By public info, this company is placed in Band A

Ownership

PUBLIC

Defence revenue, USD

2,162.30m (2013)

Defence revenue, %

7.90% (2013)

Country

US

Internal information

YES

Leadership 90%
1.
score
2

Does the company publish a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company?

Based on public information, there is evidence available of several strong statements from the Chairman and CEO supporting the company’s ethical culture and strongly advocating against corruption and unethical practices across the company. These include video statements addressing the CEO’s personal support of and investment in the ethics/anti-corruption agenda.

COMMENTS -+
2.
score
2

Does the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company?

Based on public information, there is evidence that the Chairman and CEO demonstrates a strong external facing commitment to ethics and corruption. He is a member/chair of initiatives for anti-corruption and has also written and spoken about promoting anti-corruption measures and practices in various public forums, such as the PACI initiative, WEF’s anti-corruption initiative. Video statements illustrating the CEO’s personal commitment to the anti-corruption agenda are also available.

COMMENTS -+
3.
score
0

Does the company’s Chief Executive Officer demonstrate a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure?

Based on public information, there is no readily available evidence that the CEO demonstrates a strong internal commitment to the anti-corruption agenda, for example direct involvement with staff, speaking at training events, etc. The Sustainability reports do mention a comprehensive internal communications programme; however, they do not directly mention the CEO – only, in case of the 2010 report, ‘executives’. The Fluor CEO and Chairman does publish a letter addressed to ‘Colleagues’ which is included in the company ethics handbook; however, this type of involvement is not assessed to be sufficiently active.

COMMENTS -+
4.
score
2

Does the company publish a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability?

Based on public information, there is evidence that the company publishes statements representing its values, ethics and belief in a transparency and ethics in business. It also re-enforces the same with specific statements on anti-corruption.

COMMENTS -+
5.
score
2

Does the company belong to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption?

Based on public information, there is evidence that the company is a member of several initiatives promoting anti-corruption and ethics in business. The initiatives are UN Global Compact, Global Reporting initiatives, Founding the World Economic Forum’s (WEF’s) Partnering Against Corruption Initiative (PACI), and the company Chairman is also co-chair of the B20 task force in Improving Corruption & Transparency.

COMMENTS -+
6.
score
2

Has the company appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda?

Based on public information, there is evidence that the company has appointed an Ethics and Compliance Committee that reports directly to the Board on matters of ethics and corruption.

COMMENTS -+
7.
score
2

Has the company appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board?

Based on public information, there is evidence that the company has appointed the Vice President of Corporate Compliance as the person responsible for implementing the company’s ethics and anti-corruption agenda. This person responsible also has a direct line reporting to the Board and is identifiable by name, as illustrated below.

COMMENTS -+
8.
score
2

Is there regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda?

Based on public information, there is evidence that the company has a formal Board level process of reviewing and updating the company’s ethics codes and agenda. TI has concluded that the Ethics Committee and the Audit Committee review the Code of Conduct annually and propose any major changes to the Board.

COMMENTS -+
8a.
score
2

Is there a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and evidence of improvement plans being implemented when issues are identified?

Based on public information, there is evidence that the company has a Board level process of reviewing and updating the company’s ethics codes which is based on a written plan specifying factors to be take into consideration.

COMMENTS -+
9.
score
2

Does the company have a formal process for review and where appropriate update its policies and practices in response to actual or alleged instances of corruption?

Based on public information, there is evidence that the company has a process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

COMMENTS -+
Risk management 70%
9a.
score
1

Does the company have a formal anti-corruption risk assessment procedure implemented enterprise-wide?

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise wide. However, there is no readily available evidence of mitigation plans with clear ownership and timelines. The company therefore scores 1.

COMMENTS -+
10.
score
1

Does the company have a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied?

Based on public information, there is evidence that the company has a formal process to review risks related to its ethics and compliance codes before implementing a project and prior to engaging with third parties. However, TI assesses that there is limited evidence available concerning the application of this process and in particular the business decisions to which it applies. The company therefore scores 1.

COMMENTS -+
11.
score
1

Does the company conduct due diligence that minimises corruption risk when selecting or reappointing its agents?

Based on public information, there is evidence that the company does conduct due diligence on appointment with agents. However, it is not clear whether this due diligence is refreshed at least every three years or when there is a significant change in the business relationship. The company therefore scores 1.

COMMENTS -+
12.
score
2

Does the company have contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption?

Based on public information, there is evidence that the company does have processes and also contractual specifications for control and audit of agents with respect to preventing corrupt practices.

COMMENTS -+
13.
score
2

Does the company make clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance?

Based on public information, there is evidence that the company does make clear to contractors and suppliers its policies and codes on corruption and also the potential consequences associated with breaching the same.

COMMENTS -+
13a.
score
NA

Does the company explicitly address the corruption risks associated with offset contracting?

The company has informed TI that it does not engage in offset contracting.

COMMENTS -+
13b.
score
NA

Does the company conduct due diligence that minimises corruption risk when selecting its offset partners and offset brokers?

The company has informed TI that it does not engage in offset contracting.

COMMENTS -+
Policies & codes 83%
15.
score
2

Does the company have an anti-corruption policy that prohibits corruption in its various forms?

Based on public information, there is evidence that the company has an anti-corruption policy. It also provides in details regarding the various forms of bribery to guide employees.

COMMENTS -+
16.
score
2

Is the anti-corruption policy explicitly one of zero tolerance?

Based on public information, there is evidence that the company has a detailed zero tolerance policy for bribery. This is made clear to all employees.

COMMENTS -+
17.
score
2

Is the company's anti-corruption policy easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company?

Based on public information, there is evidence that the company policies and codes related to corruption are easily accessible to employees and also contracted staff by being easily available on the website.

COMMENTS -+
17a.
score
2

Is the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties?

Based on public information, there is evidence that the company’s policies are understandable and clear for all employees as well as third parties.

COMMENTS -+
18.
score
2

Does the anti-corruption policy explicitly apply to all employees and members of the Board?

Based on public information, there is evidence that the company’s Code containing its policy on anti-corruption is applicable to all employees worldwide. The same is also applicable for members of the Board.

COMMENTS -+
20.
score
2

Does the company have a policy on potential conflicts of interest, and does it apply to both employees and board members?

Based on public information, there is evidence that the company has a clear policy on potential conflicts of interest. This is also supported by details of scenarios where such conflicts of interest may arise and what the employees are supposed to do in such instances.

COMMENTS -+
21.
score
1

Does the company have a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery?

Based on public information, there is evidence that the company has a policy for giving and receiving of gifts. The company does place limits on the value of gifts, but these apply to specific projects and are not company-wide. It is not clear whether all projects have a gift value ceiling and how the ceilings are arrived at. The company therefore scores 1.

COMMENTS -+
22.
score
1

Does the company’s anti-corruption policy include a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery?

Based on public information, there is evidence that the company has a policy for giving and receipt of hospitality. The company does place limits on the value of hospitality, but these apply to specific projects and are not company-wide. It is not clear whether all projects have a hospitality value ceiling and how the ceilings are arrived at. The company therefore scores 1.

COMMENTS -+
23.
score
0

Does the company have a policy that explicitly prohibits facilitation payments?

Based on public information, there is no readily available evidence that the company explicitly prohibits facilitation payments. TI notes that the company prohibits facilitation payments in general but allows these in certain circumstances. The circumstances are clearly defined and elaborated upon.

COMMENTS -+
24.
score
2

Does the company prohibit political contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent? Does the company record and publicly disclose all political contributions?

Based on public information, there is evidence that the company prohibits political contributions.

COMMENTS -+
25.
score
2

Does the company have a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies?

Based on public information, there is evidence that the company has a clear policy on engagement in lobbying activities and guidelines for the same. There is also evidence that the company publically discloses the issues on which it lobbies.

COMMENTS -+
25a.
score
2

Does the company prohibit charitable contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent?

Based on public information, there is evidence that the company has a policy on charitable contributions. There are regular publicly available reports on the company’s community impact with highlights of the company efforts, partnerships, supported projects and scorecards on the status of involvement.

COMMENTS -+
Training 90%
26.
score
2

Does the company provide written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda?

Based on public information, there is evidence that the company’s policies and codes regarding corruption include a number of clear definitions and examples.

COMMENTS -+
27.
score
2

Does the company have a training programme that explicitly covers anti-corruption?

Based on public information, there is evidence that the company has a specific anti-corruption training programme directed at all employees and directors.

COMMENTS -+
28.
score
2

Is anti-corruption training provided in all countries where the company operates or has company sites?

Based on public information, there is evidence that the company provides training to all its salaried employees in all geographies.

COMMENTS -+
29.
score
1

Does the company provide targeted anti-corruption training to members of the Board?

Based on public information, there is evidence that the company does provide some level of training to Board members. However, it is not clear if they are retrained at least every three years. The company therefore scores 1.

COMMENTS -+
30.
score
2

Does the company provide tailored ethics and anti-corruption training for employees in sensitive positions?

Based on public information, there is evidence that the company does provide specifically tailored anti-corruption training for employees in high risk positions.

COMMENTS -+
Personnel 79%
31.
score
2

Does the company have a clear and formal process by which employees declare conflicts of interest?

Based on public information, there is evidence that the company has a formal and clear process by which employees can declare conflict of interests to supervisors or HR. Company procedure explicitly states that conflicts of interest should be disclosed in writing.

COMMENTS -+
32.
score
1

Is the company explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities?

Based on public information, there is evidence that the company makes clear the consequences and disciplinary actions that may be taken when employees engage in corrupt activities in violation of the company’s code of conduct. However, it is not clear that discipline will be taken in each case. The company therefore scores 1.

COMMENTS -+
33.
score
2

Does the company have multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity?

Based on public information, there is evidence that the company does provide a well-publicised channel through its Fluor Hotline to report suspected corrupt activities. The hotline is managed by an independent party and there are strong guarantees of anonymity for those who report infractions (information is only disclosed on a ‘need to know’ basis).

COMMENTS -+
33a.
score
2

Are the whistleblowing channels available to all employees in all geographies?

Based on public information, there is evidence that the company’s whistle blowing channels are available to all employees in all geographies with respective country contact numbers and languages.

COMMENTS -+
33b.
score
0

Does the company have formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively?

Based on public information, there is evidence that the company creates an encouraging atmosphere for whistle blowing and they are treated supportively. However, it is not clear that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, such as ways to follow up with whistleblowers and monitor their experience.

COMMENTS -+
34.
score
2

Does the company have well-publicised resources available to all employees where help and advice can be sought on corruption-related issues?

Based on public information, there is evidence that the company has well publicised channels to report and seek advice on corruption from trained practitioners.

COMMENTS -+
35.
score
2

Is there a commitment to non-retaliation for bona fide reporting of corruption?

Based on public information, there is evidence that the company has a commitment to non-retaliation for reporting corruption and it states that it will strongly discipline those who retaliate against whistleblowers.

COMMENTS -+
Band & analysis based on internal and public information: band A
Leadership 100%
Risk management 70%
Policies & codes 83%
Training 90%
Personnel 86%