Fluor Expects Its Third Parties to Maintain the Highest Standards of Integrity

Clients depend on us to bring our ethical culture and innovative programmatic solutions to the delivery of their projects around the world. Fluor engages with clients, business partners, suppliers, subcontractors, agents and other third parties on ethics and compliance as part of our regular business processes.

Fluor's supply chain group is responsible for establishing new supplier relationships and providing oversight of suppliers. Supply chain internal controls are assessed annually during functional compliance audits, and all findings are addressed and remediated.

Fluor seeks to do business with third parties who share our standards and values. Additionally, we ask our suppliers to flow down this contractual requirement to their suppliers. We conduct risk-based due diligence when selecting a third party and identify ultimate ownership to comply with regulations on prohibited transactions. We continuously monitor suppliers and subcontractors with whom we do business. Depending on the type of third party, we embed various requirements and processes to emphasize and mitigate applicable anti-corruption risks. Fluor seeks to mitigate compliance risks whenever possible.

Fluor does not have a commission-based sales structure, which contributes greatly to the management of corruption risks. All agency relationships are subject to stringent review, including a requirement that agents adhere to Fluor's anti-corruption requirements. Fluor's law department, finance department and Sales Leadership Council review prospective agreements prior to agency agreements being reviewed and approved by a group president and Fluor's chief legal officer.

Our suppliers and contractors are required to comply, and in turn require their supply chain to comply, with Fluor's Business Conduct and Ethics Expectations for Suppliers and Contractors (the Supplier Expectations). The Supplier Expectations highlight key expectations in health, safety and environmental; human rights and employment practices; sustainability; conflict minerals; financial and operational controls; trade controls; anti-bribery and corruption; conflicts of interest; gifts, entertainment and business courtesies; competing fairly; money laundering prevention; lobbying; company resources; government work; and reporting concerns.

Clients, joint venture partners, suppliers, contractors and other third parties are encouraged to report any suspected misconduct or concern involving or affecting Fluor, whether or not the concern involves the third party, by contacting their Fluor representative, Fluor's chief procurement officer (for suppliers and contractors) or Fluor's Compliance & Ethics Integrity Portal & Hotline.