Compliance and Ethics in Action

Because Fluor understands that Fluor's Code of Business Conduct and Ethics (The Code) cannot possibly cover every subject area or situation, the company strives to ensure that individuals know the right questions to ask, the right experts to consult and the right way to make decisions.

Employee Decision-Making Model

If ever in doubt, Fluor personnel are instructed to ask the following questions and consider the following thoughts:

  • Is this legal? Have I checked with the company's subject matter expert?
  • Would it conflict with any of Fluor's Core Values: Safety, Integrity, Teamwork or Excellence?
  • Am I involving the right people?
  • How would I feel telling my family or children about my decision?
  • If I choose to act on this situation, would my decision be fair?
  • How would I feel reading about my choice in a newspaper or explaining my choice to a judge or jury?
  • If you know it's wrong, don't do it.
  • If in doubt, ask.
  • Keep asking until you get an answer.
  • Don't ignore what you believe to be illegal or unethical conduct.
  • Set an example for others.

Take responsibility by doing the right thing. For managers, this includes taking responsibility for having the proper and necessary policies, procedures and an environment to do the right thing.

Employee Training

Training is one of the most critical components for the success of any compliance and ethics program. Fluor's training program has a multi-topic curriculum to ensure employees understand the risks that apply to their positions and comply with the related Fluor policies and practices.

All Fluor salaried employees receive the Code training, with an emphasis on anti-corruption and other key risk areas.

Managers receive additional training on how to handle and escalate employee concerns about misconduct in a way that reinforces the company's commitment to maintaining an open and non-retaliatory workplace.

Additionally, employees are asked to participate in specialty, web-based training modules that focus on key risk areas related to their job function. Training classes are also conducted, including project-specific, anti-corruption training, as well as other classes focused on ethics and compliance risk areas for targeted employees and directors. These training materials are periodically refreshed. The company-wide Ethics and Compliance Training and Certification is updated every year to train employees on trending issues in compliance and address frequently asked compliance and ethics questions or reported concerns.

We assess the effectiveness of our training program on an ongoing basis. This includes analyzing and reviewing concerns raised and tracked through the integrity portal, employee surveys and new areas related to changes in business needs.

Employee Certification

As part of our ongoing commitment to adhere to the highest standards of business conduct and ethics, our employees are asked annually to review Fluor's Code of Business Conduct and Ethics to ensure their understanding of the company's commitment to integrity and ethics and to certify to their understanding and adherence to the Code. This practice also requires employees to disclose ethical concerns and actual or potential conflicts of interest for resolution.

In 2021, nearly every full-time employee of Fluor completed the Annual Ethics Certification and Disclosure training on anti-corruption, gifts and entertainment, accurate reporting, third parties and conflicts of interest.

Conflicts of Interest

All new hires and re-hires are required to disclose any conflicts of interest during the on-boarding process. Additionally, employees are asked to disclose any actual or potential conflicts of interest during the annual ethics certification process.

All disclosures are reviewed by the appropriate department (i.e., human resources, corporate compliance or the law department) and guidance is issued to employees. This process is overseen by the chief compliance officer.

Employees are not precluded from seeking elected positions provided that they disclose the matter and comply with the Code and conflicts of interest policy. Fluor does not, however, hire any current government officials as consultants, directors or employees.

Seeking Advice and Reporting Concerns

Our Core Value of Integrity provides the foundation for employees to always do what is right and to seek guidance if they are ever unsure about the right thing to do in a business situation. It is of the highest importance to Fluor that employees are empowered to readily speak up and say something when they suspect unethical behavior. Employees have access to multiple speak-up channels including their immediate supervisor, others in management, Compliance and Ethics, Human Resources, Industrial Relations, a Fluor subject matter expert or other internal investigating departments. Additionally, our company has in place the externally managed Compliance and Ethics Integrity Portal, which employees can use to report concerns, report concerns anonymously unless prohibited by local law and seek advice from anywhere around the globe via the internet or a toll free number. Fluor will not tolerate any form of direct or indirect retaliation that arises from anyone raising a compliance or ethics concern in good faith.

Clients, partners, suppliers and subcontractors also are encouraged to report any suspected misconduct or raise any concern regarding Fluor, a Fluor employee or other representative, whether or not the concern involves the supplier or contractor, by contacting their Fluor representative, Fluor’s chief procurement officer (for suppliers and contractors) or Fluor's Compliance and Ethics Integrity Portal.