U.S. Government Contracting

A SUPPLEMENT TO

Fluor's Code of Business Conduct & Ethics

for employees working on projects where the U.S. Government is involved.

Message From Group President

Adhering to our Code of Business Conduct and Ethics (Code) and our Core Values of safety, integrity, teamwork and excellence provide the foundation for everything we do and will always serve us well. Not only do they govern the way we approach and execute work, but also the way we interact with others.

The U.S. Government Contracting Supplement to our Code provides additional guidance and information to those working on projects where the federal government and its agencies are involved in any capacity including project funding. Rules and regulations are often stricter when the government is involved so it’s imperative that you understand and follow the Code and the guidelines outlined in this Supplement.

Introduction

This is a supplement to Fluor’s Code of Business Conduct and Ethics (“Code”). It is intended to provide special guidance and information to those of us who are involved in marketing to, selling to, contracting with and working on projects where the U.S. Government (Government) and its agencies and other entities are involved.

Many federal, state and local governments also have special rules for contracting that may vary from the standards outlined in this supplement. You must comply with applicable rules for all Government contracting, regardless of the source.

If you are involved in Government contracting, you should read, understand and follow the standards outlined in this document and Fluor’s Code (available at www.onefluor.com and www.fluor.com). Our Code covers many of the common business policies, regulations and laws that apply to all Fluor employees. Since they are addressed in our Code, they are not necessarily restated here. Therefore, it is critical that you understand and follow our Code and this supplement.

Our subsidiaries, including Fluor Federal Solutions LLC, Fluor Federal Petroleum Operations LLC, may have more stringent policies in place. If you are working for a Fluor subsidiary, please review and follow any supplemental materials it may provide.

The U.S. Government's Rules Are Often Different

When the Government is our customer or the ultimate customer (when Fluor is a subcontractor), special laws and rules apply. These rules are considerably stricter than those that govern our work with commercial customers. In addition, when the Government provides funding for a project, it may be necessary to follow certain Government requirements.

The topics covered here are only intended as a guide. Be sure to also familiarize yourself with our Code and any federal procurement laws or regulations that pertain to your projects. If you are working on Government contracts, you must know and abide by all of these applicable policies and laws.

If you work in both the Government and commercial sectors, you must clearly understand the different rules, regulations and procedures that apply in each sector. If you have any questions or concerns about any of those materials, contact the Government Contract Manager (GCM) for your project or Mission Solutions Compliance and Ethics, or Mission Solutions Federal Cost and Pricing. Please see the “How Can I Get Help and Report Concerns?” section at the end of this supplement for helpful guidelines and contact information.

Violations of Government contracting requirements are very serious and can result in serious consequences for Fluor and the employees involved, including civil and/or criminal sanctions, and suspension or debarment of Fluor from doing Government work.

Updates and Revisions to this Code Supplement

This supplement to our Code may occasionally be updated or amended to reflect changes in laws and Fluor policies and practices. The most current and authoritative version is available at www.onefluor.com and www.fluor.com.

Choosing Third Parties Who Adhere to Our Values

Procurement Integrity

Organizational Conflicts of Interest

Accuracy of Information and Reports

Time Charging and Unallowable Costs

Change Orders

Hiring Current and Former Government Officials

Gifts, Entertainment and Business Courtesies

Lobbying and Political Activity in the Government Context

Background Checks

Insider Threats

Client Sensitive Information

Trafficking in Persons

Accompanying U.S. Armed Forces Outside the United States

Anti-Corruption

Mandatory Disclosure of Violations

How Can I Get Help and Report Concerns?

If you face an issue relating to contracts or projects where the Government is involved and need to get help or report a concern, you should normally proceed by first contacting your immediate supervisor.

However, if you are uncomfortable discussing the matter with your supervisor or their response is not adequate, you should contact:

Your local Human Resources manager

Another supervisor in your chain of command

The GCM for your project

A Company Expert

The Compliance and Ethics Integrity Portal & Hotline

Mission Solutions Compliance and Ethics

The Federal Cost and Pricing Department

In addition, you have an obligation to promptly contact any of these resources or an investigating department, if you know of or suspect misconduct, even if you are in no way involved in the misconduct itself. Investigating departments include Corporate Security, Human Resources, Law Department, Internal Audit, Industrial Relations and Health, Safety & Environment. Reporting the suspected misconduct to these resources contributes to our ethical culture and helps Fluor minimize any damage to our fellow employees, other stakeholders, company and brand. Not reporting violations of our Code or this supplement could result in discipline.

What if I am Concerned about Retaliation?

Fluor is committed to doing the right thing, and will protect you from retaliation if you report suspected illegal or unethical conduct in good faith.

Company Experts for Government Work

If you have an ethics or compliance question regarding contracts or projects where the Government is involved, you may contact Mission Solutions Compliance and Ethics at [email protected].

Or you may contact a Company Expert who is knowledgeable in each listed area for Government work. These Company Experts can help clarify policies, laws and business practices in their particular area.

If you send an email to the address that corresponds to the subject area, it will be routed to the Company Expert in that area. A list of the names of Company Experts and their telephone numbers is also available on www.onefluor.com.