sentence
stringlengths
1
23.5k
This section of the report highlights some of the rigorous procedures we’ve put in place to counter risk and to continue developing a highly ethical workforce.
The COBC is our corporate policy addressing ethics and integrity issues.
It defines a uniform set of expectations for applying legal and ethical practices to everyday work.
The COBC applies to all employees, directors, officers, contractors and business partners around the world and guides us in our commitment to carry out our mission with integrity.
The Bribery and Corruption section of the policy is the foundation for our robust Anti-corruption and Compliance Program, which also includes detailed procedures and guidance.
Our COBC is available online in to all external parties, including suppliers, subcontractors and the general public.
It is also communicated and made available to employees and contract employees via their onboarding process, annual trainings, Zero Harm Moments, the our intranet and website, and ethics hotline posters in breakrooms.
Through our Supplier Code of Conduct, we require all suppliers and subcontractors to comply with our COBC.
International business partners must agree to abide by KBR’s COBC or the equivalent (in the event their code is substantially similar).
RESPOND to Allegations of Corruption Our anti-corruption procedures and guidelines are owned and published by the Legal Department and adhered to by all business and functional units, including Procurement/Subcontracts.
We have robust, risk-based, third-party due diligence and approval processes for agents, business partners and other third parties (including suppliers and subcontractors) who interact with nonU.S. government officials on our behalf.
We only engage such third parties that have successfully completed the due diligence review and approval process.
Our contracts with these parties include specific anti-corruption compliance provisions.
They are also required to certify compliance with the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and other applicable anti-corruption laws.
Foreign charitable and community contributions and business courtesies extended to clients undergo an anti-corruption review and approval process.
For more information, please refer to our Overview of KBR’s Anti-corruption Compliance Program.
KBR’s approach to ethical conduct is considered at the board level and is part of our enterprise risk management processes.
The audit committee of the KBR Board of Directors oversees our ethics and compliance program and controls, including its anti-corruption compliance program.
The chief compliance officer, who reports to the general counsel, has responsibility for implementing and managing both our COBC and anti-corruption compliance programs.
The chief compliance officer reports at least quarterly to the audit committee on any significant COBC and corruptionrelated compliance matters.
All our employees (both full- and part-time), directors and contract employees are required to complete compulsory annual ethics training, which reinforces KBR’s expectations that employees will conduct business ethically and in accordance with the COBC.
In settings at remote locations where online training wasn’t possible.
As part of the training, employees electronically certify that they have read and understand the COBC and that they will comply with its provisions.
A substantial portion of the workforce is also required to complete separate Combating Trafficking In Persons (CTIP) training, as mandated by the U.S. government for defense contractors.
We provide additional anti-corruption training to targeted employee groups.
Employees occupying certain positions of substantial authority or critical job functions also complete our Annual Conflicts of Interest Certification to ensure that the COBC is adhered to throughout the organization and that any potential conflicts of interests or issues are reported and evaluated.
All operations are subject to audits using a risk-based approach.
Following results of the annual risk assessment process, internal audit conducts regular audits across all KBR’s diverse portfolio, including but not limited to (The Sarbanes-Oxley Act of 2002 (SOX) compliance, (3) IT systems and cybersecurity, (4) anticorruption compliance, and (5) special projects and/or investigatio...
While the full scope of these audits varies based on their individual risk profiles, each audit includes an assessment over relevant key aspects of KBR’s ethics and compliance programs as outlined in the COBC and related policies and procedures.
Supply Chain Management https://www.kbr.com/sites/default/files/ POLICIES, PROCEDURES AND GUIDELINES FOR PROPER REQUISITIONS, COMMITMENTS, PAYMENTS AND RECORDKEEPING Collectively, our policies and procedures set the processes and guidelines for proper requisitions, commitments, payments and recordkeeping.
They serve to provide consistent, global transparency and awareness, thereby mitigating risks and misconduct, helping develop a highly ethical workforce and enhancing our status as a service provider of integrity.
As part of our internal monitoring system to detect potential corruption or suspicious payments, our internal audit services team regularly conducts anti-corruption audits of our projects and office locations through a risk-based approach, and periodically conducts anti-corruption audits of selected third parties.
We are in the process of enhancing our use of data analytics to support an internal monitoring system of compliance-sensitive payments.
Additionally, we review our general ledger accounts on a monthly basis for facilitating payments and improper fees.
Results are reported to our chief counsel for anti-corruption compliance.
COBC allegations of corruption and fraud, as well as allegations involving employees with a role in internal controls over financial reporting, are reported to the audit committee.
We also actively monitor and audit our internal compliance with our COBC via internal controls.
We encourage anyone who seeks guidance or who suspects inappropriate or unethical behavior The Ethics Hotline – This external, confidential third-party-managed ethics hotline can be used for anonymous reporting online, over the phone, by text or via email.
For all other countries, the toll-free telephone number can be found at www.ethics.kbr.com Director of business integrity via mail at P.O. Box 2464, Houston, TX 77252-2464, U.S.
fhoukbrcode% KBR is committed to promoting an environment where employees will report their concerns without any fear of retaliation and supports employees who are willing to speak up concerning unethical behavior and misconduct.
We have a strong policy against retaliation that protects employees who report potential violations, with legal protection in accordance with applicable law.
We do not tolerate retaliation of any kind, whether for good faith reporting of suspected misconduct or violations of the COBC.
Reporters are not expected to know all the facts, and we encourage employees to report without fear of retaliation even when there is a suspicion of Reporters to the KBR Ethics Hotline are made aware of KBR’s anti-retaliation policy and are encouraged to contact the business integrity team for any retaliation concerns.
Hotline reporters and any other employee that reports misconduct are advised at the conclusion of the investigation to report any forms of retaliation.
We will be implementing a feature that sends the anonymous reporter a subsequent follow-up inquiry for retaliation concerns after the conclusion of the matter.
Our anti-retaliation policy also applies to individuals that encourage reporting misconduct or cooperate with business integrity investigations.
All COBC allegations, of possible violations of the COBC including those related to potential human rights violations, are promptly and thoroughly investigated and evaluated at the corporate level with due care by a dedicated, specialized and experienced Business Integrity team.
In several options for reporting confidentially or anonymously.
Reporters can remain anonymous, only reveal their identity to the third-party hotline provider, or disclose their identity.
We also implemented an Ethics Question Manager, so employees can ask ethics questions anonymously.
For human resource disputes, employees can access a dispute resolution program (DRP).
Reports that are false or malicious are not considered good faith reporting.
We are responsible corporate citizens and neighbors in communities around the world.
We believe it is our obligation to add value to these communities beyond the professional services we provide.
We understand the importance of taxes in the context of the communities in which we operate, and we take a responsible approach to the management of our tax obligations.
Our transfer pricing strategy is aligned with our obligations under the COBC to conduct business fairly and ethically.
To ensure that intercompany and cross-border transactions are priced into the arms-length standard range, they are dictated by the Internal Revenue Code and the Organization for Economic Co-operation and Development’s transfer pricing guidelines.
tax strategy that complies with the laws of the included countries and provides an efficient structure through the life cycle of the project.
We are always reviewing our tax structure to address changes in local laws and standards and to ensure continuing compliance with foreign laws and global standards.
In accordance with the COBC, we do not engage in any planning or transactions that result in tax avoidance or evasion.
We strive to respect and promote human rights as set forth in the United Nations Guiding Principles on Business and Human Rights, and we are guided by international human rights principles encompassed by the Universal Declaration of Human Rights, including those contained within the International Bill of Rights and the...
Our human rights vulnerabilities are assessed at the board level and form part of our Enterprise Risk Management process.
In to uphold fundamental human rights in all the countries where we do business.
The policy is applicable to our employees, subcontractors, vendors, independent contractors, suppliers and business partners, and, together with the COBC, is consistently applied and enforced.
■ Complying with all applicable laws and regulations where we do business and adopting and applying our standards as set forth in this Policy where laws are less stringent.
■ Conducting due diligence on suppliers and other third parties to identify and prevent human rights risks to people in our business and value chain.
Where we have identified adverse human rights impacts resulting from or caused by our business activities, we are committed to providing for or cooperating in their fair and equitable remediation.
We seek to promote access to remediation where we are linked to or involved in those adverse impacts through our relationships with third parties.
■ Regularly assessing human rights risks, policies and impacts and providing visibility of the results to our board of directors (or applicable board committee) and senior management.
■ Including a human rights segment in our business ethics training.
We provide information and reporting procedures if any KBR employee, subcontractor, vendor, independent contractor, supplier, business partner or any of their respective representatives may have violated this policy or any applicable law, rule or regulation, or otherwise engaged in unethical behavior.
We are committed to continually evaluating the effectiveness of this policy and evaluating and improving our policies, procedures and training in each case with the help of and input from all our stakeholders.
This includes employees, subcontractors, vendors, independent contractors, suppliers, business partners, customers and members of the communities in which we operate, ensuring that the goals of this policy and the COBC are achieved.
Our governance framework is designed to achieve longterm value for our stakeholders and is guided by principles of accountability, good stewardship and integrity.
■ Risk management and strategic resilience ■ Audit, ethics and compliance program Our board of directors comprises five standing committees, each with its discrete charter.
The Sustainability and Corporate Responsibility Committee of the KBR Board of Directors provides global oversight and support of the corporation’s sustainability, human capital management and corporate responsibility policies, programs, and initiatives.
These cover, but are not limited to, issues and responsibilities related to (capital management, including diversity, equity, and inclusion, and workforce health, safety, and physical security, and (3) the corporation’s role and reputation as a socially responsible organization.
The Global Sustainability Committee, which is chaired by the CEO, responds to directives from the Sustainability and Corporate Responsibility Committee of the board and implements sustainability practices at a business level globally.
Members include business segment and corporate department executives, as well as key employees, to ensure well-rounded and in-depth discussions that support the development and implementation of KBR’s sustainability strategy and targets.
The corporate sustainability team implements the global sustainability committee’s strategy by working with key business areas and corporate functions to assist monitoring, managing and reporting on performance in ESG focus areas.
Each board committee oversees key sustainability and corporate responsibility concerns, many of which are interrelated.
Supply Chain Management Meet our board of directors Members of our board bring a wealth of experience across our five key sectors, including risk management, audit and cybersecurity.
They are responsible for closely monitoring current and emerging sustainability risk management themes, including but not limited to supporting a safe, skilled, diverse and inclusive workforce; cybersecurity and data privacy; climate change; human rights; ethics; business integrity; and environmental management.
BUSINESS STRATEGY AND RISK We continue to advance our planned core strategic focus, bringing clean technology innovation and solutions to market through our Sustainable Technology Solutions and Government Solutions businesses, supporting and guiding our customers’ decarbonization, emission reduction and energy transiti...
* KBR participated in Operation Warp Speed (OWS) and Operation Allies Welcome (OAW).
Both were special projects in response to anomaly situations: the COVID pandemic and the final days of the 2001-2021 war in Afghanistan, respectively.
To allow for a year-on-year comparison of sustainability-focused revenue growth, revenue figures and percentages exclude OAW due to materiality.
Increased investments/acquisitions (such as Mura) and focus in sustainable technology licenses, technology solutions and Technology-Led Industrial Solutions.
At the conclusion of the threeyear monitorship, the monitor certified that our current anti-corruption compliance program was appropriately designed and implemented to ensure future compliance with the Foreign Corrupt Practices Act (FCPA) and other applicable anti-corruption laws. July Revised KBR COBC to disallow all ...
third-party due diligence, business courtesies, and charitable contributions' workflows to improve accuracy, transparency and oversight.
February ERM reports are required regularly at the board level.
QCommenced applying ERM outputs to develop and implement strategic risk reduction.
KBR's Sustainability and Internal Audit teams partnered to audit the Report.
In framework and processes are applied to environmental, social and governance aspects and risks and opportunities are managed accordingly.
December KBR establishes a Climate Security working group dedicated to identifying and analyzing our climate-related risks and opportunities.
June ■ Energy Solutions combined with technology business to create Technology Solutions.
Frazer-Nash Consultancy acquired to expand international advisory footprint and Harmonic to enhance technical innovation.
Further investment into Mura Technology to expand the plastics circular economy with the Hydro-PRT technology.
August DOJ and SEC conclude investigation into KBR over Unaoil.
Based on the thorough four-year investigation of the available information, the DOJ closed its inquiry into KBR, and the SEC did not recommend any enforcement action against KBR regarding Unaoil.