FY2016 Business Conduct and Ethics Awareness Training

FY2016 Business Conduct and Ethics Awareness Training
Our Shared Commitment to “Doing the Right Thing” Section 1 Our Way – The Ethical Way Fiscal Year 2016

Introduction – John Vollmer
The outstanding AECOM and AECOM Management Services Group (MS Group) reputation for quality, safety, and ethical performance has served us well in the past and is critical for our future We have a strong “Tone at the Top” by our AECOM Corporate and MS Group leadership. We have a total commitment to ethical behavior Our AECOM purpose, core values, and Code of Conduct provide guidelines for us all All of us are responsible for ethical performance Together – as a total team – we can enhance our ethical culture which is key to mitigating risk, but also to building our reputation and performance We must work together! Ethical performance is Good Business!

Ethics Awareness Training
Welcome to our FY2016 Business Conduct and Ethics Awareness Training Session and discussion of our core ethics values We will spend an hour Reviewing the Company’s Code of Conduct and Ethics key elements Talking about our AECOM ethics values and culture Reviewing our key MS Group ethics policies Talking about ethics issues at our location Emphasizing Government ethics issues Discussing hypothetical ethical issues and how you would respond A strong company culture of ethics is vital to our growth and success We have a proud legacy of ethical performance on which to build a bright future No unethical action can do anything good for the Company.

AECOM – Who We Are AECOM – Global leader in providing fully integrated, professional, technical, and management support service for a broad range of market sectors AECOM today – U.S. $19.5B (September 2014) About 100,000 employees in more than 150 countries Ranked 332 on Fortune 500 50% of revenue generated outside the U.S. 450+ offices around the world More than 30 market sectors Recognition worldwide Recognized by Fortune Magazine as a “World’s Most Admired Company” Recognized by U.S. Chamber of Commerce as an honoree for Best Corporate Stewardship

AECOM – Global Platforms
Our Global Platform – We deliver fully integrated services collaborating across disciplines and geographies to shape innovative solutions for our clients Architecture Building Engineering Construction Design and Planning Economics Energy Environment Government Mining Oil and Gas Program Cost Consultancy Program Management Transportation Water

Organizational Overview
Our new structure strongly positions us to design, build, finance, and operate infrastructure assets for clients around the world, and brings together the former operations of AECOM and URS into five principal groups Design and Consulting Services Group (DCS): Operating in the Americas, Europe-Middle East-Africa and Asia-Pacific, DCS includes technical services such as architecture, cost consultancy, design, economics, energy, engineering, environmental, planning, and program management Construction Services Group: Made up of two segments, Building Construction; and Energy, Infrastructure, and Industrial Construction. This group is focused on leveraging its expanded capabilities to provide a full suite of construction services to multinational clients AECOM Capital: Makes direct investments in real estate and public- private projects, providing opportunities to participate as a vital partner in advancing projects with clients Management Services Group: Provides a broad array of services to the U.S. Federal Government as well as national governments around the world End Market Group: Responsible for driving global collaboration across the four operating groups to leverage the design-build-finance-and-operate model. The group comprises six growth-oriented, industry-facing practice areas with an elite, client-focused team pursuing long-term strategic growth opportunities, and promoting technical excellence, innovation, and thought leadership

Diversified Business Overview

MS Group Overview Highlights Our Capabilities
Provide Systems Engineering and Technical Assistance (SETA) services throughout the Department of Defense (DoD) and Federal civilian agencies Deliver more military aviation training than any other company Operate the largest open air test and training ranges in U.S. Have destroyed 90% of the U.S. chemical stockpile Proven cloud computing to meet Government requirements Our Capabilities Site Management and Operations Critical Infrastructure and Facility Management Global Field Services Maintenance and Logistics Systems Engineering and IT Services International Development

Management Services Group
Chief Executive, AECOM Mike Burke President, Management Services Group Randy Wotring Legal - Stuart Young Finance - Jake Kennedy Human Resources - Bob Rudisin Information Technology - Joe Walker Security - Randy Ullrich Mktg & Business Dev. - Tom Wrenn Safety - Jeff Treffinger Contracts - Terry Raley Int’l &Special Projects - Dave Swindle Ethics Advisor - Frank Visted Operations John Vollmer Campaigns EMS - Ron Hahn JUSTS - Tim Saffold Cyber - Dean Fox Advanced Technology - Phil Horvitz Business Integration - John Cooke Strategic Business Units Nuclear & Environment James Taylor Intel Community Jill Bruning Global Field Services Jeff Parsons Mission Readiness Karl Spinnenweber Systems Eng. & Info. Solutions Chris Bauer Commercial/ Other More than 14,000 employees in over 70 countries world-wide In addition, more than 20,000 Joint Venture employees

MS Group Clients and Contracts
Top 3 Clients: DoD, DOE, & IC Majority of Work is Cost Reimbursable Current Future Annual Revenue Exceeding $3.4B More than 60% of Contracts are Cost Reimbursable

Ethics The ethical culture drives behavior
Ethical culture is “The way things are done around here” U.S. Sentencing Guidelines (DOJ) – Management at every level must be fully knowledgeable about the Ethics Program and must exercise oversight Benefits of a strong ethical culture: Reduced risk Reduced fraud Reduced litigation More involved/engaged employees The ethical culture drives behavior – high levels of responsibility Ethical managers embody the purpose and values of the organization, within an understanding of ethical ideals Making integrity the centerpiece of our business is a business imperative Never a wrong time to do the right thing

An Ethical Culture - Fundamentals
Business conduct and ethics is a critical business issue The Code and Policies don’t address every specific situation, but provide a baseline to help us “make the right choice” We must sustain a culture of ethical values in support of our overarching Code of Business Conduct and Ethics We must be more than just compliant with the rules! We can be compliant with all the rules and regulations, but we must sometimes work within the “grey” or untested areas – our ethical values and culture provide a critical support structure We must be “doing the right things” An ethics culture Values Beliefs Learning Choices Just because it isn’t illegal doesn’t make it right!

An Ethical Culture – Fundamentals (cont’d)
We have a duty to comply – obeying the law – both its spirit and its letter Speaking up – the Code doesn’t have an answer for every circumstance – when in doubt, discuss the ethics question with someone Managers  Ethics Advisor HR  Hotline Legal  Talking about it – we are encouraged to talk to supervisors and managers for timely advice on ethical concerns Protection against retaliation – when you step forward to report something, it is an MS Group obligation to protect you from retaliation No form of retaliation is allowed Retaliation is in itself an ethical violation Violations can have severe consequences – violations of the law, the code, and our policies are subject to disciplinary action

Ethical Business Conduct – A Proud Legacy
Ethical business conduct is the centerpiece of the way we do business Our reputation for ethical business practice is a priceless asset Our reputation can never be taken for granted Our reputation is critical to current performance and for future growth As we grow, our reputation for ethical business performance must be maintained with every customer, site, local community, and country where we do business Our success depends on the commitment of every employee to the highest standards of ethical behavior We live our core values through our actions and performance.

AECOM – Purpose and Core Values
Purpose – to positively impact lives, transform communities, and make the world a better place Core Values – Our values recognize that our business success is founded upon commitment to certain principles People – The expertise, passion, and thought leadership of our talented people around the world make our success possible. We respect and encourage our people’s ideas, diversity, and cultures Clients – We are committed to our clients and to setting industry standards for service and delivery. We take ownership for solving our clients’ problems and anticipating new opportunities Excellence – We believe in delivering unequivocal excellence in everything we do

AECOM – Purpose and Core Values (cont’d)
Integrity – We must always maintain our commitment to acting ethically and with integrity – in all that we do, every day of the year Safety – We are a company that puts safety first. We are all accountable for keeping ourselves and our colleagues safe and for delivering work safety to our clients Innovation – We differentiate our company by challenging ourselves to look for new and better ways to deliver our expertise through innovative solutions that enable each client to realize its vision

AECOM Code of Conduct Overview
Core Values Diversity Harassment Work Place Safety Global Employment Standards Conflict of Interest Gifts and Entertainment Protecting Company Property Protecting Business Private Information Use of Company Computer Systems Anti-Corruption Laws Trade and Export Regulations International Sanctions/Boycotts Money Laundering Government Contracts Time Charging Hiring Government Employees Competing Fairly Accurate Books and Records Insider Trading Media Inquiries Reporting Concerns Non-Retaliation Integrity In All We Do

Ethics Principal Policy (MS Group) – 11.000-000.000
Applies to all MS Group employees Purpose of Policy – Establish fundamental intent and direction for ethical behavior based on the AECOM Code of Conduct Policy – MS Group committed to following the AECOM Code of Conduct and dealing ethically with all employees, customers, suppliers, stakeholders, competitors, and the communities in which we live and work MS Group shall: Manifest the values of people, clients, excellence, integrity, safety, and innovation in all behavior MS Group shall: Provide employees the leadership to ensure alignment of this behavior and ethical commitment of these values MS Group shall: Inculcate these values in all business conduct MS Group shall: Only partner with organizations demonstrating similar values and commitment to ethical performance MS Group shall: Proactively seek, assess, resolve, and prevent ethical issues

Ethics Compliance and Reporting (MS Group) – 11.010-000.000
Applies to all MS Group entities and its employees Purpose of Policy – Provide guidance for ethics compliance and reporting Policy – Major employee guidance All business operations and employee conduct shall conform to the AECOM Code of Conduct Compliance with regulations and the AECOM Code of Conduct shall be an integral part of the group internal control program Conduct business operations that prevent and detect bribery violations Require initial AECOM Code of Conduct training and annual training thereafter Report ethical violations, including the AECOM Hotline Non-retaliation rules

Integrity – The Power of Honesty in All We Do
Integrity is a constant in all we do! We deliver what we promise to all our customers, employees, suppliers, and investors AECOM is known as a company of integrity Integrity is central to the way we do business Our reputation is a priceless asset Honesty means communicating truthfully in all our relationships All our records must be complete and accurate Anyone can make a mistake Fraud is not a mistake; it is deliberate deception Fraud is not only unethical, it is illegal Timekeeping is a critical record that impacts us all We bill our customers based on time records This is the foundation of our pay system The integrity of our timekeeping process is vital

Integrity – The Power of Honesty in All We Do (cont’d)
Timekeeping – A critical record Time records, whether submitted electronically or by hard copy, are a vital legal document Basis for computing your pay Basis for billing customers You are to complete your own time record and report only time and actual hours worked You are responsible for the accuracy of the time record and your signature is a legal certification Improper charging, shifting labor costs from one contract to another, or falsifying time records is strictly forbidden Under no circumstances may any unallowable time be charged to a customer contract. See your supervisor for a proper charge number and work authorization Willful or careless incorrect time reporting will result in discipline up to and including termination

Integrity – The Power of Honesty in All We Do (cont’d)
Timekeeping – A critical record (cont’d) Note: Several times a year you will be asked to complete a time record in advance Accomplished to adjust to Federal holidays or specific cost accounting requirements Process is approved by the Defense Contract Audit Agency (DCAA) Oversight is provided by DCAA If you have a concern, discuss with your supervisor or time record coordinator For additional assistance, call the MS Group Payroll Unit at

Employees: Recognition of the Individual
AECOM policies are designed to ensure that employees are treated, and treat each other, fairly and with respect and dignity The Company recognizes that all employees want and deserve a workplace where they are respected and appreciated AECOM will not tolerate discrimination against any person on the basis of race, religion, color, gender, age, marital status, sexual orientation, national origin, or disability or any other basis prohibited by law in recruiting, hiring, placement, promotion, or any other condition of employment The diversity of our Company is a strength and acts to maximize our Company

Employees: Recognition of the Individual (cont’d
AECOM strictly forbids any form of harassment in the workplace, including sexual harassment. We encourage prompt reporting of all incidents of harassment regardless of who the offender may be or the offender’s relationship to AECOM Any AECOM employee who is found responsible for harassment or for retaliating against any individual for reporting a claim of harassment will be subject to disciplinary action, up to and including termination All personnel are expected to interact with each other in a professional and respectful manner Abusive and/or intimidating behavior cannot be tolerated at any level or position

Safety is a Core Value at AECOM
As industries change, companies must adapt their operating practices and business strategies to stay competitive and meet demand Core values, however, never change. They are the foundation for how businesses conduct themselves and perform work Safety Clients Excellence Integrity Innovation People At AECOM, providing a safe and healthy place to work and protecting the environment is a Core Value

Safety, Health, and Environment Policy
AECOM's global Safety, Health, and Environment (SH&E) policy demonstrates the commitment the organization has made to protecting our most valued asset – our staff members. The policy also describes the basic objectives of our overall program and responsibilities of our staff as described below: Our ultimate goals are simple and are derived from AECOM’s Core Values: Prevent work-related injuries or illnesses. Prevent damage to property and/or equipment from our activities. Prevent adverse impacts to the environment from our ongoing projects or operations. All employees are responsible for: Conducting themselves in accordance with directives, standards and procedures established by the applicable SH&E program. Temporarily suspending their personal work activities and requesting guidance from their supervisor before continuing a task when they identify a condition or practice that creates a serious safety, health or environmental risk. Immediately reporting safety, health and/or environmental incidents to their supervisor. Objectives

Life Preserving Principles
These “Life Preserving Principles” will enable AECOM to achieve its goal of zero employee injuries, no property damage and an environmentally friendly and sustainable workplace. Demonstrated Management Commitment Executive and managers lead the SH&E improvement process and continuously demonstrate support. Employee Participation Employees are empowered to be actively engaged in safety processes through participation in safety committees, training, audits, observations, and inspections. Budgeting and Staffing for Safety Safety staff will be competent, fully trained and qualified to provide technical resources to our projects. A budget to support safety activities will be included project proposals. Pre-Planning We will deploy effective risk mitigation efforts to design, plan and build safety into every project. Pre-Project and Pre-Task planning will be an effective tool in protecting our employees and the environment.

Life Preserving Principles
Contractor Management We will work closely with our sub-consultants, subcontractors, contractors, and JV/LLC partners to provide a safe work environment for all employees. Our goal of SH&E performance excellence will be equally shared by all project participants. Recognition and Rewards Employees will be recognized for their efforts in working safely and their support of our safety efforts. Safety Orientation and Training Employees will be provided with comprehensive safety training to identify and mitigate hazards in the workplace to prevent injuries to themselves and others. Incident Investigation Our managers and safety staff will investigate incidents and near misses to identify contributing factors and root causes to prevent reoccurrence. Lessons learned will be identified, communicated, and implemented. Fit for Duty Our employees are responsible to report to work each day fit for duty and not to pose a health or safety hazard to themselves or others.

The Safety Red Card At AECOM, every employee is responsible for their own safety and the safety of others You have the right and responsibility to STOP work if a job is unsafe or poses a danger to the environment The use of the Red Card will immediately require work to cease. Having the physical red card is not required in order to stop an unsafe practice When red-carding a job, immediately report it to your supervisor Work on a red carded job may only continue when a member of management clears the red card No one – fellow employees, customers or supervisors – has the authority to direct you to violate or disregard any safety or environmental standard Please read your Red Card carefully and keep it with you…

Safety Expectations for all Employees
CONFIDENTIAL PRIVATE INFORMATION Safety Expectations for all Employees Each AECOM employee is expected to be an active part of Safety, Health, and Environment (SH&E) through: Working safely and helping others to work safely Including safety planning in all work activities Using a job or task hazard analysis when starting work Sharing a common commitment to safety excellence Developing safety knowledge, skills, and abilities Complying with safety procedures Identifying, reporting, and helping to correct safety hazards Cooperating during incident investigations View the AECOM HSE programs at: My AECOM – Safety, Health, and Environment (SH&E) Manual.

Clients: AECOM an Ethical Corporate Contributor in an International Market
We encourage all employees to participate, as private citizens and in an appropriate manner, in community processes and activities All of us representing the Company must comply with all applicable laws If local laws conflict with our Code of Business Conduct and Ethics or policies and procedures, we follow the law with corporate legal advice and guidance If local business practices conflict with our Code, we follow the Code (under Policies) As a major Federal and defense contractor, we abide by the international rules and regulations in our statutes, including Foreign Corrupt Practice Act (FCPA) International Traffic-in-Arms Regulations (ITAR) UK Bribery Act of 2010 When in doubt, ask for help; call

Excellence: The Power of Teamwork and Collaboration
We are a total team, sharing our unique talents to help those with whom we work or support The Company’s strength and longevity are the results of our ability to sustain long-lasting and mutually rewarding relationships with customers, subcontractors, suppliers, and all with whom we do business We are aggressive but fair competitors within our marketplace. Competitive data is treated legally and ethically Protecting our “knowledge assets” is everyone’s responsibility Working together we can, as a team, produce better results and provide greater customer satisfaction than any of us can achieve alone We encourage collaboration, celebrate success, and build mutually beneficial relationships

Excellence: The Power of Commitment
The underlying foundation of our ethics culture is that there is no gap between what we say and what we do! We support an open culture where all employees feel secure in raising concerns or seeking advice If anyone is unsure of what to do in a particular scenario or is concerned that our code or policies are being broken, they have a responsibility to speak up Our Code defines the process for reporting issues and details the absolute protection against any retaliation by anyone We are all accountable for our actions Being value-driven means two things Doing what’s right – Refusing to compromise ourselves and principles despite pressure and temptations to the contrary Taking a stand against what’s wrong – Speaking or acting out whenever we see things that are incorrect or inappropriate

Excellence: The Power of Commitment (cont’d)
Responsibility is Following your conscience and values Following the Code and insisting others do the same Refusing to accept or take part in disrespectful or intimidating behavior Avoiding conflicts of interest Being accountable for your actions Our Company’s reputation and business growth depend on each of us, everywhere, every day, taking responsibility for the ethical conduct of our business Excellence in every thing we do

Special Item – “Revolving Door”
“Revolving door” occurs when individuals cycle between roles in private industry and Government organizations which influence that same organization “Revolving door” involves three major restrictions Prohibited employment discussions Compensation bans Employment activities (no contact rule) Prohibited Employment Discussions – Government employees may not discuss employment opportunities with a contractor where she/he is acting in an official capacity by: Participating in a procurement in which ANY business of the Company is a bidder or offeror Participating personally and substantially in specific issues (contracts, source selection, claims, etc.) with the Government that directly impact the Company’s financial interests Contractor’s employee “CANNOT” accept resumes, discuss job descriptions or compensation with such Government employees Prohibitions extend to all communications regardless of who initiated the contact

Special Item – “Revolving Door” (cont’d)
The Company cannot offer compensation for at least one year to certain U.S. Government (USG) employees () (Seven/Seven Rule) “No Contact” Rule – one year Senior employees of the USG may not communicate with/or appear before the USG of the department or agency in which he/she served Includes the General/Flag Officers; Level 11 or above of the Executive Schedules; Special Presidential or Vice Presidential appointees Seven Positions Seven Decisions Procuring Contracting Officer (PCO) Source Selection Authority Member Source Selection Evaluation Board Chief of Financial/Technical Evaluation Team Program Manager (PM) Deputy PM Administrative Contracting Office (ACO) Approve contracts over $10M Approve subcontracts over $10M Approve contract modification over $10M Approve task/delivery order over $10M Establish indirect rates applicable to a contract over $10M Approve contract payment of $10M Settle claim of over $10M

Special Item – “Revolving Door” (cont’d)
Two-Year Representative Ban If employee had a “particular” matter potentially involving the Company within one year of ending USG employment Lifetime Representative Ban If the employee participated personally and substantially in a “particular matter” Particular Matter – Matter that involves deliberation decision or action. May include conflict, claim, application, or other proceeding Two-Year/Lifetime Bans do not apply to enlisted personnel No AECOM MS Group employee may discuss directly or through an intermediary potential employment with a USG employee without FIRST referring the candidate to HR for proper legal screening State and local governments have similar restrictions. Review restrictions with Legal prior to any action

Special Item – Gifts and Entertainment for Government Employees
MS Group Policy – – Applies to all MS Group employees. Provides rules for gifts and entertainment relationship with private and public sector clients and business partners Accepting or giving occasional gifts, meals, or entertainment with private sector personnel may be allowed under some circumstances within policy oversight and authorizations Gifts and entertainment shall not be extended to any Federal, State, local, or foreign official or their employees A Federal employee may accept a gift given under circumstances which make it clear that the gift is motivated by a family or personal relationship with an MS Group employee, rather than the position of the Federal employee A gift for Government employees includes any form of gratuity, favor, discount, hospitality, entertainment, loan, or items having a monetary value, including gift cards as well as gifts of training, transportation, local travel, lodging, or meals

Special Item – Gifts and Entertainment for Government Employees (cont’d)
The term “gift” does not include Coffee, donuts, or other refreshments not intended to be a meal A “present” of little intrinsic value (plaques, certifications, etc.) Commercial benefits available to general public Anything the Government employee pays market value Anything accepted by the Government in accordance with agency rules U.S. Federal regulations authorize gifts (not cash) with a market value of less than $20 USD or less per source as long as the total gifts from all of AECOM do not exceed $50 USD per year – The “$20/$50” rule State and local governments – Due to the number and variation, certain items may be exempt from the MS Group policy. Prior approval by the Legal Department is required before any gifts are given Gifts and entertainment items of any value whatsoever are prohibited to Federal, State, local, or foreign procurement officials, including their families and employees

Special Item – Gifts and Entertainment for Government Employees (cont’d)
All MS Group procurement personnel are prohibited from accepting gifts from any external-related entity regardless of value MS Group employees shall not accept gifts or entertainment which may be reasonably deemed to affect individual judgment or company responsibility All employees conducting International business and travel shall review AECOM Design and Consulting Services (DCS) ethics policies for the geographic region and consult with the Legal team

Special Item – Preventing Human Trafficking
Human Trafficking – Preventing Human Trafficking Policy Human trafficking refers to the recruitment, transportation, transfer, harboring, or receipt of persons by means of threat or use of force or other form of coercion for the purpose of exploitation Provide a shared understanding and commitment across AECOM MS Group and its partner organizations. We are all responsible Exploitation shall include at a minimum – prostitution or other forms of sexual exploitation, forced labor or services, slavery or servitude AECOM MS Group shall develop and maintain a detailed anti- trafficking compliance program AECOM MS Group is committed to complying with the U.S. Government’s zero tolerance policy on trafficking in persons, including forced labor

Ethics in Action – Key Messages
When all is said and done – remember Respect the dignity of all Listen openly to concerns and suggestions Carefully follow the laws and rules that govern our work You don’t have to make tough decisions alone We will not compromise our values to reach performance goals or sales objectives It is an MS Group obligation to protect you from retaliation We will fully respect proprietary material and follow all procurement rules and procedures We will not involve ourselves with business that requires us to act illegally or unethically or that places our employees in situations that compromise our ethics We will be a safe place to work Each of us is responsible for our own actions and we are responsible to each other

Just A Thought! Ethics Principles: Actions you see! Not words you hear! We all can do better!!!

Resources to Help You Overview of workplace rules
AECOM Code of Conduct (myAECOM – Ethics and Compliance) Summary brochure The SoURSe – Ethics AECOM Ethics and Compliance Team Mike Kostiw (Ethics and Compliance Team Leader) (703) Jennifer Gorman (Senior Counsel, Ethics and Compliance (703) Monique Nguyen (Director, Ethics and Compliance, Training and Integration) (703) & Corporate/Ethics & Compliance) Benefits/personnel issues Benefits Service Center – (International) Local HR representative

Resources to Help You (cont’d)
Company policies, record retention schedule Legal Department – Stanley Harper – Conflict of interest questions Timekeeping questions Germantown Service Center – International operations questions Joaquin Legorreta – (Export Compliance) Lee Ann Rogers – (International Business Team) Political activities Environmental/safety questions Jeff Treffinger – or , Option 1

Resources to Help You (cont’d)
Helpful Web sites Ethics Resource Center (ERC) – Defense Industry Initiative (DII) – Ethics training materials Mary Fairfax – Ethics training support/general questions/Ethics Advisor Frank Visted – AECOM Hotline – AECOM Hotline –

CY2015 Business Conduct and Ethics Awareness Training
Ethics Issues How Would You Respond? Section 2 Our Way – The Ethical Way

How Would You Respond? Q: To whom should I direct questions or issues regarding ethical matters? A: In most cases, you should contact your supervisor. Sometimes you may feel more comfortable discussing the matter with someone else. In those cases, you are encouraged to contact the Human Resources representative, the MS Group Legal Department, any senior manager, the MS Group Ethics Advisor, or the AECOM Hotline.

How Would You Respond? (cont’d)
Q: What do I do when I am faced with a situation where the correct ethical decision would mean a potential loss of revenue for AECOM? Should I still be ethical? A: Yes, we want all employees to be ethical under all situations – even if we will lose some revenue. We value our long-term reputation and would never compromise our values for short-term gain.

Q: I received a fax today. The cover sheet leads me to believe the attached pages were misdirected and contain source selection proprietary data. What do I do? A: Do not look at the material. Do not copy. Contact your manager and Legal immediately.

Q: Since we see potential budget decreases and increased competition in our markets, can we “inflate” our past experience and capabilities, and “overstate” our key personnel “experiences” in our proposals? A: No. any exaggerations in our proposals and follow-on contracts could be used to prove fraud under the False Claims Act (FCA). We need to be careful about promises of future actions and what we “certify” in proposals. The Fraud Enforcement and Recovery Act (FERA) of May 2009 makes it easier for the Government to prove fraud under FCA. Under FERA, the Government need only prove the “false” statement was material to the Government decision to pay. Ethical performance and procurement integrity are AECOM hallmarks. We will not cut corners and violate our ethical standards to increase business.

Q: Your supervisor tells you that a project is over budget and you should only report 3 hours a day regardless of the number of hours you work. Since these instructions come directly from your supervisor, are you justified in following these time charging procedures? A: No. You must charge your time accurately. Charging time inaccurately is absolutely prohibited. Employees who mischarge their time, even if they are acting in compliance with a supervisor’s instructions, will be subject to discipline up to and including termination. A supervisor who instructs employees to charge their time inaccurately will also be subject to discipline up to and including termination. An employee receiving such instruction must report the supervisor to the Legal Department or the Hotline. Such concerns can be raised anonymously if you wish.

Q: You are concerned with the number of hours you have expended to date on a project and the impact it will have on the budget. Are you permitted to charge any additional time you work on the project to an overhead account? A: No. Employees are prohibited from knowingly charging an inaccurate amount of time or from charging any time to an incorrect account or project. An employee who knowingly mischarges time will be subject to discipline, up to and including termination of employment.

Q: Do gift regulations vary among countries? Are State and local rules different from Federal rules? What about different departments or agencies? A: There are significant differences. You should review with AECOM MS Group Legal, but as a general rule, AECOM does not offer gifts to its Government customers.

Q: Do Personal Conflict of Interest (PCOI) principles apply to relatives outside my household or to friends? A: Generally, the conflict applies to members of your immediate family. However, if your relationship with a friend or relative is particularly close and you could lose your objectivity, you should disclose the relationship and discuss the matter with your supervisor or Legal.

Q: Does our Code apply to consultants? A: Yes, consultants, sales agents, marketing representatives, vendors, supplies, and subcontractors are given a copy of the Code. Some of these suppliers are required under law and regulations to have their own Code of conduct which AECOM MS Group managers should review.

Q: You are working on a proposal in a newly independent country to provide training to the country’s police force. The Minister of Interior suggests that he will recommend AECOM strongly if the Company makes a contribution to his party’s candidate in the upcoming presidential election. Would it be okay to recommend this contribution? A: No. It would violate the FCPA to make a payment to a Government official of any country for the purpose of obtaining or retaining business. Political parties and candidates are expressly included in this prohibition. You and/or AECOM could be subjected to criminal and/or civil penalties by the U.S. Government. You must contact the Legal Department before entering into any agreement regarding work performed outside the United States or making any payment that could possibly be covered by the FCPA.

Q: You are responsible for overseeing the work of a freight forwarder subcontracted to AECOM in a foreign country. The freight forwarder informs you that certain shipments are delayed at a foreign border because a foreign official insists on certain fees being paid. Can the freight forwarder make these payments? After all, it’s the freight forwarder making the payments—not AECOM—so won’t AECOM be shielded from any potential FCPA violations? A: No. AECOM will not be shielded from an FCPA violation even if a subcontractor actually makes an illicit payment. You could face criminal and/or civil sanctions as well. You should not assume that such payments to border officials will not violate the FCPA. Contact the Legal Department prior to making or authorizing any such payment.

Q: In connection with a deal you are developing, a foreign government official has asked AECOM to pay a “processing fee” to expedite clearing customs. What should you do? A: You must obtain review and approval from the Legal Department before making any “expediting” payments.

Q: Someone I have worked with on a Government program is planning to retire from the Government and I think she would make a great addition to our MS Group Team. Can I try to recruit her? A: Before you have any conversation about AECOM, you must work with your Human Resources representative. You will not be able to talk to her until she takes required action to disqualify herself from further AECOM involvement and has, when required, an ethics opinion from the proper authority.

Q: My military customers (uniformed and civilian) will be holding a program review at our AECOM facility. They will have to start early and depart early to finish the agenda and meet an airline schedule. Can we provide a catered breakfast and lunch? A: No. U.S. Federal, State, and local governments: Employees, of U.S. Federal, State, and local governments are subject to laws and regulations concerning acceptance of business courtesies from firms and persons with whom the Government does business or over whom it has regulatory authority. (cont’d)

a) Federal Executive Branch Employees – You may not offer or give anything of value to Federal Executive Branch employees, except as follows: AECOM advertising or promotional items of little intrinsic value (generally $20 or less) such as a coffee mug, calendar, or similar item displaying the company logo; Modest refreshments such as soft drinks, coffee, and donuts on an occasional basis in connection with business activities; or Business courtesies, other than transportation, having an aggregate value of $20 or less per occasion. Do not provide AECOM-funded meals. (cont’d)

a) Federal Executive Branch Employees (cont’d): When combined, the value of the business courtesies may not exceed $50 in a calendar year. Although it is the responsibility of the Government employee to track and monitor these thresholds, you must not knowingly provide business courtesies exceeding the $20 individual or $50 annual limit. The “20/50 rule” is applicable. (cont’d)

b) Federal Legislative and Judiciary Branches, and State and Local Government Employees Employees of the Federal Legislative and Judiciary Branches and employees of State and local government departments or agencies are subject to a wide variety of laws and regulations. With few exceptions, you may not provide business courtesies to Senate or House of Representatives members, officers, or staffs. Generally, you also may not provide business courtesies to members of the Judiciary Branch. You may provide business courtesies of reasonable market value (less than $50 U.S.) to employees of State or local government in support of business activities, provided such practice does not violate any law or regulation or the standards of conduct of the recipient’s organization. It is your responsibility to know the prohibitions or limitations of the recipient’s organization before offering any business courtesy. (cont’d)

c) See the Business Gifts and Entertainment section of the AECOM Code of Conduct and MS Group Policy Any exceptions must be in strict compliance with applicable laws and approved in advance by AECOM MS Legal. d) See AECOM Code of Conduct – Conducting International Business for rules and regulations of business involving other countries The Foreign Corrupt Practices Act applies. Seek assistance from your supervisor or the Legal Department. (cont’d

Q: We have worked closely with a customer on a large contract that is now completed. We want to recognize the achievement by having a special event and give each team member a plaque commemorating the event. Would this violate AECOM rules of ethical conduct? A: It depends. In situations involving an agency of the U.S. Government, AECOM MS Group policy would only allow plaques, certificates, or similar items that are of little intrinsic value and intended solely for presentation. AECOM MS Group policy restricts giving Federal branch employees anything other than routine promotional items with a AECOM logo. For commercial customers, it would depend upon the policy of the individual customer and reasonable customs of the marketplace. Such events should be reviewed in advance with your manager and Legal. State, local, and foreign customers have differing requirements and should be reviewed with Legal.

FY2016 Business Conduct and Ethics Awareness Training

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FY2016 Business Conduct and Ethics Awareness Training

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