Integrity

Ethics Audits

Our Ethics Officers participate in annual Ethics audits of other operations, and support audits of their own sites by other Ethics Officers. The purpose of these audits is to ensure that the Ethics Program is being implemented in accordance with the Company's guidelines. The Corporate Ethics Program office makes the audit assignments in such a way that no two Ethics Officers audit each other's Program in the same Program Year. Audit procedures and guidelines are published each year before the beginning of Ethics Audits.

Download: Presentation on Ethics Audits

Self Audit

A self audit requires the Ethics Officer to continually monitor his or her program as it relates to each of the areas of compliance set forth in the Code, as appropriate for that project, office or location:

Workplace Environment, including review and evaluation of safety policy, procedure, practices and inspections; validation and verification of reports/certifications regarding drug-free workplace/workforce programs.

Information Recording and Reporting, including timecard/timesheet audit and verification of attendance; validation/verification of training/test data; validation/verification of cost, pricing, accounting and financial data against approved disclosure statement and correct allocation of allowable/unallowable costs.

Protecting Resources, including audit/inventory of fixed assets; audit of compliance with published security policy/procedures.

Conflicts of Interest, including audit of reports/verifications required by federal procurement integrity laws; inquiry into second jobs of employees. The Conflict of Interest/Second Job Disclosure Statement needs to be completed annually by each employee.

Community Relations, including audit of files for copies of letters to vendors regarding ethics program; review of marketing and business development guidelines for antitrust compliance.

Rights, Responsibilities and Results, including review control of allegation report records to maintain appropriate employee privacy; review procedures for compliance with the Code.