aecom code of conduct -...

AECOM CODE OF CONDUCTCourse Workbook

Table of ContentsA Message from the CEO 3

Introduction 4

Respect for Our Colleagues 6

Protecting Company Interests and Assets 11

Conducting International Business 17

Doing Business With the Government 22

Fair Dealing 27

Following Community Standards 32

Asking Questions and Reporting Concerns 33

Test Your Knowledge 37

© Corpedia 3 AECOM Code of Conduct Course

A MESSAGE FROM THE CEO As AECOM has grown and evolved as a global company, much has changed. But one constant continues to be a vital part of our culture — our commitment to integrity.

We have succeeded in earning our clients’ trust by delivering outstanding customer service and fully committing to acting ethically in all that we do. Integrity, our paramount Core Value, guides us as we conduct our business around the world. As employees, each of us is obligated to act with the highest degree of integrity and in full compliance with the law.

To help us understand the ethical and legal guidelines that must direct our business activities, we rely upon our Code of Conduct and update it periodically so that it remains timely and relevant to our work. Our Code is not a substitute for good judgment, nor does it cover every situation that you may encounter or every law that applies to us as a global company. It does, however, outline the basic legal guidelines that we must follow and the general ethical principles that will help each of us make the right decisions when conducting business on AECOM’s behalf worldwide.

If you find yourself in a situation in which you are unsure how to act, believe that a violation of the Code could or has occurred, or have a question about a particular issue, please seek assistance. Our Code contains a number of resources that you may use to resolve or report any issue related to ethics and compliance without fear of retaliation. You can be assured that the company will help and assist you in doing the right thing.

Continuing to conduct our business in an ethical manner will help ensure long-term success for AECOM, our employees, clients and shareholders. You have my personal commitment that I will do all I can to ensure that the Code is observed and honored at every level of our great company.

Thank you for your continued dedication to AECOM and for your commitment to our culture of integrity and ethical behavior.

Sincerely,

Michael S. Burke


Chairman and Chief Executive Officer

INTRODUCTION Welcome to the AECOM Code of Conduct training course.

Our Code of Conduct, or the Code, sets forth AECOM’s commitment to integrity and ethics in everything we do. AECOM believes in the principle of one AECOM, one Code. This means that AECOM expects everyone in the company to read, understand, and follow the Code.

Although the Code covers a wide range of practices and procedures, it cannot address every situation you may encounter. It is a guide to your responsibilities and provides assistance in making the correct decisions. If you ever have a question regarding the Code, do not hesitate to contact your supervisor or someone in Management, a Human Resources Representative, or an AECOM In-House Counsel.

You will never face retaliation for seeking guidance or making a good faith report.

Our commitment to ethical conduct and our Code are founded on AECOM’s Core Values.

Our Core ValuesSafeguard

• We operate ethically and with integrity, while prioritizing safety and security in all that we do

Collaborate• We build diverse teams that connect expertise to create innovative

solutions

Inspire• We develop and celebrate our people, and elevate the communities

we touchAnticipate


• We understand the complexity of our clients’ challenges and help them see further

Deliver• We grow our business through operational excellence and flawless

execution

Dream• We transcend the industry by reimagining what is possible – and realizing it

Course ObjectivesDuring this training you will learn about the practices and procedures that you must follow in order to do your job with integrity and avoid even the appearance of improper or illegal behavior.

The course will go through the key components of the Code and highlight best practices and expected conduct. At the end of the course, you will be tested on what you have learned.

In this course, you will learn to

• Use the Code of Conduct to guide you in making ethical decisions • Report suspected unethical situations if they arise


RESPECT FOR OUR COLLEAGUES

DiversityAECOM values all employees, and strives for a workplace that fosters dignity and respect. At AECOM, we believe that the differing backgrounds, experiences, and perspectives of our people give the company strength to lead in the marketplace.

The company offers equal employment opportunities for all employees and applicants. All decisions regarding recruitment, hiring, training, promotions, transfers, and layoffs are based on merit. We do not discriminate against anyone based on

• Age• Ancestry• Color• Sex• HIV status• Marital status• Medical condition• National origin• Physical or mental disability• Race• Religion• Sexual orientation• Gender identity • Veteran and citizenship status


HarassmentHarassment is any sexual or nonsexual action that creates or seeks to create a hostile, intimidating, or offensive work environment, or that interferes with a person’s work performance.

Harassment includes

• Verbal remarks, such as derogatory comments, suggestions, jokes, or requests for sexual favors

• Visual harassment, including drawings, photographs, or videos • Physical harassment, including leering, inappropriate gestures, or

unwelcome touching

AECOM does not tolerate harassment in any form, regardless of whether you are on company premises or engaged in work outside the workplace. If you experience or witness incidents of harassment or discrimination, immediately report it to Management, Human Resources, or In-House Counsel.

You will not face retaliation for making a report.

ActivityCan you identify and avoid potentially harassing or discriminatory behavior? Mark the light on the traffic signal to indicate how you should proceed.

Stop now

Use caution

Go ahead

Travis often pokes fun at a speech-impaired coworker by mocking the coworker’s communication skills

Stop now

Use caution

Go ahead

Charlie makes repeated derogatory comments about Sahlah’s Muslim faith, even though she has repeatedly asked him to stop

Stop now

Use caution

Go ahead

Mary offers Kate a handshake and says, “Welcome to the team. You’ll be a great addition”


Stop now

Use caution

Go ahead

Jenn tells her coworkers a racially themed joke she heard on a late-night TV show

Stop now

Use caution

Go ahead

Eliza hugs her coworker when he returns from sick leave

Stop now

Use caution

Go ahead

When Keyur works on team projects at work, his coworkers always put him in charge of sales forecasts because they tell him Asians are good at math

Stop now

Use caution

Go ahead

Dexter’s coworkers at the construction site constantly tease him because of his age and tell him he’s too old to work

Stop now

Use caution

Go ahead

Charisse knows Jacob could use a laugh, so she forwards him a link to a lewd video on the Internet

Stop now

Use caution

Go ahead

Jose accidentally bumps into Trent and says, “I’m sorry. Excuse me!

FeedbackHarassment can take many forms, including derogatory comments about disabilities and religious beliefs. It can also include unwelcome physical contact, bigoted statements, inappropriate jokes, references to racial or ethnic stereotypes, and pressure to participate in unwelcome activities.

It’s not harassment to touch someone by accident or to perform common courtesies such as holding a door open for a coworker or providing a well-earned compliment concerning work. But, you should be careful not to engage in conduct that could seem improper or offensive to others.


Check your answers.

Stop now Travis often pokes fun at a speech-impaired coworker by mocking the coworker’s communication skills

Stop now Charlie makes repeated derogatory comments about Sahlah’s Muslim faith, even though she has repeatedly asked him to stop

Go ahead Mary offers Kate a handshake and says, “Welcome to the team. You’ll be a great addition”

Stop now Jenn tells her coworkers a racially themed joke she heard on a late-night TV show

Use caution Eliza hugs her coworker when he returns from sick leave

Stop now When Keyur works on team projects at work, his coworkers always put him in charge of sales forecasts because they tell him Asians are good at math

Stop now Dexter’s coworkers at the construction site constantly tease him because of his age and tell him he’s too old to work

Stop now Charisse knows Jacob could use a laugh, so she forwards him a link to a lewd video on the Internet

Go ahead Jose accidentally bumps into Trent, and says, “I’m sorry. Excuse me!”

Workplace SafetyAt AECOM, the safety of employees, customers, and the public is of vital importance. The company makes every effort to comply with all applicable laws, regulations, policies, programs, and procedures involving health and safety.

It is everyone’s responsibility to maintain a safe work environment. Promptly report any job-related injury or illness, and be sure to comply with all emergency and security policies at facilities and worksites.

AECOM requires an environment that is free from threatening behavior and violence, including intimidation and physical harm. If you witness or experience a threat or act of violence, immediately report it to Management, Human Resources, or In-House Counsel.


If you experience an immediate threat to your safety or the safety of a colleague, contact local law enforcement immediately, and then report the incident internally.

A safe workplace is a drug-free workplace. Drugs and alcohol impair judgment and could interfere with your ability to perform your job safely. Therefore, the company prohibits anyone from working while impaired by alcohol, drugs, or any medication that could raise questions concerning your ability to work safely.

Global Employment StandardsAECOM operates around the world and maintains a strong commitment to the global community. We need to uphold individual human rights and follow all applicable employment laws in the locations where the company conducts business.

We hold our business partners to the same high standards. You should never conduct business with any business partner, supplier, or third party that engages in forced labor or human trafficking.

If you have reason to believe these practices are taking place, immediately report the situation to Management, Human Resources, or In-House Counsel.


PROTECTING COMPANY INTERESTS AND ASSETS

Avoiding Conflicts of InterestAECOM’s success depends on its commitment to honesty and integrity. Therefore, you must avoid actual or potential conflicts of interest.

A conflict of interest occurs when your personal interest makes it difficult to make objective business decisions on behalf of AECOM or calls your integrity into question.

Examples of conflicts of interest include

• Conducting AECOM business with family and friends• Supervising anyone with whom you have a family or romantic relationship • Taking advantage of opportunities you learn about through your

employment without first giving AECOM a chance to pursue or refuse it• Being employed by or consulting with another organization if it interferes

with your primary responsibilities at AECOM • Making significant investments in AECOM’s competitors, customers,

suppliers, or other business partners

If you become aware that a potential conflict exists, you should disclose the facts of the situation to Management, Human Resources, or In-House Counsel, who will determine whether a conflict exists and what you must do to resolve it.

In addition to these personal situations, organizational conflicts of interest can arise in work with government customers. It is essential that AECOM avoid any government contracting situations where our objectivity and fairness are called into question. You will learn more about organizational conflicts of interest later in the course.


Gifts and EntertainmentGifts and entertainment are a normal part of doing business and can help maintain strong business relationships with those with whom we conduct business. However, gifts are inappropriate if they are intended to influence business decisions or call your or the company’s integrity into question.

Consult with In-House Counsel before giving or receiving gifts, meals, or entertainment.

Appropriate courtesies may include a modest meal with a client or a gift of nominal value, such as a cap or t-shirt with a logo.

Never offer or accept a courtesy if it

• Involves a party in an active procurement with AECOM• Is cash or a cash equivalent, such as a gift card • Is sexually oriented, inappropriate, or violates another law or policy• Is lavish or extravagant or• Happens on a frequent basis

Also avoid courtesies that • Are part of an agreement to do or receive something in return• Could influence business dealings• Could be interpreted as a reward for preferential treatment or• Might be construed as a bribe or kickback

Use extra caution if you plan to provide anything of value to a government official. You will receive additional guidance on this topic later in the course.

ActivityIs this situation acceptable or not? Check the box for the correct answer.

Acceptable Unacceptable

One of our suppliers offers to take Sarah and her family on an all-expenses-paid vacation to an amusement park destination.


A long-time client sends Philip a thank you card that also contains a $25 gift card to his favorite coffee shop.


Maria is invited to a modest lunch by a supplier who wants to discuss a current contract.



After a long team meeting, a business partner suggests Francine’s team get happy hour drinks at a restaurant known for its scantily clad servers.


Terrell receives a gift bag of sample merchandise while exiting a vendor’s session at a conference.


Misty receives a dozen roses from a new supplier with a card inviting her to dinner at Chez Deluxe to “talk about personal business”.

FeedbackGenerally, it is okay to accept modest gifts and entertainment from suppliers, business partners, and clients. However, gifts are inappropriate if they are intended to influence business decisions or call your or the company’s integrity into question. Always consult with In-House Counsel before accepting courtesies.

Remember, stricter requirements may apply when working with public sector workers or government officials.

Check your answers

UnacceptableOne of our suppliers offers to take Sarah and her family on an all-expenses-paid vacation to an amusement park destination.

Unacceptable A long-time client sends Philip a thank you card that also contains a $25 gift card to his favorite coffee shop.

Acceptable Maria is invited to a modest lunch by a supplier who wants to discuss a current contract.

UnacceptableAfter a long team meeting, a business partner suggests Francine’s team get happy hour drinks at a restaurant known for its scantily clad servers.

AcceptableTerrell receives a gift bag of sample merchandise while exiting a vendor’s session at a conference.

UnacceptableMisty receives a dozen roses from a new supplier with a card inviting her to dinner at Chez Deluxe to “talk about personal business.”


Protecting Company PropertyAECOM has acquired both physical and intangible assets, and it is everyone’s responsibility to use them appropriately.

AECOM’s physical assets include

• Buildings • Facilities • Vehicles• Equipment • Computer systems• Resources • Records

Make sure you protect physical property from loss, damage, misuse, theft, and waste. Ensure that you use company resources wisely and only for business purposes.

Protecting Business Confidential InformationIn addition to physical assets, you have an obligation to protect intangible assets, such as AECOM’s reputation and goodwill in the communities in which we operate.

You must also protect the company’s business confidential information, including

• Business plans• Intellectual property• Proposals• Technical innovations• Designs• Inventions• Patents• Financial information• Personnel files• Client lists • Other information AECOM produces as part of its operations


Never reveal business confidential information to outside parties unless authorized or legally required to do so. Also, avoid revealing such information to colleagues who do not have a legitimate business need to know the information. If you have a business need to disclose business confidential information with someone outside the company, you need to ensure that a proper confidentiality agreement is in place.

Also, make sure you do not unintentionally disclose business confidential information. Do not discuss this information in elevators, taxis, restaurants, airports, airplanes, or other public places where information could be overheard.

AECOM expects you to treat client, partner, and third party business confidential information with the same care.

You have an obligation to protect the company’s business confidential information even after your employment with AECOM ends. For example, never share AECOM’s business confidential information with a future employer.

If you discover or suspect an unauthorized use or disclosure of business confidential information, immediately notify Management, Human Resources, or In-House Counsel.

Using Company Computer SystemsAECOM provides computer resources, networks, and Internet for business purposes. Although AECOM allows occasional personal use of these resources, this must never interfere with your work responsibilities.

You should never use computer resources to

• View or share sexually explicit or offensive materials• Spread discriminatory or harassing comments, or threatening or abusive

language • Download unlicensed or illegal material

Keep in mind that all electronic materials stored on or transmitted through AECOM computers or networks are the property of AECOM. The company may monitor system use or disclose these materials without notice, where allowed by law.

Social media, including blogs and social networking sites, provides AECOM opportunities to engage stakeholders. However, remember that your electronic messages on these sites are permanent, and can be altered or distributed around the world without AECOM’s consent.


If you use social media for personal business, never share AECOM’s business confidential information or post information about AECOM you are not otherwise permitted to share. Make sure others know that your views are your own and do not reflect the views of AECOM.

It is essential that you

• Follow all AECOM policies and procedures for using electronic resources and social media

• Never speak or act on AECOM’s behalf unless authorized to do so

Notify Management, Human Resources, or In-House Counsel if you know of or suspect an inappropriate use of AECOM’s electronic resources.

Scenario

Brad often takes a walk during lunch to clear his head and catch up on emails. One day he takes out his personal cell phone and updates his social media account, typing, “Busy day! Tired! Great changes coming on the board of directors! Also, clients are still really pressing us. Hope we can finish European Union courthouse project on time!”

Which of Brad’s actions are against AECOM policy?

Mark all the answers that are correct.

A. Checking personal email on a lunch breakB. Updating social media status on a personal cell phone on his own timeC. Revealing business confidential information regarding board activitiesD. Mentioning the status of an ongoing project for a specific clientE. Revealing that he is busy and tired

FeedbackIf you chose C and D: Correct! It is generally acceptable to take personal time, and to use a personal cell phone, to check email and update your social media accounts. You are generally permitted to talk in non-specific terms about your work day. However, you must never reveal business confidential information regarding other employees or changes at the executive level. You should not discuss the status of ongoing AECOM projects.


CONDUCTING INTERNATIONAL BUSINESS

Anti-Corruption LawsAECOM is subject to a number of international anti-corruption laws, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act. Both laws prohibit giving, offering, or promising bribes or improper payments to foreign government officials. The UK Bribery Act goes even further to prohibit commercial bribery—offering or accepting bribes to or from customers, suppliers, or their agents.

Who are considered foreign government officials?

Government employees on the federal, state, provincial, or local level, and also political candidates and employees of foreign government-owned businesses

A bribe is not just a cash payment, but anything of value given to influence an official’s actions or decisions, obtain or retain business, or acquire an improper advantage.

What can bribes include?

Gifts, meals, entertainment, business incentives or “commissions,” travel expenses, job offers, or bogus contracting positions

You should also never return money already paid or due to be paid as a reward for business. This is a “kickback” and is strictly prohibited.

You must never use a third party to make a payment AECOM cannot make on its own, including payments to any person or third party you believe will pass it on to conduct illegal or unethical business.


In some places it may be customary or expected to make facilitating payments, which are small, infrequent payments to expedite routine government actions, such as issuing visas or work permits. AECOM prohibits making even small payments, except in the case of employees in danger. If you become aware of an improper gift or payment, or if a government official or third party requests a payment from you, report it immediately to the Office of Ethics & Compliance.

Scenario

Tal is in charge of an overseas construction crew. Due to an unexpected equipment breakdown, he had to have specialty parts exported from an AECOM facility in the United States. The parts arrived in the country, but are being held up in customs. The delay at the port is causing critical problems with project scheduling, so Tal asks some of his colleagues for advice.

Who gives Tal the best advice? Mark the best answer.

A. Graeme: Offer a few hundred dollars to a customs official and see if he’d be willing to speed things up

B. Roz: I know of an agency by the port that will pay to get the parts through customs quickly if we provide them $1000

C. Paula: Check with In-House Counsel or Management to determine the next step

FeedbackIf you chose A: Incorrect. AECOM does not permit even small facilitation payments except in the case of employee danger. Tal should immediately contact In-House Counsel or Management to determine the best course of action.

If you chose B: Incorrect. It is not permissible to use a third party to make a payment AECOM cannot make on its own. Tal should immediately contact In-House Counsel or Management to determine the best course of action.

If you chose C: Correct! Tal should immediately contact In-House Counsel or Management to determine the best course of action.


Trade and Export RegulationAECOM’s global business requires compliance with all applicable international trade and export control regulations, including licensure requirements. Failure to follow the law puts our international business at serious risk.

An export occurs when a product, service, technology, or piece of information is shipped to a person in another country. An export can even occur without crossing borders, such as when information is provided to a non-U.S. citizen located within the United States during a meeting, over the phone, by facilities inspections, or through letters, faxes, or email.

Ensure you obtain the required licenses before exporting any product with strategic or security capability, including

• Computer software containing certain encryption or performance standards

• Military products, technology, or know-how• Classified materials

If you ever have a question about exports or licensure, contact the Ethics & Compliance Office.

International Sanctions and BoycottsIn addition to trade and export controls, many of the countries where we conduct business impose sanctions or adhere to sanctions imposed by organizations such as the United Nations or the European Union. Sanctions restrict or prohibit dealings with a country, entity, or individual.

AECOM must comply with economic sanctions to which it is subject, including restrictions on financial transactions, travel, and imports and exports.

If you have questions about a sanction program, contact In-House Counsel or Ethics & Compliance.

AECOM’s global presence also means it may receive boycott requests. However, U.S. law prohibits the company from participating in boycotts prohibited by the U.S. government, such as the Arab League boycott of Israel. If you receive any boycott requests, report the matter immediately to In-House Counsel or Ethics & Compliance. It’s not enough merely to refuse; you must report.


Scenario

Boris in sales was contacted by a company in the Middle East that was seeking assistance with an oil drilling project. Boris received approval to send a contract, which the company signed and returned to Boris. The contract came back with an additional clause stating that none of AECOM’s labor or parts can originate in, pass through, or benefit Israel.

What is Boris’s best course of action? Mark the best answer.

A. Recommend proceeding with the contract, taking special care to abide by the contract’s terms

B. Report the issue to In-House Counsel or Ethics & ComplianceC. Tell the team in charge of the project to classify Israeli parts or labor as

U.S. in origin D. Call his contact at the Middle Eastern company and try to re-negotiate

the contract without the boycott provision

FeedbackIf you chose A: Incorrect. AECOM may not participate in an unsanctioned boycott. Boris should immediately contact In-House Counsel or Ethics & Compliance and notify them of the contract provision.

If you chose B: Correct! AECOM may not participate in an unsanctioned boycott. Boris should immediately contact In-House Counsel or Ethics & Compliance and notify them of the contract provision.

If you chose C: Incorrect. AECOM may not participate in an unsanctioned boycott or engage in illegal or unethical behavior to circumvent the terms of an illegal boycott. Boris should immediately contact In-House Counsel or Ethics & Compliance and notify them of the contract provision.

If you chose D: Incorrect. Although a re-negotiation may eventually be necessary, Boris should not try to negotiate around this contract provision on his own. It’s not enough merely to refuse to cooperate with the illegal boycott.


Preventing Money LaunderingAECOM is committed to financial integrity, and this includes the global fight against money laundering.

Money laundering occurs when an individual or group attempts to conceal illegal funds or tries to make the source of illicit funds look legitimate.

To prevent this situation, it is essential that you always perform due diligence on customers, suppliers, intermediaries, and other business partners who wish to conduct business with AECOM.

Watch for red flags indicating that money laundering could be taking place. You need to know your clients and ensure that they

• Maintain a physical presence• Conduct legitimate business • Have proper controls in place

If you suspect possible money laundering, contact In-House Counsel.


DOING BUSINESS WITH THE GOVERNMENT

Government ContractingAECOM has long-standing and valuable relationships with government agencies that are key to our success. This means the company must be especially carefully to comply with the strict laws and regulations that apply when working with government entities. The consequences for violating these regulations are serious, both for the individuals involved and AECOM, including substantial fines, prison time, and getting barred from future government contracts.

During the government procurement process, you should• Provide current, accurate, and complete figures for cost or pricing data • Never receive or disclose confidential bid information belonging to

AECOM or a competitor

When fulfilling a government contract, you should never

• Deviate from contract specifications, such as by substituting materials or suppliers or failing to perform required tests

• Charge incorrect or unauthorized costs on government contracts• Use government property, equipment, or supplies for personal or non-

contractual uses

Always act with honesty and integrity, and protect all government-classified information you acquire in connection with your work.

If you know of or suspect a violation, immediately contact In-House Counsel or Management.

Time ChargingBoth client contracts and government projects require complete and accurate records. Honesty and integrity start with you, especially at the beginning and end of your scheduled work shifts. Always make sure that your weekly time reports accurately reflect hours worked on specific orders or projects.

Therefore, charge all time worked only on that project, and no other.


If you are a supervisor, you should only approve accurate employee time sheets completed according to AECOM policy.

Mischarging time exposes AECOM and the responsible individual to potential criminal and civil liability. If you are aware of or suspect mischarging, or if you are ever asked to charge time in violation of AECOM policies, immediately report the situation to your supervisor, Human Resources, or In-House Counsel.

Organizational Conflicts of InterestDue to the strict rules and restrictions that apply to working with government clients, there is a significant risk for organizational conflicts of interest. These situations often arise where a company’s performance on one government contract provides an unfair competitive advantage when bidding on another project or calls into question the fairness of the situation.

For example, if AECOM assisted the government in creating specifications for a project, it may be a conflict of interest for AECOM to then bid for the project itself—even if the tasks are handled in different divisions. Likewise, if a contractor assisted the government in preparing the specifications for a project, it may be a conflict for the contractor to then assist AECOM in the bidding process for that project.

AECOM has a responsibility to avoid these types of conflicts and to avoid working with third parties who may not be able to provide clients with impartial assistance or advice—in other words, contractors who may have impaired objectivity or who might provide an unfair competitive advantage.

Scenario

Charlene is an AECOM manager. She recently hired Jonah from an AECOM contractor, and he is eager to get started. Jonah discovers that the government is now funding a project for which his former employer created the specifications and that the bidding process is open for the actual build. He asks Charlene whether or not he can bid on the project.

Can Charlene advise Jonah to move ahead with the bid? Mark the correct answer.

A. Yes; Jonah is now an AECOM employee, so there is no conflictB. No; since Jonah’s former company assisted with the project

specifications, Jonah’s bid would be strictly illegalC. Maybe; Charlene should seek advice from In-House Counsel to

determine whether an actual conflict exists


FeedbackIf you chose A: Incorrect. Just because Jonah now works for AECOM does not mean there is no conflict. Since Jonah’s former employer was involved in creating the project specifications, there may be a potential for conflict as Jonah may have knowledge that could give AECOM an unfair advantage.

If you chose B: Incorrect. Just because Jonah worked for the former contractor does not mean it is strictly illegal to bid on this project. Charlene must seek advice from In-House Counsel to determine if Jonah may bid on the project.

If you chose C: Correct! Since Jonah’s former employer was involved in creating the project specifications, there may be a potential for conflict as Jonah may have knowledge that could give AECOM an unfair advantage. Charlene must seek advice from In-House Counsel to determine if Jonah may bid on the project.

Gifts and Entertainment for Government OfficialsRules regarding giving gifts and entertainment to government officials are particularly strict. Some countries prohibit government officials from receiving any gifts or meals, while others have strict limits on the value and frequency.

In the United States and other countries, regulations restrict providing gifts and business courtesies to employees of federal, state, and local governments and agencies, including employees of state-owned enterprises. It is important that you are aware of these rules. For example, it may be illegal to share a taxi ride with a government employee or offer to buy him or her a sandwich.

Never offer or provide a gift, meal, travel, or any other courtesy to a government employee, unless you have written permission from In-House Counsel.

It’s also illegal to provide kickbacks to prime contractors or to receive kickbacks from subcontractors who are working or hope to work with us on a government contract. It is essential that you maintain complete honesty and integrity in all dealings with government officials.

Hiring Government EmployeesHiring current or former government employees can provide benefits to AECOM, as they have knowledge of agency programs and experience with the procurement process.


But the situation presents legal and ethical issues. A number of laws and regulations dictate how we conduct business so as not to compromise the integrity of the procurement process or create a conflict of interest. This could include even discussing potential employment with current or former government employees.

Hiring or arranging to hire the family member of a government employee can also create an appearance that you’re providing favorable treatment to an official. Also, you should not use your influence with friends, peers, or family members to help government officials or their family members get a job at another company.

Violating these regulations can result in steep criminal and civil fines, protests against outstanding bids, loss of current contracts, and potential suspension or debarment from future government contracting.

Therefore, it is important that you do not discuss hiring public sector employees without advance, written approval from In-House Counsel.

Scenario

Stan, a project manager, was ready to hire a new employee for his department. An applicant, Susan, was highly qualified and had specific expertise since she currently worked at the government agency where Stan had most of his dealings. Stan had gotten to know Susan through working together on a recent contract. Unfortunately for Stan, days before the hire was made, In-House Counsel stopped the process. It seems that Susan may have a conflict of interest—and Stan himself may have blundered by having employment discussions with Susan.

Is Stan in trouble? Mark the correct answer.

A. Yes; he should not have attempted to hire a current or former government employee

B. Yes; he should have checked with In-House Counsel before discussing employment with Susan

C. No; the regulations apply to government employees, so Susan is the one in trouble

D. No; In-House Counsel knows it was a simple blunder and that Stan didn’t mean to violate the law


FeedbackIf you chose A: Incorrect. It is appropriate to hire current or former government employees. However, Stan must abide by legal requirements. Seek guidance from In-House Counsel before having employment discussions with public sector employees.

If you chose B: Correct! It is important never to violate any regulations regarding hiring current or former government employees—even inadvertently. Seek guidance from In-House Counsel before having employment discussions with public sector employees.

If you chose C: Incorrect. It’s true that Susan is subject to regulations, but so are Stan and his company. Seek guidance from In-House Counsel before having employment discussions with public sector employees.

If you chose D: Incorrect. Even if done by mistake, violations of rules regarding hiring current or former government officials can have serious consequences. Seek guidance from In-House Counsel before having employment discussions with public sector employees.


FAIR DEALING

Competing FairlyA hallmark of AECOM’s success is a strong commitment to integrity, including vigorous but fair competition.

AECOM stands behind its products and services and competes fairly, in compliance with antitrust and competition laws. These laws protect free trade and ensure that all businesses operate on an even playing field. These laws generally require businesses to make decisions independently and not in collusion with competitors, customers, or suppliers.

You must not make agreements to

• Set prices, terms, or conditions of sale for competing services or products

• Divide or allocate customers, bids, markets, or territories for competing services or products

• Refuse to do business with particular third parties

These prohibitions apply to both formal and informal agreements. Avoid discussing any of these activities with competitors. If you know of any behavior that violates these rules, report it immediately.

AECOM is also committed to providing services only in places where the company is licensed to do so, or where the law otherwise permits. Ensure that you only present AECOM’s licenses and credentials in an honest and forthright way.

If you become aware of any changes to licensure requirements, inform In-House Counsel.

Accurate Books and RecordsIt is every employee’s responsibility to maintain the accuracy of all records, including financial documents, even if not directly involved in maintaining financial data.


This information is essential to AECOM’s internal operations and business decisions, and also to outside stakeholders who require an accurate view of AECOM’s operations.

Make sure you maintain complete honesty and accuracy in all information you submit, including time cards, travel and expense reports, and safety records.

Do not

• Make false representations on behalf of AECOM either in writing or verbally

• Conceal company funds• Mischaracterize company transactions• Create undisclosed or unrecorded fund accounts• Ignore illegal activity you know of or suspect

If you become aware of an accounting irregularity or suspect fraud in financial reporting, immediately report the situation to Management, Human Resources, or In-House Counsel. You will not face retaliation for any report made in good faith.

Scenario

Phil was just hired to assist Rebecca with her department’s accounting. To get himself oriented, Phil is reviewing past monthly statements and notices some irregularities. He thinks Rebecca may have purposefully mischaracterized transactions to increase her year-end bonus check, but he doesn’t have evidence to confirm his suspicions.

What should Phil do? Mark the best answer.

A. Nothing; Phil doesn’t have proof of any wrongdoing B. Report it; Phil has an obligation to report suspected wrongdoing C. Confront Rebecca; Phil should confirm she did something wrong before

reporting itD. Investigate Rebecca; Phil should seek proof of her wrongdoing before

reporting it


FeedbackIf you chose A: Incorrect. Never ignore potential financial misstatements or irregularities. If you believe another employee has made financial misstatements, even if it is only a suspicion, you should report it promptly.

If you chose B: Correct! If you believe another employee has made financial misstatements, even if it is only a suspicion, you should report it promptly.

If you chose C: Incorrect. It is not Phil’s responsibility to confront Rebecca. She may deny Phil’s accusation and cover up any evidence, or his accusation could damage their working relationship. If you believe another employee has made financial misstatements, even if it is only a suspicion, you should report it promptly.

If you chose D: Incorrect. Phil should not investigate Rebecca on his own. By doing so, Phil is delaying AECOM’s investigation and subsequent corrective action. If you believe another employee has made financial misstatements, even if it is only a suspicion, you should report it promptly.

Records RetentionProper recordkeeping builds trust with clients, regulators, and shareholders.

A record is any information created or received by an employee, contractor, consultant, or agent that is related to AECOM’s business activity, and can include both paper and electronic documents, such as email and images.

Every employee is responsible for the care of all records generated, received, or maintained in the course of business.

Effective records management

• Ensures availability of documents when needed• Helps AECOM comply with applicable laws and regulations • Preserves documents that may be relevant in audits, investigations, or

litigation

You should

• Keep all documents for the length of time required by regulations and our records retention schedule

• Dispose of documents using secure means in order to protect confidentiality

• Never alter or destroy records or deliberately conceal information


In-House Counsel may require you to retain certain documents connected with actual or anticipated litigation or government investigations, also known as a legal hold. If a legal hold exists, all documents subject to the hold must be preserved.

If you believe a person has concealed, altered, or destroyed a record in violation of AECOM policy or a legal hold, immediately report the situation to In-House Counsel.

What is a legal hold?

An order to stop destruction and keep all records relating to a certain matter due to impending investigation, audit, or lawsuit

Insider TradingIn the course of your work, you may have access to company or partner information that is not available to the general public. You must not buy or sell securities of AECOM or any company about which you possess inside information.

Inside information must be both

• Material • Non-public

“Material” means information that a reasonable investor would consider important to his or her decision to buy or sell stock. “Non-public” information is confidential, highly sensitive information that is not available to the general public. Inside information is considered non-public until two full trading days have passed since the information has been released to the public.

Inside information can be either positive or negative and includes

• Earning or loss projections• News of a merger or significant sale of assets• Declaration of a stock split or offering of additional securities• Changes in executive management • Significant new products or discoveries


If you possess inside information, you must not tip or tell it to others, including your spouse, family members, or other members of your household.

Check with In-House Counsel if you have any questions whether information you possess is inside


FOLLOWING COMMUNITY STANDARDS

Enhancing Communities AECOM prides itself on being a positive member of the communities where it conducts business. As such, AECOM is committed to following, or exceeding, all applicable environmental laws, rules, and regulations, as well as all regulations regarding political and charitable contributions.

As an AECOM employee, it is your responsibility to assist in environmental stewardship—using natural resources wisely both in the workplace and in the community

Corporate citizenship goes beyond environmental concerns. AECOM encourages employees to also be involved in the political and charitable activities of their communities. If you choose to participate, you must conduct these efforts on your own time and at your own expense.

If you perform campaign work or engage in fundraising or speech making, make it clear that all views are your own, and not those of AECOM. Furthermore, you are not permitted to use AECOM resources, including money or supplies, for personal political or charitable ends.

Responding to Media InquiriesAECOM must speak with a voice that is both unified and consistent.

Only make public statements on behalf of AECOM if you are authorized to do so. If you are not authorized to speak for the company, refer any requests for information from investors, the media, or the public to Corporate Communications. Refer any inquiries from government officials or attorneys to In-House Counsel.


ASKING QUESTIONS AND REPORTING CONCERNS

It’s Up to YouAECOM is its people. Therefore, it is important that we all understand our role in upholding the laws and regulations in the communities where we work, as well as enact the values and uphold the policies in the Code of Conduct.

If you are ever unsure about the right course of action, it is important that you ask questions. Never hesitate to contact Management, Human Resources, or In-House Counsel if you need guidance.

Leading With IntegrityIf you are a supervisor, you have additional responsibilities to demonstrate the highest standards of ethics in your own conduct and to serve as a role model for your employees. Always strive to promote a positive work environment, and treat people with dignity and respect. Maintain an open line of communication so that employees feel comfortable coming to you with concerns. Ensure that any employee raising a concern is not subject to retaliation.

To enhance AECOM’s culture of compliance, supervisors have a duty to prevent and detect violations of the Code, law, or policy and to respond to Code inquiries. Notify In-House Counsel of any issues reported, and ensure employees complete training in a timely manner.

How to Raise ConcernsAECOM’s reputation and success depend on you.

Our Code and this course provide an overview of your legal and ethical responsibilities. To fulfill those responsibilities, all employees must report any violations, possible violations, or concerns.

If you ever have a question or concern regarding this Code, your ethical responsibilities, or the law, do not hesitate to contact your Manager, Human Resources, In-House Counsel, or Ethics and Compliance.


You may also contact the confidential AECOM Hotline, which is staffed by a third-party company operating 24 hours a day, 7 days a week with worldwide language capability. Anonymous reports may also be made where allowed by law.

How to report violations and seek guidance

Talk to your supervisor or someone in Management

Contact a Human Resources representative

Contact AECOM In-House Counsel

Contact the AECOM Chief Ethics and Compliance Officer

Contact the AECOM Hotline

How to Reach the AECOM Hotline• Call 888-299-9602 (within the United States and Canada) • Call 1-770-613-6332 (outside the United States and Canada)• Email [email protected]• https://iwf.tnwgrc.com/aecom• Refer to the Hotline poster in your office for the number in your region

or go to the AECOM Ethics and Compliance webpage on the AECOM intranet for a comprehensive listing

The toll-free number is staffed by a third-party company operating 24 hours a day, 7 days a week with worldwide language capability. You do not have to give your name. An Interview Specialist documents your concern, assigns you a personal reference number, and relays your concerns to AECOM

Commitment to Non-RetaliationAECOM does not tolerate or permit retaliation against anyone who makes a report in good faith. Good faith does not mean that you have absolute proof, but that you honestly believe your report to be true.

If you experience retaliation for reporting a policy violation or concern, report it immediately to Management, Human Resources, or In-House Counsel.

mailto:[email protected]


What is retaliation?

A deliberate action against an employee who makes a report in good faith. Examples can include firing an employee or giving him or her the most undesirable tasks at work.

Scenario

Teresa works in construction at an AECOM site. The client has been pressing AECOM to finish the project ahead of the completion deadline, and Teresa knows the whole crew is doing its best to make that happen.

While walking the grounds with her supervisor, Frank, she points out a major safety violation that could put the work crew’s safety at risk. Frank tells Teresa that if she makes a report, it will slow down progress and put future contracts in jeopardy. When she insists that she is going to place a call to the corporate office, Frank threatens to lay her off.

What is Teresa’s best course of action? Mark the best answer.

A. Ignore the violation to keep the project on an accelerated scheduleB. Take a few days to spread word of the violation, and encourage everyone

stop work until it’s fixedC. Report the safety violation to the appropriate AECOM resourceD. Tell Frank that he has two days to report the violation or she will place

the call

FeedbackIf you chose A: Incorrect. It is never appropriate to ignore safety violations. Teresa should immediately report the situation to the proper AECOM resource. She should not expect retaliation for upholding the Code and making a report in good faith.

If you chose B: Incorrect. Although a work stoppage may be necessary, it is not Teresa’s job to encourage it. Furthermore, delaying an official report could further jeopardize safety. Teresa should immediately report the situation to the proper AECOM resource. She should not expect retaliation for upholding the Code and making a report in good faith.


If you chose C: Correct! Teresa should immediately report the situation to the proper AECOM resource. She should not expect retaliation for upholding the Code and making a report in good faith.

If you chose D: Incorrect. Delaying her report could make the situation worse. Teresa should immediately report the situation to the proper AECOM resource. She should not expect retaliation for upholding the Code and making a report in good faith.

Course Summary—It’s Up to YouThank you for taking the AECOM Code of Conduct course. Always remember to act in an ethical and responsible way and to uphold AECOM’s values.

You should now be able to

• Use the Code of Conduct to guide you in making ethical decisions • Report suspected unethical situations if they arise

Thank you for your continued dedication to AECOM. For over two decades AECOM has been guided by principles of leadership, integrity, and stewardship. Your commitment to AECOM’s culture of integrity and ethical behavior ensures our long-term success.


TEST YOUR KNOWLEDGE To complete your AECOM Code of Conduct training, please complete the following test questions. Feedback is listed at the end of the section.

Question 1

Which of the following actions could create a hostile work environment?

A. Sexually offensive remarks or jokesB. Unwelcome physical activityC. The display of sexually oriented or offensive materialsD. All of the above

Question 2

Jack, who works in procurement, has hired his daughter’s business to cater an AECOM conference. Does this action present a conflict of interest?

A. No, there’s no conflict of interest because Jack doesn’t have an ownership interest in the catering company

B. No, as long as his daughter’s business has a good reputation in the catering industry

C. Yes, unless Jack discusses this first with Management, Human Resources, or In-House Counsel

D. Yes, unless Jack was able to negotiate a price that benefits the Company


Question 3

A government official is visiting Stephane’s facility. She wants to impress him, so she arranges a two-day side trip to a local tourist destination. Did Stephane do the right thing?

A. YesB. No

Question 4

Which of the following is NOT an example of business confidential information?

A. Business plansB. Technical innovationsC. AECOM Annual ReportD. Personnel filesE. Client lists

Question 5

You need to hire a local consultant in Colombia to help obtain a permit for a plant, but you suspect the fee may include a payment to a government official. What should you do?

A. Hire the consultant since you really need his help and you don’t know for sure whether he’s paying the government official

B. Discuss your concerns with the consultant and hire him if you feel comfortable with his responses

C. Consult with the Office of Ethics & Compliance before deciding whether or not to hire the consultant


Question 6

Wayne’s government project is behind schedule. He feels one of the quality checks is redundant. Can he skip it to save time?

A. No, as he didn’t seek written authorization prior to skipping the reviewB. No, because he cannot verify the service truly performs to specificationC. Yes, because the service meets all other contract requirementsD. Yes, because it’s in the government’s best interest to keep the project on

schedule

Question 7

You’ve been pursuing an important government agency account for months. The procurement official seems almost ready to sign the contract. What can you do to help close the deal?

A. Offer to discuss the remaining details over a nice dinner at your favorite restaurant

B. Ask the official if he needs any additional information from you in order to make his decision on the contract

C. Tell the official you called your alma mater to put in a good word for his daughter who is applying for admission there

D. Send a small promotional item from our Company with a card that says “looking forward to working with you”

E. Fly the official and his family to our headquarters and arrange for a side trip to a local amusement park

Question 8

AECOM In-House Counsel asks if you have any information relating to a matter being investigated by a federal agency. You have some voicemails about the matter. What should you do?

A. Don’t mention the voicemails because they are not documentsB. Don’t mention the voicemails because you are the only one who knows

they exist


C. Destroy the voicemails—the fewer the documents, the less trouble for the company

D. Tell In-House Counsel about the voicemails so that they can take appropriate action

Question 9

You inadvertently see an internal memo stating that a customer is about to unveil a new product that will potentially send its stock value soaring. What should you do?

A. Buy a large number of shares of the customer’s stock before the price goes up

B. Keep the non-public information to yourself and refrain from buying any shares of the customer’s stock

C. Contact your family and friends and encourage them to buy shares of the customer’s stock

D. Ask your coworkers whether they’re planning to buy the customer’s stock before the product is introduced

Question 10

True or false: The AECOM Hotline should be used only when you have definite proof of a violation of our Code of Conduct or the law.

A. TrueB. False

SEE ANSWERS ON NEXT PAGE


Test Answers and Feedback

Question 1

Which of the following actions could create a hostile work environment?

If you chose A: Incorrect. Although this is one action that could create a hostile environment, there are others. Sexually offensive remarks or jokes, unwelcome physical activity, and the display of sexually oriented or offensive materials are all actions that could create a hostile work environment.

If you chose B: Incorrect. Although this is one action that could create a hostile environment, there are others. Sexually offensive remarks or jokes, unwelcome physical activity, and the display of sexually oriented or offensive materials are all actions that could create a hostile work environment.

If you chose C: Incorrect. Although this is one action that could create a hostile environment, there are others. Sexually offensive remarks or jokes, unwelcome physical activity, and the display of sexually oriented or offensive materials are all actions that could create a hostile work environment.

If you chose D: Correct! Although this is one action that could create a hostile environment, there are others. Sexually offensive remarks or jokes, unwelcome physical activity, and the display of sexually oriented or offensive materials are all actions that could create a hostile work environment.

Question 2

Jack, who works in procurement, has hired his daughter’s business to cater an AECOM conference. Does this action present a conflict of interest?

If you chose A: Incorrect. The Code prohibits you or any person having a close personal relationship with you from engaging in personal business with the Company for profit or gain without proper approval

If you chose B: Incorrect. The Code prohibits you or any person having a close personal relationship with you from engaging in personal business with the Company for profit or gain without proper approval

If you chose C: Correct! The Code prohibits you or any person having a close personal relationship with you from engaging in personal business with the Company for profit or gain without proper approval


If you chose D: Incorrect. The Code prohibits you or any person having a close personal relationship with you from engaging in personal business with the Company for profit or gain without proper approval

Question 3

A government official is visiting Stephane’s facility. She wants to impress him, so she arranges a two-day side trip to a local tourist destination. Did Stephane do the right thing?

If you chose A: Incorrect. This business courtesy is inappropriate because it is too lavish. Even more important, giving anything of value to a government official could violate the law.

If you chose B: Correct! This business courtesy is inappropriate because it is too lavish. Even more important, giving anything of value to a government official could violate the law.

Question 4

Which of the following is NOT an example of business confidential information?

If you chose A: Incorrect. All information that has value to an organization and is not available to the general public, including business plans, is confidential and should be protected.

If you chose B: Incorrect. All information that has value to an organization and is not available to the general public, including technical innovations, is confidential and should be protected.

If you chose C: Correct! Generally, information that is available to the public, such as annual reports, is not considered to be business confidential information.

If you chose D: Incorrect. All information that has value to an organization and is not available to the general public, including personnel files, is confidential and should be protected.

If you chose E: Incorrect. All information that has value to an organization and is not available to the general public, including client lists, is confidential and should be protected.


Question 5

You need to hire a local consultant in Colombia to help obtain a permit for a plant, but you suspect the fee may include a payment to a government official. What should you do?

If you chose A: Incorrect. If you have reason to believe that the consultant may be making an improper payment, your action could violate both AECOM’s Code of Conduct and the law.

If you chose B: Incorrect. While conducting due diligence before hiring a consultant is advisable, there is a better choice.

If you chose C: Correct! To avoid any risk of improper payments, you should consult with the Office of Ethics & Compliance before hiring a consultant or agent to represent AECOM’s interests with the government.

Question 6

Wayne’s government project is behind schedule. He feels one of the quality checks is redundant. Can he skip it to save time?

If you chose A: Correct! You must always seek the government’s approval to modify the contract terms. In the meantime, you must follow all reviewing requirements exactly.

If you chose B: Incorrect. Actually, it’s possible that some reviews may well be redundant and the service could actually perform to specification. However, this still would not justify skipping required reviews. You must always seek the government’s approval to modify the contract terms. In the meantime, you must follow all reviewing requirements exactly.

If you chose C: Incorrect. Regardless of whether the service meets all other contract requirements, you must not skip any required reviews without the prior specific and written approval of your government customer. You must always seek the government’s approval to modify the contract terms. In the meantime, you must follow all reviewing requirements exactly.

If you chose D: Incorrect. You must not skip any required reviews without the prior specific and written approval of your government customer. You must always seek the government’s approval to modify the contract terms. In the meantime, you must follow all reviewing requirements exactly.


Question 7

You’ve been pursuing an important government agency account for months. The procurement official seems almost ready to sign the contract. What can you do to help close the deal?

If you chose A: Incorrect. Government procurement guidelines are generally more restrictive than guidelines for commercial account activity. You should check with In-House Counsel before extending gifts, entertainment, or favors. Offering to provide additional information is an acceptable action when discussing a government contract.

If you chose B: Correct! Government procurement guidelines are generally more restrictive than guidelines for commercial account activity. However, offering to provide additional information is an acceptable action when discussing a government contract.

If you chose C: Incorrect. Government procurement guidelines are generally more restrictive than guidelines for commercial account activity. You should check with In-House Counsel before extending gifts, entertainment, or favors. Offering to provide additional information is an acceptable action when discussing a government contract.

If you chose D: Incorrect. Government procurement guidelines are generally more restrictive than guidelines for commercial account activity. You should check with In-House Counsel before extending gifts, entertainment, or favors, even small promotional items. Offering to provide additional information is an acceptable action when discussing a government contract.

If you chose E: Incorrect. This sort of lavish trip is never acceptable, whether for commercial accounts or for government accounts. You must not provide travel or entertainment for a government official’s family. Offering to provide additional information is an acceptable action when discussing a government contract.


Question 8

AECOM In-House Counsel asks if you have any information relating to a matter being investigated by a federal agency. You have some voicemails about the matter. What should you do?

If you chose A: Incorrect. You have a duty to cooperate with all investigations and audits. You must provide all relevant information, regardless of its form, to those who are conducting the investigations.

If you chose B: Incorrect. You have a duty to cooperate with all investigations and audits. You must not withhold relevant information from those who are conducting the investigations and audits.

If you chose C: Incorrect. You must never destroy documents, notes, electronic files, or any other information connected to an investigation or an audit. You have a duty to cooperate with all investigations and audits.

If you chose D: Correct! You have a duty to cooperate with all investigations and audits and to provide all relevant information to those who are conducting the investigations and audits.

Question 9

You inadvertently see an internal memo stating that a customer is about to unveil a new product that will potentially send its stock value soaring. What should you do?

If you chose A: Incorrect. Those in possession of material, non-public information are restricted from trading in the customer’s stock until that information has been made public.

If you chose B: Correct! It’s illegal to use inside information to buy or sell securities, either to gain or minimize losses. Also, you may not pass inside information on to others, including family members or friends so that they may gain or minimize their losses.

If you chose C: Incorrect. You may not pass inside information on to others, including family members or friends, so that they may gain or minimize their losses.

If you chose D: Incorrect. You must not discuss inside information with others, including coworkers who do not have a legitimate need to know.


Question 10

True or false: The AECOM Hotline should be used only when you have definite proof of a violation of our Code of Conduct or the law.

If you chose A: Incorrect. In addition to clear violations of policies, team members are encouraged to make good faith reports when they suspect unethical behavior of any nature.

If you chose B: Correct! The AECOM Hotline may be used to make good faith reports of suspected or verified violations of ethics, laws, or our Company policies of any kind.

Acknowledgment of CompletionTo receive credit for taking this training, please complete this form.

I hereby acknowledge that I have received and completed the hard copy version of the AECOM Code of Conduct course.

I understand that I am required to conduct my business affairs in compliance with all applicable laws, regulations and adhere to the highest ethical standards. I also understand that my failure to comply with the policies may, consistent with applicable laws and Company policy, cause me to be subject to disciplinary action, up to and including termination.

I know that I should consult with my supervisor or my in-house Counsel, or call the AECOM Hotline, if I have any questions about laws or Company policies and how they relate to my responsibilities. Print Full Legal Name: __________________________________________ Employee ID Number: __________________________________________ Signature: __________________________________________ Work Location: __________________________________________ Date: __________________________________________

Please return the completed form to

AECOM Ethics and Compliance OfficeAttention: Monique Nguyen3101 Wilson BoulevardSuite 700Arlington, VA 22201

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