defence companies anti-corruption index - final...

JACOBS ENGINEERING 04/08/14 HTTP://WWW.JACOBS.COM/

FINAL ASSESSMENT

JACOBS ENGINEERING GROUP INC

The following pages contain the detailed scoring for your company based on

public information.

The following table represents a summary of your scores:

Topic Number of

questions

% score based

on public

information

Leadership, Governance and

Organisation

10 30%

Risk Management 5 60%

Company Policy and Codes 12 75%

Training 5 60%

Personnel and Helplines 7 64.3%

Total 39 57.7%

TI understands that the company is not involved in offsets and has therefore removed the two relevant

questions (A13a and A13b).


A1:

Does the company publish a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company?

Score:

2

Comments:

Based on public information, there is evidence that the company publishes statements from the Chief Executive Officer supporting the ethics and integrity agenda of the company. These appear on the website, in the 2013 annual report and as an introduction to the Code of Ethics, where anti- corruption is directly mentioned.

References:

Public:

Company Website: About

‘Ethics are the foundation of our relationships. Our integrity drives the trust that our relationship-based business model is built on — Craig L. Martin, President and CEO’

http://www.jacobs.com/workforus/about/

2013 Summary Annual Report, p.2:

‘Making it matter is how we approach our safety culture, our relationships with clients, our high level of quality, our focus on ethics and integrity, and our company’s growth. These things are important to all of us; over the past year we continued to strive for excellence in each of these areas, and our business performed well.’

http://invest.jacobs.com/files/doc_financials/summary/Jacobs2013AnnualReport.pdf

Anti-corruption Guidelines (July 2011), p.1:

‘Message from the CEO

Integrity and ethical behavior are at the heart of our core values and our approach to business, and over the years we have earned an industry-wide reputation for being an ethical company. Clients frequently tell us they choose to work with Jacobs, not just because of our capabilities and global reach, but because of our ethics and integrity.

A large part of our success depends on the way we conduct business and how the public

http://www.jacobs.com/workforus/about/



perceives that conduct. It doesn’t matter what others in our business do — we choose to do the right thing and follow the rules. Jacobs employees are expected to adhere to a high standard of business conduct and ethical standards. Each of us, individually, sets the ethical standard for the company. Cumulatively, our ethics become Jacobs’ ethics. Unethical actions or the appearance of unethical actions are not acceptable. If unethical behavior results in getting preference from a customer, we don’t want to work for that customer.

Governments worldwide are increasing their focus on issues of bribery and corruption, putting new laws into place, and aggressively pursuing violators — and penalties for offenses are severe. We are expected to comply with these standards regardless of where our business transactions take place. For this reason, even though laws may vary from country to country, our official company policies serve as a global standard for employee conduct. Although these requirements have been in our standards of conduct for some time, we’ve issued a new Anti-Corruption Policy to ensure our employees and business partners are absolutely clear on what is expected of them. Any employee who fails to comply with these requirements can be disciplined or even terminated.

We have also created this Anti-Corruption Guidelines document to provide guidance in making the right decisions. For a company like ours that does business all over the world in different countries with different laws and cultural customs, there may be uncertainty about

how to handle a particular situation. is document explains the responsibilities of our employees, lists available resources, outlines risks and red flags to watch out for, and more.

Many issues develop because someone doesn’t understand proper behavior for a given situation. If there is any concern about the ethical or legal conduct of our company or that of our partners, subcontractors, or suppliers, it is critical to seek help. And if an employee observes behavior or activity that is questionable, it needs to be reported. To observe behavior that violates our policies but not report it is also a violation of our policies.

Corruption issues aren’t always clear-cut, but our zero-tolerance approach to them is. We offer a variety of resources including these guidelines to help you address questionable situations and avoid negative consequences — please use them.’

http://www.jacobs.com/uploadedFiles/wwwjacobscom/20_Work_for_us/22_About/223_Integrity_and_Ethics/Anti-Corruption%20Guidelines.pdf




A2:

Does the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company?

Score:

1

Comments:

Based on public information, there is some evidence that the company’s Chief Executive Officer demonstrates a strong personal, external-facing commitment to the ethics and anti-corruption agenda of the company. He delivered a public speech on the importance of ethics but no other similar or related events/instances have been found.

References:

Public:

University of Kansas website: Jacobs Engineering Leader to Examine Ethics With Students

‘“As students who are soon to be engineers working in real-world situations, it’s important that they develop their thinking on ethical issues. Their day-to-day responsibilities are going to involve delivering complex projects for clients under pressure to meet demanding expectations in terms of cost and schedule,” Martin said. “It takes courage and conviction to put ethical considerations at the forefront of their work and to never be complacent about integrity or sacrifice their principles.”

Martin joined Jacobs in 1994, was named president in 2002 and became its CEO in 2006. With more than 65,000 employees worldwide, Jacobs is one of the largest technical professional and construction services firms in the world. It provides architecture, engineering and construction support, as well as scientific and specialty consulting, to industrial, commercial and government clients.

"Our ethics define who we are professionally and personally,” Martin said. “At Jacobs, we have core values that guide our decision-making, and we have lots of way to get help if someone is uncertain about the right thing to do. The key is to be transparent and to always surface ethical concerns so you can deal with them.”’

http://www.engr.ku.edu/news/2013-11-6/jacobs-engineering-leader-examine-ethics-students

Video of Speech: https://www.youtube.com/watch?v=4PxRpgW8e9Q



https://www.youtube.com/watch?v=4PxRpgW8e9Q


A3:

Does the company’s Chief Executive Officer demonstrate a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company through, for example, direct involvement with the staff on ethics or speaking at training events.

References:

Public:

NA


A4:

Does the company publish a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability?

Score:

2

Comments:

Based on public information, there is evidence that the company publishes a statement of values representing high standards of ethical business conduct, including honesty, trust, transparency and integrity. These values are described on the company website and throughout company documents, such as the Annual Report, the Code of Conduct and the Anti-Corruption Guidelines.

References:

Public:

Company website: About ‘Over decades of consistent behavior guided by our core values, we have earned a reputation as an ethical company. We make decisions with fairness, honesty and integrity, holding ourselves and our colleagues accountable for high standards of conduct on each job we do throughout the world.

Our Code of Conduct is a useful guide for all our employees and directors worldwide that outlines our collective commitment to our values and beliefs, and helps us exercise ethical decision making and good judgment – even in difficult situations.

We also expect the companies we partner with to operate with a high level of integrity, and our corresponding Supplier Code of Conduct is applicable to those in our supply chain. We encourage our employees and suppliers to ask questions when in doubt and report violations, which they can do via an email address or our Integrity Hotline (1.877.522.6272).

Most recently and for the second time since 2010, Jacobs has been named one of America’s Most Trustworthy Companies by Forbes Magazine. In the large-cap category, Jacobs is one of only 14 firms featured and the only engineering and construction company featured in the large cap category.’

http://www.jacobs.com/workforus/about/index.aspx#Ethics

2013 Summary Annual Report, p.5:

‘Jacobs has a longstanding and powerful culture of transparency, honesty, and integrity,



which fosters clear and open expectations of the highest professional standards. That accumulates over time into strong, trusting relationships; among Jacobs project teams, and between Jacobs and the client.

Our ethics and integrity are what drive the trust that our relationship-based business model is built on. Our commitment to that trust and integrity keep us connected, no matter the circumstances, to the ethics that are so important to us as a company.

Ethics are the foundation of our relationships. Without them we could not build the strong, long-term relationships that contribute to successful project outcomes for our clients.’

Seven Principles of Sustainability (March 2014)

‘We are open and transparent, responding to concerns as they arise

Transparency is critical to running an ethical business. We foster dialogue on issues of sustainable development and are responsive to concerns raised about our practices. We measure our performance, present a periodic progress report to our Board of Directors, and provide annual reporting as part of our public disclosure’

http://www.jacobs.com/uploadedFiles/wwwjacobscom/10_Work_with_us/11_Our_approach/112_Sustainability/7%20Principles%20of%20Sustainability.pdf

Anti-Corruption Guidelines (2011), p.1:

‘Integrity and ethical behavior are at the heart of our core values and our approach to business, and over the years we have earned an industry-wide reputation for being an ethical company. Clients frequently tell us they choose to work with Jacobs, not just because of our capabilities and global reach, but because of our ethics and integrity.’

Code of Conduct (May 2013), p.4:

‘Jacobs brings many assets to the table when we work with clients. We offer our expertise, our years of experience, our technical skills and knowledge, and our reputation, which has been earned over decades of living out the values of fairness, honesty, and ethical behavior.’

(p.7): ‘Integrity

Know the rules and your responsibilities. If unsure, ask before you act’

(p.28): ‘Thank you to each and every employee for your commitment to excellence, and for helping us maintain the trust of our clients and business associates. We value your contributions to Jacobs’ ongoing success.’

http://invest.jacobs.com/files/doc_downloads/governance/Jacobs%20Code%20of%20Conduct.pdf






A5:

Does the company belong to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company belongs to any national or international initiatives that promote anti-corruption or business ethics.

References:

Public:

NA


A6:

Has the company appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda?

Score:

1

Comments:

Based on public information, there is some evidence that the company has appointed a Board governed Audit Committee with overall corporate responsibility for its ethics agenda. However, the terms of reference in regard to matters of anti-corruption are not clear. The company therefore scores 1.

References:

Public:

Audit Committee Charter (November 2013), p.5:

‘Compliance Oversight Responsibilities

23. Obtain reports from management, the Company’s senior internal auditing executive and the independent auditor that the Company and its subsidiary/foreign affiliated entities are in conformity with applicable legal requirements and the Company’s Code of Business Conduct and Ethics. Advise the Board with respect to the Company’s policies and procedures regarding compliance with applicable laws and regulations and with the Company’s Code of Business Conduct and Ethics’

http://invest.jacobs.com/files/doc_downloads/governance/new/Audit%20Committee%20Charter_11_21_13_final.pdf

Company Website: Corporate Governance

‘Purpose: Chaired by Joseph R. Bronson, the Audit Committee assists our Board in overseeing the integrity of our financial statements, verifying our compliance with legal and regulatory requirements, and supervising the performance of our internal audit function.’

http://invest.jacobs.com/investors/default.aspx#gov





A7:

Has the company appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda.

References:

Public:

NA


A8:

Is there regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda?

Score:

0

Comments:

Based on public information, there is little evidence of regular monitoring of the performance of the company’s ethics and anti-corruption agenda and no readily available evidence of major reviews conducted at least annually.

References:

Public:

TI notes:

Audit Committee Charter (November 2013), p.5:

‘Compliance Oversight Responsibilities

23. Obtain reports from management, the Company’s senior internal auditing executive and the independent auditor that the Company and its subsidiary/foreign affiliated entities are in conformity with applicable legal requirements and the Company’s Code of Business Conduct and Ethics. Advise the Board with respect to the Company’s policies and procedures regarding compliance with applicable laws and regulations and with the Company’s Code of Business Conduct and Ethics’

Company Website: Corporate Governance

‘Purpose: Chaired by Joseph R. Bronson, the Audit Committee assists our Board in overseeing the integrity of our financial statements, verifying our compliance with legal and regulatory requirements, and supervising the performance of our internal audit function.’




A8(a):

Is there a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and evidence of improvement plans being implemented when issues are identified?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company has a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based.

References:

Public:

NA


A9:

Does the company have a formal process for review and where appropriate update its policies and practices in response to actual or alleged instances of corruption?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

References:

Public:

NA


A9(a):

Does the company have a formal anti-corruption risk assessment procedure implemented enterprise-wide?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure implemented enterprise-wide. The Sustainability Report states that business units are analysed for corruption risk, but there is no further detail provided about this process or evidence of mitigation plans being put in place.

References:

Public:

TI notes:

2013 Sustainability Report, p.70:

‘Percentage and total number of business units analyzed for risks related to corruption. (Core)’

http://invest.jacobs.com/files/doc_downloads/sustainability/Jacobs_2013_Sustainability_Report.pdf




A10:

Does the company have a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied?

Score:

1

Comments:

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for mergers and acquisitions. The company states it has a complex due diligence process for mergers and acquisitions, which is much broader than just bribery and corruption. The company therefore scores 1. To score higher, the company would need to provide further information of the due diligence process for mergers and acquisitions or evidence of anti-corruption risk assessment procedures for other proposed business decisions.

References:

Public:


‘Percentage and total number of business units analyzed for risks related to corruption. (Core)’

Anti-corruption guidelines (April 2014), p.18:

‘Q: Are the procedures for a merger or acquisition the same as those for hiring a representative or subcontractor?

A: No, mergers and acquisitions present their own set of challenges, since they involve companies that will become part of Jacobs.

The review process is complex and entails a due diligence process much broader than just bribery and corruption. If you are asked to participate in an M&A review, you will be provided specific instructions on what to do.’


A11:

Does the company conduct due diligence that minimises corruption risk when selecting or reappointing its agents?

Score:

1

Comments:

Based on public information, there is evidence that the company conducts detailed due diligence that minimises corruption risk when selecting or reappointing its agents. The company therefore scores 1. To score higher the company would need to provide evidence that the company refreshes the due diligence at least every 3 years and/or when there is a significant change in the business relationship.

References:

Public:

Anti-Corruption Guidelines (April 2011), p.19:

‘Selecting & Monitoring Representatives & Agents

When choosing a subcontractor or representative, make sure you follow all relevant Jacobs policies. That means considering not just the business qualifications of possible partners but also their record of integrity. Our policy includes a multi-tier due-diligence process based on risk.

Generally, representatives fall into two categories: sales and all other representatives.

First are sales representatives who work alongside sales staff helping Jacobs develop relationships and learn about business opportunities. The risks here are high, since unscrupulous agents could bribe government officials or others associated with our business interests on Jacobs’ behalf. Extensive screening and due diligence are necessary before agreeing to any contract.

Our procedure Appointment of Sales Representatives defines six stages in the process of selecting commercial sales representatives:

Developing a detailed business justification

Completing background and due diligence investigations

Evaluating due diligence results

Negotiating agreements containing appropriate terms and conditions

Reviewing and approving the agreement

Monitoring and performance oversight’



‘Agents and representatives.

Before we form a relationship, we must obtain internal approvals and exercise due diligence on the backgrounds and business practices of individuals who we intend will act on our behalf.’


A12:

Does the company have contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.

References:

Public:

Anti-Corruption Guidelines (2011), pp.18-19:

‘Selecting & Monitoring Representatives & Agents

When choosing a subcontractor or representative, make sure you follow all relevant Jacobs policies. That means considering not just the business qualifications of possible partners but also their record of integrity. Our policy includes a multi-tier due-diligence process based on risk.

Generally, representatives fall into two categories: sales and all other representatives.

First are sales representatives who work alongside sales staff helping Jacobs develop relationships and learn about business opportunities. The risks here are high, since unscrupulous agents could bribe government officials or others associated with our business interests on Jacobs’ behalf. Extensive screening and due diligence are necessary before agreeing to any contract.

Our procedure Appointment of Sales Representatives defines six stages in the process of selecting commercial sales representatives:

Developing a detailed business justification

Completing background and due diligence investigations

Evaluating due diligence results

Negotiating agreements containing appropriate terms and conditions

Reviewing and approving the agreement

Monitoring and performance oversight’


(p.19): ‘Conditions of Working with Jacobs

Jacobs has certain ways of doing business with which it requires agents to comply. The company must have written agreements with all representatives. The agreements will be written using Jacobs’ standard terms — this is an important condition of doing business. If a representative refuses to agree to Jacobs’ terms, this should be a red flag and should make you question the choice of this partner.’

Best Practices for Hiring Representatives

Make sure the following provisions are in place before you hire a representative:

The representative is an independent contractor and not an employer, officer, or representative of any government

The representative is aware of the requirements of Jacobs policy and other relevant laws and agrees to comply

The representative agrees to notify Jacobs if his or her status changes in any way that would violate policy — for example, if a member of his or her family becomes a government official

The representative agrees to keep accurate records that show expenses, the person to whom any payment was made, and a description of services provided Jacobs has the right to audit the representative’s books and records’


A13:

Does the company make clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance?

Score:

2

Comments:

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption. The Supplier Code of Conduct states suppliers must comply with the company’s anti-corruption policy. The Anti-Corruption Guidelines detail that the company will monitor the performance of suppliers and taken action when appropriate, suggesting contractual rights to apply sanctions in the event of a breach of the contract.

References:

Public: Supplier Code of Conduct (October 2013), p.2: ‘4. Bribery and Corruption Jacobs wins and executes projects honestly and ethically and chooses its suppliers based on the quality and value of goods and services being offered. It is Jacobs’ policy to never solicit or accept gifts that may influence or seem to influence a Jacobs employee’s decision in the selection of a bidder for the supply of goods or services. When working with Jacobs you must be aware of and comply with our anti-corruption policy and the anti-corruption laws of the countries in which we do business. The following actions are strictly prohibited by our suppliers:

Offering or accepting any form of bribe, kickback, or payoff intended to influence a business decision

Offering lavish gifts, entertainment or travel to any Jacobs employee

Offering employment opportunities to family members of Jacobs representatives’ http://www.jacobs.com/uploadedFiles/wwwjacobscom/20_Work_for_us/22_About/223_Integrity_and_Ethics/Jacobs%20Supplier%20Code%20of%20Conduct%20Final%20Rev0_11-18-13.pdf


‘The second category includes all other representatives. This category covers

http://www.jacobs.com/uploadedFiles/wwwjacobscom/20_Work_for_us/22_About/223_Integrity_and_Ethics/Jacobs%20Supplier%20Code%20of%20Conduct%20Final%20Rev0_11-18-13.pdf




subcontractors, suppliers, vendors, and other consultants. They provide a variety of commodities, supplies, and services including legal and accounting services, travel arrangements, printing, etc. Generally these firms pose less risk for the company and so the due diligence required before hiring them may be correspondingly lower. We have developed a risk-assessment process that determines the minimal amount of due diligence for these representatives.

Our procedure Third-party Intermediaries Not Engaged in Sales defines our assessment of risk through:

Country risk

Transaction risk

Business opportunity risk

Business partnership risk Through our Supply Management procedures we check out vendors and subcontractors who work for us. They must agree to comply with our standards. We monitor their performance and take action when appropriate. Due diligence of this group requires some type of government official interface. The department responsible for the relationship must achieve appropriate due diligence using internal resources or with the assistance of a qualified service provider. What’s important is that you assess the risk level posed by different contractors before you hire them and take the appropriate steps to manage that risk. As the relationship with the firm continues, your responsibility to monitor the business also continues. Is the firm acting within the scope of authority granted by Jacobs? Are they behaving with integrity and following our policies?

Company website: Integrity and Ethics

‘We also expect the companies we partner with to operate with a high level of integrity, and our corresponding Supplier Code of Conduct is applicable to those in our supply chain. We encourage our employees and suppliers to ask questions when in doubt and report violations, which they can do via an email address or our Integrity Hotline (1.877.522.6272).’




A13(a):

Does the company explicitly address the corruption risks associated with offset contracting?

Score:

NA

Comments:

The company has informed TI that it does not engage in offset contracting.

References:

NA


A13(b):

Does the company conduct due diligence that minimises corruption risk when selecting its offset partners and offset brokers?

Score:

NA

Comments:

The company has informed TI that it does not engage in offset contracting.

References:

NA


A15:

Does the company have an anti-corruption policy that prohibits corruption in its various forms?

Score:

2

Comments:

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms, including facilitation payments and kickbacks.

References:

Public:

Code of Conduct (May 2013), p.21

‘At Jacobs, we develop and maintain business relationships without giving improper gifts, taking unfair competitive advantage, or receiving kickbacks. We win jobs and execute our work honestly and ethically, whether in our dealings with public entities and government officials, or the private sector. Every country in which we operate has laws against corruption. It is a crime to offer, promise, or pay anything of value to secure and maintain business or gain an improper advantage. These laws restrict us in giving business courtesies to government officials. Anything of value can be a bribe or create the false impression of a bribe. Keep in mind that even the perception of corruption harms our reputation, and we strive to avoid even the appearance of wrong-doing.’

‘Payments made to expedite routine government actions—known as facilitation payments—are prohibited.’

‘Accepting gifts and courtesies. Accepting small memorabilia, or promotional or token items of nominal value should not cause problems. Multiple items, group events, travel, or entertainment that can be considered lavish or extravagant must be reported to a manager, Company counsel, or the compliance officer. Gifts must be infrequent, transparent, and received with no obligation or expectation for a reciprocal action.’


‘At its core, our policy is simple: The company, its employees, and representatives are


forbidden from promising, offering, giving or accepting anything of value — money, gifts, meals, or services — to gain or retain an improper advantage in business dealings. This prohibition also bars anyone from abusing a position of trust to gain an undue advantage.

These acts are not only illegal but are wholly contrary to our values. Violations can have serious civil and criminal consequences to our company and our employees.’

(p.4): ‘Do Not Promise, Offer, or Accept Bribes

It’s simple: Don’t offer cash or gifts in exchange for business, and don’t accept cash or gifts yourself.’

‘If Asked for a Bribe, Refuse

If anyone asks you for special gifts, entertainment, or contributions, or solicits you for a payment in exchange for a perceived business advantage, you must immediately refuse. Explain that your refusal is absolute and that Jacobs does not make such payments. Immediately report the request to your supervisor, Jacobs management, Jacobs legal counsel, the Corporate Compliance Officer, or the Integrity Hotline.’


A16:

Is the anti-corruption policy explicitly one of zero tolerance?

Score:

2

Comments:

Based on public information, there is evidence that the company’s anti-corruption policy is explicitly one of zero tolerance.

References:

Public:

Code of Conduct (May 2013), p.21

‘At Jacobs, we develop and maintain business relationships without giving improper gifts, taking unfair competitive advantage, or receiving kickbacks. We win jobs and execute our work honestly and ethically, whether in our dealings with public entities and government officials, or the private sector. Every country in which we operate has laws against corruption. It is a crime to offer, promise, or pay anything of value to secure and maintain business or gain an improper advantage. These laws restrict us in giving business courtesies to government officials. Anything of value can be a bribe or create the false impression of a bribe. Keep in mind that even the perception of corruption harms our reputation, and we strive to avoid even the appearance of wrong-doing.’

‘Payments made to expedite routine government actions—known as facilitation payments—are prohibited.’

‘Accepting gifts and courtesies. Accepting small memorabilia, or promotional or token items of nominal value should not cause problems. Multiple items, group events, travel, or entertainment that can be considered lavish or extravagant must be reported to a manager, Company counsel, or the compliance officer. Gifts must be infrequent, transparent, and received with no obligation or expectation for a reciprocal action.’


‘Corruption issues aren’t always clear-cut, but our zero-tolerance approach to them is.’

(p.2): ‘At its core, our policy is simple: The company, its employees, and representatives are


forbidden from promising, offering, giving or accepting anything of value — money, gifts, meals, or services — to gain or retain an improper advantage in business dealings. This prohibition also bars anyone from abusing a position of trust to gain an undue advantage.

These acts are not only illegal but are wholly contrary to our values. Violations can have serious civil and criminal consequences to our company and our employees.’


A17:

Is the company's anti-corruption policy easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company?

Score:

1

Comments:

Based on public information, there is evidence that the Anti-corruption Guidelines and associated documents are easily accessible online. However, TI notes that the company’s documentation only appears to be available in English. The company therefore scores 1.

References:

Public:

Code of Conduct (May 2013):

http://invest.jacobs.com/files/doc_downloads/governance/BusinessConductPolicyUS.pdf

Anti-corruption Guidelines (2011):



‘New employee orientation includes foundation training for all employees on our business code of conduct. Each year our staff employees are required to review the business code of conduct and reaffirm their understanding.’

http://invest.jacobs.com/files/doc_downloads/governance/BusinessConductPolicyUS.pdf




A17(a):

Is the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties?

Score:

2

Comments:

Based on public information, there is evidence that the Anti-Corruption Guidelines and associated documents are written in accessible, comprehensible language.

References:

Public:

Code of Conduct (May 2013).Anti-corruption Guidelines (2011).

Supplier Code of Conduct (October 2013).


A18:

Does the anti-corruption policy explicitly apply to all employees and

members of the Board?

Score:

2

Comments:

Based on public information, there is evidence that the Code of Conduct explicitly applies to all employees and Board members. TI notes that the company also has a Code of Business Conduct and Ethics for Board Members that contains details specific to Board members.

References:

Public:


‘Everyone at Jacobs—from the Board of Directors to our newest employee—is bound by this Code.’

(p.6): ‘Who must obey the Code of Conduct?

Every employee, director, and officer of the company; anywhere in the world. This also includes majority-owned subsidiaries. Particular aspects of the code may also apply to agents, consultants, business partners, vendors, and subcontractors.’

Code of Business Conduct and Ethics for Board of Directors (March 2014):

http://invest.jacobs.com/files/doc_downloads/governance/BOD%20Conduct%20Code.pdf



A20:

Does the company have a policy on potential conflicts of interest, and does it apply to both employees and board members?

Score:

2

Comments:

Based on public information, there is evidence that the company has a policy on potential conflicts of interest, applicable to both employees and board members, which contains a definition and relevant examples.

References:

Public:


‘A conflict of interest is defined as a circumstance that creates a risk that professional judgment or actions will be unduly influenced by a secondary interest, usually personal. In other words, a situation where the interests of the company come into conflict with the interests of an individual.

You must avoid conflicts of interest that could cloud judgment, impair objectivity, and interfere with good decision-making. You should never achieve personal gain through a Company transaction or by the use of Company information. Corporate opportunities belong to the Company. Even creating an appearance of conflict should be avoided. If a conflict cannot be prevented, it must be mitigated by full disclosure. Disclosure should involve an evaluation of the situation by a disinterested party. If you find yourself in a situation that involves a potential conflict of interest, immediately contact your manager.’

‘Points to remember:

-Insider trading. Stocks or securities may not be purchased or sold using “material non-public information.” This is defined as information that a reasonable investor would consider important in making a decision and that is not known to the general public; it may be a stock tip or corporate opportunity, and its source may be from our company or another company such as a partner or subcontractor. Neither Jacobs nor client information may be used for personal gain by you or a close family member, or passed along to others.

-Business with friends or relatives. You should avoid conducting business with friends or


relatives and take care not to be influenced by secondary interests. Business with friends and relations can result in favoritism, cronyism, or nepotism and give undue advantage to someone who does not otherwise merit it. This is unfair and breaches your primary duty of loyalty to the corporation.

-Personal conflicts. You may not supervise anyone in your family, or maintain a close personal relationship with a subordinate employee. Furthermore, a family member working for a client or competitor can create a conflict of interest or the appearance of a conflict, as can having a financial interest in or receiving compensation from a competitor or supplier.

-Disclosure. You are required to fully disclose any conflicts—personal, social, political or financial—prior to entering into the relationship.’

Code of Business Conduct and Ethics for Board of Directors (March 2014), pp.2-3:

‘2. Conflict of Interest.

Directors must avoid any conflicts of interest between the director and the Company.

Any situation that involves, or may reasonably be expected to involve, a conflict of interest with the Company, should be disclosed promptly to either the Chair of the Nominating and Corporate Governance Committee or the Chair of the Audit Committee.

A "conflict of interest" can occur when a director's personal interest is adverse to – or may appear to be adverse to – the interests of the Company as a whole. Conflicts of interest also arise when a director, or a member of his or her immediate family,1 receives improper personal benefits as a result of his or her position as a director of the Company. In addition, a conflict situation can arise when a director takes actions or has interests that may make it difficult to perform his or her duties for the Company objectively and effectively.

This Code does not attempt to describe all possible conflicts of interest which could develop. Some of the more common conflicts from which directors must refrain, however, are set out below.

-Relationship of Company with third-parties. Directors may not engage in any conduct or activities that are inconsistent with the Company's best interests or that disrupt or impair the Company's relationship with any person or entity with which the Company has or proposes to enter into a business or contractual relationship.

-Compensation from non-Company sources. Directors may not accept compensation (in any form) for services performed for the Company from any source other than the Company.

-Gifts. Directors and members of their families may not accept gifts from persons or entities who deal with the Company in those cases where any such gift has more than a nominal value or where acceptance of the gifts could create the appearance of a conflict of interest.

-Personal use of Company assets. Directors may not use Company assets, labor or information for personal use unless approved by the Chair of the Nominating and Corporate Governance Committee or as part of a compensation or expense reimbursement program available to all directors.

-Financial Matters. Directors and members of their immediate family may not accept any loans from the Company nor guarantees by the Company of any obligations of the Directors or such immediate family members.’


A21:

Does the company have a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery?

Score:

1

Comments:

Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. However, the policy lacks clarity, as employees are only instructed that gifts must not be lavish or extravagant. The company therefore scores 1. To score higher the company would need to provide evidence of clear upper limits or specific thresholds necessary for senior authorisation.

References:

Public:


‘At Jacobs, we develop and maintain business relationships without giving improper gifts, taking unfair competitive advantage, or receiving kickbacks.’

‘Offering business courtesies and hospitality. Gifts, meals, and other business courtesies must be carefully handled to avoid even the perception of corruption. You may not extend business courtesies to government officials. Courtesies may be offered to private sector clients when they are permitted by law, consistent with local customs, and the client’s policy permits it. Hospitality or modest refreshments offered during business hours in an office setting are allowed. Gifts or other courtesies must be reasonable, modest, and offered with no expectation that anything will be provided in return.

Accepting gifts and courtesies. Accepting small memorabilia, or promotional or token items of nominal value should not cause problems. Multiple items, group events, travel, or entertainment that can be considered lavish or extravagant must be reported to a manager, Company counsel, or the compliance officer. Gifts must be infrequent, transparent, and received with no obligation or expectation for a reciprocal action.’


‘At its core, our policy is simple: The company, its employees, and representatives are forbidden from promising, offering, giving or accepting anything of value — money, gifts,


meals, or services — to gain or retain an improper advantage in business dealings’

(p.10): ‘Jacobs’ anti-corruption policy prohibits the company, its employees or representatives from promising, offering, or making payments of money, gifts, meals, or anything of value to government officials or people associated with our business interests with the intent to improperly obtain or retain business.’

(p.14): ‘Gifts to Business People

Jacobs allows gifts to people associated with our business interests under certain specific guidelines:

-Gifts can only be given as a courtesy and never in expectation of getting something in return

-Cash or its equivalent is never appropriate

-Gifts may not be too lavish or extravagant

-Gifts must comply with local laws and be customary under the circumstances

-Gifts must comply with the client’s policies and practices

-Avoid giving gifts repeatedly to one individual or group — this can begin to look like a bribe

-Make sure you record the gift accurately on your expense reports and provide receipts

Gifts may not be given to government officials. Read further for more information.’


A22:

Does the company’s anti-corruption policy include a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery?

Score:

1

Comments:

Based on public information, there is evidence that the company has a policy on the giving and receiving of hospitality to ensure that such transactions are bona fide and not a subterfuge for bribery. However, the policy lacks clarity, as employees are only instructed that hospitality must be reasonable, moderate and proportional. The company therefore scores 1. To score higher the company would need to provide evidence of clear upper limits or specific thresholds necessary for senior authorisation.

References:

Public:


‘At Jacobs, we develop and maintain business relationships without giving improper gifts, taking unfair competitive advantage, or receiving kickbacks.’

‘Offering business courtesies and hospitality. Gifts, meals, and other business courtesies must be carefully handled to avoid even the perception of corruption. You may not extend business courtesies to government officials. Courtesies may be offered to private sector clients when they are permitted by law, consistent with local customs, and the client’s policy permits it. Hospitality or modest refreshments offered during business hours in an office setting are allowed. Gifts or other courtesies must be reasonable, modest, and offered with no expectation that anything will be provided in return.

Accepting gifts and courtesies. Accepting small memorabilia, or promotional or token items of nominal value should not cause problems. Multiple items, group events, travel, or entertainment that can be considered lavish or extravagant must be reported to a manager, Company counsel, or the compliance officer. Gifts must be infrequent, transparent, and received with no obligation or expectation for a reciprocal action.’


‘At its core, our policy is simple: The company, its employees, and representatives are


forbidden from promising, offering, giving or accepting anything of value — money, gifts, meals, or services — to gain or retain an improper advantage in business dealings’

(p.10): ‘Jacobs’ anti-corruption policy prohibits the company, its employees or representatives from promising, offering, or making payments of money, gifts, meals, or anything of value to government officials or people associated with our business interests with the intent to improperly obtain or retain business.’

(p.14): ‘Q: Does Jacobs policy limit my ability to entertain clients?

A: That first depends on whether the client is a government official or not. Government officials may not be entertained — even simple hospitality — until the General Counsel approves an exception.

For other clients our rules permit reasonable and proportionate hospitality (meals and refreshments) and promotional expenditures. They must directly support our business interests, foster relationships, improve the image of the company, promote or demonstrate our products and services, or are required in the performance of a contract. It may never be provided in return for a benefit. Gifts and entertainment are allowed under the following conditions:

-The expenditures are reasonable in amount and made in good faith

-They are permissible under local regulation and the client’s policy

-They are not offered to induce or reward improper conduct”

-The frequency does not give rise to an appearance of impropriety

-The expense is properly documented

These are general guidelines and proper interpretation depends on your situation. If you have questions, ask for advice.’

(p.15): ‘Hospitality and Entertainment

Business meals and entertainment must be handled with care to avoid the appearance of impropriety. Again, there can be no expectation of receiving something in return.

Entertainment costs should be reasonable — not too extravagant or too frequent. Neither laws nor Jacobs policy define “extravagant.” Use common sense to determine what is appropriate. A variety of considerations must be taken into account, including client policies and local etiquette. Ask yourself: Will I be embarrassed trying to defend this expense? If so, you shouldn’t incur it. If you’re not sure, ask advice before taking a client out to dinner.

Hospitality and entertainment that is required by contract is allowed so long as it is moderate and proportional. It is helpful to consider the impact of these provisions when the contract is negotiated. For example, clients sometimes visit Jacobs' offices for several weeks at a time. It is perfectly legitimate to provide hospitality and entertainment on nights and weekends in such cases. What’s important is that the proposed entertainment should be spelled out ahead of time in the contract.

Consider the following guidelines:

-Obtain advice and clearance before making your plans


-Ensure the arrangement is allowed by the visitor’s local laws

-Use invitation letters that set out the proposed itinerary and that detail what expenses are to be paid

-Pay service providers such as restaurants, theaters, and hotels directly

-Keep plans reasonable and not extravagant

-Invite only relevant personnel and not their spouses, family, or friends

-Comply with the client’s policy

-Record all expenses accurately’


A23:

Does the company have a policy that explicitly prohibits facilitation payments?

Score:

2

Comments:

Based on public information, there is evidence that the company has a policy that explicitly prohibits facilitation payments, except in situations where the safety or welfare of an employee or family member is threatened. Employees are instructed to notify company authorities for proper handling and follow-up in such cases.

References:

Public:


‘Making facilitation payments.

Payments made to expedite routine government actions — known as facilitation payments — are prohibited. Facilitation payments are typically demanded by low level and low income officials in exchange for providing services to which one is legally entitled without such payments. While they may be small in value, or even customary, it is impossible to regulate and constitutes an illegal practice in most countries.’

Anti-corruption Guidelines (2011), p.5:

‘Facilitation Payments

Facilitation payments involve paying small sums to government officials to obtain routine and non-discretionary government actions such as granting a permit or license, providing utility services, allowing border crossings, providing police protection, registering vehicles, or loading cargo. Jacobs policy prohibits facilitation payments, even when they may be legal under the FCPA. U.S. law allows facilitation payments under certain circumstances, but most local laws forbid it; furthermore, the distinction between facilitation payments and bribery is often unclear. Jacobs has a zero-tolerance policy toward facilitation payments.

There is a very limited exception to the policy toward facilitation payments in circumstances where the health, safety, welfare, or personal liberty of an employee or family member is threatened. As soon as practical, notify the company authorities for proper handling and follow-up.’


‘Q: Can third party representatives make facilitation payments on behalf of Jacobs?

A: No, our policy carries over to all third parties acting on our behalf or at our direction. This practice is not allowed.’

(p.15): ‘Q: I am traveling to a country where I have heard that immigration officials sometimes solicit payments from foreign travelers. What should I do if I find myself in this situation?

A: Our policy prohibits the payment of bribes or facilitation payments. But, if after rejecting the request, your life, liberty, safety, or health are in imminent jeopardy, take necessary actions, even if that means paying money.

Once you are safe and the situation has stabilized, make the necessary notifications and seek advice on what to do next.’


A24:

Does the company prohibit political contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent? Does the company record and publicly disclose all political contributions?

Score:

1

Comments:

Based on public information, there is readily available evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent. Political contributions go through multiple reviews, including legal for compliance with all applicable laws. The company therefore scores 1. To score higher the company would need to provide evidence that recipients are publically declared.

References:

Public: Code of Conduct (May 2013), p.14: ‘Jacobs sometimes uses its corporate voice to educate public officials and promote government support for relevant issues. The Company may express its views through contributions to political activities that do not involve the election of candidates. Except as permitted, we do not use company funds for contributions to candidates. You may not make contributions on behalf of the Company. We encourage you to personally support political causes that are important to you; but such support must be done outside the office, on your own time, using your own resources, and in your own name. Contacts with government officials are highly regulated. You may not contact officials regarding a policy, regulation or legislation unless the action has been approved by your manager.’ ‘Political Action Committee. The Jacobs Good Government Committee accepts donations from employees to make contributions to support candidates and issues that are deemed favorable to the Company. Participation is personal and voluntary. Coercing others to contribute to or support the PAC or any political position is prohibited. Except for the PAC, you may not make any political contribution on behalf of the Company.’ Anti-Corruption Guidelines (2011), p.16: ‘Contributions to candidates for political office, political parties, and party officials must be


carefully controlled. The FCPA and many local laws forbid making political contributions for the purpose of obtaining or retaining business. Even when the contribution is intended to be a legitimate lobbying effort, any contribution can create the appearance of impropriety and may be difficult to defend legally. Therefore, contributions must go through multiple reviews:

Senior Management and Sales Organization for business purpose and suitability,

Legal for compliance with all applicable laws, and

Board of Directors approval for contributions in excess of $10,000 This includes "in-kind" contributions such as administrative support, company supplies and facilities, or donated hours during the work time’ ‘Q: How can a corporate donation become a bribery problem? A: There are a number of possible issues with corporate donations. Sometimes the recipients’ identity is not clear; there may be hidden relationships unless it is an internationally recognized organization. The donation may be considered an inducement, or it could be used to get special access to a government official. Even a good faith charitable donation could be subjectively valued as providing an intangible benefit of enhanced self-worth or prestige to an official.’


A25:

Does the company have a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies?

Score:

1

Comments:

Based on public information, there is some evidence that the company has a policy on for engagement in lobbying activities. However, there is no readily available evidence that the company publically discloses the issues on which it lobbies. The company therefore scores 1.

References:

Public: Anti-corruption Guidelines (2011), p.16: ‘Political Contributions to candidates for political office, political parties, and party officials must be carefully controlled. The FCPA and many local laws forbid making political contributions for the purpose of obtaining or retaining business. Even when the contribution is intended to be a legitimate lobbying effort, any contribution can create the appearance of impropriety and may be difficult to defend legally. Therefore, contributions must go through multiple reviews:

Senior Management and Sales Organization for business purpose and suitability,

Legal for compliance with all applicable laws, and

Board of Directors approval for contributions in excess of $10,000 This includes "in-kind" contributions such as administrative support, company supplies and facilities, or donated hours during the work time’ (p.5): ‘Q: What is a “representative?” A: “Representative” means any retained individual or entity who acts on behalf of Jacobs to support business development with our clients or to handle dealings with government or public bodies. Representatives can include country sponsors, joint venture partners, subcontractors, customs brokers, freight forwarders, lobbyists, lawyers, and accountants.’ Code of Conduct (May 2013), p.14: ‘Jacobs sometimes uses its corporate voice to educate public officials and promote government support for relevant issues. The Company may express its views through


contributions to political activities that do not involve the election of candidates. Except as permitted, we do not use company funds for contributions to candidates. You may not make contributions on behalf of the Company. We encourage you to personally support political causes that are important to you; but such support must be done outside the office, on your own time, using your own resources, and in your own name. Contacts with government officials are highly regulated. You may not contact officials regarding a policy, regulation or legislation unless the action has been approved by your manager.’


A25(a):

Does the company prohibit charitable contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent?

Score:

1

Comments:

Based on public information, there is evidence that the company’s charitable contributions are regulated in order to prevent undue influence or other corrupt intent. For example, for all contributions there are strict criteria and approval must be sought from the Executive Vice President of Finance and Administration. The company states that all corporate charitable contributions are made through the Jacobs Engineering Foundation. The company therefore scores 1. To score higher the company would need to provide evidence that recipients are publically declared.

References:

Public:


‘Charitable contributions.

Corporate charitable contributions are made exclusively through the company’s philanthropic organization, the Jacobs Engineering Foundation. Employees may offer recommendations of worthy organizations and causes. Contact your human resources representative if you have a suggestion. All charitable contributions must be approved by management, and amounts in excess of USD $10,000 per year, individually or in the aggregate, must be approved by the Board of Directors’


‘Charitable Donations

The legal limits on charitable donations are strict and Jacobs policy is correspondingly firm. There are plenty of places where companies are required to make a donation to win a contract. Donations are not allowed under the following circumstances:

If a foreign official or family member of an official is affiliated with the organization

If the organization lacks financial transparency

If there is a possibility that the contribution could be diverted from its intended purpose

If there is the possibility that the contribution could constitute quid pro quo (e.g. one


favor in exchange for another).

All corporate charitable contributions must be approved through the Executive Vice President of Finance and Administration — and the Board of Directors for contributions in excess of $10,000.’


A26:

Does the company provide written guidance to help Board members and

employees understand and implement the firm’s ethics and anti-corruption

agenda?

Score:

2

Comments:

Based on public information, there is evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. The Anti-Corruption Guidelines contain questions and answers, and lists a range of resources that are available to help employees understand and follow procedures.

References:

Public:

Anti-Corruption Guidelines (2011), pp.2-3:

‘Resources Available

We provide a variety of ways to help you understand and follow policies and procedures regarding bribery and corruption. You can review the policies themselves; the following documents are available on JNet:

Global Policy Supplement — Business Conduct GPS1-the procurement process by defining bribery and other prohibited practices. It further references our Code of Business Conduct and requires the reporting of noncompliances and other violations through our Integrity Hotline.

Global Policy Supplement — Corporate Policy Concerning Business Conduct, Integrity, and Ethics — U.S.A. GPS1-103f1 and Corporate Policy Concerning Business Conduct — International GPS1-103f3. These policies incorporate the Foreign Corrupt Practices Act (FCPA) as company standards. They are the sources of annual training and employee certification.

Global Policy Supplement — Compliance and Business Practices Program GPS01-policy sets forth the structure for the company’s compliance program, which includes anti-corruption. It reiterates that every employee is responsible for matters of integrity.

Global Policy Supplement — Anti-Corruption Policy GPSO1-103-07 This policy defines the company’s commitment to integrity, scopes and responsibilities of employees, and


prohibited actions as those requirements are set forth in the FCPA, Bribery Act, and other statutes.

Global Procedure — Appointment of Sales Representatives Outside the United States (pending) This is a detailed working procedure that defines how outside sales representatives will be appointed and monitored.

Global Procedure — Third-party Intermediaries Not Engaged in Sales (pending)

Global Policy Supplement — Global Anti-Corruption Policy for Private Sector Suppliers (pending).’

(p.5): ‘Q: What is a “representative?”

A: “Representative” means any retained individual or entity who acts on behalf of Jacobs to support business development with our clients or to handle dealings with government or public bodies. Representatives can include country sponsors, joint venture partners, subcontractors, customs brokers, freight forwarders, lobbyists, lawyers, and accountants.

Q: Is Jacobs responsible for the actions of subcontractors and other representatives?

A: Yes, we are responsible for actions of our representatives. Our policy incorporates the features of both the FCPA and the U.K. Bribery Act, which hold that companies are liable for the acts of its subcontractors, joint-venture partners, and agents — essentially all individuals or firms hired on Jacobs’ behalf — when Jacobs knows of their actions. “Knowing” requires awareness, a firm belief, or a high probability that a violation will occur. That is why we have a program to detect and prevent the occurrence of bribery and corruption by these representatives. Jacobs policy, therefore, requires us to screen and monitor our representatives. You need to be alert to warning signs of bribery or corruption and immediately notify appropriate parties of any potential violations (the “red flags”). “Looking the other way” or ignoring red flags exposes both you and the company to risk.

Q: Anti-corruption laws talk a lot about the “books and records of the company.” But I’m not in accounting. Do I have any responsibility in this area?

A: Yes, you should ensure that all records for which you are responsible are accurate and complete and destroyed only under specific direction. Books and records generally refer to the company’s financial and tax data and other financial and management information, including accounting records. Most of these records are in fact created by employees not in accounting. Have you ever authorized payment on an invoice? Approved an expenditure? Submitted an expense report? Made a purchase on behalf of the company and obtained a sales receipt? Processed a P-Card transaction? Requested or paid from petty cash? You’ve created records for the company.’

(p.12): ‘Q: Who is a “Government Official”?

A: Jacobs policy refers to “government officials.” This sounds straightforward: a government official works for a government, right? But in practice it can be complicated. The following individuals have all been considered government officials in U.S. government anti-corruption prosecutions:

-Officials of a government-owned bank in Argentina

-The director of a regional health fund in Poland


-Physicians and laboratory employees at government-owned hospitals in China, Taiwan, and Mexico

-Officials of the National Petroleum Investment Management Service of Nigeria

-U.S. citizens employed by the state oil company in Angola

-Customs officials in Haiti

-Airport officials in China, the Philippines, and Thailand

-A member of the Nicaraguan legislature

-A tax official in India

-A general in the Thailand air force

-Employees of Kazakstan’s national oil company.’

(p.14): ‘Q: Does Jacobs policy limit my ability to entertain clients?

A: That first depends on whether the client is a government official or not. Government officials may not be entertained — even simple hospitality — until the General Counsel approves an exception.

For other clients our rules permit reasonable and proportionate hospitality (meals and refreshments) and promotional expenditures. They must directly support our business interests, foster relationships, improve the image of the company, promote or demonstrate our products and services, or are required in the performance of a contract. It may never be provided in return for a benefit. Gifts and entertainment are allowed under the following conditions:

-The expenditures are reasonable in amount and made in good faith

-They are permissible under local regulation and the client’s policy They are not offered to induce or reward improper conduct

-The frequency does not give rise to an appearance of impropriety

-The expense is properly documented

These are general guidelines and proper interpretation depends on your situation. If you have questions, ask for advice.’

(p.15): ‘Q: I am traveling to a country where I have heard that immigration officials sometimes solicit payments from foreign travelers. What should I do if I find myself in this situation?

A: Our policy prohibits the payment of bribes or facilitation payments. But, if after rejecting the request, your life, liberty, safety, or health are in imminent jeopardy, take necessary actions, even if that means paying money. Once you are safe and the situation has stabilized, make the necessary notifications and seek advice on what to do next.’

(p.16): ‘Q: How can a corporate donation become a bribery problem?

A: There are a number of possible issues with corporate donations. Sometimes the recipients’ identity is not clear; there may be hidden relationships unless it is an internationally recognized organization. The donation may be considered an inducement, or it could be used to get special access to a government official. Even a good faith charitable


donation could be subjectively valued as providing an intangible benefit of enhanced self-worth or prestige to an official.

Q: What if I want to make a personal donation to a political party or charitable organization?

A: You can make personal donations to political parties or charitable groups, but Jacobs will not reimburse you for these expenses.

If you want to make a donation, keep in mind two important points. First, there usually are legal limits and conditions that you must abide by. Second, Jacobs is involved in a multitude of projects throughout the world, and in some situations, a contribution from an individual may be attributed to the company. You should seek guidance to ensure your donation is legal and appropriate.’

(p.17): ‘Q: Do these limits on gifts and entertainment mean all business courtesies have been abolished?

A: No, meals and entertainment are still allowed, but they must be reasonable. Only excessive, out-of-proportion hospitality is out of bounds.

Q: Don’t we have internal controls to catch these things?

A: Yes, Jacobs internal controls normally identify problem expenses and flag them for review. However, we don’t want to run our business only catching violations after they’ve occurred. We want to educate employees on appropriate actions to avoid problems in the first place.

Q: Can third party representatives make facilitation payments on behalf of Jacobs?

A: No, our policy carries over to all third parties acting on our behalf or at our direction. This practice is not allowed.’

(p.18): ‘Q: Are the procedures for a merger or acquisition the same as those for hiring a representative or subcontractor?

A: No, mergers and acquisitions present their own set of challenges, since they involve companies that will become part of Jacobs.

The review process is complex and entails a due diligence process much broader than just bribery and corruption. If you are asked to participate in an M&A review, you will be provided specific instructions on what to do.’


A27:

Does the company have a training programme that explicitly covers anti-corruption?

Score:

2

Comments:

Based on public information, there is evidence that anti-corruption training is explicitly provided as a separate training programme, albeit to certain employees. However, further evidence implies that the guidelines of the FCPA are incorporated into wider employee annual training.

References:

Public:


‘Training

Certain employees are also required to periodically complete anti-bribery training. The training you receive depends on your job assignment. In addition, as part of our ethics program, all employees must complete ethics training every two years.’

(p.13): ‘The goal of Jacobs policy is to prevent corruption before it happens, not just catch wrong-doing after the fact. That’s why our policy involves extensive training and widespread awareness campaigns.’

(p.2): ‘Global Policy Supplement—Corporate Policy Concerning Business Conduct, Integrity, and Ethics — U.S.A. GPS1-103f1 and Corporate Policy Concerning Business Conduct — International GPS1-103f3 These policies incorporate the Foreign Corrupt Practices Act (FCPA) as company standards. They are the sources of annual training and employee certification.’


‘You are responsible for several things. First, you must read this Code and familiarize yourself with its contents. Second, you must participate in the annual acknowledgement and self-certification process confirming that you’ve read and understood the latest version of the Code, and agreeing to complete any other training required for your position.’


(p.7): ‘Does Jacobs provide training and awareness opportunities regarding the Code?

Certain individuals in the organization must complete appropriate training to ensure they understand and can apply the Code of Conduct and relevant policies and procedures to their work. If your position requires additional training, your manager will let you know.’


‘New employee orientation includes foundation training for all employees on our business code of conduct. Each year our staff employees are required to review the business code of conduct and reaffirm their understanding. additional supplemental training is required to be completed every other year by our supervisors/managers and other employees depending on their role in the company’

‘Training

Jacobs also established a global ethics and compliance training initiative program to further help employees understand the legal and ethical standards that must be upheld. Our organization-wide program is designed to provide a strong learning foundation and supplemental training, such as those conducted through regional training efforts, at our annual business Meeting, and through Jacobs college. Since 2005, Jacobs college has offered senior leader-led training with modules dedicated to ethics. Training is highly interactive, leveraging actual company scenarios.

Due to our many geographic locations around the world, the majority of our training is delivered through on-line learning. The training is enhanced with in-person learning events.

The following concepts are woven throughout all on-line compliance courses:

observance of moral and ethical standards of society and fair dealing

Reporting and resolving suspected irregularities

Corporate governance

Jacobs integrity hotline’

‘In addition to the business code of conduct Reaffirmation, Jacobs offers additional ethics and compliance courses, including:

procurement integrity

information Security

insider trading

conflicts of interest

global bribery and

corruption awareness’

(p.76): ‘Anti-Corruption

Classroom anti-corruption training led by compliance officer:

25 classes = 618 people

On-line anti-corruption policy training:


Fy12 24,743 completed (95% of those assigned)

Procurement integrity (1–hour, on-line course):

3,395 completed (96% of those assigned)

Global bribery & corruption awareness (1–hour, on-line course):

last completed in 2010

Scheduled in 2012 for approximately 3,000 individuals

Global anti-corruption – new course roll out scheduled in Fy13

for approximately 3,500 people

Global competition (1–hour, on-line course):

3,395 (96% of those assigned) completed

Ethics: 1,478 hours (943 people)

Jacobs college, ethics: 2.5 hours completed by 231 leaders

Annual business Meeting – keynote speaker –

ethics from a cultural perspective – 1 hour – 379 senior leaders

Professional Women’s conference, ethics Workshop:

2 hours completed by 140 leaders

Jacobs Future network Weekend – project ethics – 75 minutes –

193 early career professional employees’


A28:

Is anti-corruption training provided in all countries where the company operates or has company sites?

Score:

1

Comments:

Based on public information, there is evidence that the company has an anti-corruption training programme. The 2013 Sustainability Report states that in FY2012 nearly 25,000 employees completed on-line anti-corruption policy training, out of nearly 50,000 permanent employees. However, it is unclear if this training programme is provided in all countries where the company operates or has company sites. The company therefore scores 1. To score higher, the company must provide evidence that anti-corruption training is provided in all countries where the company operates or has company sites.

References:

Public;


‘Training


(p.13): ‘The goal of Jacobs policy is to prevent corruption before it happens, not just catch wrong-doing after the fact. That’s why our policy involves extensive training and widespread awareness campaigns.’


‘New employee orientation includes foundation training for all employees on our business code of conduct. Each year our staff employees are required to review the business code of conduct and reaffirm their understanding. additional supplemental training is required to be completed every other year by our supervisors/managers and other employees depending on their role in the company’

‘Training


Jacobs also established a global ethics and compliance training initiative program to further help employees understand the legal and ethical standards that must be upheld. Our organization-wide program is designed to provide a strong learning foundation and supplemental training, such as those conducted through regional training efforts, at our annual business Meeting, and through Jacobs college. Since 2005, Jacobs college has offered senior leader-led training with modules dedicated to ethics. Training is highly interactive, leveraging actual company scenarios.

Due to our many geographic locations around the world, the majority of our training is delivered through on-line learning. The training is enhanced with in-person learning events.

The following concepts are woven throughout all on-line compliance courses:

observance of moral and ethical standards of society and fair dealing

Reporting and resolving suspected irregularities

Corporate governance

Jacobs integrity hotline’

‘In addition to the business code of conduct Reaffirmation, Jacobs offers additional ethics and compliance courses, including:

procurement integrity

information Security

insider trading

conflicts of interest

global bribery and

corruption awareness’


Classroom anti-corruption training led by compliance officer:


On-line anti-corruption policy training:


Procurement integrity (1–hour, on-line course):


Global bribery & corruption awareness (1–hour, on-line course):

last completed in 2010

Scheduled in 2012 for approximately 3,000 individuals

Global anti-corruption – new course roll out scheduled in Fy13


Global competition (1–hour, on-line course):


Ethics: 1,478 hours (943 people)

Jacobs college, ethics: 2.5 hours completed by 231 leaders

Annual business Meeting – keynote speaker –



Professional Women’s conference, ethics Workshop:


Jacobs Future network Weekend – project ethics – 75 minutes –


Note: Permanent Staff as mentioned in the Annual Report is 49,400


A29:

Does the company provide targeted anti-corruption training to members of the Board?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board. Evidence suggests that training was provided to ‘leaders’ but it does not specify whether Board Members were included.

References:

Public:

TI notes:


‘Training Jacobs also established a global ethics and compliance training initiative program to further help employees understand the legal and ethical standards that must be upheld. Our organization-wide program is designed to provide a strong learning foundation and supplemental training, such as those conducted through regional training efforts, at our annual business Meeting, and through Jacobs college. Since 2005, Jacobs college has offered senior leader-led training with modules dedicated to ethics’


■ Jacobs college, ethics: 2.5 hours completed by 231 leaders

■ Annual business Meeting – keynote speaker –

ethics from a cultural perspective – 1 hour – 379 senior leaders’


A30:

Does the company provide tailored ethics and anti-corruption training for employees in sensitive positions?

Score:

1

Comments:

Based on public information, there is evidence that the company has a varied ethics and anti-corruption training programme for employees. For example, classroom anti-corruption training is provided to 618 people, suggesting particular employees receive additional training. The company therefore scores 1. To score higher, the company would need to provide evidence that its ethics and anti-corruption training programme is tailored for employees facing different levels of risk.

References:

Public:


‘Training


(p.13): ‘The goal of Jacobs policy is to prevent corruption before it happens, not just catch wrong-doing after the fact. That’s why our policy involves extensive training and widespread awareness campaigns’


‘Each year our staff employees are required to review the business code of conduct and reaffirm their understanding. Additional supplemental training is required to be completed every other year by our supervisors/managers and other employees depending on their role in the company’


■ Classroom anti-corruption training led by compliance officer:



■ On-line anti-corruption policy training:


■ Procurement integrity (1–hour, on-line course):


■ Global anti-corruption – new course roll out scheduled in Fy13


■ Global competition (1–hour, on-line course):


■ Ethics: 1,478 hours (943 people)

■ Jacobs college, ethics: 2.5 hours completed by 231 leaders

■ Annual business Meeting – keynote speaker –


■ Professional Women’s conference, ethics Workshop:


■ Jacobs Future network Weekend – project ethics – 75 minutes –


Note: Permanent Staff as mentioned in the Annual Report is 49,400


A31:

Does the company have a clear and formal process by which employees declare conflicts of interest?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest. The company only states that employees in a situation that involves a potential conflict of interest must immediately contact their manager. To score higher the company would need to provide evidence that employees are instructed to inform either their managers formally in writing or an independent department.

References:

Public:


‘A conflict of interest is defined as a circumstance that creates a risk that professional judgment or actions will be unduly influenced by a secondary interest, usually personal. In other words, a situation where the interests of the company come into conflict with the interests of an individual. You must avoid conflicts of interest that could cloud judgment, impair objectivity, and interfere with good decision-making. You should never achieve personal gain through a Company transaction or by the use of Company information. Corporate opportunities belong to the Company. Even creating an appearance of conflict should be avoided. If a conflict cannot be prevented, it must be mitigated by full disclosure. Disclosure should involve an evaluation of the situation by a disinterested party. If you find yourself in a situation that involves a potential conflict of interest, immediately contact your manager.’

‘Disclosure. You are required to fully disclose any conflicts—personal, social, political or financial—prior to entering into the relationship.’

Code of Business Conduct and Ethics for Board of Directors (March 2014), p.2:

‘2. Conflict of Interest.

Directors must avoid any conflicts of interest between the director and the Company. Any


situation that involves, or may reasonably be expected to involve, a conflict of interest with the Company, should be disclosed promptly to either the Chair of the Nominating and Corporate Governance Committee or the Chair of the Audit Committee.

A "conflict of interest" can occur when a director's personal interest is adverse to – or may appear to be adverse to – the interests of the Company as a whole. Conflicts of interest also arise when a director, or a member of his or her immediate family,1 receives improper personal benefits as a result of his or her position as a director of the Company. In addition, a conflict situation can arise when a director takes actions or has interests that may make it difficult to perform his or her duties for the Company objectively and effectively.’


A32:

Is the company explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities?

Score:

2

Comments:

Based on public information, there is evidence that the company has an explicit commitment to apply disciplinary procedures to employees, Directors and Board members found to have violated its Code of Conduct and Anti-Corruption Guidelines.

References:

Public:


‘Everyone at Jacobs—from the Board of Directors to our newest employee—is bound by this Code.’

(p.6):

‘Who must obey the Code of Conduct? Every employee, director, and officer of the company; anywhere in the world. This also includes majority-owned subsidiaries. Particular aspects of the code may also apply to agents, consultants, business partners, vendors, and subcontractors.’

(p.7): ‘What are the consequences if I violate the Code of Conduct? Violations are taken seriously, and consequences depend upon the situation. All violations are investigated so we understand the circumstances before acting. We have the right to take disciplinary action, including termination, for acts of misconduct. The appropriate disciplinary action is determined based upon the severity of the violation and the actual or potential impact on the Company. Some violations may involve civil and criminal liability, and violators may be subjected to incarceration or fines if prosecuted by law enforcement authorities.’


‘Any employee who fails to comply with these requirements can be disciplined or even


terminated’

(p.2): ‘Any employee who fails to comply with these requirements can be disciplined’

(p.22): ‘Jacobs policy is clear: You have an obligation to immediately report actual or suspected violations. Even if you don’t have all the facts, you must bring what you know to the attention of the company. This is mandatory for all employees. If the company learns about a violation and discovers that you knew about the situation but did not report it, you can be disciplined.’

(p.23): ‘Progressive Discipline

What will happen if you are the one who committed a violation? Jacobs’ discipline policy strives for fairness. Its driving principle is that the discipline should be consistent with the violation. Major violations can result in severe disciplinary action, including termination. Minor violations will have less severe consequences. You may not be fired for a minor accounting error, but you can lose your job if you offer a bribe to a government official and expose Jacobs to prosecution. Management and Human Resources are responsible for determining any appropriate disciplinary action.’


A33:

Does the company have multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity?

Score:

2

Comments:

Based on public information, there is evidence that the company has multiple, well-publicised channels that are easily accessible, to guarantee confidentiality or anonymity where requested by the employee, to report concerns or instances of suspected corrupt activity. Channels include reporting to the Corporate Compliance Officer by phone or email, or using one of the numerous toll-free numbers for the Integrity Hotline. Evidence suggests that employees may report anonymously using the Integrity Hotline.

References:

Public: Anti-Corruption Guidelines (2011), p.3: ‘The Integrity Hotline at 1.877.JACOBS2 (877.522.6272) For international access code numbers see JNet > About Jacobs > Business Conduct/Ethics’ (p.6): ‘You have a duty to promptly report suspected or actual violations with full disclosure. Reporting may be anonymous if necessary, and confidential to the extent permitted.’ (p.22): ‘Making the Call - Report potential or actual violations to one of the following: -Your supervisor -Jacobs management -Jacobs legal counsel (either the counsel for your region or Corporate Legal Department) -Corporate Compliance Officer at +1.626.578.6860 or [email protected] -The Integrity Hotline at 1.877.JACOBS2 (877.522.6272) For international access code numbers see JNet > About Jacobs > Business Conduct/Ethics -Board of Directors / Presiding Director Some of these resources can be used anonymously. All will maintain confidentiality.’ Code of Conduct (May 2013), p.7:


‘Where do I go to report violations? It’s a good idea to start with your manager or Jacobs senior managers. Our Company’s legal counsel is always a great source for advice and resolving complaints. We also have a Corporate Compliance Officer (+1.626.578.6860), as well as an Integrity Hotline (1.877.JACOBS2 in the U.S. See page 25 for international numbers). Finally, the Board of Directors/Presiding Director are also available as a resource.’ (p.27): ‘The Jacobs Integrity Hotline is available to employees and others who wish to report non-compliance or suspected violations of law and policy, or to seek guidance on specific situations regarding company policy.’ This page lists toll-free numbers for numerous countries. 2013 Sustainability Report, p.73: ‘Jacobs integrity hotline is a worldwide reporting line answered 24 hours a day, seven days a week by a professional independent contractor. Calls are confidential and can be anonymous.’


A33(a):

Are the whistleblowing channels available to all employees in all geographies?

Score:

2

Comments:

Based on public information, there is evidence that the company’s whistleblowing channels are available to all employees in all geographies. Employees are able to report to the Corporate Compliance Officer by phone or email, and the Integrity Hotline has toll-free numbers worldwide.

References:

Public: Anti-Corruption Guidelines (2011), p.3: ‘The Integrity Hotline at 1.877.JACOBS2 (877.522.6272) For international access code numbers see JNet > About Jacobs > Business Conduct/Ethics’ (p.22): ‘Making the Call - Report potential or actual violations to one of the following: -Your supervisor -Jacobs management -Jacobs legal counsel (either the counsel for your region or Corporate Legal Department) -Corporate Compliance Officer at +1.626.578.6860 or [email protected] -The Integrity Hotline at 1.877.JACOBS2 (877.522.6272) For international access code numbers see JNet > About Jacobs > Business Conduct/Ethics -Board of Directors / Presiding Director Some of these resources can be used anonymously. All will maintain confidentiality.’ Code of Conduct (May 2013), p.7: ‘Where do I go to report violations? It’s a good idea to start with your manager or Jacobs senior managers. Our Company’s legal counsel is always a great source for advice and resolving complaints. We also have a Corporate Compliance Officer (+1.626.578.6860), as well as an Integrity Hotline (1.877.JACOBS2 in the U.S. See page 25 for international numbers). Finally, the Board of Directors/Presiding Director are also available as a resource.’


(p.27): ‘The Jacobs Integrity Hotline is available to employees and others who wish to report non-compliance or suspected violations of law and policy, or to seek guidance on specific situations regarding company policy.’ This page lists toll-free numbers for numerous countries. 2013 Sustainability Report, p.73:

‘Jacobs integrity hotline is a worldwide reporting line answered 24 hours a day, seven days a week by a professional independent contractor. Calls are confidential and can be anonymous.’


A33(b):

Does the company have formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively?

Score:

0

Comments:

Based on public information, there is some evidence that the company encourages employees to report any concerns or violations of the Code of Conduct and the Anti-Corruption Guidelines. However, there is no readily available evidence of formal mechanisms to ensure employees are comfortable reporting concerns, such as monitoring of whistleblowing channel usage statistics, commissioning independent employee surveys or formal procedures for follow up with whistleblowers.

References:

Public:

TI notes:


‘Jacobs policy is clear: You have an obligation to immediately report actual or suspected violations. Even if you don’t have all the facts, you must bring what you know to the attention of the company. This is mandatory for all employees. If the company learns about a violation and discovers that you knew about the situation but did not report it, you can be disciplined.’

‘Q: I recently discovered evidence of what I think is a problem. What will happen when I report it?

A: Our objective is to conduct a fair and complete investigation, and take prompt remedial action if necessary.

First we must determine what happened. Your statement will be important in preparing a report. The information gathered will result in a report which executive management will review in deciding what action to take.

At all times we strive to handle cases quickly and professionally while maintaining your personal and legal confidentiality. You will be instructed not to discuss the matter with others. The findings will not be discussed with you or others since as a matter of policy, we


do not share information about our investigations.

Our experience shows that many times a situation that appears to violate a policy can be resolved without any action. This may be difficult to understand, nevertheless, we encourage employees to identify possible problems because we want to solve them quickly, and make changes to avoid recurrence.

If you notify us with a good faith belief that a violation occurred, regardless of the outcome, we will not take retaliatory action against you.’

(p.23): ‘Non-Retaliation

If you genuinely believe you have identified a problem, Jacobs cannot retaliate against you or prevent your advancement within the organization. In other words, if you have reason to suspect your supervisor of making improper payments to a government official, you cannot be fired or disciplined for reporting him or her — even if it turns out nothing improper took place.

It’s important to emphasize that such a report must be made in good faith. You must truly believe — and have some reason to believe — that a violation took place. Acting out of spite or malice can have severe consequences.’


‘You have a duty to promptly report suspected or actual violations with full disclosure. Reporting may be anonymous if necessary, and confidential to the extent permitted. When a complaint is made, the Company conducts a timely and thorough investigation. We promote openness and encourage you to come to us directly with any complaints or problems so they may be addressed. We take all reports and complaints seriously.’

(p.7): ‘The point is: You must speak up if you see something that you think isn’t right.’


A34:

Does the company have well-publicised resources available to all employees where help and advice can be sought on corruption-related issues?

Score:

2

Comments:

Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues, such as the Corporate Compliance Officer or the Integrity Hotline.

References:

Public: Anti-Corruption Guidelines (2011), p.3: ‘Guidance Experts Employees can contact Jacobs experts for guidance in challenging situations or to report violations. Remember: It’s better to ask for help before a problem develops. If you have an issue or concern, you can contact one or more of the following: -Your supervisor -Jacobs management -Jacobs legal counsel (either the counsel for your region or Corporate Legal Department) -Corporate Compliance Officer at +1.626.578.6860 or [email protected] -The Integrity Hotline at 1.877.JACOBS2 (877.522.6272) For international access code numbers see JNet > About Jacobs > Business Conduct/Ethics -Board of Directors / Presiding Director Some of these resources can be used anonymously. All contacts maintain confidentiality. The core message is this: If you have concerns about a situation, seek help.’ (p.6): ‘You have a duty to promptly report suspected or actual violations with full disclosure. Reporting may be anonymous if necessary, and confidential to the extent permitted.’ (p.22): ‘Making the Call - Report potential or actual violations to one of the following: -Your supervisor -Jacobs management -Jacobs legal counsel (either the counsel for your region or Corporate Legal Department) -Corporate Compliance Officer at +1.626.578.6860 or


[email protected] -The Integrity Hotline at 1.877.JACOBS2 (877.522.6272) For international access code numbers see JNet > About Jacobs > Business Conduct/Ethics -Board of Directors / Presiding Director Some of these resources can be used anonymously. All will maintain confidentiality.’ Code of Conduct (May 2013), p.7: ‘Where do I go to report violations? It’s a good idea to start with your manager or Jacobs senior managers. Our Company’s legal counsel is always a great source for advice and resolving complaints. We also have a Corporate Compliance Officer (+1.626.578.6860), as well as an Integrity Hotline (1.877.JACOBS2 in the U.S. See page 25 for international numbers). Finally, the Board of Directors/Presiding Director are also available as a resource.’ (p.27): ‘The Jacobs Integrity Hotline is available to employees and others who wish to report non-compliance or suspected violations of law and policy, or to seek guidance on specific situations regarding company policy.’ This page lists toll-free numbers for numerous countries. 2013 Sustainability Report, p.73: ‘Jacobs integrity hotline is a worldwide reporting line answered 24 hours a day, seven days a week by a professional independent contractor. Calls are confidential and can be anonymous.’


A35:

Is there a commitment to non-retaliation for bona fide reporting of corruption?

Score:

1

Comments:

Based on public information, there is evidence available that the company makes a commitment to non-retaliation for bona fide reporting of corruption. However, there is no readily available evidence that the company applies disciplinary measures to employees who breach this policy. The company therefore scores 1.

References:

Public:


‘Will I get into trouble for reporting a violation? No. There will be no retaliation for a report made in good faith out of genuine concern.’


‘If you notify us with a good faith belief that a violation occurred, regardless of the outcome, we will not take retaliatory action against you.’

(p.23): ‘Non-Retaliation - If you genuinely believe you have identified a problem, Jacobs cannot retaliate against you or prevent your advancement within the organization. In other words, if you have reason to suspect your supervisor of making improper payments to a government official, you cannot be fired or disciplined for reporting him or her — even if it turns out nothing improper took place.

It’s important to emphasize that such a report must be made in good faith. You must truly believe — and have some reason to believe — that a violation took place. Acting out of spite or malice can have severe consequences.’


Information Sources:

Company website:

www.jacobs.com

2013 Summary Annual Report:


Anti-corruption Guidelines (July 2011):


Seven Principles of Sustainability (March 2014):


Audit Committee Charter (November 2013):


2013 Sustainability Report:


Supplier Code of Conduct (October 2013):


Code of Business Conduct and Ethics for Board of Directors (March 2014):


http://www.jacobs.com/


















Code of Conduct (May 2013):




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