URS Corporation

Based on public information, there is no readily available evidence that the company publishes a statement from the CEO or Chairman supporting the ethics and anti-corruption agenda of the company. TI notes the statement in the Annual Report but does not assess this to be a strong enough statement to score here.

Based on public information, there is no readily available evidence that the company’s CEO or Chairman demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. This engagement could for instance take the form of leading internal anti-corruption workshops or chairing a review of the anti-corruption agenda.

Based on public information, there is evidence that the company publishes a statement of values representing high standards of business conduct, including integrity, transparency, honesty and accountability. The values are briefly explained in several short sentences in the Code of Business Conduct and Ethics and on the company’s website, as well as a video from Mike Kosti, head of the company’s anti-corruption compliance program.

Based on public information, there is evidence that the company belongs to the Defence Industry Initiative (DII).

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.

Based on public information, the company has appointed a person at a senior level within the company with responsibility for implementing the company’s ethics and anti-corruption agenda. Mike Kostiw, Corporate Counsel of Anti-bribery and Compliance, is head of the company’s Anti-corruption Compliance Programme and is responsible for ‘communicating the importance of ethics generally, for managing our policies and procedures on anti-corruption and then lastly for developing the process by which we vet third-party business partners’. TI notes that there is also a Chief Compliance Officer, Joseph Masters, Vice President and General Counsel, who oversees compliance of the Code of Business Conduct and Ethics.

Based on public information, there is evidence that the Audit Committee reviews and assesses the Company’s Code of Business Conduct and Ethics, and the Company’s system to monitor compliance with and enforce the Code. This is carried out on an annual basis.

Based on public information, there is no readily available evidence of 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 process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide.

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.

Based on public information, there is evidence that the company conducts due diligence that minimises corruption risk when selecting agents. The company therefore scores 1. To score higher there must be 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.

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 agree: to abide by the URS Anti-Bribery Policy; to allow the company to conduct audits to assess compliance and; that noncompliance with any part of the Anti-bribery policy is a basis for the company to withhold payment and terminate the agreement between it and the agent.

Based on public information, there is evidence that contractors and suppliers are aware of the company’s stance on bribery and corruption. Contractors and suppliers must agree to follow the company’s Anti-bribery policy and company supervisors must ensure they conform to the Code of Business Conduct and Ethics in their working practices. Evidence also suggests that noncompliance with any part of the Anti-bribery policy is a basis for the company to withhold payment and terminate the agreement between it and the contractor.

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 bribery, facilitation payments, improper gift exchange and conflicts of interest.

Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. While the company abides by the UK Bribery Act, it does not issue its own zero tolerance statement of corruption.

Based on public information, there is evidence that the company’s Code of Business Conduct and Ethics is easily accessible to board members, employees, and contracted staff. Employees receive a copy of the Code of Business Conduct and Ethics annually and are alerted to any updates, while evidence suggests it is made available to Board members and contracted staff. The Code of Business Conduct and Ethics and Anti-bribery Policy are also available on the company’s website. TI notes that the Code of Business Conduct and Ethics is available in three languages and the Anti-bribery Policy is available in English.

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.

Based on public information, there is evidence that the anti-corruption policy explicitly applies to all employees and members of the Board. The Code of Business Conduct and Ethics clearly states that every employee and director must read, understand and apply the Code to their business responsibilities.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest that applies to both employees and Board members. The policy contains a defintion of conflicts of interest and numerous examples.

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 policy states that all gift exchange requires approval from the employee’s supervising manager and lists what gifts are completely prohibited, such as gifts of a greater value than $50. The policy also specifically mentions regulations in regard to public officials.

Based on public information, there is 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 policy states that all hospitality exchange requires approval from the employee’s supervising manager and lists what hospitality is completely prohibited, such as hospitality consisting of travel and lodging ; hospitality in excess of $100 per person must be approved in advance by the Business President. The policy also specifically mentions regulations in regard to public officials.

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments. In cases of risk to personal safety or security of Company employees exceptions may be made only with the approval of the Legal Department, and with an accurate accounting record of the payment.

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

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or that it discloses the issues on which it lobbies.

Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent. Nor does the company publically declare recipients of donations.

Based on public information, there is insufficient evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. TI notes that the Code of Business Conduct and Ethics provides some scenarios, for example regarding conflicts of interest and gift and hospitality exchange. However, aside from this there is a lack of written guidance for other areas of the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the company has a training programme that explicitly covers anti-corruption, specifically in regard to the FCPA and the UK Bribery Act.

Based on public information, there is evidence that training on the Code of Business Conduct and Ethics is provided to employees in all countries where the company operates.

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 some evidence that the company has a varied ethics and anti-corruption training programme but it is unclear if this is targeted at all high risk positions.

Based on public information, there is evidence that the company has a clear and formal process by which employees declare conflicts of interest. If employees are aware of an actual or potential conflict of interest they are advised to discuss the matter with their supervisor or the Compliance Officer. The Audit Committee is responsible for addressing executive officer and director conflicts of interest.

Based on public information, there is evidence that the company may apply disciplinary procedures to employees and directors found to have engaged in corrupt activities. To score higher, the company needs to provide evidence of an explicit commitment using language such as ‘will’ rather than ‘may’.

Based on public information, there is evidence that employees can report concerns or instances of suspected corrupt activity using the Ethics Hotline by email or phone. Reports using the Ethics Hotline can be made anonymously. However, there is no evidence that the company provides an independent whistleblowing channel. The company therefore scores 1.

Based on public information, there evidence that across geographies, all employees have access to more than one whistleblowing channel. This includes the Ethics Hotline and the Compliance Officer.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively. However, TI does note that the company provided evidence to a whistleblower study conducted by the Ethics Resources Center (ERC).

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 directed to seek help and advice from their supervisor, the General Counsel or the Ethics Hotline.

Based on public information, there is evidence that there is a commitment to non-retaliation for bona fide reporting of corruption, with disciplinary measures applied to those breaching the non-retaliation policy.