Compliance and Ethics Program Structure

Fluor has a multifaceted compliance and ethics 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 compliance and ethics program by monitoring our evolving risks, including any strategic changes (e.g., new markets and businesses) 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. The board delegated oversight of the compliance and ethics program to the Audit Committee and executive day-to-day oversight to Fluor's chief compliance officer. The chief compliance officer has direct access to the Audit Committee to address compliance and ethics issues and to provide regular program updates, including quarterly Executive Sessions with the committee and monthly calls with the Audit Committee chairperson.

The chief compliance officer is responsible for the continuous improvement of the program. Program improvements are based on management input, risk assessments, audit findings, integrity portal reports, industry trends and best practices.

Additionally, the chief compliance officer and the compliance team support many cross-functional initiatives and processes, including providing input with respect to entering new markets and geographical locations and working with new clients.

A Compliance and Ethics Committee was formed to provide assistance to management and the Audit Committee to ensure that Fluor continues to operate according to the highest ethical business standards and in compliance with applicable laws, regulations, policies and practices.

Overview of Compliance and Ethics Program Organization

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