Ethics and Compliance Program Structure

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

Fluor's Board of Directors is committed to Fluor maintaining an effective compliance and ethics program. They delegated Board oversight to the Audit Committee, executive oversight to Fluor's Chief Financial Officer, and appointed a Vice President of Corporate Compliance to oversee the day-to-day activities of the program.

The Vice President of Corporate Compliance meets with the Board and Audit Committee on at least a quarterly and annual basis to provide updates on the program. A Compliance and Ethics Committee was formed to provide assistance to the company's management and the Audit Committee to enable Fluor to continue to operate according to the highest ethical business standards and in accordance with applicable laws.

Overview of Compliance and Ethics Program Organization

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