Ethics and Compliance Program Structure

Fluor has a multi-faceted Ethics and Compliance 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 ethics and compliance program by monitoring our evolving risks including any strategic changes (e.g., new markets, businesses, etc.) 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. They delegated Board oversight to the Audit Committee and executive day to day oversight to Fluor's Chief Compliance Officer. The Chief Compliance Officer provides regular program updates to the Audit Committee, including with respect to the Annual Ethics Certification process.

The Chief Compliance Officer is responsible for the continuous improvement of the program. Program improvements are based on management input, risk assessments, audit findings, hotline reports, industry trends and best practices.

Additionally, the Chief Compliance Officer supports many cross-functional initiatives and processes, including providing input with respect to entering into new markets and geographical locations and working with new clients.

A Compliance and Ethics Committee was formed to provide assistance to the company's management and the Audit Committee to enable Fluor to continue to operate according to the highest ethical business standards and in accordance with applicable laws.

Overview of Compliance and Ethics Program Organization

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