Fluor's Management and Board of Directors are committed to ensuring the company has an effective Compliance and Ethics Program. The Audit Committee of the Board of Directors oversees Fluor's Compliance and Ethics Program and receives periodic reports, at least quarterly, from management regarding the program. The Chief Financial Officer has executive oversight and the Vice President, Corporate Compliance oversees the day-to-day activities of the Program.

Fluor's Compliance and Ethics Committee, comprised of cross-functional senior management, assists the company's management and Audit Committee to enable Fluor to operate in accordance with the highest ethical business standards and applicable laws. The committee is responsible for the following:

• The continued development, implementation, and operation of an effective Compliance and Ethics Program
• Promoting an organizational culture that encourages ethical conduct
• Considering and resolving any issues of interpretation regarding any aspect of the program

The Compliance and Ethics Committee formed a Compliance and Ethics Council, comprised of cross-functional senior management, to which it delegated certain responsibilities for reporting, investigating and recommending discipline for compliance and ethics-related policies and procedures, subject to continued oversight by the committee.

Furthermore, Fluor has eleven Task Forces that were created to address Fluor’s main risk areas.  The Task Forces are led by Subject Matter Experts and include cross-sections of employees from various business groups and functions.  The Task Forces inventory existing company policies and practice, develop and implement action plans for their risk areas, and monitor changes in Fluor’s business, laws and regulations.