Professional Documents
Culture Documents
Code of Conduct
Code of Conduct
Sofia
GET ANSWERS.
Ask before you act.
Use this document to understand company
policies and your responsibilities.
As we work together to tackle some of the world’s most complex challenges, there
may be times when we are faced with an ethical dilemma. When we understand
our Code of Conduct and commit to these standards, we are better equipped to
successfully navigate issues and prevent harm to our business.
It is imperative that we make the right call and conduct our business with the
integrity that reflects our heritage and ethical reputation.
The Code of Conduct is a living document that will continue to grow and evolve
alongside our company and our ever-changing global market.
Respectfully
Steven J Demetriou
Chairman & CEO
July 2018
Steve Demetriou
Chairman and CEO
It is also a living document. We plan to review and update the code as needed. Just
as we strive to continually improve our performance, we are continually improving
our Code of Conduct.
Our Code of Conduct can help. Many sections contain links to policies and
procedures that provide additional subject matter detail. These can also be accessed
at JacobsConnect>Business Practices System. Be sure you understand the rules;
and, if ever in doubt, ask before you act.
FREQUENTLY ASKED
QUESTIONS
What is the purpose of the Who must obey the Code of Conduct?
Code of Conduct? This Code applies to every employee, director, and
Jacobs is accountable to many different officer of the Company, anywhere in the world.
stakeholders, from our shareholders and Board of This also includes majority-owned subsidiaries
Directors, to our clients and business associates, and subsidiaries over which Jacobs has managerial
to our employees and their families, and not control. Particular aspects of the Code may also
least to the communities where we work and apply to agents, consultants, business partners,
live. This Code provides a consistent, company- suppliers, and subcontractors.
wide statement of our business practices and
workplace conduct, and thereby establishes the
What is my responsibility as
expectations, obligations, and responsibilities
an employee?
You are responsible for several things. First, you
of our employees to abide by these business
must read this Code and familiarize yourself with
practices in all situations and circumstances,
its contents. Second, you must participate in the
regardless of local culture or business climate,
annual acknowledgement and self-certification
and regardless of the competitive environment
process confirming that you’ve read and
in which we may find ourselves. Our Code is the
understood the latest version of the Code, and
foundation of the Jacobs’ Ethics and Compliance
agreeing to complete any other training required
program, is one of many tools we use to advance
for your position. Third, you must follow the
our Vision, Mission and Values, and helps
Code in your daily work. Finally, you must agree
promote our strategy as we seek to grow our
to seek advice from your manager, the Ethics &
business and bring value both financially and
Compliance department, the Human Resources
ethically to our stakeholders.
department, or the Legal department if you are
Because the Code itself cannot address the range confronted with a legal or ethical challenge.
of ethical challenges we face, we offer more
detailed guidance and policy statements. A list
of more detailed policy documents is attached.
FREQUENTLY ASKED
QUESTIONS
What is my responsibility as a supervisor? It is important that employees not conduct their
If you are a manager or supervisor, you are own investigations. Investigations often involve
responsible for ensuring that employees who complex legal issues and acting on your own may
report to you understand and follow the Code compromise the company's ability to conduct an
and applicable policies and procedures. You appropriate investigation.
should be a positive role model and create a
The point is: You must speak up if you see
work environment that is respectful, inclusive,
something that you think isn’t right.
and encourages employees to speak up with any
concerns. Employee concerns should be taken Will I get into trouble for reporting a violation?
seriously and elevated to the Human Resources No. Jacobs strictly forbids any form of retaliation
department, Legal department or Ethics & against an employee who makes a report in good
Compliance department as appropriate. faith out of genuine concern.
What do I do if I have a concern or need What are the consequences if I violate
to report a violation of the Code? the Code of Conduct?
You have a duty to promptly report suspected or Violations are taken seriously, and consequences
actual violations with full disclosure. Reporting depend upon the situation. All violations are
may be anonymous if necessary, and confidential investigated so we understand the circumstances
to the extent permitted. When a complaint is made, before acting. We have the right to take disciplinary
the Company conducts a timely and thorough action, including termination, for acts of
investigation. We promote openness and encourage misconduct. The appropriate disciplinary action is
you to come to us directly with any complaints or determined based upon the severity of the violation
problems so they may be addressed. We take all and the actual or potential impact on the Company
reports and complaints seriously. and in accordance with applicable law. Some
violations may involve civil and criminal liability,
Where do I go to report violations? and violators may be subjected to incarceration or
Employees have many ways to seek fines if prosecuted by law enforcement authorities.
guidance or report suspected violations of the
Code. You can contact your manager, Jacobs
senior managers, the Human Resources
department, the Legal department, the
Ethics & Compliance department directly
at compliance@jacobs.com, the Hotline
at https://integrity.jacobs.com, telephone number
(1.844.543.8351), or at askaquestion@jacobs.com.
Finally, the Board of Directors/Lead Director are
also available as a resource. Jacobs has an open
door policy and encourages employees to raise
concerns in the way they are most comfortable
doing so.
FREQUENTLY ASKED
QUESTIONS
Does Jacobs provide training and awareness The Board of Directors adopted the Code as a
opportunities regarding the Code? fundamental part of Jacobs’ Ethics & Compliance
Certain individuals in the organization must program. The SVP & Chief Administrative Officer,
complete appropriate training to ensure they in coordination with the SVP & General Counsel,
understand and can apply the Code of Conduct oversees the Ethics & Compliance program.
and relevant policies and procedures to their work. The VP for Ethics & Compliance is responsible
If your position requires additional training, your for the management of the Ethics & Compliance
manager will let you know. department, and in coordination with other
functional departments, implementation of the
How does the Code of Conduct fit Code. The Ethics & Compliance department are
into the Ethics and Compliance Program? local resources that employees can turn to for
Jacobs has implemented a comprehensive guidance on the Code.
program to maintain our commitment to integrity
by ensuring compliance with both Company See our Ethics & Compliance program on
policies and the laws and regulations applicable JacobsConnect for more information:
to our business. The Code of Conduct is part of this Company>Ethics & Integrity.
overall program. It is intended to communicate
the importance of ethical behavior to our business,
and to provide guidance on requirements and
compliance.
INTEGRITY
Know the rules and your responsibilities.
If unsure, ask before you act.
ALWAYS FOLLOW
THE LAW
OUR GENERAL POLICY REGARDING
COMPLIANCE WITH LAWS
In conducting the business of the Company, employees, agents, officers and
directors must follow the Code of Conduct. It is the policy of the Company that
we observe and comply with all laws that apply to us – worldwide. In some
cases, our values and ethics require us to do more than the law requires. In all
cases we act with integrity in our business transactions and relationships.
J
acobs is a global company headquartered in countries' laws. To apply one legal system against
the United States. Depending on where you another is never a satisfactory approach, and there
live and work, there may be circumstances will be times that rules must be harmonized. Please
where you perceive a conflict between this Code consult with the Legal department or Ethics &
and the laws or customs of your country. When Compliance department if you discover a conflict,
we conduct business outside the U.S., we refer to so an appropriate solution can be determined.
U.S., UK, EU, and international conventions as a
guide to our conduct, but we must also follow other
BeyondZero
®
COMMITMENT
We believe employee health and safety is a top priority.
E
mployee health and safety is the number accidents altogether and promote better well-being
one priority at Jacobs. We strive to achieve in all aspects of our lives. This positive mind-set
BeyondZero by preventing even one accident follows us home to benefit our families and the
from occurring and promoting positive mental people we interact with outside of Jacobs.
health and physical well-being for all. We are
committed to not only complying with industry For Further Reference:
• Global HSE Policy Statement
safety regulations, but we have ingrained safety in
how we do business—we believe in a “culture of
caring” where safety is rooted in everything we do. Sustainability Commitment
People are the heart of our business, and we work Jacobs is committed to providing solutions for
diligently to promote your overall well-being. a more connected, sustainable world. We aim
to deliver this by integrating sustainability into
In turn, our teammates are responsible for our business; through our business model, our
promoting safety and extending our culture of procedures, how we deliver our projects and
caring. That means following health and safety infusing it across our culture. We intend to work
rules; maintaining the safety of the workplace; collaboratively with employees, clients and supply
promoting safe work practices with our clients, chain to achieve our sustainability commitments
projects, and contractors; reporting incidents and and deliver on our vision.
violations (even minor injuries and “near misses”);
and having concern and empathy for the well-being
For Further Reference:
of yourself, your family and your colleagues. • GSOP 350 – HSE Program
• Jacobs Sustainability+
For BeyondZero to thrive, it requires effort and
commitment from everyone at Jacobs. You can help
us achieve a healthy, safe, productive and positive Quality Commitment
work environment if you have the courage to care, We work safely and protect the health and safety of
to intervene, and to challenge yourself and your all around us. We strive for flawless execution of our
colleagues to pursue safe practices. If each of us is work, and to deliver superior value to everyone.
committed, we believe we can eliminate workplace
ACTING RESPONSIBLY
IN THE WORKPLACE
We believe the use of alcohol, drugs, or controlled substances
Drug and in the workplace is unsafe and inappropriate.
Alcohol
Use You are responsible for abstaining from drug or alcohol consumption in the
workplace or in any manner outside the workplace that negatively affects
your ability to do your job.
Y
our health and safety is a paramount concern. Anyone using illegal drugs or alcohol, or misusing
Employees are expected to perform their work prescription drugs in the workplace will be subject
free from the influence of alcohol, drugs, or to discipline, up to and including termination.
controlled substances. The use of these substances
creates an unreasonable risk to personal safety, to For Further Reference:
fellow employees, clients, and the public. Alcohol • GPS05-303 – Drug, Alcohol and Contraband
• GPS05-305 – Smoking in the Workplace
may be served at certain company functions, but its
consumption should be in moderation.
W
e maintain a zero-tolerance policy toward Employees are required to report all violent
workplace violence. Workplace violence incidents or threats. Contact authorities in case of
is broadly defined; it ranges from actual imminent danger.
physical assault to threats and verbal abuse and
can take place either at the workplace or elsewhere. For Further Reference:
Damage to property is also prohibited. • GPS05-306 – Employee Conduct and Work Rules
ACTING RESPONSIBLY
IN THE WORKPLACE
We believe conduct in the workplace should be professional, appropriate
and devoted to business efforts.
Appropriate
Work Conduct
You are expected to focus your efforts in the workplace on the Company’s
business objectives and to perform your work in a professional and
appropriate manner.
E
mployees are expected to use their time and other materials owned by third parties unless
energy to perform their job responsibilities permitted by that third party. Downloading
while in the workplace. Use of Company illegal copies of music, films, games or other
resources, such as information systems (i.e. software is also prohibited.
computer equipment, company networks,
• Gambling. Wagering, gambling or playing
accessing the internet) must be appropriate to the
other games of chance is prohibited and
workplace.
detracts from productivity in the workplace.
Points to remember:
Anyone engaging in prohibited use of Company
• Company Information Systems. Transmitting, information systems, or gambling in the workplace,
displaying or viewing images or other media will be subject to discipline, up to and including
that could be offensive is prohibited in the termination.
workplace or on Company information
systems. For Further Reference:
• GPS05-306 – Employee Conduct and Work Rules
• GPS05-304 – Policy Against Harassment
• Software Usage. You may not publish or • GPS06-107 - Information Systems Authorized Use
share any copyrighted software, media or
INTERACTING
WITH OTHERS
We believe in diversity, inclusion, and treating employees fairly.
A
t Jacobs we are committed to promoting and Today, we serve clients through operations in more
celebrating inclusion and diversity. Our than 230 locations worldwide. Our employees
workforce spans the globe, and our diversity come from a variety of backgrounds and bring a
is an asset; we attract and retain talented staff wealth of experience to their work each and every
with many different viewpoints. We expect our day. Additionally, crossing international borders
employees to be respectful of such differences and regularly is vital to our business model.
to treat one another with courtesy and respect.
At Jacobs, inclusion means welcoming global
Jacobs is firmly committed to providing a workplace backgrounds, experiences and ideas. We value
free of discrimination or harassment for any reason inclusion and diversity because it energizes our
including but not limited to national origin, race, people and encourages creativity, collaboration,
religion, sex, age, marital status, sexual orientation, and innovation. Considering diverse points of view
gender, gender identity or other protected status. results in better decisions and solutions for our
clients, our investors and ultimately, our Company.
Our team reflects varied cultures, backgrounds and
experiences which serve to strengthen our Values. As always, I appreciate your dedication to Jacobs’
Enabling all employees to have a voice and provide values and your commitment to serving our clients
their unique perspectives is fundamental to our across the globe.
organizational growth and future success.
Thank you,
Chairman and CEO Steve Demetriou shares his Steve Demetriou
thoughts on the importance of inclusion and
diversity below.
For Further Reference:
Jacobs Reaffirms Commitment to Inclusion • GPS05-301 – Problem Resolution
• GPS05-304 – Policy Against Harassment
Our founder, Joe Jacobs, was born into a Lebanese
immigrant family and went on to build what is
today one of the most successful companies in the
world. My own parents emigrated from Cyprus
many years ago, so I understand firsthand the
importance of a global mind-set and a genuine
respect for others.
HANDLING
PERSONAL DATA
We believe in processing personal data lawfully, securely and responsibly.
You are responsible for handling personal data in a confidential and secure
manner.
A
s the number of ways that personal data We work to protect the privacy of our employees,
can be distributed has increased due to clients, and business partners no matter where they
new technologies, so too has concern about live or work. Personal data may be processed only
maintaining privacy. A number of countries have if authorized and for legitimate business reasons.
responded by strictly regulating the distribution If you are entrusted with personal data, you must
of personal data. Jacobs follows these laws; protect its confidentiality, use it as intended, and
maintaining access, disclosure, retention, and keep it secure. If you learn that personal data has
destruction controls that address the rules in the been improperly released or exposed, you should
countries where we operate. Privacy laws vary from immediately notify your manager, the Privacy Team
jurisdiction to jurisdiction, but as a multi domestic (privacy@jacobs.com) and Jacobs' Cyber Security
company, we’ve designed our global policy to work organization.
across regions and to apply to all employees.
For Further Reference:
• GPS05-110 – Global Privacy Policy
• GPS01-104 – Protection of Confidential Material
• GPS05-106 – Employee Records
Further discussion:
Defining personal data
Personal data contained in personnel or medical records is any information
that can be connected to a natural person and can be used to identify a
person or the unique characteristics of a person's data. It can be contained
in personnel or medical records; common examples of personal information
are date of birth, identification documentation and numbers, passport
information, photographs, address and contact information, and payroll
and banking records and correspondance. Personal data can also include
education details, health and employment history, group membership and
affiliations, and opinions about an individual’s performance or abilities.
PARTICIPATING IN POLITICAL
AND COMMUNITY INITIATIVES
We believe in using our voice as a corporation to educate public officials
and secure support for our priorities.
J
acobs sometimes uses its corporate voice • Community support. You are encouraged to
to educate public officials and promote be an active and responsible citizen in your
government support for relevant issues. community, to participate in civic and support
The Company may express its views through organizations, and to donate to workplace-
contributions to political activities that do not giving campaigns. Remember that volunteering
involve the election of candidates. your personal time can be as important as
donating money.
Except as permitted, we do not use Company
funds for contributions to candidates. You may • Charitable contributions. Corporate
not make contributions on behalf of the Company. charitable contributions are generally made
We encourage you to personally support political through the Company’s philanthropic
causes that are important to you; but such support organization, the Jacobs Engineering
must be done outside the office, on your own time, Foundation. Employees may offer
using your own resources, and in your own name. recommendations of worthy organizations and
causes. Contact your manager if you have a
Contacts with government officials are highly
suggestion. All charitable contributions must
regulated. You may not contact officials, on behalf
be approved by management in accordance
of the Company, regarding a policy, regulation or
with the policies referenced below.
legislation unless the action has been approved by
executive management.
For Further Reference:
Points to remember: • GPS01-103-17 – Charitable and Political Contributions
• GPS01-103-07 – Anti-Corruption Policy
• Political Action Committee. The Jacobs Good • GPS01-108 – Due Diligence of Third Parties
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.
PROTECTING COMPANY
ASSETS AND EQUIPMENT
You are responsible for treating Company assets and equipment carefully
and protecting them from waste, loss, damage, and abuse.
A
t Jacobs, the assets of our Company—that • Protecting company systems. Company
is, things of financial value—belong to our systems may be used to process or store data,
shareholders. This includes tangible assets records, or communications; and they may
such as buildings, furnishings, office equipment, be linked by computers or networks. You
tools, vehicles, cash, and other property used in the must follow all Company security protocols,
execution of our jobs. It also includes intangible including the protection of passwords or access
assets such as data, designs, processes, information numbers to prevent unauthorized use of these
resources, company time, and intellectual property. systems or networks. You are responsible
We are responsible for protecting these assets and for the security of information accessed or
using them in an efficient and economical manner. modified under your password
Theft of Company assets may result in termination or access procedure.
and criminal prosecution. Similarly, property
If you are issued communications and
owned by others—that of coworkers, suppliers and
IT equipment for business purposes, the
customers—may not be used without permission.
equipment and its contents remain Company
Points to remember: property and must be protected and returned.
• Use of equipment. Company equipment, Any loss or theft must be immediately reported.
including copiers, telephone, internet, and
• Use of software. Only approved and licensed
email communication equipment, should
software may be placed on Company
be used for the benefit of the Company.
equipment, and only after it has been checked
Employees should have no expectation of
for viruses prior to installation and use.
privacy when using Company resources
You may not make unauthorized copies of
(except as dictated by local laws). They may
software programs or use personal software on
never be used for offensive or illegal purposes,
company equipment.
conducting a business, or helping a competitor.
Employees are expected to use good judgment
For Further Reference:
for their occasional personal use of Company • GPS05-306 – Employee Conduct and Work Rules
assets. The use must be reasonable in duration, • GPS05-106 – Personal Device Access to Company
Guest/Public Internet
must not result in significant added cost, • GPS06-107 – Information Systems Authorized Use
and must not interfere with our business
or productivity.
I
nformation is a valuable asset of our Company, • The process of ensuring confidentiality.
our clients, and our suppliers. Information that A deliberate approach is necessary to protect
is unknown to the general public and that could confidential information. Only accept sensitive
disadvantage someone by its release is defined as or proprietary information from clients or
confidential. Releasing confidential information suppliers when you really need it. When
can harm our interests. Similarly, misusing creating confidential information, ensure it is
information from others violates their trust in us. treated as such. Familiarize yourself with the
In any contract or interaction, you should have a system of controls we have in place to manage
clear understanding of what information you are the receipt, use, and destruction of proprietary
receiving, how you are to deal with it, and what you information, so that you are able to comply
are to use it for. with this process.
Points to remember: • Exposure to confidential information. Do
• Honest communications. Our relationships not seek out confidential information unless
are founded on truthfulness and openness. We it is vital to the completion of your duties. Get
value honesty not only because it is the right advice immediately if you are inadvertently
thing to do, but also because it contributes to exposed to or receive confidential information.
business profits and productivity. Sometimes
• Gathering business intelligence. We regularly
being honest means speaking up when
gather information about our competitors to
something isn’t right; but even when voicing
help us make business decisions. To ensure
a concern or complaint, be sensitive in how
fair competition and maintain our reputation,
you craft your messages, and remember the
the information we gather must be publicly
difference between fact and opinion. Honesty
available. You may not seek information
extends to our sales materials, which must
through illegal means or by misrepresenting
characterize us fairly and accurately.
yourself, misusing consultants, or exploiting
proprietary information or trade secrets.
Finally, our agents, consultants, suppliers,
and partners must be bound by the
same requirements.
Be loyal to Jacobs, avoid conflicts of interest, and make decisions in the best
interest of the Company.
A
conflict of interest is defined as a circumstance Points to remember:
that creates a risk that professional judgment • Insider trading. Stocks or other securities may
or actions will be unduly influenced by a not be purchased or sold while in possession
secondary interest, usually personal. In other of “material non-public information.” This
words, a situation where the interests of the is defined as information that a reasonable
Company come into conflict with the interests of investor would consider important in making
an individual. an investment decision and that is not known
to the general public. The Company’s financial
You must avoid conflicts of interest that could
results, financial projections, a material
cloud judgment, impair objectivity, and
acquisition or joint venture and material
interfere with good decision-making. You
litigation that have not been broadly disclosed
should never achieve personal gain through a
to the public are just some examples of things
Company transaction or by the use of Company
that may constitute material non-public
information. Corporate opportunities belong to
information. This also applies to information
the Company. Even creating an appearance of
about our clients and others we do business
conflict should be avoided. If a conflict cannot be
with. You are also prohibited from disclosing
prevented, it must be mitigated by full disclosure.
material non-public information to anyone
Disclosure should involve an evaluation of the
other than those within the Company whose
situation by a disinterested party. If you find
jobs require them to have such information.
yourself in a situation that involves a potential
You may not provide “stock tips” to family
conflict of interest, immediately contact your
members or others who may trade on the
manager, the Human Resources department, the
basis of such information. Additionally, our
Legal department or the Ethics & Compliance
directors, senior management and others who
department.
regularly have access to material non-public
information (known as “insiders”) must obtain
pre-clearance before trading in Company
securities and are subject to trading blackout
windows. Insiders are also restricted from
shorting, hedging or pledging Company stock.
INTERACTING WITH
THE MEDIA
We believe in maintaining Jacobs’ reputation by presenting a consistent
message to the media. In order to do this, we follow a policy that prohibits
Jacobs' employees from speaking to the
media on behalf of Jacobs without explicit permission from
Global Communications.
You are responsible for seeking approval from the office of the
Vice President of Global Communications prior to any interaction with the
media on behalf of Jacobs.
J
acobs enjoys the well-earned reputation of a publication or presentation at a conference or trade
company that follows the highest principles of show, to assure that copyright and intellectual
conduct, integrity, and ethics. In our interaction property considerations are properly dealt with.
with the media, we are careful to protect that
Images and photography are critical components
reputation—and the reputations and confidentiality
of our brand. Photography and image use often
of our clients—above all else. We also have special
has stringent copyright, trademark, licensing,
considerations and legal responsibilities as a
intellectual property, right-to-privacy, and client
publicly traded company and must adhere to the
permission requirements. You must comply with
rules of the Securities and Exchange Commission
the rules outlined in Jacobs’ Images & Photography
(SEC) as well as other agencies on occasion.
Style Guide.
For these reasons, all media interaction at Jacobs
Jacobs is proud of the accomplishments and
is handled at Corporate Headquarters. Employees
contributions of our employees and of the work we
are not official spokespersons of the Company and
do. By following Jacobs’ media relations policies
may not participate in interviews or make public
and procedures, we are able to share significant
announcements or statements to the press on
news about our Company’s activities with the
behalf of Jacobs without the prior approval and
public while ensuring that the information is
participation of Global Communications. If you
appropriate, factual, consistent, and in the best
are approached with a media inquiry or interview
interests of our clients and our company.
request, notify Global Communications so the
opportunity can be reviewed and appropriate
action taken. Likewise, all technical papers, For Further Reference:
• GPS01-105 Media Interaction and Press Releases
presentations, and client materials that mention • Images & Photography Module of Jacobs Style Guide
Jacobs must be reviewed and approved by
Global Communications prior to submission for
INTERACTING
ONLINE
E
xercise good judgment when using the Online communication is public and permanent.
internet for personal or professional activities. Whether expressing an opinion or merely
Social media (such as LinkedIn, Facebook, chatting, take precautions to use good judgment.
Twitter and any other service that allows open When you communicate online, you are
exchange over the Internet) has enormous representing yourself; you are not a Company
potential for opening communication, but also spokesperson. You should make it clear that your
carries risks. Standards of honesty, discretion, and communications represent your personal views
confidentiality are as essential online as they are and do not represent Jacobs' views. It is never
in any other setting. You should never release non- permissible to disclose confidential, proprietary,
public financial or operational information about or non-public information related to your work;
your work at Jacobs. whether it belongs to us, a customer, partner, or
supplier.
COMPETING
FAIRLY
We believe in maintaining competitive advantage through fair and
honest means.
You should comply with antitrust laws and compete fairly and
with integrity.
J
acobs provides services of the highest caliber informal—that fix prices, restrain trade, or
and has no need to compromise its integrity promote anti-competitive activities.
to succeed. We are committed to complying
• Dealing with competitors. There is
with antitrust and fair competition laws and believe
certain information we may not share with
everyone benefits from open and free markets.
competitors; such as prices, pricing policies,
Competitive advantage is earned through superior
terms and conditions, trade secrets, intellectual
performance, not through unethical or illegal
property, and business strategies - whether
business practices.
ours or someone else’s. Similarly, we may not
We do not share bid information or make disparage, mislead, or misinform competitors.
agreements with competitors to divide markets, Information passed on during trade shows
allocate customers or locations, or direct the or through industry associations should be
outcome of the bidding process. Our prices are monitored for possible violations of these rules.
determined by the costs we incur, the value we
• Agents, suppliers, and subcontractors may
provide, and the risks we assume.
also be sources of improper information. Be
Points to remember: on guard for improper appearances that may
• Rules we must follow. Many countries, be created when working with others as well as
including the United States and the European substantive issues.
Union, have laws that define anti-competitive
practices. Generally, illegal practices are For Further Reference:
• GPS01-103 - 14 – Antitrust
defined as any agreements—written or
COOPERATION
AND HONESTY
Code of Conduct | Integrity Hotline: +1.844.543.8351 | www.jacobs.com | askaquestion@jacobs.com
Learn more at: https://integrity.jacobs.com. This website can be accessed anywhere in the world confidentially and anonymously. GPS01-103, Rev. 11, Effective July 25, 2018 22
3 D OIN G Y OU R J OB WITH I N T E G R I T Y & D I S C R E T I O N
MAINTAINING RECORDS
AND DOCUMENTS
We believe properly maintained business records provide a necessary
framework to support decisions in day-to-day operations.
You are responsible for keeping records that are timely, correct
and complete.
B
usiness documents play a significant role in • Financial statement reliability. We routinely
tasks such as financial reporting, personnel file certified financial statements for the
management, execution of projects, and investment community and the public.
regulatory compliance. No matter what their As a U.S. public corporation, we are required
purpose, you are required to prepare records to create and maintain a system of controls
that are timely, accurate, complete, detailed, and that is designed to assure the reliability of our
understandable. You must be able to back up financial records. You must understand the
information on records so that they are supportable internal controls relevant to your position and
and auditable. We do not tolerate falsification or commit to following policies and procedures
alteration of records. for complete and accurate accounting. Controls
undergo regular testing by internal and external
Points to remember: auditors to assure the information we provide
• Proprietary or confidential information.
the Securities and Exchange Commission
Many of our business documents contain
complies with regulations, standards, and
information that must be protected from
practices.
improper use or release, either because of the
nature of the information itself (for example • Records retention. Individuals in project and
if it is private, unique, or valuable) or because corporate support positions are responsible
of the requirements of a contract or regulatory for planning the record management needs
authority. We safeguard the security and of their operation through a planning process
confidentiality of documents commensurate that identifies legal and contractual retention
with the sensitivity of the information. requirements, defines access, delineates
Disclosure requires proper prior approval and preservation and storage, and sets destruction
a legitimate business need. schedules. Records may not be destroyed
contrary to directions or if there is a reasonable
• Labor Accounting. Time is a precious
possibility they will be necessary to an
Company asset. We bid it, sell it, and bill for it.
investigation or litigation.
Time is the primary source of our revenue and
critical to our profitability. A timesheet is the
legal authority to both pay an employee and For Further Reference:
• GPS01-106 – Records Retention
get reimbursed by a client. Our policy requires • GPS01-107 – Operations-Labor Charging Procedure
employees to provide an accurate and timely
accounting of their hours worked and leave
used, entered in their timesheets.
PREVENTING BRIBERY
AND CORRUPTION
We believe in winning jobs and executing work honestly, without resorting
to bribery, corruption, or kickbacks.
You are responsible for behaving legally and ethically, as well as for
understanding and following our anti-corruption policy.
A
t Jacobs, we develop and maintain business true when dealing with government officials.
relationships without giving improper gifts, Hospitality may be offered to clients when it is
taking unfair competitive advantage, or permitted by law, consistent with customary
receiving kickbacks. We win jobs and execute business practices, and when the client’s policy
our work honestly and ethically, whether in our permits it. Hospitality or modest refreshments
dealings with public entities and government offered during business hours in an office
officials, or the private sector. Every country in setting are generally allowed. Gifts or other
which we operate has laws against corruption. It is courtesies must be reasonable, modest, and
a crime to offer, promise, pay or receive anything of offered with no expectation that anything will
value to secure and maintain business or gain an be provided in return. Before you offer any Gift
improper advantage, and a violation of our ethical or Hospitality, you must familiarize yourself
standards to fail to execute work honestly and with the Gift and Hospitality Policy for further
ethically. These laws restrict us in giving business detailed guidance which may prohibit such
courtesies to government officials. Anything of business courtesies, or require advance written
value can be a bribe or create the false impression approval if they exceed certain monetary
of a bribe. Keep in mind that even the perception of thresholds.
corruption harms our reputation, and we strive to
• Soliciting or accepting Gifts and Hospitality.
avoid even the appearance of wrong-doing.
You may never request or solicit a Gift,
Points to remember: Hospitality, meal or anything of value. When
• No bribery or corruption. At Jacobs, we do not offered (unless you are in a procurement
offer or accept bribes or kickbacks in role), you may accept small memorabilia, or
any form and we do not tolerate corruption promotional or token items of modest value.
in connection with any of our business Gifts must be infrequent, transparent, and
dealings. You may not offer or receive bribes or received with no obligation or expectation
kickbacks to, or from, any individual, whether of a reciprocal action. Before you accept any
that individual is a government official or a business courtesies, you must familiarize
private party. yourself with the Gift and Hospitality Policy for
further detailed guidance which may prohibit
• Offering Gifts and Hospitality. Gifts,
your acceptance of such Gifts or Hospitality or
Hospitality, and other business courtesies
require advance written approval if they exceed
must be carefully handled to avoid even the
certain monetary thresholds.
perception of corruption. This is particularly
PREVENTING BRIBERY
AND CORRUPTION
• Making facilitation payments. Payments our judgment. It is presumed that the bribe is
made to expedite routine government actions included in the subcontractor's price.
— known as facilitation payments — are
prohibited. Facilitation payments are typically Defining government officials
demanded by low level and low income A government official is any official of a
officials in exchange for providing services government, political party, candidate, or an
to which one is legally entitled without such employee of a company owned or controlled by
payments. While they may be small in value, a government. Jacobs’ policy prohibits offering
or even customary, it is impossible to regulate anything of value to any government officials.
and constitutes an illegal practice in most Defining improper advantage
countries. An improper advantage is anything to which
the Company was not clearly entitled possibly
• Due Diligence on third parties. Before we
through collusion or coercion. In other words, it
form a relationship with a third party, we must
is a preference or benefit that has been secured
obtain internal approvals and exercise due
improperly, regardless of the cost expended or the
diligence on the backgrounds and business
value received.
practices of individuals and entities who will
act on our behalf. Defining collusion
The agreement or arrangement for illegal, deceitful,
For further discussion:
or improper purposes.
Defining bribery
Anything of value can be a bribe. This includes
Defining coercion
The threat or use of force or power to compel an
money, gift cards, travel expenses, meals
action or decision against one’s will.
and drinks, lodging, gifts, services, prizes,
entertainment, recreation, and political and For Further Reference:
charitable contributions. • GPS01-103-07 – Anti-Corruption Policy
• GPS01-108 – Due Diligence of Third Parties
Defining kickbacks • GPS01-103-12 – Gift and Hospitality Policy
• GPS01-103-17 – Charitable and Political Contribution Policy
A kickback is when a supplier or subcontractor • GPS01-109 – Supplier Code of Conduct
offers or pays us a bribe to improperly influence
UNDERSTAND OUR
ANTI-CORRUPTION
POLICY
COMPLYING WITH
INTERNATIONAL TRADE LAWS
We believe in the importance of trade laws and we comply with all relevant
restrictions.
E
xport control laws govern international borders, therefore the rules can become
trade and affect the transmission of goods, very complex. Not adhering to them could
services, and technology across national expose the Company and individuals to
borders. The U.S. restricts the shipment, fines, penalties, and other more serious
transmission, and transfer of certain types of consequences. It is crucial that you seek advice
information, technologies, or products overseas on trade regulations from your office’s legal
or to foreign nationals on U.S. soil. The rules also representative before making commitments or
apply to “re-exports” from one foreign country engaging in action. This is also true if we have
to another. partners or agents acting on our behalf.
We recognize that countries have differing • Exempt activities. Although many of our
regulations regarding commerce, and that activities are exempt from export controls,
some may conflict with those of the U.S. As an some may be restricted and some may require
employee of a U.S. corporation, you must comply a license. Even if our activities are excluded or
with U.S. rules, no matter where you are located exempted, regulations dictate that we must be
or where you are doing business. Consult with able to document that certain activities do not
your manager if you discover a conflict between require a license and provide a record of export
U.S. law and applicable local law. control reviews demonstrating the exemption.
Our Company does not conduct commerce with • Conflicts with U.S. sanctions. As an
countries against which there is an embargo or employee of a U.S. registered company, you
other prohibition. We comply with U.S. anti- are responsible for complying with any U.S.
boycott laws that prohibit refusing to do business sanctions that may be in effect. Home country
with certain countries, people, or organizations, sanctions may also apply. If you are in a
and we report requests for boycott information situation where home country sanctions are in
when required. conflict with U.S. sanctions, seek advice from
the Legal department. In general, the most
Points to remember: severe or restrictive sanction usually applies
• Complying with export restrictions.
in such situations.
Our goods and services are produced in
many countries and shipped across many For Further Reference:
• GPS01-103-9 – Compliance with Export Laws
You are responsible for understanding and complying with Jacobs’ public-
sector policies.
D
oing business with public-sector customers act as a resource for the entire Company. If
often means following different rules than you need advice on this topic, reach out to
those for private-sector clients. Jacobs’ strict the following:
compliance programs for government clients
• The Contracts Management Group
ensure that we meet all the qualifications of public-
sector contracting. These programs, combined with • The Legal department.
our integrity and operational excellence, boost our
reputation and contribute to our status as a market • Special accounting and estimating
leader. You need to know how these programs and personnel in the Accounting and
policies affect you, and you must always act with Finance Group.
awareness of these issues when dealing with public • Business Development staff who sell to
clients. public-sector agencies.
Points to remember: • Working with classified or restricted
• Procurement Integrity. The U.S. government information. When working on a project that
— as well as many other public sector entities involves classified or restricted information,
— prohibits obtaining, using, or disclosing you have a responsibility to safeguard emails,
contractor bid, proposal, or source selection electronic documents, and printed information
information. This prohibition applies to pertaining to the project. Use appropriate
Jacobs, to our agents, and to current or former security measures with regard to passwords,
government employees. keeping track of equipment, locking files
Additionally, this prohibition limits our containing confidential data, and taking
ability to hire or even discuss employment particular care to keep their systems and
opportunities with federal employees who are sensitive data secure from unauthorized access.
or were substantially involved in procurement It is also important that you securely dispose
involving Jacobs. Please understand that these of unnecessary confidential information in an
prohibitions may apply to other public sector approved manner.
work as well.
For Further Reference:
• We’ve built a strong team of experts in public- • GPS01-103-6 – FAR 52.203.13 – Compliance Program
• GPS05-109 – Hiring of Government Officials, Former Government
sector contracting who understand the Officials, and Relatives of Government Officials, and External
complications of these rules. These experts Requests for Hiring
EXPERT ADVICE IS
JUST A CLICK AWAY.
askaquestion@jacobs.com
INVESTIGATING VIOLATIONS
AND PROHIBITING RETALIATION
We conduct fair and thorough reviews of possible non-compliance with our
policies, and appropriate consequences for violations will be enforced.
You are responsible for cooperating with audits and investigations and
complying with corrective measures.
W
e encourage employees to report any for such actions, refusals, or reports. We will review
questionable accounting and auditing complaints of retaliation, and any attempted or
practices, policy violation, or other actual retaliatory action which may subject the
wrongdoing. You may do this in confidence, violator to disciplinary action, up to and including
anonymously where allowed by law, and without termination of employment.
fear of retaliation. Additionally, the U.S. and many
We will take all reasonable steps to protect
other governments around the world provide
and respect the rights of a person who reports
protections to those who report violations.
alleged improper, unethical or illegal conduct
We conduct audits and internal investigations to or who participates in an investigation.
check for compliance with policies and rules, to If you become aware or are concerned about
follow-up on reports of non-compliance, and to departures from, or an attempt to depart
assess the effectiveness of our programs. We strive from, the Code of Conduct, or other improper,
to be prompt and fair in our investigations. We unethical, or illegal conduct, please contact
cooperate with government investigations and the Ethics & Compliance department at
inquiries to the greatest extent possible. Should you compliance@jacobs.com or through
be informed of any warrants, subpoenas, or court the Jacobs Integrity Hotline at
orders regarding your work, you must contact the https://integrity.jacobs.com (1.844.543-8351 in
Legal department immediately. If you are involved the US); see page 28 for international numbers or
in an investigation, you are expected to cooperate askaquestion@jacobs.com.
fully and comply with corrective measures if they
are found to be needed.
For Further Reference:
Jacobs and Jacobs personnel do not retaliate • GPS01-103-8 – Audit and Investigation
• GPS01-103-15 – Whistleblower Protection
against individuals who engage in activities that are
consistent with Jacobs policies, refuse to engage in
unlawful activities, or make a good-faith report of
wrongdoing or policy violation. No personnel shall
be discharged, demoted, suspended, threatened,
harassed, or in any other manner discriminated
against in the terms and conditions of employment
*Please note that countries with the line type “WWC” (World Wide Connect) are a two-step dialing process.
The reporter first has to dial a country-specific access code, followed by your domestic number.
**ITFS, GIS, Domestic, Collect calls are a one-step dialing process rather than two-step. If it’s a one-step dialing process,
there is no AT&T Direct Access Code listed.
Code of Conduct | Integrity Hotline: +1.844.543.8351 | www.jacobs.com | askaquestion@jacobs.com
Learn more at: https://integrity.jacobs.com. This website can be accessed anywhere in the world confidentially and anonymously. GPS01-103, Rev. 11, Effective July 25, 2018 32
4 CON C LU S ION
ASK BEFORE
YOU ACT
With Jacobs’ Vision, Mission and Values in mind and this Code as a
guide, you can properly navigate most situations you come across in
the course of your work.
POLICY INDEX
GPS01-103-06 FAR 52.203-13 Compliance Program
GPS01-103-07 Anti-Corruption Policy
GPS01-103-08 Audit and Investigation
GPS01-103-09 Compliance with Export Laws
+1.214.638.0145 | www.jacobs.com