KBR Inc.

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or Chair of the Board supporting the ethics and anti-corruption agenda of the company. TI notes a Chief Executive Officer statement on the Sustainability Story that supports the Code of Business Conduct. However, this is assessed to be insufficiently strong to score on this question.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company. However, there is evidence that this commitment has been delegated to the company’s Director of Compliance. The Director of Compliance Julia Symon has attended many panel discussions in relation to anti-corruption. The company therefore scores 1. To score higher the company would need to provide evidence that the Chief Executive Officer or the Chair of the Board demonstrates such commitment.

Based on public information, there is no readily available evidence that the Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is evidence that the company publishes a statement of values, including integrity, transparency and accountability. The company clearly explains the importance of these values, while also referencing openness and honesty.

Based on public information, there is evidence that the company is a signatory of the Defense Industry Initiative (DII) and subscribes to the Common Industry Standards.

Based on public information, there is evidence that the company has appointed the Audit Committee with overall corporate responsibility for its ethics and anti-corruption agenda. The Audit Committee is expected to advise the board in regards to Code of Business Conduct and establish procedures for the receipt, retention and treatment of complaints. The General Counsel reviews the Ethics agenda periodically and makes recommendations to the Board.

Based on public information, there is evidence that the General Counsel, Andrew Farley, has responsibility for implementing the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. The General Counsel reports to the Audit Committee at least annually regarding the effectiveness of the Code of Business Conduct. The Committee itself reviews the company’s compliance policies and procedures, as well as any complaints received. Evidence suggests this occurs at least anually, as the Committee meets quarterly. The company therefore scores 2.

Based on public information, there is limited evidence of a formal, written plan on which the review of the ethics and anti-corruption agenda by the Audit Committee is based. The Committee reviews reports on compliance by the company’s foreign entitities, advises the board in regard to compliance policies and procedures, manage procedures to receive complaints, and review any specific legal matters with the General Counsel. To score higher the company would need to provide further evidence of the formal, clear, written plan, as well as the implementation of improvements plans.

Based on public information, there is evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption. The General Counsel and Audit Committee are able to make recommendations to the Board of Directors when necessary.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The Audit Committee is responsible for risk-assessment procedures and mitigation plans, and there are clear guidelines on how this responsibility is applied.

Based on public information, there is no readily available evidence that the company has 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. TI notes that the company has a risk assessment procedure for new projects, but these are related to potential price and financial risk, not to corruption risk.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing agents. However, there is no evidence that the company refreshes the due diligence at least every 3 years and/or when there is a significant change in the business relationship. The company therefore scores 1.

Based on public information, there is evidence that the company has contractual rights and processes for the behaviour, monitoring, control and audit of agents with respect to countering corruption. Agents are expected to commit to compliance of the company’s Code of Business Conduct and the Anti-Corruption Laws. There is evidence that agents are monitored and in case of violations the contracts are terminated.

Based on public information, there is evidence that the company communicates its ethics and anti-corruption agenda down the supply chain. Third parties must ascribe to the standards set in its Code of Business Conduct and refrain from paying bribes. However, there is no evidence that the company has contractual rights to apply sanctions in the event of a breach of its contract. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms, including the giving and receiving of bribes and kickbacks.

Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. However, the company has a zero tolerance policy of violations of the Code of Business Ethics and Conduct, as shown by its explicit commitment to disciplinary procedures in the event of a violation by any employee or director. The company therefore scores 1.

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible to Board members, employees and third parties. The Code of Business Conduct has been translated into multiple languages and is available online.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear to Board members, employees and third parties. The company’s policy is assessed to be understandable to a non-legal audience.

Based on public information, there is evidence that the company’s anti-corruption policy explicitly 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 for employees, Directors and senior management. The company policy gives examples of potential conflicts of interest.

Based on public information, there is evidence of a company policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. The giving and receiving gifts is regulated, but the company does not set clear upper limits or a specific threshold for senior authorisation. The company therefore scores 1.

Based on public information, there is some evidence of a company policy for the giving and receipt of hospitality to ensure that such transactions are bona fide and not a subterfuge for bribery. The company states that hospitality for suppliers or customers needs prior approval according to Company procedures. However, aside from this there appears to be no reference to set upper limits or a threshold for senior authorisation. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a clear policy that explicitly prohibits facilitation payments. TI notes that the company states that it will try to minimise facilitation payments and that they require prior approval.

Based on public information, there is evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent. Political contributions are subject to authorisation from the General Counsel and a review by the Director of Government Relations and Director of Compliance. The company therefore scores 1. To score higher the company would need to provide evidence that it publically declares the recipients of political contributions.

Based on public information, there is some evidence that the company has a policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent. The company states that it follows all relevant laws and regulates lobbying by requiring a pre-approval from the Company’s Government Relations office when employees engage in political activities, including lobbying. However, the guidelines on the application are not clear and the company does not publically disclose the issues on which it lobbies. The company therefore scores 1.

Based on public information, there is some evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent. The company states that an approval is required for foreign community contributions and that the company only approves charitable contributions to organisations that meet certain criteria. However, there is no readily available evidence that the company publically declares the recipients of such contributions. The company therefore scores 1.

Based on public information, there is some evidence that the company provides written guidance to help Board members and employees understand and implement its ethics and anti-corruption agenda. The company provides definitions for the terms it uses in its policy, including definitions for gift, political contributions, improper payments and different actors, such as foreign officials. The company therefore scores 1. To score higher the company would need to provide evidence of written guidance that contains illustrations of particular situations in which employees might encounter corruption, to enhance understanding of company policies.

Based on public information, there is evidence that the company has a training programme that explicitly covers anti-corruption. The company states that it provides training related to the Code of Business Conduct, as well as a separate anti-corruption training programme.

Based on public information, there is evidence that anti-corruption training is provided in all countries where the company operates or has company sites.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest. TI notes that employees are required to disclose conflicts of interests to a manager. However, there is no evidence that this disclosure is conducted in writing.

Based on public information, there is evidence that the company will apply disciplinary procedures to employees and Directors found to have violated the Code of Conduct. The company states that employees will be held accountable for failure to adhere to the company’s Code.

Based on public information, there is evidence that employees can report concerns or instances of suspected corrupt activity using multiple, well-publicised channels. Employees are able to report using the anonymous EthicsPoint online reporting tool, the Ethics Hotline or the Code of Business Conduct post office box. Ethicspoint is an independent reporting channel that allows two-way confidential communication. Other channels include the Law Department, Audit Services, HR department, and management.

Based on public information, there is evidence that across geographies, all employees have access to more than one whistleblowing channel. This includes the Ethics Hotline, the Director of the Code of Business Conduct, or a representative of a compliance-related department.

Based on public information, there is some evidence that the company has mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively. The company states that discouraging employees from making a report is prohibited and upper management is said to review all alleged violations of the Code of Business Conduct. Additionally, the company publishes whistleblowing data, suggesting that the company analyses such data to discover issues. However, it is not clear what is communicated to employees and if there are other formal mechanisms to ensure that whistleblowing is otherwise not deterred. 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. Employees are able to contact the Ethics Hotline, the Law Department, the Director of Business Conduct, or the Director of Compliance.

Based on public information, there is evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption, with disciplinary measures applied to employees who breach this policy.