November 2021

Code of
Conduct

© AECOM Restricted
Contents
A letter from Troy Rudd  03 Obtaining business with integrity 25

Our Vision and Core Values 04 Competing fairly 26

Introduction 05 Handling competitive information 28

Integrity in everything we do  05 Avoiding corrupt practices 29

One AECOM, one code  06 Conducting international business30

What laws should I know and follow?07 International sanctions 32

It’s up to you to ask question and report Boycott requests 32

concerns 08
Our shareholders, business partners and
Why is reporting important? 08 customers rely on our excellence  33
How do I raise concerns? 08 Providing quality products and services33
What happens next?  08 Licensing 33
Our commitment to non-retaliation 09 Charging time 34
We rely on our colleagues’ respect 10 Accurate books and records 36

Our commitment to equity, diversity and Record retention 37

inclusion 10
Audits and investigations 38
Keeping our workplace safe  12
Protecting inside information 39
Meeting global employment standards 13
Preventing money laundering 40
Leading with integrity 14
Additional expectations 41
AECOM relies on our honesty 15
Our communities rely on our integrity
Avoiding conflicts of interest 15 and innovation 42

Avoiding organizational conflicts of interest17 Environmental, social and governance

approach – Delivering sustainable legacies42
Business gifts and entertainment 18
Political and charitable contributions43
Protecting company property and data
privacy 20 Responding to media inquiries 44

Using company computer systems22 Waivers 45

The Global Marketplace relies on our It’s up to you 46

integrity  24

Honesty in everything we do 24

© AECOM Restricted
AECOM Code of Conduct (EC1-001-PL1)
Revision 12 November 29, 2021
PRINTED COPIES ARE UNCONTROLLED. CONTROLLED COPY IS AVAILABLE ON COMPANY INTRANET. 2
A Letter from Troy Rudd

A message from our chief executive officer

One of our greatest strengths as a company is our ability to remain agile

in a constantly changing operating environment, delivering exceptional
results and upholding the highest standards of integrity and ethical
business practices.

Our clients, employees and stakeholders know us to be the best in what

we do and how we do it. But we cannot create Sustainable Legacies
without ensuring that we operate with integrity. The reputation we’ve
built has been the foundation for our continued success and has helped
us navigate the intricacies of operating as a global company. As such, it
is imperative that every employee adheres to the guidelines outlined in
our Code of Conduct, which are regularly updated to reflect the dynamic
nature of our business.

Our Code of Conduct provides a framework of ethical and legal principles

to help us act appropriately when making business decisions, and it
includes useful resources for you to report and resolve any issues related
to ethics and compliance. Our Code of Conduct is not meant to be an
exhaustive list of prohibited activities or a comprehensive manual. If you
find yourself in a situation that makes you question whether a violation of
applicable law or our Code has occurred, you can always ask for help and
guidance. Rest assured that the company will assist you and have your
back in doing what’s right.

Your honest and sincere judgment— in tandem with our Code — is the
first line of defense against any potential harm to our company and our
reputation. While all of us work collectively toward this common goal,
please remember: Ethics Starts with You.

Thank you for upholding our culture of integrity and ethical behavior.

Troy Rudd
Chief Executive Officer

© AECOM Restricted | November 2021 3

Our Vision and Core Values

Our core values define

who we are, how we act
and what we aspire to be.
Our vision: A world where infrastructure creates opportunity for
everyone — uplifting communities, improving access and sustaining
our planet. Our work has the power to create opportunities for
people and transform spaces and environments. We continue to
work toward our vision for the future.

Safeguard Deliver

We operate ethically and with We grow our business

integrity, while prioritizing safety through relentless client focus,
and security in all that we do. operational excellence and
exceptional project execution.

Innovate Sustain

We think without limits and embrace We take action to make a positive

new ideas, shaping digital solutions impact on the planet, enrich the
to help clients address current and communities we touch and build
future challenges. legacies for future generations.

Collaborate Thrive

We connect unrivaled expertise We build diverse teams, create an

from around the world to anticipate inclusive workplace and provide
and solve our clients’ most opportunities where each one of our
pressing challenges. people can reach their full potential.

© AECOM Restricted | November 2021 4

Introduction
Integrity in everything we do

At AECOM, we are committed to doing the right thing, every time. We

believe this commitment to integrity has made our company an industry
leader and will continue to serve our growth in the years ahead. AECOM’s
Code of Conduct (“Code”) addresses our company’s professional, ethical,
financial and social values. It sets forth what is expected of all AECOM
employees, wherever we conduct business. Our Code also represents our
commitment to our clients, shareholders, partners and the communities
in which we live and work.

Our Vision and Core Values are the foundation for this Code.
The following principles set forth the guidelines To help you determine whether a particular
of behavior that we must follow: action is appropriate, ask yourself the following
questions:
• Ethical behavior is the basis for everything we do. • Would my action comply with the spirit and purpose
• AECOM is committed to treating its employees of AECOM’s policies?
fairly and providing each of us with opportunity • Would I feel comfortable doing this, or would it
for advancement and growth. violate my personal standard of conduct?
• Teamwork, mutual respect and trust, and • Is this action honest in all respects?
open communication are the foundation of
AECOM’s culture. • How might this action affect others?

• AECOM strives to be a responsible corporate • Would this action embarrass me or AECOM if it

citizen in the communities in which we operate. became known to my clients, coworkers,
professional colleagues, family or friends?
• Meeting clients’ needs is of utmost importance.
• We are committed to compliance with the laws, If you have any questions about this Code or any
rules and regulations applicable everywhere we doubts about a particular course of action, you
conduct business. should consult with a member of AECOM’s Ethics &
Compliance team, Management, Human Resources
Our Code is meant to provide guidance regarding
or In-House Counsel. You may also visit the Ethics &
these principles. However, one document cannot
Compliance webpage on the AECOM intranet, where
possibly address every law, rule, policy or scenario
you can find links to AECOM’s policies and procedures
we may encounter in our daily work. Nor is our Code
as well as processes and guidelines.
a substitute for exercising common sense and good
judgment or seeking guidance when we need it.

© AECOM Restricted | November 2021 5

One AECOM, one code

We all have an obligation to read, understand and follow this Code of Conduct. It applies to
all AECOM employees, officers and directors, including those of our subsidiaries and joint
ventures where AECOM has the majority interest. Further, we expect that our suppliers,
agents, business partners, consultants and licensees will follow similar principles. Using
our Code to guide our actions allows us to preserve our reputation for doing business the
right way.

To this end, each of us must: You are responsible for reading and understanding
the Code and expected to abide by it. How you embody
• Personally abide by the Code. AECOM’s ethical values expressed in the Code is an
element of the employee performance evaluation process.
• Not assist others in violating the Code. Violations of the Code will result in disciplinary measures,
including termination of employment.
• Report any perceived violation, or request
that might constitute a violation, by following the AECOM also expects its consultants, subcontractors and
procedures outlined in the “How Do I Raise Concerns?” other third parties to be aware of and adhere to the ethical
section of this Code. standards described in this Code. If you become aware
of any activity involving the conduct of these individuals
• Take action as requested to remediate any that violates the principles of this Code, you must disclose
violations or potential violations of the Code. it to a member of AECOM’s Ethics & Compliance team,
Management, Human Resources or In-House Counsel.
• Complete training on the Code and other
assigned learning in a timely manner.

© AECOM Restricted | November 2021 6

What laws should
I know and follow?

AECOM is a global company, and laws differ among the various locations where we conduct
business. Wherever we are located, we must know and follow the laws and regulations that
apply to our business and the countries where we operate. Many of our clients also have
their own Codes of Conduct and may ask us to comply with them as part of our work. If you
are ever unsure about whether a law, regulation or other obligation applies — or if there is a
conflict between local law or another company’s code and this Code — contact a member
of AECOM’s Ethics & Compliance team, Management or In-House Counsel for guidance.

In addition, you must abide by AECOM’s internal policies, particularly

the Approval Matrix, as it is the basis for our authority to act on behalf
of the company. The Approval Matrix is available on AECOM’s intranet.

© AECOM Restricted | November 2021 7

It’s up to you to ask question
and report concerns
Why is reporting important? In addition to the AECOM Ethics Hotline, you may raise
honest and sincere concerns or make a report by reaching
out to any of the following resources via email, online,
It is important to raise questions and
phone, letter or in person:
come forward with our honest and
sincere concerns. Doing so reinforces • Your supervisor or someone in Management.

our commitment to act ethically in every • The Human Resources department.

business decision we make. Early detection • An AECOM In-House Counsel.

also allows AECOM to address concerns • AECOM’s Chief Ethics & Compliance Officer.

before they become widespread problems, • A member of the Ethics & Compliance team.

and to take corrective action if necessary. AECOM treats all reports confidentially to the extent our
Above all, AECOM is committed to company is able to. We do so consistent with the law,
maintaining a culture where each of us feels company policy and the requirements for conducting a
comfortable asking questions, speaking up thorough investigation. Suspected violations may even be
reported anonymously, where allowed by local law.
and working toward solutions.

How do I raise concerns?

All AECOM employees should raise honest and sincere
concerns. One method for reporting is through the AECOM
Ethics Hotline, which 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 will document your concerns and
relay them to AECOM.
You can contact the AECOM Ethics Hotline by visiting
aecom.ethicspoint.com, calling 1-888-299-9602 (within
the U.S. and Canada) or scanning the QR Code on this page
with a mobile device to visit the hotline mobile site, aecom.
navexone.com. Please refer to the Ethics Hotline poster in
your office for the telephone number in your country or go
to the AECOM Ethics Hotline page on the AECOM intranet.

What happens next?

AECOM promises to investigate all reports promptly, thoroughly and

consistent with applicable law. Investigations will be kept confidential
to the extent possible. If necessary, AECOM may report certain
investigations to the appropriate authorities. Our company will take
appropriate corrective or disciplinary action for Code violations
whenever necessary.

© AECOM Restricted | November 2021 8

Our commitment
to non-retaliation
AECOM does not tolerate acts of retaliation against anyone who
makes an honest and sincere report of a possible violation of law
or of AECOM’s Code of Conduct or policies, or who participates in
an investigation of possible wrongdoing. Simply stated, it does not
matter whether your report actually uncovers unethical behavior, as
long as you are honest and sincere in making it. Many countries have
enacted legislation to protect those who report misconduct. AECOM
enforces any applicable protections afforded by such laws.

Q A
Paulo, an AECOM technician, witnesses his Paulo is right to be concerned about the instructions
supervisor, Suzanne, being particularly harsh to and hostile atmosphere his supervisor’s actions
a few of his colleagues. Performance has been have created. While Suzanne’s actions may or may
suffering lately, and Paulo assumes Suzanne is not be a direct violation of our Code, the result of
simply frustrated with recent mistakes his team has her behavior is a problem. Paulo should take the
made. However, her behavior has become more matter to Suzanne’s manager or another resource
aggressive, and morale on the team is low. She has with whom he feels comfortable so that AECOM can
recently begun berating team members to charge investigate and resolve the issue. Paulo — and all
less time to overhead and more time to projects, other AECOM colleagues who make an honest and
even though their billable work has slowed down. sincere report of potential misconduct — will be
Paulo feels that he should tell another member protected from retaliation after making his report.
of Management about the environment Suzanne
has created, but he is worried that he will be the
next person she punishes. What is his best course
of action?

© AECOM Restricted | November 2021 9

We rely on our
colleagues’ respect
Our commitment to equity, diversity and inclusion

AECOM is committed to fostering a workplace where we are all treated

with dignity and respect. Our different backgrounds, experiences and
perspectives give our company the strength we need to lead in our
marketplace and reflect our commitment to equity, diversity and inclusion.
AECOM will not tolerate unlawful discrimination or harassment in the
workplace. We all have the responsibility to treat our colleagues — as
well as applicants for employment — with respect and in a fair,
non-discriminatory manner.

AECOM offers equal employment opportunities for all

applicants. This gives each of us equal consideration for
In any form, harassment is
employment, regardless of background. AECOM makes a violation of our Code and
all decisions regarding recruitment, hiring, training,
promotions, transfers and layoffs based on merit, and not
company policy. If you feel
on any trait protected by applicable law. Such traits include, you or someone else is being
but are not limited to, age, ancestry, color, sex (including
pregnancy, childbirth or breastfeeding), marital or familial
harassed or discriminated
status, medical condition, national origin, physical or mental against, report your concerns
disability, race, religion, sexual orientation, gender identity,
gender expression and veteran and citizenship status.
to a member of AECOM’s
Ethics & Compliance team,
Maintaining a respectful workplace also means that we
never engage in or tolerate any form of harassment. To be
Management, Human
clear, “harassment” is any action that creates or seeks to Resources or In-House
create a hostile, intimidating or offensive work environment.
Harassing behavior can be sexual or nonsexual in nature. In
Counsel right away.
either case, it has no place at AECOM. Harassing conduct
can include, but is not limited to:

• Verbal remarks (comments, suggestions, jokes

or requests for sexual favors)

• Pictures (drawings, photographs orvideos)

• Physical behavior (suggestive looks, leering or

unwelcomed touching)

• Bullying

© AECOM Restricted | November 2021 10

We embrace the diversity
of every employee
through an inclusive and
accountable culture.

Q A
Shanique is an engineer at AECOM and has recently Learning to work in a new environment can be
relocated to the Middle East to work on a large challenging — even more so when faced with
project. Most of her new colleagues have been impatience or hostility. Shanique, like all AECOM
welcoming and helpful, making it easy for Shanique colleagues, deserves to work in an environment
to settle in. However, another AECOM colleague, where she can be both comfortable and successful,
Bruce, has expressed exasperation with the time consistent with our commitment to diversity and
it is taking Shanique to adapt to her new work inclusion. Bruce’s behavior is depriving Shanique of
environment. Bruce often rolls his eyes and sighs that right. If Shanique feels comfortable speaking to
when Shanique asks him a question. Lately, Bruce Bruce directly, she should explain that his comments
has begun asking Shanique, “Don’t they teach you to her are hurtful, offensive and need to end. If
anything in your country?” and implies that Shanique Shanique doesn’t wish to approach Bruce directly,
is ignorant and incompetent. When Bruce invites his or Bruce’s behavior doesn’t end, Shanique should
colleagues to go to lunch, he does not include her. reach out to her supervisor or Human Resources
Shanique now feels so uncomfortable around Bruce representative for assistance.
that she avoids asking questions altogether, causing
her work product to suffer. What can Shanique do?

© AECOM Restricted | November 2021 11

Keeping our
workplace safe

Our Safeguard Value demonstrates our commitment to

operating ethically and with integrity in all that we do,
while prioritizing the safety and security of our people,
our physical assets and the environment.
In all aspects of our work, each of us concern to Management, SH&E or so as not to pose a health and safety
is responsible for complying with all In-House Counsel immediately. hazard to themselves or others. This
applicable laws and regulations, as well extends to use of alcohol or drugs
A safe and secure work environment
as AECOM’s internal Safety, Health (including improper use of prescription
is one that is also free from violence.
and Environment (SH&E) and Security medication), excessive fatigue or other
Threatening behavior — even if
requirements. personal circumstances that could
meant in jest — is never permissible
diminish, or even raise questions
To assist our employees with at AECOM. If you witness or receive
concerning, our ability to perform
managing these responsibilities, we a threat or act of violence, report it
at our best.
maintain robust management systems to a member of AECOM’s Ethics &
and programs specific to each of our Compliance team, Management,
businesses. In addition, we publish Human Resources or In-House
a global SH&E Policy Statement and Counsel immediately. If you ever face
SH&E Life Preserving Principles that an immediate threat to your safety or
apply to all operations. If you have that of your colleagues, contact local
any indication that we are operating law enforcement immediately, and then
outside of our established business- report the incident internally.
level programs or the requirements
Further, our employees are responsible
of our global SH&E Policy and/or Life
to report to work each day fit for duty,
Preserving Principles, report your

© AECOM Restricted | November 2021 12

Meeting global
employment standards
As part of our commitment to our global community, we conducting business with an entity engaging in forced
uphold individual human rights and follow employment labor or human trafficking practices, report your concerns
laws in all the locations where we conduct business. to a member of AECOM’s Ethics & Compliance team,
Management, Human Resources or In-House Counsel
In support of this commitment, we provide reasonable
immediately.
working hours and conditions. Further, AECOM’s Anti-
Human Trafficking/Modern Slavery Policy establishes our Keep in mind that our company operates in countries
zero tolerance policy regarding the use of forced labor, where we do not have a permanent presence. Because
human trafficking or other forms of modern slavery. We of this, supervisors should seek guidance from In-House
will never knowingly conduct business with subcontractors, Counsel regarding the employment law standards
business partners, suppliers or third parties who violate governing these operations.
these laws. If you have reason to believe AECOM is

© AECOM Restricted | November 2021 13

Leading with integrity
Our leaders serve as resources and role models for proper business conduct. For that
reason, supervisors have additional responsibilities when it comes to upholding our Code.
They are expected to promote a positive working environment where people are treated
with dignity and respect and feel comfortable raising concerns. Supervisors must also make
an effort to create a culture of compliance. This can be done, in part, by:

1. Acting as role models for Code compliance. 5. Appropriately responding to inquiries about our Code.

2. Fostering an environment that encourages 6. Immediately notifying In-House Counsel

open discussion about legal and ethical concerns. of any matter reported to them.

3. Recognizing employees who exhibit 7. Ensuring training is completed in a timely manner

exemplary ethical behaviors. by all employees.

4. Vigilantly preventing and detecting violations 8. Considering an employee’s commitment to ethical

of our Code, company policy or the law. conduct during the performance evaluation process.

Q A
Li is a manager heading one of AECOM’s key No. Li should listen to the individual’s concerns and
business initiatives. His team is preparing a bid to ensure that his team is not pursuing a bid in a manner
a new client, a government-owned company in a that could cause AECOM to jeopardize its reputation
country where AECOM has not done major business and ethics. When we are working on new projects
before. At a meeting to discuss bid strategy, an in new areas, it is critical that we educate ourselves
employee of another company teamed with AECOM on the national and international restrictions that
asks detailed questions about how AECOM will will apply. Anti-bribery laws can affect our selection
handle compliance with anti-corruption laws and of local consultants, while export regulations and
sanctions for the bid. Li shuts off discussion, sanctions may restrict dealing with or transferring
saying it’s okay to take a few risks now and deal technology to certain entities and individuals.
with “the red tape” later once we win. Is this the The Approval Matrix sets out requirements for
right response? management review that identify and mitigate these
risks. Properly complying with these rules requires
planning and oversight, but breaking them can
create catastrophic risk for AECOM.

© AECOM Restricted | November 2021 14

AECOM relies on our honesty
Avoiding conflicts of interest

We each have a personal stake in acting in the best interest of AECOM. To

ensure our continued success, it is crucial that we avoid conflicts of interest,
whether actual, potential or perceived. A “conflict of interest” occurs when
we use our position at AECOM, or information we have acquired during our
employment, in a way that may create a conflict between our personal interests
and those of our company or its customers.
In other words, if a situation arises that makes it difficult to act in an unbiased, objective manner on AECOM’s
behalf, then a conflict of interest may be present. If a conflict of interest — or the potential for one — arises,
you must disclose it to a member of AECOM’s Ethics & Compliance team, Management, Human Resources or
In-House Counsel at once for review.

Of course, not all scenarios that would give rise to a conflict of interest can be listed here. However, the following
examples are some of the more common conflict situations you are likely to encounter in your daily work.

Business with family and friends Corporate opportunities

Our decisions about selecting suppliers, customers and At times, we may learn of business opportunities through
other persons doing or seeking to do business with AECOM our employment at AECOM. We may not take personal
must be impartial. The sole criterion of any business advantage of those opportunities or refer them to a third
decision must be whether AECOM’s best interests are being party unless AECOM has had a chance to evaluate the
advanced. If a family member or close friend has an interest
prospect and has decided not to pursue it.
in a company with which we seek to conduct business,
you must remove yourself from the selection process and
disclose the conflict immediately to In-House Counsel.

Outside employment Investments

Being employed by or consulting with another organization AECOM does not seek to control personal financial
could also create a conflict of interest. In general, we may decisions. However, some outside financial interests may
not accept another job that interferes with our ability to do improperly influence — or could be perceived by others
our work for AECOM. This means we may never conduct to influence — the decisions we make for AECOM. As a
outside business during designated work hours or use
result, AECOM limits investments by its employees (and
AECOM’s property, equipment or information for another
members of their households) in publicly traded companies
business. Further, we cannot accept employment from
a supplier or competitor of AECOM without an express that are AECOM’s competitors, customers, suppliers or
written waiver from In-House Counsel. In any case, prior other business partners; such investments are only allowed
written approval from In-House Counsel is required before if they do not exceed the lesser of 1% of the company’s
performing any outside work. outstanding shares or a fair market value of $25,000
(calculated at the time of the investment). Before you, or a
member of your household, own or seek to own a financial
interest in a publicly-traded competitor, customer, supplier
or other business partner of AECOM that is above the
foregoing threshold or in any privately-owned competitor,
customer, supplier or other business partner of AECOM, you
must obtain prior written approval from the Chief Ethics &
Compliance Officer.

© AECOM Restricted | November 2021 15

Avoiding conflicts
of interest
Personal Relationships Serving on a Board of Directors
Supervising anyone with whom you have a family or At times, we may seek to sit on a board of directors outside
romantic relationship could give rise to the appearance of of AECOM. While impacting your community by serving
favoritism. Therefore, we should never be in a position where on a board of directors for a non-profit organization is
a personal relationship is also a reporting relationship. encouraged and does not require prior approval, you
These personal relationships include relationships with may only accept this position if it does not interfere with
your immediate family members (such as your spouse, your ability to do your job. However, serving on the board
children, stepchildren, parents, step-parents, siblings, in- of directors for an outside company requires advance
laws and any other members of your household) and your approval. Always seek approval from In-House Counsel
romantic or intimate relationships (such as with a partner, before accepting such a position, including sitting on public
fiancé or fiancée, or domestic partner). If you find yourself commissions or taking public service appointed positions.
in a position where you would supervise or otherwise
make employment decisions regarding a family member or
partner, disclose the situation immediately.

Remember that prompt and full disclosure is required for all circumstances that you
believe might constitute, or appear to constitute, a conflict of interest. If you are unsure,
seek guidance. Never engage in any conduct involving a possible or apparent conflict of
interest unless you receive prior written approval from Ethics & Compliance or
In-House Counsel.

Q A
Abdul is an accomplished civil engineer who has Yes. While Abdul is still employed at AECOM, he
put in many years of design work for AECOM. As he must not accept work from a business partner,
nears retirement, Abdul is considering taking on supplier or competitor of our company. Doing
part-time work as a design consultant. A current so could create a serious conflict of interest.
business partner of AECOM hears about this and Additionally, depending on the type of work Abdul is
immediately expresses interest in making use of performing, he must be careful not to disclose any
Abdul’s services if they will cost less than AECOM’s confidential AECOM information — an obligation
rates. Does Abdul need to discuss this with anyone? that applies even after his employment with AECOM
ends. Before pursuing any opportunities with this
business partner, Abdul must first check with
Management or In-House Counsel to ensure he is
not entering into a conflict of interest situation.

© AECOM Restricted | November 2021 16

Avoiding organizational
conflicts of interest
When we work with government Organizational conflicts of interest primarily arise
as a result of one of the following three situations
clients, we must avoid
concerning AECOM’s work:
organizational conflicts of interest,
as the guidelines and restrictions
for government procurement are
very strict. Just as we must avoid
situations that could make us
1
Biased ground rules
biased, we must also avoid working Situations in which a firm, as part of fulfilling a contract, has
set the ground rules for another contract, for example, by
with others who could be unable writing the statement of work or the specifications. In these
to provide a client with impartial “biased ground rules” cases, the primary concern is that
the firm could skew the competition, whether intentionally
assistance or advice. or not, in its own favor. These situations may also involve a
concern that the firm, by virtue of its special knowledge of
In short, we must never hire contractors whose
the customer’s future requirements, would have an unfair
objectivity may be impaired, or who may have an advantage in competing based on those requirements.
unfair competitive advantage. We should exercise
common sense, good judgment and sound discretion

2
to assess whether an actual or apparent conflict of
interest exists and work with Management and
In-House Counsel to develop an appropriate way
to resolve any such conflict.
Impaired objectivity
Situations in which a firm’s work under one contract could
entail evaluating itself, either by performing an assessment
of work completed under another contract or by evaluating
proposals. In these “impaired objectivity” cases, the
concern is that the firm’s ability to render impartial advice
to the customer could appear to be undermined by its
relationship with the entity whose work product is being
evaluated.

3
Unequal access to information
Situations in which a firm has access to non-public
information as part of its performance of a contract and
where that information may provide the firm a competitive
advantage in a later competition for a second contract. In
these “unequal access to information” cases, the concern
is limited to the risk of the firm gaining a competitive
advantage; there is no issue of bias.

© AECOM Restricted | November 2021 17

Business gifts and
entertainment

Accepting or giving occasional gifts or entertainment with business partners is allowed

under some circumstances. However, we must act in a manner consistent with our core
values, the various laws that govern our actions and our contract requirements. Any gift
that could create an obligation or influence the business relationship should never be
offered, provided or accepted.

AECOM employees should never request a gift from another party. Our customers, suppliers and
the public at large should know that our employees’ judgment is not for sale. For these reasons,
we may only offer, provide or accept gifts or entertainment in accordance with applicable law and
our enterprise, group and regional gift and entertainment policies and procedures.

We must never offer, provide or accept these courtesies if:

• It is illegal under any applicable laws or regulations. • It would violate any law, regulation, rule or the standards
of the recipient’s organization.
• It is part of an agreement to do or accept
anything in return. • It could be construed as a bribe or a kickback.
• It could influence the recipient or the recipient’s • It might reasonably be interpreted as a reward for
organization in any business dealings. preferential treatment, actual or perceived, or as creating
an obligation on the other party.
• It is cash or cash equivalent, such as gift cards or
certificates, loans, stock, stock options, etc. • It is lavish or extravagant.
• It is entertainment that is sexually oriented, offensive, • It happens frequently.
in poor taste or otherwise violates AECOM’s commitment
to mutual respect.

© AECOM Restricted | November 2021 18

Business gifts and
entertainment
Additional restrictions apply when interacting with a public official,
whether local, regional or national. We may never provide gifts, meals
or entertainment to public officials or employees associated with an
active procurement.

Q A
One of AECOM’s vendors in the U.K. sponsors an No. This creates a conflict of interest, and you
annual golf outing for its major customers each should decline the invitation. Accepting the golf
year with all expenses paid at an exclusive resort outing may put you in a position of obligation to
in Scotland. Because I use this vendor’s products the vendor. In addition, you may be viewed as
on some of my projects at AECOM, the vendor has accepting the gift or unusual favor because of your
invited me to go. Can I accept? position at AECOM.

Q A
Deepak is working closely with a government The rules governing the types of gifts and
employee, Elba, on a contract. Next week, he’ll be entertainment we can offer government employees
traveling to Elba’s offices so that she can update him are much stricter than those governing our
on the project and discuss next steps. Deepak also interactions with commercial contacts. Since Elba is
knows that AECOM has submitted a bid for another involved in evaluating a bid from AECOM, taking her
project, and Elba is one of the officials evaluating the to lunch could raise questions under multiple anti-
bid. Deepak would like to take Elba to lunch while he corruption laws, including the U.S. FCPA and U.K.
is visiting as a business courtesy. Is it okay to take Bribery Act, and may violate local laws. Deepak must
her out to lunch? check with In-House Counsel to evaluate whether
this is permissible or wise.

© AECOM Restricted | November 2021 19

Protecting company property
and data privacy
We have worked hard to acquire our valuable assets, both physical and
intangible. AECOM’s physical property includes its buildings, facilities,
vehicles, equipment, computer systems, resources and records. We are
responsible for protecting such property from loss, damage, misuse,
theft and waste. We can do this by using company resources wisely and
only for business purposes.
It is also important to protect our intangible assets — things like our reputation and goodwill in
the communities in which we operate. Such assets also include our confidential information,
like business plans, intellectual property, proposals, technical innovations, designs, inventions,
patents, financial information, client lists and other information we produce as part of our work
for AECOM. We may never reveal our company’s confidential information to any outside parties
unless we are properly authorized or legally required to do so.

In addition, we may not disclose such information to If you discover or suspect the unauthorized use or
our colleagues who do not have a legitimate business disclosure of confidential information, you should
need to know it. When you do have a business need to notify Management or In-House Counsel of the
disclose such information to a colleague or third party, situation immediately.
you must ensure that the appropriate confidentiality In addition to protecting the confidential information
agreement is in place. Remember, the obligation to of AECOM, we must afford this same respect to the
protect confidential company information continues confidential information of our employees, clients,
even after your employment with AECOM ends. partners and other third parties.

AECOM takes seriously the privacy and protection

of the personal data of our employees, our clients
and our shareholders in accordance with applicable
laws. The personal data files of any person — such as
payroll, group insurance, benefits and working files —
should be kept and transmitted securely and should
not be accessed without proper authority.

© AECOM Restricted | November 2021 20

Protecting company property
and data privacy

Q A
May I provide the addresses of our employees to No, as this would violate our privacy policy.
an outside organization that wants to offer them Employee records are confidential, and there is no
merchandise at a discount? valid business reason to provide this information.

© AECOM Restricted | November 2021 21

Using company
computer systems

Just as we have a duty to protect our company’s assets, we share an

obligation to use AECOM’s computer resources, networks and internet and
email systems responsibly and securely. These resources are provided for
business purposes and are intended to be used for such.

While AECOM allows incidental, occasional personal AECOM understands the unique opportunity we have
use of its internet/email system, it must be kept to a to engage with our stakeholders through social media.
minimum and not detract from our work. You must These include blogs, micro blogs, social networking
also take care to avoid improper use, such as: sites (such as Twitter®, Facebook®, LinkedIn®), wikis,
photo/video sharing sites and chat rooms. However,
• Communicating inappropriate, sexually explicit
when utilizing these resources, we must keep in mind
or offensive statements that are not in line with our
that electronic messages are permanent, transferable
Core Values.
records of our communications. They can be altered
• Viewing or sharing sexually explicit or offensive without our consent and can affect AECOM’s
materials. reputation if released to the public. Therefore, we are
• Spreading profanity, derogatory remarks, expected to follow all AECOM policies and procedures
discriminating or harassing comments, or when using social media and to exercise good
threatening or abusive language. judgment and common sense. Never speak or act on
our company’s behalf unless authorized to do so.
• Downloading unlicensed or illegal material.
If you are aware of or suspect inappropriate use of
We should never use AECOM’s networks or internet/
AECOM technologies or electronic communications,
email system to send, receive or store any messages
notify Management, a member of AECOM’s Ethics
we intend to keep private. All information, data and
& Compliance team, Human Resources or In-House
files belong to our company, and — to the extent
Counsel immediately. If you have any questions about
permitted by applicable law — AECOM reserves the
who may communicate on a given issue, or whether a
right to monitor or disclose any messages, documents
communication is appropriate, please see our Social
or any other files on company or client computers
Media Policy.
without notice. We are expected to be familiar with
our company’s information resource policies. These
include, but are not limited to, policies concerning the
appropriate distribution of emails and compliance with
copyright laws.

© AECOM Restricted | November 2021 22

Using company
computer systems

Q A
Rafaella is working on a major bid and traveled No. While Rafaella has the right idea — keeping
abroad with the rest of the AECOM team, preparing information locked up and out of plain view — even
for a live presentation to the client at their secure locations aren’t perfectly safe. If someone
headquarters. Everyone on the team is going to enters her room and steals her laptop or downloads
dinner at the hotel at which they are staying. Rafaella her data, they could have access to many of
is in her hotel room working on the pricing details for AECOM’s bid details, proprietary design materials,
the presentation to the client. She saves her work, business plans and other private information. The
leaves the laptop in her room and locks the door best, safest option is for Rafaella to carry her laptop
before she goes to dinner. Has Rafaella done all she and all of its confidential contents into the restaurant
can to protect AECOM property and information? with her. What may be a mild inconvenience to
Rafaella now could save her and AECOM from
trouble later on.

© AECOM Restricted | November 2021 23

The Global Marketplace
relies on our integrity
Honesty in everything we do
Our customer-centric ethic and mission
orientation must never get in the way of
complete honesty and accuracy in everything
we say, do or write.

Obtaining business with integrity

In order to serve our business Similarly, we will not make It is also important to keep in
partners to the best of our false statements about our mind that many of our clients
abilities, we must always be competitors or their services, have strict rules about how to
truthful about what AECOM nor will we use unfair practices prepare and submit proposals
can and cannot achieve. Any against our competitors, such to obtain their business, as
time we discuss our capabilities, as obtaining their confidential well as rules for what types
credentials, qualifications information. of information relating to a
or corporate history, either proposal we may receive from
verbally or in writing, we must the client’s personnel. Each
make sure to be honest and AECOM office is responsible
accurate. for obtaining and maintaining
copies of relevant rules, and we
must make sure that we know
and follow the rules that apply
to our work.

© AECOM Restricted | November 2021 24

Obtaining business
with integrity

Q A
A long-standing and important client of AECOM No. If the improvements have not been made fully
has asked me to certify that improvements have and completely at the time of the certification,
been made to their health and safety system as you cannot certify that they have been made.
part of obtaining a government certification. The Government and other entities rely upon
improvements are in the process of being made certifications and representations we make as
but would not be completed by the time of the part of permitting and other approvals. False
certification. Can I do this? certifications or representations directly violate
AECOM’s commitment to integrity.

© AECOM Restricted | November 2021 25

Competing fairly

Because AECOM competes based on the quality of our products and

services, we are committed to promoting fair competition at all times.
We must never engage in or support unfair or predatory business
practices or any activities that would improperly restrain trade.
Similarly, it is critical that we abstain from any activity that may violate or give
the appearance of violating competition laws. While competition laws vary
between the different countries in which we conduct business, these types
of conduct are generally prohibited:

Agreeing on the prices, terms or Dividing or allocating customers, Agreeing to refuse to do business
conditions of sale for competing bids, markets or territories for with particular third parties.
services or products. competing services or products.

These rules apply to informal understandings

as well as formal agreements. In order to
make sure that we are competing fairly, we
should refrain from discussing any of these
activities with our competitors — or from
discussing any other matters that could be
seen as an attempt to limit competition.
Behavior that violates these rules should
be reported.

© AECOM Restricted | November 2021 26

Competing fairly

Q A
I am submitting a proposal, and a friend at the client No, unless doing so is consistent with the client’s
organization has offered to share information about rules. Typically, such rules would require the
the client’s selection criteria. May I receive it? individual to obtain appropriate authorization to
provide this information, and the information is
being made available to all who are submitting
proposals on the job. In some cases, accepting or
reviewing such information can invalidate our bid.
You should consult with your In-House Counsel
before accepting any such selection criteria or
similar information.

© AECOM Restricted | November 2021 27

Handling competitive
information

We strive to outperform our competition fairly and competitively.

Advantages over our competitors are obtained through superior
performance of our products and services, not through unethical or
illegal business practices.

At times, we may need information about our If confidential information about a competitor is
competitors. We may use publicly available deliberately or inadvertently disclosed to you,
discuss the issue with In-House Counsel, and do
information, but we must always make sure
not use it without express permission from
that we only acquire information about our In-House Counsel.
competitors in a legal, ethical and responsible
manner. For example, we must never pressure
anyone to breach a confidentiality agreement,
such as by asking a colleague to reveal
confidential information about a previous
employer. We should also never attempt to
gather information about our competitors
through deceptive or misleading actions.

© AECOM Restricted | November 2021 28

Avoiding corrupt
practices
AECOM is proud of the work we do throughout the world. We believe that our ability to
continue to foster good working relationships with companies, communities and governments
around the world depends on us acting ethically in all our business dealings. As described
in our Anticorruption Policy, this means we never give, offer or accept improper payments
in any form.
Numerous countries, including the U.S., the U.K., Canada, employees of businesses that are owned by a government.
Australia, Russia, China and other countries in which we At AECOM, we also prohibit acts of “commercial bribery,”
conduct business, have enacted laws that strictly prohibit or offering or accepting a bribe to or from our customers,
the giving, receiving, offering or soliciting of bribes, suppliers or anyone working on their behalf with the intent of
kickbacks or other improper payments to government obtaining or retaining business.
officials. A “bribe” is anything of value given in an attempt to
Similarly, we must never offer or accept a “kickback,” which
influence an official’s actions or decisions, obtain or retain
is the return of a sum already paid (or due to be paid) as a
business, or acquire any sort of improper advantage (such
reward for making or fostering business arrangements. We
as obtaining information that is normally unavailable or
may not retain a third party or enter into a joint venture or
being allowed to submit a late bid or proposal). To be clear,
other business association to engage in any activity that we
“government officials” include federal, state, provincial or
are prohibited from participating in ourselves.
local government employees, political candidates and even

© AECOM Restricted | November 2021 29

Conducting
international business
With operations throughout the world, AECOM is truly a global company.
For this reason, it is critical that all of our activities fully comply with
the export control laws and regulations of the U.S., the U.K. and other
jurisdictions in which we do business. Laws governing trade are complex,
but if we do not follow them, we risk losing our ability to conduct
business internationally.

An “export” occurs when a product, service, If your job involves any of the following responsibilities,
technology or piece of information is shipped to a you have an obligation to ensure that you are aware
person in another country. In the U.S., an export can of and comply with the laws that pertain to our
also occur when technology, technical information international trading activity:
or software is provided in any way (including verbally, • Accepting or processing client contracts and orders.
in the case of information) to a non-U.S. citizen,
regardless of where that person is located. In this • Authorizing or processing the international
regard, an “export” of technical data can occur during movement of goods or technology.
meetings, telephone conversations and facilities • The performance of defense services.
inspections and by memoranda, letters, faxes, email
• Any other activity that affects AECOM’s compliance
and other written materials.
with export control laws.

Other examples of items controlled by host

country laws that may require an export license or
a re-importation license include:
• Computer software containing certain encryption
or performance standards.
• Military products, technology or know-how.
• Any materials considered classified for purposes
of national security by the U.S. or other government.

If you have any questions regarding export controls, you should send an
email to [email protected] or contact Ethics & Compliance.

© AECOM Restricted | November 2021 30

Conducting
international business

Q A
Julio, an AECOM employee in Latin America, is Yes. Julio must know where that money is going, for
told that he can hire a consultant to acquire all the what purpose it is being used and the qualifications
necessary permits AECOM needs from a foreign and reputation of the consultant. Moreover, he is
government to start a new project. However, the required to take steps to ensure that this money is
consultant requests a U.S. $25,000 retainer and not used as a bribe. Julio must seek the advice of
says that he would use the money to “speed up the Management and In-House Counsel and comply
process.” Since Julio doesn’t know where the money with the Approval Matrix before proceeding with this
is going, and isn’t the one using it, does he need to consultant.
say anything?

© AECOM Restricted | November 2021 31

International
sanctions

Many countries in which we conduct business sometimes impose

sanctions, or adhere to sanctions imposed by multi-national
organizations such as the United Nations or the European Union,
that restrict or prohibit dealings with certain countries or individuals.
Because AECOM is a U.S. corporation, we must all adhere to the
economic sanctions administered by the U.S. Office of Foreign Assets
Control, which include, but are not limited to, restrictions on financial
transactions, travel, and imports and exports.

We also adhere to those imposed by other countries International sanctions may also apply to activities
and multi-lateral institutions, such as the European such as providing services and exporting sensitive
Union or World Bank, if they do not conflict with technology. Because each sanctions program
U.S. or international law. Make sure you understand is based on different foreign policy and national
the most up-to-date regulations if you handle security objectives, the prohibitions vary between
international business. programs. Please check with In-House Counsel or a
member of the Ethics & Compliance team regarding
such requirements. You can also refer to our
Export, Sanctions and Anti-Boycott Procedure.

Boycott requests

Due to our global operations, we must also be alert for illegal boycott requests. U.S. law prohibits us from
cooperating with unsanctioned boycotts, regardless of where we are located. This applies to boycotted
companies as well as boycotted countries and their nationals. We must take care that nothing we do or
say could be seen as participating in an illegal boycott. For example, we may not certify that an entity is not
blacklisted nor may we provide information on a company’s activities with a boycotted entity. Our company
must report any boycott requests to the U.S. government. Therefore, if you believe you have received a boycott
request or have any questions about boycott activities, it is crucial that you notify In-House Counsel and refer to
the Export, Sanctions and Anti-Boycott Procedure.

© AECOM Restricted | November 2021 32

Our shareholders, business
partners and customers rely
on our excellence
Providing quality products and services
The foundation of AECOM’s reputation is the high quality of the
products and services we provide. In order to keep our standards
high, we must each comply with all quality control procedures and
follow contract specifications at all times. Make sure to familiarize
yourself with the standards and specifications that apply to the
projects you work on. We must each be aware of and follow these
company policies and procedures designed to protect the quality
and safety of our products.

Raise any quality or safety issues you spot with your For these reasons, we conduct due diligence when
supervisor immediately. We further guarantee quality selecting our suppliers and other business partners.
services to our customers through proper supply We firmly hold our suppliers accountable for assuring
chain due diligence, monitoring and enforcement. the quality of the goods and services they provide us.
AECOM takes great care in choosing our suppliers, If you have reason to believe that a supplier has failed
contractors, agents, consultants and other business to provide quality products and/or services, contact
partners. We aim to do business only with companies a member of AECOM’s Ethics & Compliance team,
that match our high standards of ethical business Management, Human Resources or In-House Counsel
conduct. Ultimately, our goal is for all of our business immediately.
partners to comply with our Code and to operate in an
ethical and lawful manner.

Licensing

We are responsible for maintaining appropriate licenses. Our Company is committed to providing professional
services only in jurisdictions where we are licensed to do so, unless otherwise exempted by applicable law.

We must inform In-House Counsel in a timely manner if there is any change to the status of our individual
licensing, including circumstances in which we are qualifiers on our corporate licenses. Furthermore, we must
represent our credentials in a forthright way.

© AECOM Restricted | November 2021 33

Charging time

Each of us has a responsibility to ensure that our

weekly time reports accurately reflect the hours
worked on a specific work order or project. Time
worked on a project must be charged to that
project and no other. Government regulations
and many clients’ contracts also mandate
complete and accurate records.

All employees are required to complete time Mischarging time is a serious offense that can
sheets in accordance with the requirements subject AECOM and the responsible individual
established by AECOM policies. Supervisors to criminal and civil liability. If anyone directs
are responsible for ensuring that the or suggests that time be charged in a manner
timesheets they approve are accurate and other than in accordance with this Code, it is
reflect the hours worked by the employees the responsibility of the employee to inform In-
who report to them. House Counsel immediately.

Prepared for: Client name 34

Licensing and
charging time

Q A
We have been asked to submit a proposal for a Check with In-House Counsel or the Corporate
project in a jurisdiction where AECOM has never Secretary. They maintain the licenses and
worked before. How do I know if we are licensed in a registrations.
particular jurisdiction?

Q A
Right now I don’t have any client work to do, but I No. In all situations, time must be charged accurately.
am concerned that my job may be at risk if I charge You should discuss your work availability with your
too much time to overhead. Is it okay to put time supervisor.
down on a fixed price contract since it won’t hurt
the customer?

© AECOM Restricted | November 2021 35

Accurate books
and records
We must each do our part to make certain allows our company to make well-informed
that the financial documents our company business decisions. Therefore, every piece
discloses to the public are accurate and of information that we submit in company
honest. Even if maintaining financial data records of any kind must be absolutely
is not your primary job duty, each of us honest, accurate and complete. Each of us
contributes to record keeping in some form, is responsible for knowing and following
such as by completing timecards, submitting AECOM’s internal controls and any applicable
travel and expense reports or keeping safety accounting requirements when recording
records. The information we record provides this data. We must also submit appropriate
an accurate view of our operations and contract documentation at all times.

Our commitment to ethical business conduct requires our business transactions to be authorized and
legitimate. To be clear, we may not engage in any of the following activities:

1
Making false representations
2
Hiding company funds.
3
Circumventing internal controls.
on behalf of our company,
either verbally or in writing.

4
Mischaracterizing
5
Creating undisclosed or
6
Knowingly allowing similar
company transactions. unrecorded fund accounts. illegal activities to occur.

If you notice any accounting or auditing irregularities, or incidents of fraud by individuals responsible
for our company’s accounting or financial reporting, you should report your observation to a member of
the Ethics & Compliance team, Management or In-House Counsel. Please keep in mind that it is against
company policy to retaliate against anyone who makes an honest and sincere report of fraud or any
other accounting or auditing irregularity.

© AECOM Restricted | November 2021 36

Record retention

Keeping our records in order helps us to build trust with our clients,
regulators and shareholders. This commitment applies to both paper
and electronic documents, including files such as emails, images and
text messages. In short, we must take care with all the records we create,
receive or maintain in order to do our jobs. Effectively managing these
records allows us to ensure they are available when needed. In addition,
it helps us comply with all applicable laws and regulations and preserve
any documents that may become relevant in audits, investigations
or litigation.

Make sure you know and follow the records management policies and retention schedules that apply to your
work and your location. These documents will tell you how long you should maintain business records as well
as procedures for compliance with legal holds. (A legal hold applies to records connected to actual or
anticipated litigation.)

If you believe that anyone has improperly concealed, altered or

destroyed a record, you should report it to In-House Counsel. For
more information, please refer to our Records Management Policy.

© AECOM Restricted | November 2021 37

Audits and
investigations
During your employment, you may be asked to take part in a
company or government audit or investigation of AECOM or certain
employees. It is important to cooperate with such a request, and,
as with all our activities, we must be forthright when we deal with
audits or investigations. At no time may we conceal, alter or destroy
any requested records. In addition, we must never attempt to exert
improper influence on the results of an investigation or audit. If you
are ever approached by an external party, including a government
official, about conducting an audit or investigation, please contact
In-House Counsel immediately.

Q A
Alberto is a financial controller who learns that his Alberto’s supervisor should explain that he needs
AECOM business unit is going to be reviewed by to appreciate that audits are one of the key means
Audit Services for the first time since it was acquired by which AECOM meets its responsibilities to its
a year ago. He becomes upset and defensive shareholders, management and employees as a
when the audit team reviews expense report public company. The company relies on accurate
reimbursements and petty cash processes and and complete records as the basis of our financial
asks him questions about some of the payments. He system and in order to access capital markets. All of
tells his supervisor that the auditors are not treating us have a duty to cooperate fully and completely with
him with respect and do not understand the local audits and investigations and integrate any lessons
culture by questioning his work. How should his learned as a result into our work.
supervisor respond?

© AECOM Restricted | November 2021 38

Protecting inside
information

In our work for AECOM, we sometimes have access to information

about our company and our business partners that is not available to
the general public. In order to avoid unfair and illegal transactions, we
must never buy or sell the stock of any company (including AECOM)
about which we possess inside information.

For information to be considered Inside information can be either positive or negative,

and commonly includes the following examples:
“inside,” it must be both material
(meaning that it would affect the • Projections of future earnings or losses.

decisions of a reasonable investor) • News of a pending or proposed merger.

and non-public (meaning that it has • News of a significant sale of assets.
not been released to the public). • Declaration of a stock split or offering of additional
Information becomes public only securities.
after two full trading days have • Changes in executive management.
passed since the public release of
• Significant new products or discoveries.
the information.

If you have any questions as to whether the information you possess

qualifies as inside information, please consult our Insider Trading
Policy or contact In-House Counsel.

© AECOM Restricted | November 2021 39

Preventing money
laundering
AECOM is committed to helping in the
global fight against money laundering.
“Money laundering” is the process by which a
person or group tries to conceal illegal funds
or attempts to make the sources of their illicit
funds look legitimate.

In order to keep AECOM from becoming For example, make sure that the party with
inadvertently involved in this type of whom you are conducting business maintains
misconduct, we should always perform a physical presence, is engaged in legitimate
due diligence on customers, suppliers, business and has proper compliance processes
intermediaries and other business partners who in place. If you need more information about
wish to conduct business with our company. how to identify money laundering, you should
Look out for red flags that may signal money consult In-House Counsel.
laundering activities.

© AECOM Restricted | November 2021 40

Additional
expectations

Certain company officers and the directors of AECOM have a special

responsibility to promote integrity within our company. Their role requires
them to ensure that our company’s public disclosures are accurate and
complete. In order to do so, these individuals are required to know and
understand the financial disclosure laws that apply to their work. Violations
of financial disclosure laws will be viewed as a severe offense that may
result in disciplinary action, up to and including termination. This includes
failing to report potential violations by others.

If you have an honest and sincere belief that a violation has occurred,
contact a member of the Ethics & Compliance team, Management
or In-House Counsel. If you prefer to report on an anonymous basis,
where allowed by law, you may submit a report by contacting the
AECOM Ethics Hotline. Keep in mind that it is against company policy
to retaliate against anyone who makes an honest and sincere report of
a violation.

© AECOM Restricted | November 2021 41

Our communities rely on our
integrity and innovation
Environmental, social and governance
approach – Delivering sustainable legacies
AECOM is committed to embedding Environmental, Social and Governance (ESG)
principles into everything we do in support of our Sustain Core Value. This defines
how we can deliver Sustainable Legacies by positively impacting our company, our
communities, and our planet. This means complying with and, where possible, looking
to perform better than all human rights and environmental laws, rules and regulations in
effect wherever we conduct business.
We also look to embed sustainable development and emissions from our energy use, travel and purchasing
resilience across our project work by working with our decisions to achieve our net zero targets. We look to
clients, partners and supply chain providers to tackle improve governance performance by considering
and adapt to climate change, enhance biodiversity ESG risk in line with the risk triggers identified by the
and improve social value. Improving social value Approval Matrix, as well as reporting progress against
also includes considering how we can make positive set ESG goals for employees and across the business.
impacts in the communities we touch and internally You are encouraged to submit your suggestions and
fostering an open and fair working environment. ideas on bringing our practices closer to these goals
Internally, we should strive to reduce carbon to Management or Corporate Sustainability.

© AECOM Restricted | November 2021 42

Political and charitable
contributions
Although AECOM encourages us to participate in political and charitable
activities, this must always be on our own time and at our own expense.
We must never attribute our personal activities (such as campaign work,
fundraising or speech-making) to AECOM. Similarly, we may never use
AECOM resources (such as funds, facilities, equipment or supplies) in
connection with our personal political or charitable activities, and we
should never expect AECOM to reimburse us for any political and
charitable contributions or other political and charitable expenses.

We should be prepared to report Since many government clients If you need information or have any
any personal political contributions attribute personal political questions, consult with a member of
if required to do so in accordance contributions and fundraising activities the Ethics & Compliance team or
with applicable law and, in limited to AECOM, certain personal political In-House Counsel.
circumstances, may be prohibited contributions may require approval
from making personal contributions under the U.S. Personal Political
due to local law. Contributions Policy.

© AECOM Restricted | November 2021 43

Responding to
media inquiries
Providing our communities with an accurate picture of our Similarly, requests for financial and legal information must
operations, transactions and intentions helps us to preserve always be directed to the appropriate channel. If an investor,
AECOM’s integrity. In order to do this, we need to make security analyst or other key public contact contacts you to
sure that our company speaks with one consistent voice. request information, even if the request is informal, please
Therefore, only those who have been approved to serve as refer them to Corporate Communications. Inquiries from
an AECOM spokesperson by Corporate Communications government officials or attorneys should be referred to
should make public statements about our company. In-House Counsel. For more information, please see our
External Communications Policy.
For example, if a member of the media contacts you for
any reason, you should refer the request to Corporate
Communications.

© AECOM Restricted | November 2021 44

Waivers
In some cases, our company may waive compliance with this Code. Such waivers will only be granted on a limited basis and
will be considered case by case. Only the Board of Directors may issue a waiver of this Code for a member of our Board or
an executive officer. Any waiver of this Code for a member of our Board or an executive officer will be promptly disclosed, as
required by applicable law, Securities and Exchange Commission rules and regulations, and the New York Stock Exchange
(NYSE) listing standards.

© AECOM Restricted | November 2021 45

It’s up to you

AECOM’s reputation and

success as a good corporate
citizen of the world depend
upon each of us meeting our
obligations under this code.

If you have any questions or do

not understand what is expected
of you, it is your duty to raise your
concern with a member of the
Ethics & Compliance team, your
manager, Human Resources or
In-House Counsel.

© AECOM Restricted | November 2021 46