Bechtel Corporation

Based on public information, there is readily available evidence that the company publishes three statements from the CEO and Chairman, supporting the ethics and anti-corruption agenda of the company. The company website contains a video statement by the CEO supporting the company’s ethics agenda, the Code of Conduct contains an introductory piece by the Chairman and the 2014 Annual Report contains a small statement jointly written by the CEO and Chairman.

Based on public information, there is limited evidence that the CEO and the Chairman demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. However, there is evidence that the commitment is delegated: for example, Nancy Higgins, Chief Compliance Officer, has done two interviews with the Wall Street Journal in the last year. However, the examples that TI has had sight of illustrate commitment which mostly pertains to the company as a whole, rather than the CEO personally; therefore, the company scores 1.

Based on public information, there is some evidence that the company Chairman and CEO 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. TI notes that evidence indicates that a video message from the Chairman accompanies annual compliance training. However, this video is not publicly available. TI notes that a video message from CEO Bill Dudley is available online; however, this video is focused on the company as a whole, rather than the CEO’s personal commitment to ethics and anti-corruption. The company therefore scores 1.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of ethical business conduct, including integrity, honesty and trustworthiness. The values are explained in detail and clearly translated into company policies.

Based on public information, there is evidence that the company is a member of TI-USA and of Ethisphere’s Business Ethics Leadership Alliance.

Based on public information, there is evidence that the company has appointed an individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda.

Based on public information, there is readily available evidence that the company has appointed Nancy Higgins, Chief Ethics and Compliance Officer, with responsibility for implementing the company’s ethics and anti-corruption agenda. Ms Higgins reports to the General Counsel and the Audit Committee.

Based on public information, there is readily available evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti- corruption agenda. The Audit Committee receives periodic reports from the Chief Ethics and Compliance Officer on the status of the company’s ethics and compliance program. Similarly, the Senior Management Ethics and Compliance Committee meets quarterly and reviews the ethics and compliance agenda; the General Counsel is a member.

Based on public information, there is evidence of a formal, clear, written plan on which the review of the ethics and anti-corruption agenda by the Board and senior management is based. The Audit Committee receives periodic reports from the Chief Ethics and Compliance Officer on the status of the company’s ethics and compliance program. This includes the status of policies and procedures, significant violations of the Code of Conduct, and procedures for whistleblowing. The Senior Management Ethics and Compliance Committee reviews the ethics and compliance agenda, which includes a review of training procedures, whistleblowing data, and policies and procedures. Evidence suggests that improvements are implemented when issues are identified, using survey and helpline statistics.

Based on public information, there is evidence that violations of the ethical code are reported to the Chief Ethical and Compliance Officer and to the Board, as are company responses to these violations. Members of the Corporate Compliance Committee appear to be responsible for overall monitoring and improvement of the compliance and ethics agenda. The Audit Committee receives periodic reports regarding significant violations of the Code of Conduct, and the Ethics and Compliance Committee is responsible for updating company policies in ethics and compliance areas.

Based on public information, there is evidence that the company has a formal risk assessment procedure implemented enterprise-wide, which includes ethics and compliance issues and applies to different geographies. However, the information available is not sufficiently detailed to provide evidence of mitigation measures being applied, with process timelines and ownership details. The company therefore scores 1.

Based on public information, there is limited evidence that the company has a formal anti-corruption risk assessment procedure for proposed business decision. Evidence suggests that before it does business with any company it checks the restricted party list and determines if the company is politically connected. If there are any concerns further due diligence is carried out. Public information available suggests that the risk assessment is applied to a wider range of business decisions (such as hiring agents, contractors or consultants); however, it is not clear that there are criteria specifying the application of the procedure to all proposed business decisions, such as acquisitions. The company therefore scores 1.

Based on public information, there is evidence that the company conducts due diligence when selecting agents and that it is renewed at least every 2 years.

Based on public information, there is evidence the company has 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 communicates its ethics and anti-corruption agenda down the supply chain and makes clear its requirement for suppliers to conform to its anti-corruption policies. The company also reserves contractual rights to apply sanctions in the event of corrupt activities.

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

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

Based on public information, there is readily available evidence that the company has a policy that prohibits the giving and receiving of bribes, and is explicit on the various forms corruptions can take.

Based on public information, there is evidence that the company’s anti-corruption policy is explicitly one of zero tolerance.

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily accessible to Board members, employees and other third parties. The Code of Conduct is given to all parties and is available on the company’s website in multiple languages, as is the company’s Anti-Corruption Compliance Guidelines

Based on public information there is readily available evidence that the company’s ethics and anti-corruption policies are easily understandable and clear to Board members, employees and third parties. They are clearly written and use questions and answers to explain key regulations.

Based on public information, there is evidence that the company’s Code of Conduct applies to all employees and Board members.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest. The policy is clearly written, defines a conflict of interest and provides numerous examples. The policy applies to employees and Board members, as it is housed within the Code of Conduct which applies to both.

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. The Anti-Corruption Compliance Guidelines set upper limits for gift exchange or require senior authorization and provides specific guidance and examples of such transactions and how they might occur.

Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality 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 that explicitly prohibits facilitation payments. The policy is clear and provides examples. In the same section of the Code of Conduct employees are informed to seek guidance from the Legal Department or an ethics and compliance officer if faced with a request to make a payment.

Based on public information, there is evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent. All corporate contributions must be approved by the company’s Washington D.C. office, corporate External Affairs and Communications or the applicable country manager. However, there is no readily available evidence that recipients are publicly declared. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent. Different lobbying activities require the respective approval of company’s Washington D.C. office, corporate External Affairs and Communications or the applicable country manager. However, there is no readily available evidence that the company publicly discloses the issues on which it lobbies. The company therefore scores 1.

Based on public information, there is evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent. TI notes that the recipients of donations must be recorded in Bechtel’s records; however the policy does not state that this list is publicly available. The company therefore scores 1.

Based on public information, there is evidence that the company’s Code of Conduct is well organized and contains numerous examples, to help Board members and employees understand and implement the company’s ethics and anti-corruption agenda. Several videos on the company website assist with general understanding of the ethics and anti-corruption agenda.

Based on public information, there is evidence that the company has a training programme on its ethics and compliance systems, which incorporates an anti-corruption policy. This includes a module on bribery and corruption issues.

Based on public information, there is evidence that anti-corruption training is provided in all countries where the company operates or has company sites. All employees participate in annual ethics awareness workshops, which also contain anti-corruption training.

Based on public information, there is evidence that the company provides targeted anti-corruption training to Board members that is refreshed at least every 3 years. TI notes the distinction between Executive and Non-executive members of the Board.

Based on public information, there is evidence that each business unit can tailor training to its needs and that employees in higher risk positions receive tailored ethics and compliance training.

Based on public information, there is evidence that the company has a process by which employees declare conflicts of interest. The Code of Conduct states that employees can direct questions to their manager, an ethics and compliance officer, HR, the Legal Department, or the Ethics HelpLine. It instructs employees to obtain a conflict of interest determination from their ethics and compliance officer before they or a family member undertakes any outside activity that could constitute a conflict of interest. The process for declaring and determining the existence of conflicts of interest is formal, conducted in writing, and with the involvement of an independent department.

Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities. The company’s Chief Ethics Officer states in a video that employees who violate the Code of Conduct will face consequences, which can include discipline.

Based on public information, there is evidence that the company has multiple, well-publicised channels that are accessible, secure and confidential, for employees to report instances of suspected corrupt activity. Channels include reporting to a supervisor, an ethics and compliance officer, the HR Department, and the Legal Department. In particular, the third-party hosted Bechtel Ethics HelpLine is available 24/7 and facilitates anonymous reporting online or by phone.

Based on public information, there is evidence that the company’s whistleblowing channels are available to all employees in all geographies. For example, employees can report to the Bechtel Ethics HelpLine, an ethics and compliance officer or the HR Department. In particular, the Ethics HelpLine supports 200 languages.

Based on public information, there is evidence of efforts to ensure whistleblowing is not deterred. The company states that employees have an obligation to inform the company of unethical conduct or violations of company policy, and that it takes appropriate corrective action if retaliation is found to have occurred. Other materials indicate that the company conducts employee surveys and monitors helpline use data; however, the available evidence does not specify particular mechanisms aimed specifically at whistleblowers. The company therefore scores 1.

Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. These resources include ethics and compliance officers and the Bechtel Ethics HelpLine.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. The Code of Conduct and company policies state that the company will take appropriate corrective action, up to and including termination, if retaliation is found to have occurred.