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Program Overview

Good intentions and lofty words, of course, are not enough. We must not only "talk the talk" but "walk the talk" as well, something that Fluor is doing through a series of increasingly effective programmatic actions.

The Board of Directors is strongly committed to enhancing the effectiveness of Fluor's Compliance and Ethics Program. To optimize the program's success, it assigned key oversight responsibility at high levels of the organization. This included delegating Board oversight to the Audit Committee and executive oversight to Fluor's Chief Financial Officer Mike Steuert while appointing Wendy Hallgren as Vice President of Corporate Compliance to oversee the program's day-to-day activities.

In addition, a Compliance and Ethics Committee — a cross-functional senior management team — enables Fluor to continue to operate in line with the highest ethical business standards and in accordance with applicable laws. This Committee in turn created a Compliance and Ethics Council to regularly review the status of all investigations, ensure that appropriate investigative bodies are involved as necessary, and assess any recommended corrective action for adequacy and consistency. Thoughtful and detailed policies and codes of conduct, backed up by training and certification initiatives, help employees and others make appropriate decisions, and avoid ethical lapses. In addition, we regularly monitor and audit our businesses to ensure compliance with our codes and policies.

Program Structure

Fluor's Board of Directors is committed to the enhancement of the company's Compliance and Ethics Program. They delegated Board oversight to the Audit Committee, executive oversight to Fluor's Chief Financial Officer Mike Steuert and appointed Wendy Hallgren, Vice President of Corporate Compliance to oversee the day-to-day activities of the program. A compliance and Ethics Committee was formed to provide assistance to the company's management and the Audit Committee to enable Fluor to continue to operate in line with the highest ethical business standards and in accordance with applicable laws.

Program Structure

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