- A Sustainable Future
- Letter from the CEO
- Sustainability Strategy
- Ethics and Business Conduct
- Human Rights
- Economic Performance
Ethics and Business Conduct
CH2M was founded by remarkable professionals who put honesty and integrity above all else. Each generation since has built on that solid footing, as new companies have joined the CH2M family. CH2M’s unwavering commitment to management with integrity and corporate responsibility dates back to the early days of our history, when the company’s cofounder, Jim Howland, authored the Little Yellow Book. The Little Yellow Book, known and beloved throughout the organization for its commonsense advice and simplicity, is legendary among CH2M’s current and former employees. Its simple wisdom is often quoted in company meetings and casual conversations as a way to confirm the core values of how CH2M does business.
As a companion to the Little Yellow Book, we developed our Employee Ethics & Business Conduct Principles (our employee code of conduct). This work builds on the simple and lasting concepts of the Little Yellow Book, and translates them into clear policies and aspirational, values-based guidance about the behavior expected from those who work for CH2M. The principles guide our employees through complex ethical decisions that must be made every day in the ever-changing global marketplace.
Our Employee Ethics & Business Conduct Principles is a living document, which is periodically updated to reflect our changing business and evolving regulatory environment. It combines all CH2M ethics and compliance policies and offers tools and practical advice. Both new and seasoned employees, wherever they are based and from top to bottom in the organization, review the principles annually, and take a training course and quiz on the key components embedded in the document. As a condition of employment at CH2M, employees must affirmatively attest to their commitment to following these principles. The standards encompassed in the Employee Ethics & Business Conduct Principles are published in the eight languages most commonly used by employees. They are also available on our intranet and Web site. The Ethics and Compliance team, within our corporate legal function, is responsible for program implementation.
In addition, as part of our continuing commitment to educate employees about our anticorruption policies and raise awareness about the different forms of corruption, we published our Anticorruption Compliance Guidance brochure.
For our suppliers, subcontractors, and business partners, we established and implemented a set of ethics and conduct principles that complement the employee ethics and conduct principles in 2011. Our Supply Chain Ethics & Business Conduct Principles and a companion Supplement for U.S. Government Work serve as the standard of expectations for entities that wish to work with CH2M. Our suppliers, subcontractors, and business partners must agree to comply with Our Supply Chain Ethics & Business Conduct Principles when registering and submitting their qualifications as potential business affiliates. The terms and conditions of agreements to perform work with us for our U.S. government customers directly incorporate the policies in Our Supply Chain Ethics & Business Conduct Principles.
Employee Reporting and Communications
Knowing that vigilance, transparency, access without fear of retribution, and oversight are imperative to confirming that our employees around the world have the information and support they need to make difficult ethical decisions, we have instituted a variety of employee reporting tools and educational programs.
The GuideLine, our confidential hotline, is a versatile phone- and Web-based tool that employees and members of our supply chain can use to seek guidance, discuss ethical concerns, or report potential violations of laws or policies. The GuideLine is available 24 hours a day, 7 days a week, 365 days a year, anywhere in the world, offering users the ability to report concerns without fear of reprisals. The Web-based hotline tool can be accessed in more than 200 languages. All contacts through The GuideLine are investigated and addressed by a team of trained professionals whose objective is to make sure that the company does the right thing and delivers services to our clients with integrity.
During 2015, the total number of hotline contacts received (224) was slightly lower than the rolling 5-year median of 231 contacts and a rolling 5-year average of 232 contacts. Contacts are categorized by concern, such as ethics and integrity, accounting and fraud, human resources, and safety.
In 2015, CH2M, like many companies, saw more reports related to human resources than any other category (this includes the subcategories of bullying, discrimination, retaliation, and workforce violence). To promote prompt and appropriate response to these reports, the Ethics and Compliance and Human Resources (HR) teams hold regular meetings to review the reports received, status of investigations, and lessons learned.
By increasing employee awareness of our expectations regarding how CH2M does business with integrity, and by including open discussions about the importance of ethics and integrity for CH2M, we are seeing greater employee engagement across all of our global operations. This is evidenced by an increase in the use of The GuideLine, for example,to report concerns and ask questions on the best ways to address ethical challenges. We are encouraged by these increases because they speak to greater awareness among our employees about our expectations in the ethics and compliance arena and the confidence employees have in our confidential reporting system. Moreover, the rise in contacts to The GuideLine gives us an opportunity to assist our employees in proactively making sound decisions, instead of expending time and energy on a reactionary basis.
Senior leaders in the firm provide regular messages about our business ethics through featured news stories, e-mails, reminders, links, in-house social media, and face-to-face and direct communications, keeping our ethics program highly visible. In addition, CH2M has declared May as “Ethics Month,” and we take the opportunity through increased communication to heighten ethics awareness among our employees. As Chairman and CEO Jacque Hinman has said, “By continuing to emphasize our core value of respect for people, partners, and the planet, as well as our other Little Yellow Book values, we have the opportunity every day to serve our clients and communities with distinction.”
Another important component of the ethics program at CH2M is our ethics ambassador program, re-launched in 2015. This program provides employees with direct access to local senior leaders, who understand how business is done in local geographies and are able to translate our expectations about doing business with integrity into local commercial contexts. Our ethics ambassadors are respected by their local peers. They are perceived as safe and reliable sources of information and guidance. The new program includes training and a new group of ethics ambassadors, covering every major office and project site. They are an additional resource for ethics questions and guidance, offering a reliable way to connect our employees in the field to their home offices, where ethics policies are set and preventive measures are enforced for compliance.
We regularly conduct an ethics survey to test our employees’ knowledge and familiarity with our training, awareness, and methods of receiving and handling employee reports received through The GuideLine. Our last survey, conducted in June 2013, indicated that the vast majority of our employees (over 90 percent) are familiar with our ethics materials and how to contact The GuideLine, and they believe CH2M is serious about its commitment to ethics and integrity. Our next survey will be conducted in 2016.
Anti-corruption Policies and Procedures
CH2M has operations in more than 90 countries on five continents, where we support private and public customers and do work for the United States and other national and local governments. Because we do business in some of the most difficult places on the planet (as rated by the global organization Transparency International), our anti-corruption program is a cornerstone of our Employee Ethics & Business Conduct Principles. We train our employees and educate our supply chain on how to avoid corruption pitfalls that are common in many places around the globe.
Wherever our work takes us, we follow our company’s core values for ethics and integrity. As a matter of principle, we neither seek nor are interested in attracting business through corrupt means. CH2M conducts rigorous legal, ethical, and risk-based assessments of our supply chain as part of our supplier qualification processes. Our procurement procedures and policies on gifts, entertainment, and hiring political consultants govern how we engage with anyone who could provide access or influence in helping us secure work. Before a political consultant is hired, we require thorough due diligence and senior executive review.
As part of our risk management process, we engage with each of our business groups to keep them aware of the risks of corruption in jurisdictions where they work. This process includes providing training and easy access to tools and advice. For those business groups with extensive project commitments in countries known for high corruption risk, we perform specialized training and periodic audits. We routinely engage with our business groups in open and frank communication about the risk of corruption, how to recognize red flags that might be evidence of possible corrupt business activities, and what to do when employees become aware of corruption risk. CH2M’s anti-corruption policies are reviewed and updated periodically to reflect the latest developments in laws and best practices on the subject. This is particularly important in countries that rank high on the Transparency International Corruption Perceptions Index.
We provide training on issues raised in the U.S. Foreign Corrupt Practices Act, UK’s Bribery Act, and other similar anti-corruption mandates from jurisdictions where we do business, through a combination of Web-based and in-person training. Additional anti-corruption training is provided as part of our project-specific risk management and mitigation planning. All senior employees also receive training focused specifically on corruption, conflicts of interest, and ethics and compliance in general.
When a corruption-related allegation is reported through The GuideLine or other tools, it is investigated by a multidisciplinary team that includes representatives of legal, internal controls, and, when necessary, forensic accounting staff. After obtaining the relevant facts through document review, in-person interviews, and review of available computer data, the investigation team arrives at an independent, unbiased conclusion regarding the veracity of the complaint. Disciplinary and retraining actions are taken quickly by management, if necessary, based on the recommendations made by this specialist team.
Government Participation and Lobbying
Public policy creates business opportunities and challenges that affect CH2M and our customers. Our Government Relations team promotes the business and professional interests of CH2M, its employees, and its customers, both in the U.S. and abroad, at national (including U.S. federal), state, provincial, and local levels. The team focuses on our business interests, important issues to the engineering and construction industry, and issues that affect the general quality of our communities. These government affairs professionals are responsible for managing firmwide legislative initiatives, educating our employees about our ethics and compliance programs associated with political advocacy, supporting business development, managing the company’s political action committees, and working with leading professional societies and relevant nongovernmental organizations (NGOs).
We are actively engaged in staff-level briefings and consultations in the U.S. and foreign legislatures; executive branch agencies; and state, provincial, and local governments to address the realities of resource limitations and sustainable solutions to our communities’ needs. Our Government Relations team actively tracks key legislation and regulatory efforts in the areas of water, wastewater, and water resources, among other important issues. Our employees also serve in leadership positions in professional organizations that take positions on these issues.
The Government Relations team, in coordination with the Legal Department, carefully evaluates all political consultants with whom the company partners. We are cautious and conservative when selecting individuals who perform lobbying or business development roles on our behalf. We will do business only with those who share our zero tolerance policy for corruption.
To promote ethics principles as our business imperative and provide industry leadership on this important issue, CH2M became a founding signatory of the World Economic Forum’s Partnering against Corruption Initiative, a member of the UN Global Compact Working Group on the 10th Principle, and a member of the Construction Industry Ethics and Compliance Initiative.
As a testament to these proactive measures and the quality and ethical commitment of our dedicated employees, Ethisphere®* Institute named CH2M one of the World’s Most Ethical Companies for the eighth consecutive year (*World’s Most Ethical Companies” and “Ethisphere” names and marks are registered trademarks of Ethisphere, LLC).
Additionally, in 2012, CH2M qualified for inclusion in a global, Geneva-based, ethics and reputation analysis service that provides monthly reports and rankings on multinational companies. Using six major international treaties as its framework—including the UN Global Compact and the Organization for Economic Cooperation and Development’s Guidelines for Multinational Enterprises—and applying 45 criteria, ranging from lobbying and political contributions to community volunteerism and financial support, Covalence tracks over 500 of the world’s largest companies.
In December 2015, Covalence again ranked CH2M in the top 5 percent of the global companies for its ethics and integrity; we worked to maintain our ranking through the end of the year. The firm ended the year ranked No. 25, and No. 2 for the construction and materials sector. Covalence was founded in 2001. Its director and cofounder, Antoine Mach, has been recognized as one of the world’s most influential people in business ethics (according to the research-based Ethisphere Institute).