Are you a good ambassador for Atkins?• Are you diligent in your business processes?• What do the Atkins Design Principles mean to you?• Do you always strive for excellence in your work?• Do you expect professionalism and high standards from yourself

and your colleagues?



d. Be safe and secure What do we mean by ‘Be safe and secure’?

Being safe and secure means that we should all:

• Look out for our own safety and security and that of others. This includes taking sensible steps to protect ourselves and others and being prepared to challenge a process and even to stop the work if necessary

• Adopt the ‘Stop, Think, Act’ approach and follow the advice and guidance provided by Atkins’ Safe and Secure by Choice programmes

• Introduce Safety moments into our daily activities.

For details of the accident and incident reporting system, see page 56 of this code, or go to tinyurl.com/kd5xum8



Nothing is more important than safety and security.

Atkins’ Safe and Secure by Choice programme is an important part of our approach to maintaining our industry-leading status.

The safety and security of our people and those affected by our work is critical, both to us and our clients. We are committed to ensuring the well-being of and minimising the risk of harm to our people, contractors and third parties.

We set the very highest standards of safety and security.



Safe and Secure by Choice

To ensure the safety and security of ourselves and our colleagues, we must develop a mindset that deliberately chooses safe and secure behaviours, until it becomes entirely natural to do so.

Atkins’ Safe and Secure by Choice programme promotes personal safe and secure behaviours and encourages everyone to make choices that reduce risk. This is particularly important when working on sites, lone working or working in a high risk country.

The approach is based around the fact that our behaviour is always a choice and emphasises that:

• You should be alert to situations in which safety and security might be compromised and take action to prevent this

• You are empowered to ‘Stop, Think and Act’, and take responsibility and ownership for your own safety and that of others around you

• Every one of us has the authority to stop work immediately when anything appears unsafe.

For advice on safety and security, contact your local QSSE Representative.

“Nothing is more important than personal safety and security”– Uwe Krueger, CEO


What are Atkins’ Safety moments?

Atkins’ Safety moments are regular challenges designed to encourage good safety conversations with each other and in our teams. If done well, challenging and encouraging each other to be safe is one of the more effective ways of developing a stronger safety culture and reducing injuries.

A ‘Safety moment’ could involve a team member proposing an idea or learning from a project, or a safety initiative used by a client or competitor. It might be sharing real life incidents outside of work or be based on a particular theme or weekly safety challenge.

Safety moments have been designed to encourage us all to be more safety conscious and to work more safely – whether we’re on site, in an office, or travelling.

Ask yourself…

• What does being ‘safe and secure’ mean to you?• Do you feel able to challenge others if you think they are

compromising on safety or security? • Are you ready to be challenged on your own behaviour?• When challenged, would you respond openly and positively, in

the interests of good practice?• Do you ‘Stop, Think and Act’ when you encounter risks to the

personal safety and security of yourself or others?• Do you report near misses, accidents, injury and ill health?• Would you know how to report a near miss, accident, injury or

ill health?



e. Take personal responsibilityWhat do we mean by ‘Take personal responsibility’?

Taking personal responsibility means that we should all:

• Be alert to potential risks, take action to address them where we can and report them through the relevant channels

• Protect our information and assets and that of our clients and partners, including treating property with respect and protecting the confidentiality of information

• Think ahead. Think about the implications and consequences of our actions, and learn from past experience.


At Atkins, we value a questioning mind. Our people are forward looking and proactive by nature, quietly thinking through the issues and seeing challenges from different angles. It is one of the key reasons our clients choose to work with us.

We take personal and professional pride in our work and its outcomes, and we share responsibility for getting the job done right first time and delivering on our promises.


Ask yourself…

• Do you take personal responsibility for your decisions and the company’s assets?

• Do you recognise the contribution of others when something is successful?

• If a situation or behaviour makes you feel uncomfortable, what would you do about it?

• Have you taken action to highlight a risk or concern?• Do you always think ahead and understand the potential

consequences?



f. Protect information and assetsWhat do we mean by ‘Protect information and assets’?

Protecting information and assets means that we should all:

• Handle information with due care• Protect company assets as if they were our own• Use, maintain and dispose of information and assets

appropriately and responsibly.


Protecting our information and assets is vitally important to both us and our clients. From a business perspective it is essential that information such as financial results, business plans, technical designs, or personal information is not compromised. Asset security is equally important and even a small scale security breach could leave us without access to critical equipment, services or IT systems for hours or days.

It’s imperative that we maintain the trust of our clients, partners and colleagues by ensuring that we have adequate controls in place to address confidentiality, integrity and availability of information. In doing so we protect our reputation.

These obligations extend across all our businesses and are not limited to those sectors with specific contractual and legal requirements.

Ask yourself…

• What steps do you take to protect all information and data you have access to?

• How do you look after the assets (including IT equipment and premises) you use to do your job?

• What could go wrong if information, data or assets were compromised?

• Do you require training in security awareness, systems and tools?• Do you understand the sensitivity of information you hold?


g. Enable a sustainable futureWhat do we mean by ‘Enable a sustainable future’?

Enabling a sustainable future means that we should all:

• Avoid wasting the planet’s resources, such as energy, water, food and paper, and take steps to reduce unnecessary travel

• Use our skills, knowledge and influence for the good of the communities in which we live and work, including local charities and community groups, educational and professional bodies

• Propose innovative, sustainable and low carbon solutions to our clients at every opportunity.


As one of the world’s leading design, engineering and project management consultancies, Atkins is privileged to take a lead in developing and encouraging sustainability on a local and global scale in the projects we deliver for our clients – from water conservation and flood protection to urban regeneration and transportation solutions.

Each of us has a responsibility to consider the sustainability of our own work practices and their effect on society and the environment, in line with Atkins’ Sustainability Principles.



What are Atkins’ Sustainability Principles?

The future depends on what we do today...A society for our future:

Inspire the next generation

Promote science, technology, engineering and mathematics to children and young adults to encourage them to become planners, designers, project managers and engineers of the future.

Sustainability knowledge and skills

Support our people on a development pathway to deliver innovative and sustainable solutions.

Social and community investment

Encourage and support our people to realise their capability to contribute to the social, environmental and economic health of our communities.

A healthy, safe and secure workplace

Promote and maintain the highest degree of physical, mental and social well-being in the workplace.

An employer of choice

Value and respect our people; providing both advantage, and equality of opportunity in recruitment, development, recognition and reward.


An environment with a future:

A low carbon economy

Lower carbon

Continue our work to become a low carbon organisation and help governments, businesses and society to make the transition to a low carbon economy

Adapt to change

Prepare ourselves and help to equip our clients for the potential impacts of climate change

Respect for the environment

Resource efficiency

Manage natural resources efficiently and help to build the resource resilience of our clients

Ecosystems

Protect and improve ecosystems, recognising the valuable services they provide

NOW IS THE TIME TO ACTFUTURE

PROOFING CITIES

For further information on Future Proofing Cities, please go to tinyurl.com/mhwc3eu



A responsible business of the future:

Economic prosperity

Plan, design and enable to provide sustainable value and technical excellence for our clients. Support governments, investors and other authorities to achieve economic and environmental resilience through infrastructure and technological investment

Strong governance and accountability

Demonstrate responsibility, transparency and fairness in the way we manage our worldwide business

International business; local service

Recognise the importance of sustaining local economies by employing local expertise and selecting and developing local suppliers

Strategic engagement for innovation

Collaborate with key organisations to develop innovative solutions that meet the complex sustainability challenges faced by society

Ask yourself…

• What contribution do you make to your local community and to the society you live in?

• Are you ever wasteful?• Do you use your car more than you need to?• What do Atkins’ Sustainability Principles mean to you? • What would happen if we turned our backs on sustainable

work practices?



Section 3:

Putting it into practice

In this section, we detail the practical application of our core behaviours.

In other words, the expectations and responsibilities of all Atkins people every day, wherever you work, and whatever you do.


Section 3:

Putting it into practiceHaving described the way we approach business activities and the behaviours we expect from all Atkins people, this section details the practical application of the behaviours. It lists:

The things we must always do and must never do, in order for us to meet our ethical and legal obligations. Whilst this list is not exhaustive, within each of the four core processes, we identify:

• Our expectations and your responsibilities • The ways in which we must all put the expectations into practice.

Failure to comply with the standards and procedures set out in this code, and the processes and principles detailed in supporting documents will result in appropriate corrective or disciplinary action.

If there is anything you don’t understand, please ask your line manager or supervisor.



PeopleOur expectations, your responsibilities

• Take action on risks – stop immediately if you think an activity is unsafe

• Reinforce and reward positive behaviour• Work collaboratively with colleagues and clients• Ensure the safety and security of everyone – nothing is more

important• Be diligent – follow business processes and maintain accurate, up

to date records• Encourage people to take personal ownership and responsibility

for the things they control and the decisions they make• Develop people to maximise their potential and needs as well as

meeting both current and future business needs• Hold others to account based on the content of this code • Work for the good of the business – leave behind personal

agendas• Support and enable people to ask questions and raise concerns• Build and maintain relationships; be courteous, respectful,

actively listen and involve others• Exercise personal and professional judgement – never turn a

blind eye• Be professional – lead by example and reinforce the right

behaviours at all times.


Always:

9 lead by example – model and reinforce the right behaviours at all times

9 collaborate and work with others to find solutions

9 help people to develop to their full potential

9 hold people to account based on clear expectations

9 be forward thinking and strategic in managing resources

9 persuade rather than control people’s responses

9 value your colleagues and clients.

Never:

× keep copies of sensitive information including information relating to team members

× recruit on the basis of preconceived views

× proceed if there are potential conflicts of interest

× compromise security or fail to report incidents

× overlook mistakes, misunderstandings, errors or faults

× display or tolerate unprofessional behaviour towards anyone.

“For me, Atkins’ strength is in helping its people to develop their own strengths. It’s all about improving and succeeding together.”– Caroline, business manager



Win workOur expectations, your responsibilities

• Show integrity – ask yourself, ‘Is this ethically right?’• Work collaboratively and don’t lose sight of the big picture.

Together, we are one Atkins• Build constructive relationships for the longer term benefit

of Atkins • Handle information with due care – respect and maintain

confidentiality• Be commercially astute – recognise the commercial imperatives• Be a professional – set and achieve high standards you are

proud of • Protect our reputation – each one of us is a representative

for Atkins• Exercise personal and professional judgement – use due care and

be free from bias.

Always:

9 seek to deliver on promises 9 be active in building

relationships and engaging with clients

9 understand your own limits and your teams’ capabilities and competences when bidding

9 actively listen to and involve others, including current and potential clients

9 learn from past experience and endeavour to incorporate this into action

9 seek to understand different perspectives

9 maintain the highest ethical standards.

Never:

× give or receive gifts or hospitality which compromise or appear to compromise your personal integrity or that of the company

× proceed if there are potential conflicts of interest

× defraud or deceive anyone or act dishonestly

× collude with competitors × take bribes, improper

payments or participation in any kind of corrupt activity

× take on work we are unable to deliver.


Deliver workOur expectations, your responsibilities

• Be professional – set and achieve high standards for the work we do

• Work collaboratively – build constructive relationships and actively engage with clients

• Take ownership – be responsible for the things we control and take action on risks

• Think ahead – recognise the consequences of decisions and actions

• Be impartial – be fair, objective and treat others consistently• Be diligent – have good discipline, an enquiring mind and pay

attention to detail• Be commercially astute – deliver value and service whilst

controlling cost and expenditure• Ensure sustainable work practices – consider the impact of our

work on the environment• Engage, actively challenge and work collaboratively with our

supply chain• Handle information securely and sensitively – respect and

maintain confidentiality.



Always:

9 ensure contracts are honoured e.g. maintain payment terms and deliver on contractual commitments

9 report concerns, particularly where significant risk exists

9 take responsibility – actively challenge what is proposed (e.g. in reviewing designs)

9 ensure safety and environmental considerations are integrated within your designs

9 show integrity – charge honestly for your services

9 be safe and secure – Stop, Think and then Act when risk is encountered

9 be diligent in delivering our commitments on quality and technical excellence

9 protect our reputation and get things ‘right first time’

9 ensure you are meeting our ‘Design Principles’ standard (best possible solution given the project constraints).

Never:

× share client information with third parties without permission

× take risks without considering the impact and outcome

× compromise the quality of our services

× accept changes to the scope of work until these have been fully agreed

× hold onto information that should be shared in an open and timely manner

× claim for anything we do not believe we are entitled to

× overbook time to a job.


Business operationsOur expectations, your responsibilities

• Follow the Business Management System (BMS) processes to ensure you carry out our work in an effective manner

• Protect assets as if they were your own – take care to secure and protect them

• Ensure assets are maintained to an acceptable standard and not used inappropriately

• Take responsibility for the security of the information and data you use

• Show integrity – be open, honest and truthful and ‘do the right thing’

• Ensure goods and services are purchased for the good of the business and not for personal gain

• Be diligent – ensure good discipline, record keeping and attention to detail; check validity of information

• Take action – use shared services and knowledge databases, maximising learning opportunities and self-improvement

• Minimise energy usage through energy efficiency, considering the impact of your work on the environment.



Always:

9 honour our contractual commitments and comply with legal requirements and regulations

9 keep accurate, up to date records

9 use and comply with Atkins security systems and measures

9 stop work if you think something is unsafe or may cause harm

9 be willing to act to protect the safety and well-being of others

9 know how to respond in an emergency, and how to alert others.

Never:

× purchase or receive goods and services for personal gain

× act outside the confines of your authority

× treat company property carelessly

× fail to report theft, damage or corruption or suspected breaches of information

× access or store inappropriate information, data or images through or on company equipment

× circumvent company processes and systems.

“Having a great relationship with your clients and a reputation for excellent delivery are key to success, as they always have been.”– Victor, senior project manager



Section 4:

Reporting an issue or raising a concern


Section 4:

Reporting an issue or raising a concernConfidential reporting

If you see something that you feel isn’t right, is unethical, illegal, unsafe or not secure, there are a number of resources that you can use to report or escalate your concerns.

In the first instance, you should report an issue or concern to your line manager or supervisor, or to another senior manager.

If you feel that your concern has not been addressed, then you have the opportunity to raise this confidentially using Safecall, the confidential ‘whistleblowing’ phone lines.

At Atkins, we believe that everyone has a right to voice concerns and be listened to.

We are committed to reviewing, investigating and taking appropriate action regarding all allegations of illegal, unsafe or inappropriate behaviour. As such, all reports will be treated seriously and questions will be channelled to the appropriate people. We will follow up allegations conscientiously, discreetly and without bias. Anything you raise will be treated in confidence.


What is Safecall?

Safecall is an independent organisation that specialises in providing a confidential service for individuals to report on any inappropriate conduct that they may become aware of in their organisations.

Calls are handled locally by a professional team whose job it is to ensure that concerns are routed quickly, with sensitivity and in confidence to a member of senior management who will take responsibility to investigate the issue.

The Safecall numbers are:

Asia Pacific

China 10800 7440605 (China Unicom)10800 4400682 (China Telecom)

Australia 0011 800 7233 2255

Hong Kong 3077 5524

Singapore 001 800 7233 2255 (Sing tel.)002 800 7233 2255 (M1)

Malaysia 1 800 220 054

Vietnam 120 11157

Thailand 001 800 7233 2255

Middle East & India

Kuwait +44 20 7696 5952

Bahrain 8000 4264

Oman 800 72323

Qatar 8000 250

United Arab Emirates 8000 441 3376

Saudi Arabia 800 844 2067

India 000 800 440 1256

The Americas

USA 1 800 587 5104

Brazil 0800 892 1750

Canada 1877 59 98073

Puerto Rico 1866 901 3295

Trinidad and Tobago 1888 388 1596

Europe

UK 0800 915 1571

Denmark 00800 7233 2255

France 00800 7233 2255

Germany 00800 7233 2255

Greece 00800 4414 1966

Ireland 1800 812 740

Netherlands 00800 7233 2255

Norway 00800 7233 2255

Poland 00800 7233 2255

Portugal 00800 7233 2255

Sweden 0850 252122

Most Other Countries 00800 7233 2255

You can also make a report online at www.safecall.co.uk/atkins

Telephone numbers are correct at time of going to press. These numbers are reviewed frequently based on our operations. For the latest information please check Axis: tinyurl.com/m 2dy5j4


“If there is one subject that sits at the core of our culture, it is health and safety. Most importantly we want you, your clients and the people we are responsible for in our supply chain to go home safely at night.Whether you’re working in an office environment, on a project site, or even in a car with colleagues, you have my personal authority, at any point in time, to raise your hand and stop work if you see that something is unsafe.” – Uwe Krueger, CEO

Reporting accidents and incidents

Remember that all accidents and incidents (health and safety, security and environmental) should be reported through our reporting system.

• For health, safety and environmental reporting, go to tinyurl.com/kd5xum8

• For security reporting, go to tinyurl.com/q2fwjme

If the security incident includes loss or theft of IT equipment, this must also be reported to Group IS.



Section 5:

Further information


Level and example inputs

Board

• Articles of association

• Matters reserved to the Board

• Committee terms of reference

• Values and ethics

Group

• Strategy

• Quarterly business reviews

• Group authority matrix

• Service delivery process

• Design principles

• Support function manuals (such as finance, Human Resources, QSE)

Region/business

• Local legislation

• Industry requirements

• Budgets

• Systems

• Project controls

Framework Assurance

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Section 5:

Further information

This code describes the way we behave at Atkins. It is part of the Atkins corporate governance framework and is one of a suite of documents that articulates our vision, ethos, policies and principles.

Our corporate governance framework

Policy Statements

Board

Group Controls Code of conduct

Business Management System (BMS)

Deliver Work

PeopleBusiness Operations

Win Work



1. Our Group Policy Statements are reviewed every year and set out our agreed vision, commitment and approach in a series of single page statements. There are eleven Group Policy Statements, each of which is summarised on pages 60–65 of this code. To read the Group Policy Statements in full, please visit tinyurl.com/pcbnw8d

2. The Atkins Business Management System (BMS) provides further detail, identifying the controls and processes that we use on a day-to-day basis to implement the Group Policy Statements

3. Atkins’ Design Principles (part of the BMS) are fundamental to the design journey. The objective of the principles is that the final design should represent the best possible solution. To read Atkins’ Design Principles, please go to page 29 of this guide, or visit tinyurl.com/mjq2ytv

Please make sure you have read and understood our Group Policy Statements, the BMS and our Design Principles together with the content of this code.

If there is anything you don’t understand, please ask your manager or supervisor.


Atkins’ Group Policy Statements

We are committed to conducting business with integrity by being open, honest, honourable and transparent in everything we do. Our vision is for the Atkins’ core behaviours to be totally embedded within our culture. We will show respect for human dignity and the rights of the individual, as well as respecting traditions and cultures. Where business practices differ in different countries, we will obey the law and act responsibly in international trade and investment. We will seek to ensure consistent procedures wherever practical, which may also exceed local legislation.

This means that we will not tolerate business misconduct, including bribery or corruption. We will work with regulatory authorities in all the jurisdictions in which we operate to ensure that we comply fully with all legislation (including the UK Bribery Act 2010) and reporting requirements. We encourage anyone who has concerns about the behaviour of the Company or any individual associated with the Company to report their concerns.

How we conduct our business is underpinned by our values as described in the following policy statements:

• How we govern our business

• Managing our risks

• Employer of choice

• Working with our clients

• Excellence in delivery

• Health and safety leadership

• Enabling a sustainable future

• Communicating with our stakeholders

• Partnering with our supply chain

• Securing our business

We pursue our commitment to how we conduct our business by:

• employees using their judgement and common sense to consider if a benefit is excessive, if it is a gift, bribe, hospitality or seeking to unduly influence;

• providing a confidential whistleblower service for anyone to report any concerns regarding misconduct including, but not limited to, breaches of law, bullying or harassment, health, safety or environmental exposure, financial exposure, unauthorised disclosure of personal or confidential information and deliberate concealment of any such matter;

• the Audit Committee reviewing concerns raised through the whistleblower service to make sure that matters receive independent investigation, as necessary;

• maintaining a register of all Sponsorship and Agency Agreements and making such information available by request.

We ensure that these requirements are defined within the business management

system, with our behaviours defined in ‘Behaving the Atkins way: our code of

conduct’.

Atkins’ businesses are accountable for implementing this policy and we look to

our employees’ support and professionalism in making it truly effective.

Uwe Krueger

Chief Executive

February 2014

How we conduct our business

www.atkinsglobal.com

WS Atkins plc Business Conduct Policy Statement | Issued in 2013, 2014 – minor changes made to reflect the introduction of the new Code of Conduct

1. How we conduct our business

Conducting business with integrity and honesty is a core part of the Atkins culture. We show respect for human dignity and the rights of the individual, as well as respecting traditions and cultures.

We will obey the law in all the countries in which we operate, act responsibly in international trade and investment and ensure procedures are followed as consistently as possible, even if that means exceeding local legislation.

We will not tolerate business misconduct, including bribery or corruption.

We will work with regulatory authorities in all the jurisdictions in which we operate to ensure that we comply fully with all legislation (including the UK Bribery Act 2010) and reporting requirements.

We encourage anyone who has concerns about the behaviour of the Company or any individual associated with the Company to report their concerns.

To read the statement in full, please go to tinyurl.com/k4t28r8

2. How we govern our business

We acknowledge that an effective system of corporate governance will help us to generate an attractive, long term return to investors, protecting the interests of our shareholders and other investors.

Our Board is responsible for ensuring the long term success of Atkins by determining the company’s long term direction and strategic aims within a governance framework.

This framework includes robust internal financial and operational controls, risk management and audit, as well as values and ethics.

To read the statement in full, please go to tinyurl.com/m88qn92

The Board is responsible for ensuring the long term success of Atkins by determining the Company’s long term direction and strategic aims within a governance framework. This framework includes robust internal financial and operational controls, risk management and audit, as well as values and ethics. Atkins operates through a devolved and decentralised structure, which is considered necessary to deliver local services to its clients. This is reflected in our governance framework at Board, Group and Region / Business levels. The Board reviews and approves the governance framework to ensure its adequacy and effectiveness, as set out in the Financial Reporting Council’s Internal Control Revised Guidance for Directors on the Combined Code. Joint ventures in which the Company does not have overall control are not covered by the Atkins governance framework. However, we will ensure that they meet the Atkins governance requirements as a minimum.

We pursue our commitment to our governance framework by:

• operational management controls being delegated to the chief executive officer, which are further delegated into the businesses using a matrix of authorities within clearly prescribed limits, including escalation where either project size, investment or risk profile requires a higher level of authority;

• tracking performance through monthly and quarterly reports and auditing effectiveness via internal audit and self-assessment reviews;

• implementing business controls to ensure compliance with relevant legislation and defining them in the business management system;

• controlling investment through an acquisition and divestment process, requiring appropriate approval, with due diligence and internal investment being controlled through the Internal Investment Team (IIT);

• the Audit Committee monitoring the integrity of the financial statements of the Company and reviewing the internal controls. The Committee also has oversight of the internal audit, the independent auditor and whistleblower arrangements;

• internal audit providing the directors, through the Audit Committee, with an objective evaluation of the governance framework;

• appointment of an independent auditor approved by shareholders annually with the audit of the financial statements being conducted in accordance with international standards issued by the Auditing Practices Board;

• the Remuneration Committee setting remuneration policy and structure for the Company’s chairman and executive directors. The Committee also has oversight of remuneration practice across Atkins;

• complying with the range of legal and regulatory requirements governing the conduct of companies quoted on the London Stock Exchange.

Atkins’ Board and businesses are accountable for implementing this policy and we

look to our employees’ support and professionalism in making it truly effective.

Uwe Krueger

Chief Executive

February 2014

How we govern our business

www.atkinsglobal.com WS Atkins plc Governance Policy Statement | Issued in 2013, 2014 – minor changes to Governance Framework statement



3. Managing our risks

Our vision is for the principles of risk management to be totally embedded within the culture of Atkins – where the ownership and management of risk is not just the exclusive responsibility of senior management, but is passed down to appropriate staff. This means proactively managing risks though effective leadership, developing appropriate behaviours and working with colleagues, clients and our supply chain.

We believe that for risk management to be effective, it must be embedded into the governance framework and integrated into all activities, which supports the systematic identification, assessment and management of risk at all levels. This seeks to ensure that the public, employees and the environment are safe from potential risks inherent in our operations, and the potential impact to our corporate reputation, or financial loss to shareholders and other stakeholders, is minimised.

To read the statement in full, please go to tinyurl.com/lhmcwyp

4. Employer of choice

We are committed to maintaining a positive working environment within which all Atkins people from across a broad range of disciplines and cultures are able to flourish and to collaborate.

Selection, progression and promotion are on the basis of merit, irrespective of gender, race, age, religion or belief, disability, sexual orientation, gender identity, marriage and civil partnership, pregnancy, parental obligations and background, subject only to the laws of the jurisdictions in which we operate.

To read the statement in full, please go to tinyurl.com/l5h4z6r

Our vision is for the principles of risk management to be totally embedded within the culture of Atkins – where the ownership and management of risk is not just the exclusive responsibility of senior management, but is passed down to appropriate staff. This means proactively managing risks through effective leadership, developing appropriate behaviours and working with colleagues, clients and our supply chain.

We believe for risk management to be effective it must be embedded into the governance framework and integrated into all activities, which supports the systematic identification, assessment and management of risk at all levels. This seeks to ensure that the public, employees and the environment are safe from potential risks inherent in our operations, and the potential impact to our corporate reputation, or financial loss to shareholders and other stakeholders, is minimised.

We pursue our commitment to risk management by:

• ensuring risk is an integral part of business strategy and operational objectives;

• having mitigating strategies and action owners for all significant risks;

• providing a governance framework that mandates the Service Delivery Process for all services that Atkins delivers on behalf of its clients. The Service Delivery Process will not only improve management of risk, it will also add value by increasing win rates, reducing wasted effort and reducing the frequency of commercial and technical errors;

• the Risk Committee, chaired by the chief executive officer, overseeing the operation of Atkins’ risk management and providing support to the Board and the Audit Committee;

• fully articulating operational risks by using risk registers and regularly reviewing these across the organisation as part of our business management process;

• providing adequate resources, training and the appointment of competent professionals;

• implementing business controls to ensure compliance with relevant legislation

and client requirements, including arrangements to maintain our resilience

during a crisis and incidents and ensuring business continuity;

• operating a culture that encourages disclosure of issues or concerns, so that timely and appropriate action can be agreed and implemented as necessary.

We ensure that these requirements are defined within the business management

system, which has been developed to meet the needs of our clients and our

businesses.



Uwe Krueger

Chief Executive

February 2014

Managing our risks


WS Atkins plc Risk Management Policy Statement | Issued in 2013, 2014 – no change

We are committed to maintaining a positive working environment within which employees from across a broad range of disciplines and cultures are able to flourish and to collaborate.

Selection, progression and promotion are on the basis of merit, irrespective of gender, race, age, religion or belief, disability, sexual orientation, gender identity, marriage and civil partnership, pregnancy, parental obligations and background, subject only to the laws of the jurisdictions in which we operate.

We pursue our commitment to be the employer of choice by:

• recruiting employees with the skills, experience and commitment to meet our clients' and the organisation's current and future needs;

• maintaining appropriate controls to ensure that recruitment is properly planned and executed, and that qualifications, experience and right to work are validated;

• selecting employees on the basis of open, objective criteria;

• investing in the skills and capabilities of our employees, with an emphasis on the responsibility of each employee to take ownership of their own development;

• promoting and rewarding employees on the basis of merit, supported by objective data;

• providing every employee with the opportunity for a Performance and Development Review, at least annually;

• promoting diversity at every level and in every area of the organisation;

• encouraging mobility within and between businesses and regions, both to meet client/project requirements and to provide opportunities for career development;

• maintaining a safe, healthy and secure working environment;

• engaging actively with employees through regular and open communications, providing an opportunity for feedback including via an annual employee engagement survey (Viewpoint);

• ensuring that complaints, grievances and concerns, including whistle-blowing, are dealt with promptly and confidentially;

• maintaining business controls and regional HR policies to provide employees and line managers with clear employment principles to ensure fair treatment in line with local legislation;

• monitoring our people performance, reporting to the Board on a regular basis and more widely through our Annual Report.



Uwe Krueger

Chief Executive

February 2014

Employer of choice


WS Atkins plc Employment Policy Statement | Issued in 2013, 2014 – no change


5. Working with our clients

Our vision is to be the world’s best infrastructure consultancy. Core to this vision is helping our clients to plan, design and enable capital programmes to resolve complex challenges in the built and natural environment.

Through the use of professional and competent resources, we strive to offer the highest possible standards of safety, quality, value, service, innovation and trust in the services we provide.

To read the statement in full, please go to tinyurl.com/kqxawoz

6. Excellence in delivery

Atkins is committed to providing excellent standards of service to our clients. We aspire to lead industry and apply best practice in all of our operations.

Our vision is for excellence in delivery to be a natural and integral part of the culture of Atkins. We aspire to this through effective leadership and developing appropriate behaviours. This means proactively working with colleagues, clients and our supply chain to ensure that it is fully integrated into our decision making processes.

To read the statement in full, please go to tinyurl.com/lleo5xd

Our vision is to be the world’s best infrastructure consultancy. Core to this vision is helping our clients to plan, design and enable capital programmes to resolve complex challenges in the built and natural environment.

Our clients range across the public, regulated and private sectors. They include central and local government, major financial and retail companies, developers, manufacturers and utility companies. Our strength lies in the breadth and depth of our technical expertise which enables us to provide practical solutions to the most complex challenges for clients in a number of sectors, in different locations across the world.

Through the use of professional and competent resources, we strive to offer the highest possible standards of safety, quality, value, service, innovation and trust in the services we provide.

We pursue our commitment to working with our clients by:

• working collaboratively with our clients to understand their needs and expectations;

• being open, transparent and fair in our communications and dealings with clients wherever we work in the world, acting in an honest and ethical manner at all times;

• not engaging in bribery or any form of unethical inducement or facilitation payments;

• not undertaking work for which we are not qualified, nor making misleading claims regarding experience or capability. Atkins’ internal Service Delivery Process ensures that we only undertake work within our capability;

• having contracts and other agreements with all third parties to ensure we have appropriate provisions, including those safeguarding confidentiality;

• ensuring that we protect our clients’ information and assets;

• all employees engaging with clients, suppliers and partners in an open and honest manner, to enable us to deliver on our commitments on safety, quality, technical excellence and all other contractual commitments;

• actively engaging with our clients to obtain feedback on our performance and how we can improve, including investigating customer complaints about our services and responding to the findings of our investigation.

We ensure that these requirements are defined within the business management system, which has been developed to meet the needs of our clients.

Atkins’ businesses are accountable for implementing this policy and we look to our employees’ support and professionalism in making it truly effective.

Uwe Krueger

Chief Executive

February 2014

Working with our clients

WS Atkins plc Client Policy Statement | Issued in 2013, 2014 – our commitment includes protecting client’s information and assets www.atkinsglobal.com

Our vision is for excellence in delivery to be a natural and integral part of the culture of Atkins. We aspire to this through effective leadership and developing appropriate behaviours. This means proactively working with colleagues, clients and our supply chain to ensure that it is fully integrated into our decision making processes.

We pursue our commitment to excellence in delivery by:

• continually improving the quality of our project management and technical

work;

• providing professional and competent resources, augmented by suitable training and development plans;

• implementing business, project and technical controls, including the Atkins’

Design Principles and Service Delivery Process, and developing these under

our ongoing business improvement programme;

• ensuring the suitability and effectiveness of our suppliers by working in partnership to deliver the requirements of this policy;

• improving the effectiveness of our service by undertaking appropriate

assurance programmes as well as capturing and acting on lessons learnt;

• monitoring our performance and progress against objectives and reporting

externally through our Corporate Sustainability Report.

We ensure that these requirements are defined within the business management system, which has been developed to meet the needs of our clients and our businesses. Businesses have either achieved or are working towards the International Standard ISO 9001:2008 (Quality Management Systems), and other sector-specific equivalents, as appropriate.



Uwe Krueger

Chief Executive

February 2014

Excellence in delivery


WS Atkins plc Quality Policy Statement | Issued in 2013, 2014 – minor changes including expansion of the controls to incorporate technical



7. Health and safety leadership

Atkins acknowledges its potential to influence change in occupational health and safety management. We are committed to providing and maintaining a safe and healthy working environment for our employees and ensuring the safety of others affected by our operations and services.

Our vision is for health and safety to be a natural and integral part of the culture of Atkins. We aspire to this through effective leadership and developing appropriate behaviours. This means proactively working with colleagues, clients and our supply chain to ensure that it is fully integrated into our decision making processes.

To read the statement in full, please go to tinyurl.com/knyxozc

8. Enabling a sustainable future

We are clear about what sustainability means to Atkins in terms of our leadership role, our operations and the services we provide.

Atkins’ Sustainability Principles have been developed around three key areas and detail how we can support society, reduce our impact on the environment, and be a responsible business. These are defined as:

• A society for our future• An environment with a future• A responsible business of the future.

To read the statement in full, please go to tinyurl.com/mmqqqjl

Our vision is for health and safety to be a natural and integral part of the culture of Atkins. We aspire to this through effective leadership and developing appropriate behaviours. This means proactively working with colleagues, clients and our supply chain to ensure that it is fully integrated into our decision making processes.

We pursue our commitment to health and safety leadership by:

• continually improving our occupational health and safety management by

setting risk-based objectives and targets as part of our overall business

improvement programme;

• promoting a vibrant safety culture through two-way communication and

participation;

• implementing the Atkins behavioural-based ‘Be safe and secure’ programme,

including Safe by Leadership, Safe by Choice and Safe by Design;

• promoting the importance of the health and wellbeing of our employees, including physical, mental and social within the workplace

• providing adequate funding and resources that contribute towards a safe and healthy working environment, including supervision, training and the appointment of competent professionals;

• implementing business controls, health and safety legislation and client

requirements, including arrangements for crisis management, accidents,

ill-health and first aid;

• proactively working with industry and our partners to influence changes to health and safety;

• improving and assessing our health and safety performance by investing in

training, awareness, systems, tools and an assurance programme;

• monitoring our performance and progress against objectives and reporting

externally through our Corporate Sustainability Report.

We ensure that these requirements are defined within the business management system, which has been developed to meet the needs of our clients and our businesses. Businesses have either achieved or are working towards the British Standard OHSAS 18001:2007 (Occupational Health and Safety Management Systems), and other sector-specific equivalents, as appropriate.



Uwe Krueger

Chief Executive

February 2014

Health and safety leadership


WS Atkins plc Health & Safety Policy Statement | Issued in 2013, 2014 – minor changes to include ‘Be safe and secure’ and health and wellbeing

A

Our vision is to create a pathway to a sustainable future by defining what sustainability means to Atkins in terms of our leadership role, our operations and the services we provide. This is based on the key sustainability principles of how we can support society, reduce our impact on the environment, and be a responsible business. These are defined as:

A society for our future – inspiring the next generation; investing in communities; developing sustainability knowledge and skills; becoming an employer of choice; and creating a healthy, safe and secure workplace.

An environment with a future – supporting a low carbon economy; demonstrating respect for the environment through resource efficiency and by preventing pollution; and protecting and improving ecosystems.

A responsible business of the future – supporting sustainable economic growth with strong governance and accountability; being an international business whilst recognising the importance of providing local services; and collaborating with key organisations to develop innovative solutions.

We pursue our commitment to enabling a sustainable future by:

• embedding sustainability within the culture of Atkins, based on active

engagement and participation with our employees, clients and other key

stakeholders;

• senior management being accountable to lead on the key principles by

setting objectives and targets;

• utilising the existing knowledge and skills of our people, as well as providing sufficient resources and appropriate training;

• implementing business controls to ensure compliance with relevant legislation and client requirements, including arrangements for crisis management and incidents;

• ensuring the suitability and effectiveness of our suppliers by working in partnership to deliver the requirements of this policy;

• improving and assessing our sustainability performance by investing in

training, awareness, systems, tools and an assurance programme;

• monitoring our sustainability performance and progress against objectives and

reporting externally through our Corporate Sustainability Report. Our carbon

emissions are independently verified to International Standard ISO 14064 and

are also reported through the Carbon Disclosure Project.

We ensure that these requirements are defined within the business management system. In terms of environmental management, businesses have either achieved or are working towards the International Standard ISO 14001: 2004 (Environmental Management Systems).



Uwe Krueger

Chief Executive

February 2014

Enabling a sustainable future


WS Atkins plc Sustainability Policy Statement | Issued in 2013, 2014 – minor changes to the Sustainability Principles


9. Communicating with our stakeholders

We take into account the interests of all our external and internal stakeholders, including current and potential stakeholders, clients and colleagues, as well as governments, media, professional bodies and trade associations, academia and educational establishments and our communities around the world.

Consistent, effective, open, honest and timely communication is important to help us convey our aims, objectives and policies, and to endorse our credibility as a publicly quoted company.

We provide corporate information through a number of channels including traditional media and through digital channels, such as our website and social media sites.

We ensure at all times that our communications convey Atkins’ beliefs and values.

To read the statement in full, please go to tinyurl.com/kxop8to

10. Partnering with our supply chain

We work in collaboration with our suppliers, contractors and joint venture partners in a manner consistent with our values on quality, safety and sustainability.

This enables us to have a proactive relationship with our Supply Partners based on honesty, openness, respect and fairness throughout our procurement lifecycle.

To read the statement in full, please go to tinyurl.com/kf6vcyd

Our vision is to work collaboratively with our ‘Supply Partners’, comprising suppliers, contractors and joint venture partners, on customer focus, continuity and sustainable procurement. This enables us to have a proactive relationship with our Supply Partners based on honesty, openness, respect and fairness throughout our procurement lifecycle. Our commitment to our Supply Partners is that we will:

• be open, transparent and fair in our communications and dealings with Supply Partners wherever we work in the world, acting in an honest and ethical manner at all times;

• not engage in bribery or any form of unethical inducement or facilitation payments;

• create open and effective competition that still enables the development of commercial relationships with proven sustainable suppliers, including local suppliers where appropriate;

• promote and maximise the use of Atkins-wide contracts and framework agreements;

• view their services based on value for money, competitiveness and consistency with our values on quality, safety and sustainability;

• take reasonable steps to ensure payment terms and other conditions are fulfilled;

• regularly monitor their performance against a clear set of indicators and targets.

Supply Partners’ commitment to Atkins is that they will:

• share our commitment to protecting the health, safety and security of employees, clients and others who could be affected by their activities;

• pay everyone a fair wage and provide good working conditions;

• supply good quality products and materials from sustainable, local and ethical sources;

• ensure everyone has the right competency and appropriate training to undertake their job;

• ensure all accidents and incidents are reported and undertake investigations as appropriate;

• protect Atkins’ assets including confidential information;

• comply with all relevant legislation and, where appropriate, work towards or maintain ISO 9001, ISO 14001, EMAS or BS8555, and OHSAS 18001.

We ensure that these requirements are defined within the business management system, which has been developed to meet the needs of our clients and our businesses.


Uwe Krueger

Chief Executive

February 2014

Partnering with our supply chain


WS Atkins plc Supply Chain Policy Statement | Issued in 2013, 2014 – minor changes including where appropriate the Supply Partner will have certification

Our success depends not only on high standards of performance and service delivery but also on our ability to understand, influence and manage the expectations of our stakeholders. We will take into account the interests of all our external and internal stakeholders. These include current and potential shareholders, clients and colleagues; as well as governments, media, professional bodies and trade associations, academia and educational establishments and our communities around the world. We recognise that consistent, effective, open, honest and timely communication is important to help us convey our aims, objectives and policies, and to endorse our credibility as a publicly quoted company. We provide corporate information through a number of channels including traditional media and through digital channels, such as our website and social media sites. We ensure at all times that our communications convey Atkins’ beliefs and values.

We pursue our commitment of open and honest communication through:

Shareholders and potential investors – we communicate with shareholders and potential investors via our investor relations website and share information about Company performance through the Annual Report, at our Annual General Meeting and through full and half year results presentations. We also meet analysts regularly for briefing meetings.

External Stakeholders – we use a range of media to communicate with external stakeholders. These include face-to-face meetings and events as well as sharing marketing materials such as brochures, case studies and newsletters. We operate a proactive programme of communications to share information with the media and ensure we provide timely, accurate information about our achievements, performance and successes on our websites and social media channels.

Internal Stakeholders – we communicate with our colleagues worldwide through informal and formal communication channels, with a particular focus to ensure we have feedback mechanisms in place to promote open and active dialogue between colleagues. These communication channels include intranet sites, webinars, staff notices, newsletters, posters, roadshows and conferences, to ensure colleagues understand Atkins’ aims and objectives and know where they fit in to help achieve these. This also provides a mechanism for knowledge exchange throughout the Group.


Uwe Krueger

Chief Executive

February 2014

Communicating with our stakeholders


WS Atkins plc Communication Policy Statement | Issued in 2013, 2014 – no change



11. Securing our business

Atkins acknowledges that the security of our staff and assets is critical to both us and clients. We are committed to the wellbeing of our staff, as well as protecting physical and information assets from loss, damage or theft.

Our vision is for security to be a natural and integral part of the culture of Atkins. We aspire to this through effective leadership and developing appropriate behaviours. This means proactively working with colleagues, clients and our supply chain to ensure that it is fully integrated into our decision making processes.

We define securing our business as:

• Be safe and secure – minimising the risk of harm to our staff, contractors and third parties as a result of physical abuse, verbal abuse and threats to their health or safety whilst working or travelling

• Protect information and assets – safeguarding physical and information assets from loss, damage or theft. It is critical to maintain the trust of our clients, partners and colleagues by ensuring that we have adequate controls in place to address confidentiality, integrity and availability of information. These obligations extend across all our businesses and are not limited to those sectors with specific contractual and legal requirements.

To read the statement in full, please go to tinyurl.com/m99h423

ff and contractors

Our vision is for security to be a natural and integral part of the culture of Atkins. We aspire to this through effective leadership and developing appropriate behaviours. This means proactively working with colleagues, clients and our supply chain to ensure that it is fully integrated into our decision making processes. We define securing our business as:

Be safe and secure – minimising the risk of harm to our staff, contractors and third parties as a result of physical abuse, verbal abuse and threats to their health or safety whilst working or travelling; Protect information and assets – safeguarding physical and information assets from loss, damage or theft. It is critical to maintain the trust of our clients, partners and colleagues by ensuring that we have adequate controls in place to address confidentiality, integrity and availability of information. These obligations extend across all our businesses and are not limited to those sectors with specific contractual and legal requirements.

We pursue our commitment to securing our business by:

• continually improving our security by setting risk-based objectives and targets

as part of our overall business improvement programme;

• promoting a vibrant security culture through two-way communication and

participation;

• implementing the Atkins behavioural-based ‘Be safe and secure’ programme, including Secure by Leadership and Secure by Choice;

• ensuring information is useful, useable and easily accessible by those who are authorised to use it;

• raising awareness of protecting information and assets;

• providing adequate funding and resources that contribute towards a secure working environment, including supervision, training and the appointment of competent professionals;

• implementing business controls to ensure compliance with security legislation

and client requirements, including arrangements to maintain resilience of our

systems during a crisis and incidents and ensuring business continuity;

• improving and assessing our security performance by investing in training,

awareness, systems, tools and an assurance programme.

We ensure that these requirements are defined within the business management system, which has been developed to meet the needs of our clients and our businesses. Businesses have either achieved or are working to the principles of the International Standard ISO 27001 (Information Security Management Systems), and other sector-specific equivalents, as appropriate. Those businesses certified to ISO 27001:2005 are transitioning to ISO 27001:2013.



Uwe Krueger

Chief Executive

February 2014

Securing our business


WS Atkins plc Security Policy Statement | Issued in 2013, 2014 – changes to incorporate Be Safe and Secure, information and assets and ISO 27001:2013

© Atkins Ltd except where stated otherwise.

The Atkins logo and the strapline ‘Plan Design Enable’ are trademarks of Atkins Ltd.


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