Sorry, you need to enable JavaScript to visit this website.

Doing Business Globally

    Zero Tolerance for Bribery

    In many parts of the world, paying bribes to win business contracts or to get work done is unfortunately both accepted and expected. However, Fluor will not tolerate bribery of any form – with any third party, public or private, whether done directly or indirectly through third parties, even if we lose business or encounter delays because of our refusal to do so.

    A “bribe” is an offer or promise to give, or the giving of, or authorizing to give, anything of value or another advantage to improperly influence the actions of a third party, public or private.

    Bribes may include money, gifts, travel or other expenses, hospitality, below-market loans, discounts, favors, business or employment opportunities, political or charitable contributions, or any direct or indirect benefit or consideration. Improper influence typically involves the intent to secure a quid pro quo to buy the misuse of someone’s position.

    Bribes violate anti-corruption laws. It is your duty to know and follow the local and other applicable anti-corruption laws that apply to your assigned duties. Consequences for violating anti-corruption laws are severe for both our Company and the individuals involved, including possible civil and criminal liability.

    Facilitating Payments

    At Fluor, facilitating payments are prohibited, unless they are:

    checkmark icon

    Pre-approved in writing by the Law Department

    gavel icon

    Allowed under all applicable anti-corruption and local laws

    paper with checkmark icon

    Properly and accurately accounted for in our company’s records

    A “facilitating payment” is a small payment given to a government employee, usually in cash, to expedite or secure the performance of a routine process such as to expedite utility services, provide needed police protection or approve the granting of a work permit or visa. Anti-corruption and local laws often prohibit facilitating payments.

    If there is an immediate and credible threat to an employee’s physical safety or security and it is not reasonably possible to get advance approval for a proposed payment demanded, the payment may be made without prior approval but must be promptly reported in writing to the Law Department.

    Does your work involve the U.S. Government?

    If your work involves projects in which the U.S. Government or its funds are involved, there are additional guidelines for Anti-Corruption

    Use of Agents, Consultants, Representatives, and Other Third Parties

    Fluor may be liable under anti-corruption and local laws not only for the actions of our employees, but also those of our business partners. If you have a reasonable suspicion that a business partner or other third party might pay a bribe but fail to take the appropriate steps to attempt to prevent such payment, we may be seen as implicitly authorizing the bribe.

    We expect our joint venture partners, suppliers, contractors, consultants, agents, and other business partners to maintain a zero tolerance for bribery, as described in Fluor’s Business Conduct and Ethics Expectations for Suppliers and Contractors, available at www.onefluor.com and www.fluor.com.

    While we generally discourage the use of third-party agents, in many parts of the world, it is necessary and even required to use agents, consultants, representatives, or other third parties to arrange or broker deals with governments, government entities, and private entities. These relationships can be tricky.

    If you interact with agents or other third parties, such as joint venture partners, suppliers, subcontractors, or consultants, you must follow the proper practices put in place by Fluor, including due diligence procedures, functional approval processes and practices, and contractual provisions. Report any suspicious or questionable behavior, transactions, or receipts to the Law Department immediately.

    RED FLAGS THAT WARRANT FURTHER INVESTIGATION WHEN SELECTING OR WORKING WITH THIRD PARTIES INCLUDE:

    • “High-risk” country known for corruption

    • Lacks experience with product, field, or industry or qualified staff

    • Inconsistencies or misrepresentations in the due diligence process and unclear on incomplete ownership information

    • Reference check reveals flawed reputation

    • Objects to anti-corruption contractual provisions or certifications

    • Commission or fee exceeds the going rate

    • Requests unusual payment arrangements, such as payment in cash, in another currency, or in a third country

    • Recommended by a government official

    • Close social, business, or family ties to a government official

    Common Questions

      No. You may not approve reimbursement for the customer’s non-business-related expenses, such as sightseeing trips or plane tickets for family members. Fluor cannot pay for these expenses, since doing so might create the appearance of bribery. All expenses must be (1) directly related to a bona-fide business purpose, (2) reasonable, and (3) permissible under Fluor’s and the client’s applicable standards and all applicable laws and rules.

      Was this answer helpful?

      Thank you, your feedback has been sent!

        Trade Controls and Customs Compliance

        As a U.S. company operating globally, Fluor must comply with all applicable national and international trade control laws and regulations that govern the import, export, and transfer of goods, services, technology, technical data, and software and the provision of technical assistance. These activities may be restricted or prohibited for national security, foreign policy, regional stability, and human rights reasons depending upon the countries, or nationals of countries, involved and depending upon their nature, classification, intended end-use, or the location or nationality of recipients. Keep in mind that imports, exports, and provision or transfers can take many different forms, including, but not limited to:

        • The actual physical movement of goods and software,
        • Providing foreign persons or entities access to technology or technical data, wherever you or the recipient are located, including visual inspection, virtual meetings, emailing documents or drawings, and
        • Providing technical assistance or training to foreign persons or entities, wherever you or the recipient are located.

        If you are involved in the import or export of goods and software, the transfer of technology or technical data, or provision of services or technical assistance, you are responsible for:

        • Obtaining and recording the appropriate import tariff classification and export control classification for goods and software that are being moved internationally,
        • Export control classification for technology, technical data, or services and assistance that may be shared with foreign persons or entities – whether in your local country, their home country, or a third country, and
        • Seeking guidance from Fluor’s Trade Compliance Subject Matter Expert.

        Before engaging in any of these activities, all required licenses and permits must be obtained, and counterparties must be screened to ensure they are not restricted or prohibited from these activities.

        The import, export, re-export, provision, transfer, or re-transfer of any controlled goods, software, technology, or technical assistance must be consistent with the terms of any import or export license, Fluor’s policies and procedures, and all applicable laws and regulations. Additionally, the import of goods and software carries with it the requirement that all declarations made to customs officials provide accurate descriptions, classifications, quantities, values, and origins.

        Consequences for violating trade control laws and regulations are severe for the company and the individuals involved, including the potential loss of export or import privileges and civil and criminal penalties including fines and jail time. If you have any questions about exports, re-exports, or imports, please contact Fluor’s Trade Compliance Subject Matter Expert at [email protected]).

        Common Questions

          No. “Controlled” technology cannot be released outside the U.S. without prior approval in the form of an approved export license by the Department of Commerce. Your procurement representative or Fluor’s Trade Compliance Officer can help you get the necessary license.

          Was this answer helpful?

          Thank you, your feedback has been sent!

            Trade Sanctions and Boycotts

            We must abide by all U.S. trade and economic sanctions. Additionally, we must adhere to other trade and economic sanctions applicable to our business. For an up-to-date list of those countries and individuals with which we cannot do business, contact our Trade Compliance Subject Matter Expert or the Law Department.

            In addition, we may not participate in any boycott or restrictive trade practice against countries considered “friendly” to the United States that are “blacklisted” by other countries or firms. For example, some companies in the Middle East may seek to include language in contracts that prohibits Fluor from doing work in Israel. We cannot allow such language to be included or enforced in a Fluor contract. You should promptly report any request to participate in a boycott to your manager and our Law Department, even if Fluor decides not to bid on the project.

            Common Questions

              Possibly. Doing business with a country that has trade sanctions imposed against it is broadly construed. Even moving goods through a country on the list could violate the trade sanctions. If your goods are transiting through Iran or another sanctioned country, you must first consult with Fluor’s Trade Compliance Officer or Law Department. Additionally, if you are working in a geographic location where there are sanctioned countries, it would benefit the project for you to be familiar with the applicable sanction regulations.

              Was this answer helpful?

              Thank you, your feedback has been sent!

              No. You need to obtain any necessary permits before leaving the country with “controlled” technology that would qualify as an export. If you are unsure whether you need to obtain an export license, you should consult Fluor’s Trade Compliance Officer or our Law Department.

              Was this answer helpful?

              Thank you, your feedback has been sent!

                Money Laundering

                Fluor is committed to fighting money laundering in the countries where we do business. “Money laundering” is the process by which individuals or entities move criminal funds through the financial system in order to hide traces of their criminal origin, or otherwise try to make these funds look legitimate.

                While you may never be in the position to violate money laundering laws, you need to be on the lookout for irregularities in the way payments are made. If you see any of the following, you should report the matter to our Treasury Department immediately:

                hand with money symbol icon

                Payments made in currencies other than those specified on the invoice

                hand with money symbol icon

                Payments made to or received from countries unrelated to the transaction

                hand with money symbol icon

                Attempts to make payments in cash or a cash equivalent

                hand with money symbol icon

                Payments made by a third party not involved in the contract or an account other than the normal business relationship account

                hand with money symbol icon

                Payments made in cryptocurrency

                hand with money symbol icon

                Requests or attempts to make payments for each invoice or group of invoices through multiple forms of payment

                hand with money symbol icon

                Requests to make an overpayment

                  Modern Slavery: No Child or Forced Labor or Human Trafficking

                  Our belief that all individuals should be treated with dignity and respect is firmly rooted in our core value of Integrity. Fluor is committed to fostering an environment that recognizes and supports all aspects and dimensions of human rights. Fluor does not tolerate the use of child or forced labor, trafficking in persons, or procurement of commercial sex acts. You must work to ensure that Fluor does not have suppliers, contractors, or other business partners who do so, as reflected in Fluor’s Business Conduct and Ethics Expectations for Suppliers and Contractors, available at www.onefluor.com and www.fluor.com. These standards apply wherever Fluor works regardless of local laws and customs.

                  Refer to Fluor’s Modern Slavery Statement located on www.fluor.com for more information.

                  Does Your Work Involve the U.S. Government?

                  If your work involves projects in which the U.S. Government or its funds are involved, there are additional guidelines for Trafficking in Persons

                  Common Questions

                    Fluor is committed to the welfare of our employees and the workers of our suppliers and contractors. Poor working conditions, being fearful or reluctant to discuss work or living conditions, inability to speak for themselves, and lack of access to personal identification papers are all potential signs of modern slavery. If you suspect someone is a victim of modern slavery, raise your concern to the site manager or the senior Fluor person on site. Additionally, you can report the concern to Corporate Compliance, HSE, or via our Compliance & Ethics Integrity Portal & Hotline.

                    Was this answer helpful?

                    Thank you, your feedback has been sent!
                    Relevant Policies & Resources

                    IMPORTANT NOTICE - DISCLAIMER

                    THE FOLLOWING COMPANY POLICIES ARE A GUIDE TO GENERAL EMPLOYMENT PROCEDURES AND POLICIES OF THE COMPANY.  THE POLICIES ARE FOR INFORMATION ONLY, AND IS NOT A CONTRACT OF EMPLOYMENT.  ANY COMPANY PROCEDURE OR POLICY MAY BE MODIFIED, AMENDED, INCREASED, DECREASED, OR DELETED BY THE COMPANY AT ANY TIME, WITH OR WITHOUT NOTICE.

                    THESE POLICIES ARE NOT AND IS NOT INTENDED TO ADDRESS EVERY POSSIBLE EMPLOYMENT/EMPLOYEE SITUATION.  THE COMPANY RESERVES THE RIGHT TO TAKE ACTION OR MAKE A DECISION WHICH IS INCONSISTENT WITH THE POLICIES TO ADDRESS UNIQUE SITUATIONS, ON A CASE-BY-CASE BASIS, IN THE COMPANY'S SOLE DISCRETION.

                    NEITHER THESE POLICIES NOR ANY OTHER MANUAL, POLICY, OR OTHER DOCUMENT ALTERS, IN ANY WAY, THE AT-WILL EMPLOYMENT STATUS OF THE COMPANY'S EMPLOYEES.  AT-WILL EMPLOYMENT MEANS THAT EITHER YOU OR COMPANY CAN TERMINATE THE EMPLOYMENT RELATIONSHIP AT ANY TIME, FOR ANY OR NO REASON, WITH OR WITHOUT CAUSE, AND WITH OR WITHOUT NOTICE, SUBJECT TO RESTRICTIONS UNDER ANY APPLICABLE LAW.  THE AT-WILL EMPLOYMENT STATUS OF EACH EMPLOYEE CANNOT BE ALTERED BY ANY ORAL STATEMENT OR ALLEGED ORAL AGREEMENT,  IT CAN ONLY BE CHANGED BY A LEGALLY BINDING, WRITTEN CONTRACT COVERING EMPLOYMENT STATUS. 

                    Note: Your Edge or Chrome web browser must be open to an active session of OneFluor to directly access some of these resources.

                    Can't find what you are looking for?

                    Our Compliance and Ethics team here at Fluor are here for you. Please reach out if you are unsure or have any questions about our Code of Conduct or your responsibilities as a team member.

                    Contact Us     Frequently Asked Questions     Ask a Question

                    All Rights Reserved