Compliance & Ethics Hotline
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Common Questions and Answers for Employees

ABOUT NAVEX Global

REPORTING – GENERAL

TIPS & BEST PRACTICES


ABOUT NAVEX Global

Who is NAVEX Global?

NAVEX Global is an independent third party provider to Fluor. Fluor has contracted with NAVEX Global to provide the Fluor Compliance and Ethics Hotline. The NAVEX system is a comprehensive and confidential reporting tool to assist management and employees in working together to address any potential violations of the Fluor Code of Business Conduct and Ethics, company policy or law. You can also seek guidance or ask a compliance and ethics related question through this system.

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REPORTING – GENERAL

May I report using either the Internet or the telephone?

Yes. The Fluor Compliance and Ethics Hotline gives you the ability to file a confidential, anonymous report via either the telephone or the Internet.

What type of situations should I report?

The Fluor hotline is designed for employees to report any known or suspected violation of our Code of Business Conduct and Ethics, company policy, law, or other concerns you may have.

What happens when I contact the Fluor Compliance and Ethics Hotline?

Fluor’s Compliance and Ethics Hotline is available 24 hours a day, seven days a week. Reports may be made in more than 150 languages. NAVEX Global, a third party administers our Hotline, including web-based reports. For Hotline calls, the third-party call center answers these calls and transcribes the information you report. Caller ID is never used and there will be no effort to trace your call. You may report anonymously, where local law permits. However, keep in mind that the more information you provide, the easier it will be for the company to investigate and appropriately respond to your report.

How are reports handled at Fluor? Where do these reports go? Who can access them?

Fluor investigates all Hotline reports and is committed to maintaining confidentiality to the maximum extent possible. The company will disclose the information you provide only on a strict need-to-know basis. Further information on how Fluor handles Hotline reports can be found in HR 705 and HR 705 EU.

Reports are entered directly to a NAVEX Global secure server to prevent any possible breach in security. NAVEX Global makes these reports available only to specific individuals within the company who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

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TIPS & BEST PRACTICES

I am not sure if what I have observed or heard is a violation of company policy or involves unethical conduct, but it just does not look right to me. What should I do?

Seek guidance If you are ever unsure about the right thing to do in a business situation, you should seek guidance. If appropriate, you should discuss the question or concern directly with the person involved. You are also encouraged to contact your immediate supervisor. However, if you are uncomfortable discussing the matter with your supervisor or his or her response is not adequate, you should contact:

  • Your local Human Resources manager
  • Your Industrial Relations manager
  • Your supervisor’s supervisor (and up the reporting structure as necessary)
  • A Fluor Subject Matter Expert

You can also file a report through the Fluor Compliance and Ethics Hotline. We would rather you report a situation that turns out to be harmless than let possibly unethical behavior go unchecked because you were unsure.

What if I remember something important about the incident after I file the report?

When you file a report, either using the Internet or telephone, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to the Fluor Compliance and Ethics hotline again, either by Internet or telephone, and access the original report. At that point, you can add more details.

What if you have questions for me concerning my report?

The Fluor Compliance and Ethics Hotline provider, NAVEX Global, provides a functionality that enables company representatives to post questions for you, even if you report anonymously. When you receive your report key, you will be provided with the amount of time we expect for the report to be processed. When that time has passed, we strongly suggest you check to see if any questions have been posted. Providing the opportunity for such anonymous dialogue means situations may not only be identified but can also be resolved, no matter how complex.

What if I am concerned about retaliation?

Fluor will not tolerate any form of direct or indirect retaliation that arises from reporting suspected illegal or unethical conduct in good faith. If a report is made in good faith, you will be protected even if the concern turns out to be unsubstantiated. If you suspect you are experiencing retaliation, you should contact Human Resources or Fluor’s Compliance and Ethics Hotline. Retaliating against someone who makes a report in good faith will result in prompt and strong disciplinary action, up to and including termination.

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