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Frequently Asked Questions

Getting Help and Reporting Concerns

    Fluor provides several different reporting channels, which include confidentiality and escalation measures. Since you do not feel comfortable raising this concern involving your department head, you may report this concern to your local Human Resources manager, the Law Department, or Fluor’s Compliance and Ethics Integrity Portal & Hotline. If a report is made in good faith, Fluor will not tolerate any form of retaliation even if the concern turns out to be unsubstantiated.

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    Treating Your Fellow Employees Fairly

      Fluor will not tolerate discrimination or harassment of any kind in our workplace. This global standard won’t be compromised. All employees must be treated fairly and with respect regardless of location.

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      You should contact your supervisor or your local Human Resources manager so that the company can conduct a proper investigation to determine if age discrimination has occurred in practice, not just in conversation. Fluor makes promotion decisions based on a person’s skills, knowledge and ability. The company will not permit retaliation for reporting problems in good faith.

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      You should discuss the matter with your supervisor and/or your local Human Resources manager and tactfully tell the client that you are not comfortable with his apparent advances and that you wish to keep the relationship purely professional.

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      While the company does not attempt to regulate employees’ private behavior, the situation you describe takes place on company property, on company time and on a company email system. Company assets should not be used for this purpose. This unprofessional behavior does not fit in our workplace, even in the privacy of your office.

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      Health, Safety & Environmental Protection (HSE)

        No. Even if the client pressures you to “just get the job done,” do not proceed. Stop work and determine an appropriate means to prevent the employee from falling. Precautionary measures to protect the well-being of our employees must never be compromised. Schedule and budget impacts are never good reasons to put an employee in harm’s way.

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        Yes. Always report all incidents and near misses. Your injury could get worse if not treated early on, and the uneven step could cause more severe incidents if not reported and corrected. You will never be disciplined for making a good faith report of an incident or near miss, whereas you may be subject to disciplinary action if you do not report.

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        Ensuring Proper Financial Controls & Transparency

          You should first try to explain your concern to your project manager to make sure he or she understands the problem. If this does not resolve the problem, you should report the matter to one of the resources listed in “Getting Help and Reporting Concerns.” Don’t fear retaliation for making a report in good faith.

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          No. You have come across inside information through your work for our company. Insider trading laws prohibit trading the securities of our company or any other company involved on the basis of such inside information. You should check with the Law Department for further guidance.

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          Only designated spokespersons may speak about the company’s financial status. Fluor’s policy is never to comment on market rumors. You should politely tell the analyst you are prohibited from speaking about such matters and direct them immediately to the Investor Relations Department.

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          Avoiding and Resolving Conflicts of Interest

            Possibly. Working for a Fluor supplier while being employed by our company could create a situation in which a conflict of interest might arise. Before doing any work on behalf of this Fluor supplier, you must first consult with and get authorization from your supervisor or Human Resources manager. If you are permitted to continue working with the supplier, remember that the second job should not interfere with your responsibilities or job duties for Fluor. You should not do work for the other company when you are supposed to be working for Fluor. Please also remember that you cannot use Fluor equipment or supplies in your work for the other company. That includes computer equipment, electronic mail and telephones. You must also carefully guard against disclosing confidential information to the other company.

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            You shouldn’t do anything to help your spouse’s company get the contract. If you are involved in the selection process, you should tell your manager and remove yourself from the situation. Helping your spouse’s company is a conflict of interest. Even if you are certain you can be unbiased and award the contract to the best bidder, you should not be involved because of the perception of a conflict of interest.

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            Probably not. If the full costs directly relate to a legitimate business purpose and are not excessive, and your supervisor has approved the business trip, then it is not problematic. Additional review and documentation by the Law Department will be required if a government entity or official is involved.

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            You must be cautious before accepting gifts and entertainment from suppliers and subcontractors, particularly during a proposal or competitive bidding process. This entertainment likely involves unusual features, for example, an event with a significant market value, duration exceeding one day, complimentary overnight accommodations and out-of-town travel. If you strongly believe attending the tournament is important for the business relationship, and it is not during a proposal process, consult with your supervisor to determine what is appropriate.

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            Before sending a gift to or entertaining a client, you should check the client’s requirements or limitations with regard to receiving gifts and entertainment. You don’t want to put the recipient in a tight spot. Generally a gift basket at the holidays would not present a problem, as long as it is reasonable for the industry and your function and position. If you have any doubt, ask your supervisor or Human Resources manager. Be sure to follow all applicable approval and expense processes. If the client involves a government entity or official, consultation with the Law Department and prior approval from your supervisor are always required.

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            We always want to be transparent with our clients. While it may be necessary to purchase the equipment from our subsidiary, we should disclose the situation to the client first.

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            Probably not. A supplier discount is only acceptable if it is available to all Fluor employees. If the discount is offered only to you, then it is not appropriate. This situation could be a problem from a variety of perspectives: an improper gift, an attempt to influence Fluor business decisions, and an appearance problem.

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            Doing Business Globally

              No. You may not approve reimbursement for the customer’s nonbusiness-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.

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              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.

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              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.

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              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.

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              Protecting Company Assets

                No. It’s never okay to use company or client computers or network systems to view or forward inappropriate emails, even if you’re alone in the office, at home or on a business trip, or you are forwarding the email to someone who is not employed by Fluor. This is an inappropriate use of company time and resources and may result in disciplinary action up to and including termination.

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                While Fluor-related community and charitable initiatives are permitted and important to the company, you should promptly inform your supervisor that it is impairing your ability to complete your work to determine how to proceed. Only your supervisor can decide whether or not you should continue working on the community project.

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                You may need permission from the client to use project site photographs. In addition, you may need to obtain permission from the photographer and any other companies whose logos may be depicted in the photographs. Individuals also have the right to consent how their images are being used.

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                You should immediately file a police report and ask for a copy. Then immediately contact Fluor Corporate Security with a copy of the police report and Fluor Information Security to report the theft. Familiarize yourself with Fluor’s IT Security Policies. You should never keep your passwords with your laptop or other password-protected devices. In addition, you should not store any personal information (such as social security numbers or credit card information) on your computer unless it is encrypted.

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                No. It is against our Code and company policy to publicly post confidential or proprietary information on social media sites, including message boards or chat rooms. Doing so may subject the individuals involved and our company to reputational damage and civil or criminal fines. Since information about this project is nonpublic, you should not comment on it.

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                Competing Fairly in the Marketplace

                  Probably not. Proposal costs may only be reimbursed if the process is fully transparent and acceptable to the prospective client. Typically, any reimbursement for bidding expenses is made by the prospective client.

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                  Engaging in Lobbying in Political Activities

                    Company resources cannot be used for personal political activities. This includes the resources to express mail a personal check and the involvement of your assistant.

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                    No. You may never seek corporate reimbursement for political contributions or for expenses tied to political fundraising events. Before participating, you should consult Fluor’s head of Government Relations.

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                    You should inform the mayor that Fluor has an established practice for reviewing and approving corporate contributions and that the contribution decision is not yours. You should then report the request to the head of Government Relations for review.

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                    U.S. Gov't Contracting Supplemental Code

                      First, do not open the email. There are clear indicators in this message that it contains competition-sensitive source selection information, which means it is restricted for authorized Government personnel. You should not reply to or forward the message, and promptly notify your supervisor and the Mission Solutions Law Department for proper handling instructions.

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                      It may. The Government contracting officer may believe our design work gives us an unfair competitive advantage in the build phase of this project. If so, we need to be prepared to demonstrate that our design does not favor us in the competition, or to show how the playing field can be leveled to neutralize any advantage that we might derive from our design work. In future procurements of this type, you should consult with the Mission Solutions Law Department before seeking the design contract in order to make an informed decision as to whether the design work will create an unacceptable OCI.

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                      These two contracts might create an “impaired objectivity” OCI. That is, FEMA may believe that one part of the company can’t be relied on to be objective in evaluating the work of another part of the company. If there is an OCI, we may need to make a business decision as to which contract to seek, or to develop a plan to neutralize or avoid the OCI. You should consult with your supervisor, the Mission Solutions Law Department and the leadership of the other group that is interested in the FEMA support contract immediately.

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                      No. You may not even mention or hint at the possibility to the Government employee. Check with the Mission Solutions Human Resources Department and Mission Solutions Law Department for advice first.

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                      It is possible to have a personal relationship with employees of Government agencies, and you may invite the couple to your home for dinner. However, taking them out to a restaurant or providing a catered dinner at your house would not be acceptable, since it might bring his objectivity into question or create the appearance that you are attempting to influence him.

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                      It is probably acceptable. The cost of the trophy is not the measure of its value—the intrinsic value of the trophy or the trophy materials becomes the measure. If the trophy has no market value, and contains no materials that have intrinsic value (such as crystal or precious metals), then it is excluded from the definition of a gift. If you are unsure whether you should provide anything of value to a Government employee, you should seek guidance from the GCM for your project, Mission Solutions Compliance and Ethics or Mission Solutions Law Department.

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                      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.

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