1. science
2. social science
3. philosophy
4. ethics

CODE OF
BUSINESS
CONDUCT
Achieving Success I Putting Our Values into Action
OUR VISION AND VALUES
Founded upon its values and
competitive strengths, it is
Louis Berger’s vision to build an
integrated, worldwide practice
that makes a positive contribution
to society through the
performance of quality services
that meet our clients’ needs while
providing a work environment
that allows our employees to
meet their professional and
financial goals.
At the core of everything we do is the promise to provide
solutions that have a positive impact on society.
We follow through on this promise by focusing on client
needs to deliver quality, safe, financially successful projects
with integrity.
Encompassing everything we do is our passion for our work, our
industry and for delivering on our promise to provide Solutions
for a better world.
From our executive leadership to our teams in the field, we
share a genuine sense of respect and stewardship for the places
where we work and the people whose lives we impact.
A Message from
Nicholas J. Masucci
President and CEO
Dear Colleagues,
The Berger Group of Companies (Louis Berger) has enjoyed tremendous growth
and success since our founding in 1953. Dr. Louis Berger founded this company
60 years ago based on the notion that through our work, we should leave lasting
and positive impacts on the social, economic and physical well-being of the
communities where we work and live.
Whether we are building infrastructure in war-ravaged states, transitioning a
new national currency program in the developing world or navigating postdisaster recovery requirements in the U.S., it is our ability to deploy technical
experts quickly and operate within a local context that sets us apart from
our peers. We specialize in managing client programs in the world’s most
complex environments.
As we continue to grow, we strive to stay true to the ideals upon which our
company is based. That requires a focus on ethics, not just in our compliance to
laws, but in solidifying the common practices around our ethical behaviors and
best practices in business. Our clients trust us to do the right thing, deliver quality
services, and behave ethically and legally.
We are currently in an exciting period of corporate development in which our
operational systems and practices are better aligned with the technical excellence
and project delivery expertise of our people. These investments are intended to
help us adhere to the highest standards of ethical leadership as we continue to
push growth globally.
Thank you for your continued dedication to excellence.
Sincerely,
Nicholas J. Masucci
President and CEO
LOUIS BERGER CODE OF BUSINESS CONDUCT
1
Louis Berger
Code of Business Conduct
The Louis Berger Code of Business Conduct represents our shared values on
ethical business conduct. By consistently implementing these shared values every
day – on every task and project – we distinguish ourselves from our competitors
and send a powerful message to our customers and clients. No matter the
business pressures, or where the project is located, Louis Berger commits to
providing high-quality, ethical services in compliance with applicable laws.
The Code is especially important since the Louis Berger often provides services
in countries with differing laws, cultures and business pressures. Maintaining a
consistent ethical standard in such circumstances can be challenging unless a
consistent set of shared values are implemented across the entire organization.
To make the Code a practical tool as well as representative of our shared values
and challenges, a cross section of employees was involved in designing the
concepts and drafting the document. Senior managers, business unit managers
and the Audit Committee of the Louis Berger Board of Directors directly
supported this process by reviewing and approving the Code.
It is Louis Berger’s objective to comply with all applicable laws. Therefore, in
limited instances where provisions of the Code may be inconsistent with local
legal requirements, Louis Berger will enforce the Code in compliance with
applicable and local laws.
Louis Berger includes Holdings Berger France SAS/Louis Berger International,
The Louis Berger Group, and Louis Berger Services. For ease of the reader, the
firms will collectively be referred to as “Louis Berger” in the Code.
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ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
A Message from
Thomas Nicastro
Senior Vice President | Chief Compliance and Ethics Officer
Dear Colleagues,
The Louis Berger Code of Business Conduct provides guidance to help you make ethical decisions
while conducting business on our behalf. The ethical challenges and demands of our clients
and government regulators are not static. Key aspects of our compliance program are always
being reviewed to ensure that it stays relevant and effective. The Code represents our continued
commitment as a company to always operate with integrity, irrespective of social or business
pressures. Therefore, it is important that you read, understand and comply with these values.
The Code is the result of three factors: the labor of employees; a review of our “best practices”
program; and an understanding of business challenges. I am pleased to say that the Code contains
several important revisions, which I believe make it a better resource for you.
Here are some of the Code enhancements:
• Broad statement of Our Vision and Values to help you better understand
company expectations
• New and renewed corporate commitments on anti-corruption, retaliation,
conflicts of interest, human rights and human trafficking
• Clear expectations for implementing Code values
• Real-world examples and simple-to-understand guidance
• Improved layout and an easy-to-navigate index
We at Louis Berger are justifiably proud of our professional work and its impact. Nonetheless,
if after reading the Code you are uncertain about your responsibilities, or you wish to provide
feedback on improving our program, please contact the Office of Compliance and Ethics using the
contact information provided in this document. Additionally, if you have questions regarding the
appropriateness of any conduct, please use the resources outlined in this document.
Remember, your actions make it possible for Louis Berger to continue to distinguish
itself in the marketplace as a company that is committed to providing solutions for
a better world.
Sincerely,
Thomas Nicastro, Ph.D., CCEP
Senior Vice President | Chief Compliance and Ethics Officer
LOUIS BERGER CODE OF BUSINESS CONDUCT
3
Contents
A Message from Nicholas J. Masucci
1
Louis Berger Code of Business Conduct
2
A Message from Thomas Nicastro
3
Responsibility to Do the Right Thing
6
Ethical Actions...................................................................................... 6
Responsibilities to Private Sector Clients,
Government Clients and Business Partners
18
Business partner relations..........................................................................18
Ethical dealings.................................................................................. 18
Integrity in government contracting................................................. 18
Business partner diversity.................................................................. 19
Authority................................................................................................ 6
Trade restrictions and economic embargoes................................... 20
Integrity matters................................................................................... 6
Technology transfers.......................................................................... 20
Who’s covered by the Code................................................................ 7
Boycotts............................................................................................... 20
Compliance with applicable laws,
the Code, policies and procedures.................................................... 7
Conflicts of interest............................................................................ 21
Compliance Committee...................................................................... 7
We don’t tolerate retaliation............................................................... 7
Louis Berger’s commitment to compliance and ethics..................... 8
Compliance matters............................................................................. 8
Office of Compliance and Ethics......................................................... 8
Human Resources................................................................................. 8
Office of General Counsel................................................................... 8
Louis Berger develops ethical leadership.......................................... 8
Training.................................................................................................. 8
Potential conflicts of interest............................................................. 21
Gifts and business courtesies............................................................ 23
Creating business records................................................................. 24
Accuracy and transparency in financial reporting............................ 24
Records management........................................................................ 24
Accurate time charging and expense reporting.............................. 25
Confidential company information................................................... 26
Competitor information..................................................................... 27
Louis Berger’s confidential, proprietary and other
nonpublic business information........................................................ 26
Your responsibility................................................................................ 9
Ethical decision making....................................................................... 9
Watch out and speak up.................................................................... 10
Reporting matters............................................................................... 10
Government investigations................................................................ 10
Government disclosure...................................................................... 10
Responsibilities to One Another
12
Louis Berger’s commitment to teamwork and innovation.................12
Harassment-free workplace............................................................... 13
Safety, employee health and security............................................... 14
Substance abuse................................................................................. 14
Protecting Louis Berger assets.......................................................... 15
Responsibilities as Corporate Citizens
28
Environmental sustainability.............................................................. 28
Social responsibility............................................................................ 29
Fundamental human rights................................................................ 29
Human rights/trafficking.................................................................... 29
Anti-corruption and bribery............................................................... 30
Facilitating, expediting, or
grease payments: “Facilitating payments”...................................... 30
Examples of routine non-discretionary government action
for which payments may be approved............................................. 30
Political involvement.......................................................................... 31
Insider trading..................................................................................... 32
Anti-trust and fair competition.......................................................... 33
Electronic media................................................................................. 15
Privacy of employee information...................................................... 16
Communicating with the public........................................................ 17
Certification Statement
35
Standards for personal use of social media..................................... 17
Index36
LOUIS BERGER CODE OF BUSINESS CONDUCT
5
Responsibility
to Do the Right
Thing
Ethical Actions
In today’s global market, no matter where in the world
Louis Berger operates, we take pride in conducting our business
in accordance with the highest ethical standards. Our Vision and
Values state how each of us is expected to conduct business at
Louis Berger. It frames our Code of Business Conduct that, in
turn, shows us how to apply these standards in our daily work.
Integrity matters
We are continually judged by our
behavior — not simply by whether we
are law-abiding, but also by how we
demonstrate integrity. We all like to
think that we are honest, responsible,
respectful, trustworthy, dependable and
loyal. In the business world, however,
our integrity can be tested. The lure
of being selected for an assignment,
financial gain, or business or individual
success can challenge our commitment
to conduct ourselves with integrity.
Louis Berger depends on you to conduct
yourself responsibly, consistent with the
law and Louis Berger values. When we
all act in this way, we enhance the honor,
reputation and usefulness of ourselves,
our professions and Louis Berger.
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ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
Our success at Louis Berger depends on our individual integrity.
Integrity is an innate quality that guides behavior. It enables us to
do what is right in any given situation. Doing the right thing is the
foundation of our long-term success. As individuals, our personal
integrity means that others can trust our actions to match our
values and depend on our reliability to be honest, fair and
forthright. Integrity means we comply with all laws applicable to
our business, deliver a quality product, and treat our clients fairly
and with respect. Additionally, integrity means we will always
honor our commitments and be a reliable business partner.
Integrity not only enhances our brand but also protects our
reputation. Integrity enables us to thrive in today’s demanding,
complex and competitive business environment.
The Code communicates the standards and values that Louis
Berger expects you and anyone else acting on behalf of Louis
Berger to apply. It is also a resource to help when you have
questions about what to do in specific situations. By following
the Code and Louis Berger’s Vision and Values, we ensure
that our business activities and decisions are consistent with
applicable laws, policies and procedures, general ethical
business standards, and the expectations of our clients and
business partners.
Authority
The Code has been approved by the Audit Committee
of the Louis Berger Board of Directors. The Audit
Committee consists of directors appointed by, but
independent of, the Louis Berger Board of Directors.
Who’s covered by the Code
All Louis Berger employees are covered by
the Code. The Code provides the ethical
framework and standards for conducting
business on behalf of Louis Berger anywhere
we do work around the world. This includes
all of our domestic and foreign subsidiaries
and operations where Louis Berger has a
controlling interest. The Code applies to all
shareholders, directors, officers, managers,
full-time and part-time employees, as well as to
temporary, contract and local employees.
Third parties, including suppliers, vendors,
subcontractors, joint venture partners, prime
contractors, agents and consultants, can act
as an extension of our company. Such partners
who conduct business on behalf of Louis Berger
are collectively referred to in this document
as “business partners.” Our business partners
are expected to carry out their responsibilities
on behalf of Louis Berger in a legal and ethical
manner and to adhere to the spirit and the
intent of the Code, as well as any applicable
contractual obligations. Business partners’
conduct can have a positive or negative impact
on our business reputation, and can result in
legal liabilities for Louis Berger.
Compliance with applicable
laws, the Code, and policies and
procedures
As a Louis Berger employee, you are
responsible for being aware of relevant laws
and regulations that apply to your work.
You must be vigilant in complying with all
applicable laws and regulations and alert to
changes in the law or new requirements that
may affect your responsibilities.
You are required to comply with all
Louis Berger policies and procedures.
Some clients also require Louis Berger to be
in compliance with additional regulations
when working on their behalf. These
additional requirements can be found on the
Louis Berger Intranet. You must comply with
these supplements while working on projects
for these clients.
Working globally can raise additional
compliance and ethics issues because in many
cases local business and cultural practices
vary. While we respect the norms of our clients
and colleagues throughout the world, you
must comply with applicable laws, the Code,
and policies and procedures unless they
are inconsistent with local law. If you have
questions, seek guidance from any resource
listed in the Code.
Compliance committee
Violating applicable law, the Code, or policies
and procedures, or encouraging others to
do so, exposes Louis Berger to liability and
puts our reputation at risk. If a compliance or
ethics problem does arise, you must contact
one of the resources listed in the Code so that
Louis Berger can investigate the allegation and
take corrective steps.
Louis Berger’s corporate compliance committee,
working with the Office of Compliance and
Ethics, reviews allegations and investigations
made against employees and business
partners. It will then make the appropriate
disciplinary action recommendations to
your Louis Berger president. Your failure to
comply with committee disciplinary action
recommendations is considered personal
misconduct. Membership in the committee will
vary by company. Generally the committee is
composed of senior Louis Berger managers,
including the HR director. You should contact
your Compliance and Ethics Officer or HR
director for the composition of your committee.
For details concerning enforcement of the Code
and the consequences of violations (subject to
the applicability of local laws and regulations),
refer to the Louis Berger Intranet.
We won’t tolerate retaliation
Louis Berger will not tolerate retaliation or
retribution against anyone who makes a good
faith report of an alleged violation of the law,
the Code, or policies and procedures, even if
the investigation finds no wrongdoing.
LOUIS BERGER CODE OF BUSINESS CONDUCT
7
Louis Berger’s commitment to
compliance and ethics
Louis Berger is committed to supporting
your efforts to comply with the Code and has
developed resources to assist employees in
understanding and adhering to the Code.
Office of Compliance and Ethics
Louis Berger has established an Office of
Compliance and Ethics led by the Chief
Compliance and Ethics Officer (CCEO). The
CCEO provides direction
and oversight to the
Compliance matters
compliance and ethics
program. The Office of
Much of our work involves
Compliance and Ethics
governments, governmentis tasked with preventing
controlled bodies and public
and detecting violation of
international institutions.
law and the Code. It also
Therefore you must understand
identifies and assesses areas
and comply with laws, rules
of compliance risk, conducts
and regulations pertaining to
training, implements a
anti-corruption, government
retaliation-free internal
procurement, reporting and
reporting system, mentors
disclosure. Our policies and
employees in compliance
procedures are designed to
and conducts investigations
help you comply.
when necessary. The CCEO
reports administratively to the
Louis Berger CEO and functionally to the Audit
Committee of the Board of Directors.
Human Resources
Louis Berger’s offices of human resources
provide direction and oversight for all
human resources functions, including policy
compliance and complaint procedures.
Human resources develops, monitors and
enforces company policies and procedures. It
also identifies and assesses needs for training
and conducts investigations when necessary.
Office of General Counsel
The Office of General Counsel is led by the
General Counsel. The Office assists employees
to understand laws and regulations applicable
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ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
to the company’s business activities. The Office
also assists the CCEO in investigations and in
identifying and mitigating areas of legal risk
requiring policies and procedures.
Louis Berger develops ethical
leadership
Louis Berger leaders are required to:
• Lead by example, exemplifying the highest
standards of business conduct;
• Be a resource for others and communicate
to employees and business partners
about how the Code and policies apply to
daily work;
• Listen to employees;
• Seek opportunities to discuss and address
the application of the Code with others;
• Create a secure, retaliation-free work
environment that exemplifies the
Louis Berger values and the Code;
• Promote a culture that makes everyone
feel comfortable asking questions and
reporting potential violations of the Code
and policies;
• Recognize limits of authority;
• Delegate authority only where permissible
and to individuals who will carry out
those tasks in a compliant and
responsible manner;
• Supervise business partners to ensure
that they understand Louis Berger’s
expectations of them to conform to the
spirit and the intent of the Code; and
• Promptly report possible violations or
concerns to the Office of Compliance
and Ethics.
Training
Louis Berger has a Compliance and Ethics
Training Program. You are responsible for
completing all compliance and ethics training
on a timely basis and providing an attestation
confirming that you have read, understand and
will abide by the Code.
Your responsibility
Ethical decision making
As a Louis Berger employee, you have
the responsibility to be compliant and to
always maintain the highest ethical and legal
standards. In particular you must:
• Abide by applicable laws, the Code,
policies and procedures, and all clientspecific requirements that apply to
your work;
• Always be professional, honest
and responsible;
• Complete all required employee training in
a timely manner;
• Complete annual certification on the Code
and maintain your current professional
standards and expectations;
• Promptly report possible violations of the
law, the Code, or policies and procedures
to resources provided in the Code;
• Cooperate and truthfully respond to
investigations and audit requests;
• Never alter or destroy records in response
to an investigation or if you anticipate
an investigation;
• Never ask or pressure another person to do
something on your behalf that
is prohibited;
• Never permit business pressures to be an
excuse for violating the law, the Code, or
policies and procedures; and
• Keep any information you may know about
an investigation strictly confidential unless
otherwise instructed by the Office of
Compliance and Ethics.
As a Louis Berger employee, you have a responsibility to
make ethical decisions. Making the right decision is not always
easy. There will be times when you will be under pressure or
unsure of what to do. Always remember that when you have a
tough choice to make, you are not alone. The resources cited
throughout the Code are available to help you.
When faced with ethical decisions, pause and ask
these questions:
• Is it the right thing to do?
• Is it legal?
• Is it consistent with the Code and Louis Berger policies and
procedures?
• Have I considered all the options?
• Will I be comfortable telling others about
my decision?
• If it’s subsequently made public, can I honestly say I’d be
proud of the choice I made?
• What is the possible impact of my actions on Louis Berger,
my family and others?
LOUIS BERGER CODE OF BUSINESS CONDUCT
9
Watch out and speak up
Louis Berger wants you to ask questions if
you are unclear about any of the information
presented in the Code and also to speak up
when you see possible violations. You will
see “watch out and speak up” examples
throughout the Code. When you need to
speak up, you may use any of the following
resources, but most importantly, you are
encouraged to speak with the person with
whom you feel most comfortable:
• Your supervisor or any other member of
management
• Any member of the Office of Compliance
and Ethics, in person or by mail at any of
the following offices:
-- Washington, D.C. – Primary Office
-- New York, N.Y.
-- Greenville, S.C.
-- Paris, France
-- By e-mail: [email protected]
• Any member of the Office of General
Counsel
• Director of Human Resources (HR) or local
HR Representative
• Helpline +1.877.315.9932 or
www.tnwgrc.com/louisberger
Government investigations
As a Louis Berger employee, you may in
the course of business be contacted by
federal, state or local agents or perhaps
be served with a subpoena. Louis Berger
expects you to cooperate with these agents,
but you must contact the Office of General
Counsel and/or the Office of Compliance
and Ethics as soon as possible. Until you
have received guidance from the Office of
General Counsel, you should avoid answering
any questions, providing documentation,
or permitting a search of the premises, if
possible. This will ensure that legal rights
are preserved and responses are accurate,
timely and appropriate. When notified of an
investigation, take prompt action to preserve
documents that may be relevant.
Disclosure of possible improper
conduct on U.S. government contracts
The U.S. Federal Acquisition Regulations
(FAR) require timely disclosure of any
wrongdoing in connection with the award,
performance, or closeout of certain U.S.
government contracts. Disclosure may
be required if Louis Berger has credible
evidence that a principal, employee, agent or
subcontractor has committed a violation of
federal criminal law involving fraud, conflict
of interest, bribery, gratuity violations or a
violation of the civil U.S. False Claims Act.
If you have any questions about compliance
with this provision, contact the Office of
Compliance and Ethics or the Office of the
General Counsel.
Reporting matters
Employees have the opportunity to help Louis Berger improve every time a question
is asked or a concern raised. When you seek clarification of a policy or report
questionable conduct, you are protecting your colleagues and the reputation of
Louis Berger. Remember, an issue cannot be addressed unless someone knows about
it. Please note that for privacy reasons the precise nature of disciplinary measures may
not be shared with the person making the report.
10
ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
Q
I reported that my supervisor was
billing time to a client while working
on business development activities.
Since then, I feel I have been retaliated
against. Can I bring this concern to the
Helpline for a resolution?
A Yes, you can call the Helpline. We take
claims of retaliation seriously. Reports of
retaliation will be promptly investigated.
If the allegations are found to be true,
retaliators will be disciplined up to and
including termination.
Q
As a manager, what are my
obligations if someone comes to me with
a possible violation of the Code?
A Your obligation is to report all
allegations to the Office of Compliance
and Ethics, no matter whom it involves,
including allegations against a leader
on the management team. The Office of
Compliance and Ethics will investigate;
under no circumstance should managers
undertake any investigation on their own.
Q What if someone uses the Helpline to make
an anonymous call or falsely accuses someone else
of wrongdoing?
A
All reports will be promptly investigated. Anyone found
to have used the Helpline in bad faith to spread falsehoods,
or threaten others with the intent to unjustly damage another
person’s reputation will be subject to disciplinary action up to
and including termination.
Q
I just learned that a good friend of mine has been
accused of sexual harassment and that an investigation
is being launched. I can’t believe it’s true and I think it’s
only fair that I give my friend an advance warning so that
he can defend himself. Don’t I have a responsibility to tell
my friend?
A
No, a fair and impartial investigation will be conducted.
Under no circumstances should you give your friend a headsup. Your friend will be given the opportunity to respond to
the allegations. An allegation of sexual harassment is a very
serious matter with implications not only for the individuals
involved but also for Louis Berger. Alerting your friend
could jeopardize the investigation and potentially expose
Louis Berger to additional risk.
LOUIS BERGER CODE OF BUSINESS CONDUCT
11
Responsibilities
to One Another
Louis Berger’s commitment to teamwork and
innovation
Louis Berger embraces a commitment to diversity of individuals
in our workforce and a sense of teamwork among our
employees. As a global company, we are committed to:
• Making a positive contribution to society;
• Ensuring the ethical sound performance of quality services
that our clients and business partners expect;
• Providing a work environment that allows you to meet your
professional development goals;
• Creating an environment that cultivates new ideas by
encouraging you to be forward-thinking;
• Collaborating and building on unique perspectives, original
solutions and pioneering work; and
• Promoting communication, respect and diversity of ideas.
We believe that diversity in experiences, thoughts and
capabilities is essential to compete successfully in today’s global
economy. The differences among people, their backgrounds,
life experiences and ideas give Louis Berger a competitive
advantage. It is Louis Berger policy that no employee shall be
directly supervised by a family relation. Any employee who has
a personal relationship with another employee must be aware of
and adhere to company policy on sexual harassment. Managers
are responsible for ensuring equitable treatment of employees
regardless of familial relationships.
At Louis Berger we treat one another with respect and fairness.
Colleagues, job applicants and business partners are judged
on the basis of their qualifications, demonstrated skills and
achievements. Louis Berger is an Equal Opportunity Employer
and supports laws prohibiting discrimination based on a
person’s age, race, creed, color, religion, gender, national origin,
physical or mental disability, marital status, sexual orientation,
status of citizenship, or other protected characteristics.
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ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
How can I implement our
values?
As a colleague:
• Treat others respectfully and professionally;
• Avoid making comments or
sending information that might be
considered offensive;
• Never discriminate against anyone on
the basis of characteristics protected by
applicable law or the Code;
• Never tolerate sexual harassment,
including requests for sexual favors and
other unwelcome verbal or physical
conduct of a sexual nature;
• Do not display sexually explicit or offensive
pictures while at work or on companyissued equipment; and
• If you experience or see any harassment,
promptly report the incident to your
supervisor or any of the resources provided
in the Code.
As a manager or supervisor:
• Promote the importance of diversity
in ideas, perspectives and decisions in
employment decisions;
• Use only business-related criteria in
evaluating the performance of colleagues
and subordinates; and
• Review your own decisions to ensure that
objective merit and business considerations
drive your actions.
Harassment-free workplace
Everyone is responsible for creating
and maintaining an environment free of
harassment, intimidation and abuse. Verbal
or physical conduct that harasses another,
disrupts another’s work performance, or
creates an intimidating, offensive, abusive or
hostile work environment will not be tolerated.
A common form of harassment is sexual
harassment, which occurs when an
intimidating, offensive, or hostile work
environment is created by unwelcome
sexual advances, insulting jokes or other
offensive verbal or physical behavior of
a sexual nature.
Watch out and speak up
when you observe:
• Unwelcome and repeated remarks,
gestures, or physical contact;
• The display of sexually explicit or offensive
pictures or other similar materials;
• Sexual or offensive jokes or comments
(explicit or by innuendo);
• Verbal abuse, threats or taunting;
• Dismissive attitudes or comments about
our anti-harassment policies; or
• Depiction of harassers as victims or of
victims as complainers.
Q One of my co-workers sends e-mails containing jokes and derogatory comments
about certain nationalities. They make me uncomfortable, but no one else has spoken
up about them. What should I do?
A It is your responsibility to report possible misconduct to your supervisor or any of
the other resources listed in the Code. Sending such jokes is contrary to our values, and
it violates our policies pertaining to the use of e-mail and our standards on diversity,
harassment and discrimination. By doing nothing, you condone inappropriate conduct and
possibly tolerate harassment and/or discrimination.
LOUIS BERGER CODE OF BUSINESS CONDUCT
13
Safety, employee health and
security
Louis Berger is committed to providing a
healthy, safe and secure work environment for
all employees and visitors to our facilities. You
are responsible for acting in a way that protects
others, and for operating in accordance
with applicable laws, the Code, policies and
procedures. We can achieve our goal of a
healthy, safe and secure work environment only
through the active participation and support
of everyone.
Situations that may pose a health, safety or
security risk must be reported immediately.
Be proactive and speak up. The more we
communicate, the better we can respond to any
unsafe or unhealthy working conditions. In some
instances, you will need to follow the policies
of clients and business
partners where we share
facilities. Louis Berger often
While on a business trip,
works in conflict areas. If
a colleague repeatedly asked
you work in these areas,
me out for drinks and made
you must understand the
comments about my appearance
risks and conduct yourself
that made me uncomfortable.
in as safe a manner as
We weren’t in the office and it
possible. Seek guidance
was after hours, so I wasn’t sure
from your supervisor in
what I should do.
these situations.
Q
A Tell your colleague that such
actions are inappropriate and must
stop. If they continue, you need
to discuss the situation with your
supervisor. This type of conduct
is not tolerated during working
hours nor is it tolerated in any
work-related situation, including
business trips.
Substance abuse
The use of illegal drugs,
as well as the abuse of
prescription or over the
counter drugs or alcohol,
impairs job performance. It
can lead to a loss of proper
judgment, irresponsible
conduct and an unsafe
work environment with
the potential for accidents, personal injury or
fatalities. Therefore, employees may never carry
out Louis Berger work while under the influence
of such substances.
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ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
Alcohol may be available at business-related
events such as some client visits, corporate
celebrations or meals, unless prohibited by
local law.
Employees are responsible for keeping their
alcohol consumption to a minimum at such
events. Never consume alcohol to the point of
impairment at business functions. Employees
are responsible for complying with policies and
procedures on the use of drugs and alcohol.
How can I implement our
values?
• Promptly report any acts or threats of
violence made against you or which you
observe in the workplace.
• Know and observe the health, safety and
security rules and practices that apply to
your job.
• Notify your supervisor immediately about
any unsafe equipment or any situation
that could pose a threat to health, safety
or security.
• Stop working in any situation or with any
equipment that is unsafe.
• Maintain a neat, safe working
environment free of obstacles and other
potential hazards.
• Be proactive and make every effort to
anticipate and address safety, health and
security hazards.
• If you work in conflict or other similarly
high-danger environments, understand
the security situation and maintain
communications with management and your
security coordinator.
Watch out and speak up
when you observe:
• Lax enforcement of security standards,
such as facility entry procedures and
password protocols;
• Threats, intimidation and violence;
• Intentional damage to someone else’s
property or aggressive actions that causes
someone else to fear injury; and
• Unauthorized possession of firearms,
weapons or explosives on Louis Berger
premises or in fieldwork locations.
Protecting Louis Berger assets
As a Louis Berger employee, you are entrusted
with company assets and are responsible for
protecting them and using them with care.
Louis Berger assets include funds, facilities,
equipment, information systems, intellectual
property, time and confidential information.
Louis Berger assets should be used for
business purposes and never be used for
outside businesses or outside employment.
Louis Berger may choose to inspect any asset
at any time for a business reason. The contents
of any desks, cupboards, company cars,
private cars on company property, companyowned computers, and communication or
other electronic devices may on occasion
be inspected and reviewed. All content on
company-owned electronic equipment and
devices is Louis Berger property.
Electronic media
When using electronic media, you must
observe IT security protocols. When you
create, store and send content, ensure
that it will not offend others or embarrass
Louis Berger. Keep passwords confidential
and prevent unauthorized individuals,
including friends and family, from using and
accessing Louis Berger systems. The copying
or use of unlicensed or pirated software
on computers and other equipment is
strictly prohibited.
Q I have a part-time business that I mostly run on
my own time, but once in a while I get calls about my
business while I’m at work or I may need to send an
occasional e-mail or make some copies. Is this going to
be a problem?
A This question brings up two issues: the appropriate
use of electronic media and possible conflict of interest.
Incidental and infrequent personal use of our electronic
devices and networks is permissible. Employees who are
also self-employed may not conduct their personal work
on Louis Berger premises, equipment or time. Before you
engage in any outside employment, you must disclose and
discuss this with your supervisor for his or her concurrence.
This will ensure that there are no conflicts of interest and
that possible concerns are addressed.
Watch out and speak up
when you observe:
• Promptly inform your supervisor and the
Office of Compliance and Ethics if you
suspect any fraud or theft.
• Use of software that has not been properly
licensed;
• Louis Berger property that is not
properly secured;
• Unauthorized access or use of
Louis Berger equipment;
• Unknown individuals without proper
credentials in our facilities; or
• Password sharing.
How can I implement our
values?
• Avoid any use of Louis Berger assets in a
manner that might cause loss or damage.
• Follow all policies and procedures that
are intended to help control and maintain
our resources.
LOUIS BERGER CODE OF BUSINESS CONDUCT
15
Louis Berger reserves the right to search,
audit, investigate or otherwise monitor the
use of any company equipment and to access
personal information maintained on company
equipment. This includes computers, company
e-mail accounts, phones, desks and company
cars. When conducting investigations,
Louis Berger will observe all applicable laws,
the Code, and policies and procedures. In
addition Louis Berger recognizes that in some
countries the protection of personal data is
covered by specific legislation and regulation.
How can I implement our
values?
Privacy of employee information
Louis Berger is committed to complying with
all applicable privacy laws to maintain your
trust and the trust of our clients and business
partners whenever they share personal
information with us.
For Louis Berger to function, it needs to
collect and use a variety of information,
including personal information relating to our
employees, clients and business partners.
Personal information is any information that
identifies an individual. Examples include
government-issued identification documents,
name, age, date of birth, national origin,
citizenship and health conditions. You trust
Louis Berger to appropriately safeguard
your personal and confidential information.
It is used only for authorized purposes and
will be securely retained no longer than
necessary or legally required. You may collect
and use personal information only for a
legitimate business purpose and you must
apply reasonable safeguards to prevent the
unauthorized access, disclosure, or destruction
of the information. Louis Berger will share
personal information with third parties only if
necessary and only if they are committed to
the same high standards.
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ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
• Follow the law, the Code, policies and
procedures to protect all personal and
confidential information of current
and former colleagues as well as job
applicants, business partners and clients.
• Never share confidential or personal
information with unauthorized individuals
or entities.
• Refer all requests for employee information
from law enforcement, regulatory authorities
and any other person outside Louis Berger
to Human Resources or the Office of
General Counsel.
• Collect or store personal information only
for a legitimate business reason.
• Don’t access or discuss confidential or
personal information without a legitimate
business reason.
Communicating with the public
Louis Berger must exhibit objectivity, openness
and honesty in its communications with the
public. Louis Berger needs consistency when
making disclosures; providing information,
collateral, and/or branding materials; and
placing advertisements. It is imperative that
only authorized persons speak on behalf of
Louis Berger. Compliance with Louis Berger’s
communications policy entails the following.
• Prior to making public speeches, writing
articles for professional journals, or other
public communication, notify Corporate
Communications and obtain proper
management approvals.
• Direct all inquiries from reporters and
other outside sources about our activities,
sales, financial results or strategic plans to
Corporate Communications.
• If you identify yourself as an employee
on a social media site, you are bound by
Louis Berger’s ethics policies regarding
professionalism and public release
of information.
• Never speak “off the record” to reporters
or others who ask you for information
about Louis Berger or our clients.
To learn more:
• Discuss any questions or concerns
regarding release of information
or communicating with the public
with Corporate Communications at
[email protected].
Standards for personal use of
social media
Be careful
when writing
communications that
might be published
online. Follow these
standards:
Respect the privacy of employees, clients
and business partners. If you, as a private
individual, participate in online forums, blogs,
newsgroups, chat rooms, bulletin boards
or other social media such as Facebook
and Twitter, remember that you are not to
speak on behalf of Louis Berger nor give the
impression that you are speaking on behalf of
Louis Berger.
Ask yourself, “Am I saying the right thing as
a Louis Berger employee — even when I am
using my personal account?”
Never send or post confidential business or
government-classified information.
Don’t send or post information that could
damage Louis Berger’s or a business
partner’s reputation.
LOUIS BERGER CODE OF BUSINESS CONDUCT
17
Responsibilities
to Our Private
Sector Clients,
Government
Clients and
Business Partners
Business partner relations
Just as Louis Berger is committed to dealing fairly with our
business partners, we expect them to act ethically and legally
in their dealings with us. The actions and the reputation of any
business partner can have a significant effect on our reputation
and corporate brand. Consequently, Louis Berger is committed
to selecting business partners that comply with the law and
abide by the values contained in the Code.
Ethical dealings
Louis Berger is committed to conducting business activities
ethically and legally. This is paramount to everything we do. Louis
Berger treats clients and business partners fairly and works to
understand and complete their missions. We respect people and
communities affected by our work and always remain loyal to our
shared values and compliance and ethics standards.
You must never knowingly make false or misleading statements
to anyone doing business with Louis Berger. We anticipate our
clients’ needs and target our actions to meet their goals while
conducting our business truthfully and with trust. In short, we treat
our clients and business partners as we would like to be treated.
The principles described below apply to private sector clients,
government clients, and business partners.
Integrity in government contracting
Louis Berger’s values stress the importance of honesty and
openness in our business and client interactions. We take the
trust our clients put in us seriously. Louis Berger follows specific
laws and procedures designed to ensure that U.S. and other
government contracts are awarded fairly.
To ensure compliance with these rules, you:
• Must follow bid, tender and other contracting rules and
requirements;
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ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
• Must not offer, give or authorize any item
of value, gift or money to a government
employee for the purpose of gaining an
inappropriate business advantage;
• Must not share or obtain prior, during, or
after a bid any confidential information
associated with that bid in violation of
applicable tendering rules and procedures;
• Must not agree with a competitor or
business partner to submit a noncompetitive bid;
• Must not have undisclosed employment
discussions with a government employee
who is engaged in the procurement
process, or has discretionary authority
over the award of a contract for which
Louis Berger has submitted or intends to
submit a bid; or
• Must not use or compensate a former
government employee who served as a
procurement official during the preceding
one-year period in the government
department in which the bid is being
submitted without prior approval from
the CCEO.
Sometimes Louis Berger partners with
companies on one project while competing
against them on other projects. It is particularly
important that we do not improperly use
partner cost and pricing information when
competing against them on other projects.
How can I implement our
values?
• Treat clients and business partners fairly and
honestly, consistent with the Code and our
Vision and Values.
• Promptly report to your supervisor any
error, omission, undue delay or defect in
the quality of our services.
• Always act fairly and justly with vendors
and subcontractors.
• Promise only what you can deliver, and
deliver what you promise.
• Consider the reputation, technical
capabilities, resources, value and industry
standards when selecting business
partners on Louis Berger projects.
• Properly document all contract terms.
• Monitor business partners for adherence to
the Code and other ethical standards.
Watch out and speak up
when you observe:
• Delivery standards or compliance with
applicable law, the Code, policies, and
procedures that are not being met; and
• Telling people what they want to hear
rather than the truth; if a situation is
unclear, begin by presenting a fair and
accurate picture as a basis for decisions
or recommendations.
Business partner diversity
Diversity of business partners is good for us, our clients and for
the community. Louis Berger identifies qualified minority and
woman-owned business enterprises, small business enterprises
and local business enterprises capable of providing products
and services. Louis Berger continues to build upon its business
partner base to reflect the diversity of the overall community
and meet competitive bidding and procurement procedures.
Q Is it ever appropriate to pay a business partner in cash?
A You should always consider this a warning sign. Before
proceeding, get guidance from your procurement department
representative and the Office of Compliance and Ethics. With
a very few exceptions, Louis Berger will make all payments
by check, bank order or credit note. When cash payments
are necessary, adequate safeguards must be implemented to
ensure that the payment is for a legitimate purpose and that it
is properly documented.
LOUIS BERGER CODE OF BUSINESS CONDUCT
19
Trade restrictions, sanctions and
economic embargoes
Louis Berger complies with all applicable
trade restrictions, sanctions and economic
embargoes. We expect all of our business
partners to do the same when acting on behalf
of Louis Berger.
Many of our clients — including the World
Bank, United Nations, and the U.S. and other
governments — have trade restrictions,
sanctions and economic embargoes that
prohibit Louis Berger from dealing with
specifically identified individuals, entities and
countries. These trade restrictions, sanctions
and economic embargoes may prohibit
commercial and financial transactions, travel,
the export of goods
(including hardware
and software) and
Technology transfers
the exchange
U.S. and local export rules may
of information
restrict the transfer of technology
(e.g., technology
and technical data to some foreign
transfers). Finally,
countries or their nationals:
these trade
Transfers can occur through the
restrictions,
internet, e-mail, conversations,
sanctions and
meetings and database access.
economic
embargoes may
also impact your
ability to carry your computer and other IT
equipment to certain restricted countries.
Trade restrictions, sanctions and economic
embargoes are complex and may in certain
instances be in conflict with one another. In
instances where Louis Berger is considering
dealing with new clients, governments or
countries, it is imperative that the procurement
department conduct a review of the new
customers, governments or countries to
ensure no trade restrictions, sanctions and
economic embargoes apply that would prohibit
Louis Berger from dealing with them.
20
ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
Similarly, if there are requirements in a tender
that requires Louis Berger to deal with clients,
governments or countries that are subject to
trade restrictions, sanctions and economic
embargoes, Louis Berger will not respond to
the tender if the offeror does not agree to
eliminate these requirements. Employees
needing guidance on trade restrictions,
sanctions and economic embargoes should
contact [email protected].
Boycotts
U.S. law prohibits Louis Berger from
participating in another nation’s economic
boycotts or embargoes. Conduct that is
prohibited includes:
• Agreements to refuse, or actual refusal,
to do business with or in Israel or with
blacklisted companies;
• Agreements to discriminate, or actual
discrimination, against persons based on
age, race, creed, color, religion, gender,
national origin, status of citizenship or other
protected characteristics;
• Agreements to furnish, or actual
furnishing of, information about business
relationships with or in Israel or with
blacklisted companies;
• Agreements to furnish, or actual furnishing
of, information about age, race, religion,
gender, national origin, status of citizenship
or other protected information; and
• Implementing letters of credit or contracts
containing prohibited boycott terms
or conditions.
Louis Berger will not participate in any boycott
request. You must promptly report to the
Office of General Counsel any request from
a client or business partner requiring us to
participate in a boycott of any person, item or
service as listed above.
How can I implement our values?
Exports (hardware, software and
technology)
• Understand which trade restrictions,
sanctions or economic embargoes may
apply before you export any item.
• Obtain all necessary licenses before the
export or re-export of any products,
services or technology.
• Report complete and accurate information
regarding every exported product.
A conflict of interest may happen whenever
you, or a member of your immediate family,
has a competing personal interest that may
interfere with your ability to make an objective
decision with respect to the client or our other
business partners. You are expected to use
good judgment and avoid situations that can
lead to even the appearance of a conflict.
As employees, we have a duty of loyalty to
Louis Berger that requires us to act in the
best interests of the company, even when
our personal interests are in conflict.
Business development
• Comply with procurement and
contracts requirements as well as all
appropriate screening procedures before
committing Louis Berger to any business
partner relationship.
• Promptly report to the Office of General
Counsel any request to join in, support, or
furnish information concerning the age,
race, creed, religion, gender, national origin,
status of citizenship, or other protected
characteristics of our employees, clients
and business partners.
Conflicts of interest
As a company, Louis Berger has a duty to act
fairly and with integrity when dealing with
our clients and business partners. We must
not jeopardize the trust our business partners
place in us by ever allowing personal gain
or personal financial interest to cloud our
judgment or come ahead of the interests
of our company, our clients or our other
business partners. We will not knowingly enter
into a relationship with a client while having
an interest with another client that could
materially interfere with the proper exercise
of our judgment on the first client’s behalf,
without fully discussing the circumstances
creating the conflict with each client and taking
appropriate action.
Potential conflicts of interest
Self-dealing and corporate opportunities — If you learn
about a business opportunity in the course of doing your job,
this opportunity belongs to Louis Berger.
Personal and family interests — These are situations in which
a member of your immediate family works for or with (or has
a significant ownership interest in) one of our competitors,
suppliers, contractors, subcontractors, consultants, or clients.
Information-handling — Always treat information coming to
you in the course of your work at Louis Berger as confidential
and do not use such information for personal profit.
Outside employment — Always disclose and discuss with
your supervisor any outside employment, side jobs or
personal business.
Former government employees — Have you complied with
Louis Berger’s policy and procedures when hiring former
government employees?
Personal investments — This requires a significant investment
in or obligation to one of Louis Berger’s competitors,
suppliers, clients or business partners.
Civic activities and outside organizations — Outside
activities could conflict with your duties at Louis Berger or
negatively impact your job performance.
LOUIS BERGER CODE OF BUSINESS CONDUCT
21
Because conflicts of interest are not always
clear-cut, you must keep your actions
transparent and fully disclose to your
supervisors any actual or potential conflicts
of interest that you may have. Once they are
disclosed, Louis Berger can then properly
evaluate, monitor and manage them.
Ownership or the holding of a decisionmaking position by you or a member of your
immediate family in an actual or potential
competitor, supplier, contractor, subcontractor,
consultant or client of Louis Berger may create
a serious conflict of interest. It may violate
applicable laws, the Code, and policies and
procedures and subject you individually and/or
Louis Berger to liability.
Accordingly, unless you first obtain the
prior written approval of your business unit
manager or the Office of Compliance and
Ethics, you must not select, retain, negotiate
with, or supervise any supplier, contractor,
subcontractor or consultant, or participate in
the submission of bids, negotiate nor manage
any project on behalf of Louis Berger for any
client for which you or a member of your
immediate family is a principal or officer, or has
any significant ownership interest in that client
or any other such business partner.
For purposes of the Code:
• An ownership interest is not significant
where the holding is three percent (3%) or
less of any class of securities of a company
listed on any nationally or internationally
recognized security exchange and the
value of such holding does not exceed
five percent (5%) of the individual’s net
worth; and
• “Immediate family” means your spouse,
parents, step-parents, children, stepchildren, siblings, mother- and father-in-law,
sons- and daughters-in-law, brothers- and
sisters-in-law and anyone (other than a
domestic employee or tenant) who shares
your home.
22
ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
How can I implement our
values?
• Always make business decisions in the best
interests of Louis Berger and our clients.
• Never take or advise others to take any
potential business opportunity that might
otherwise be available to Louis Berger.
• Do not perform services directly or
through any competing firm in which you
or an immediate family member has a
significant ownership.
• Discuss with your supervisor, the Office
of General Counsel, or the Office of
Compliance and Ethics the full details of
any situation that could be perceived as a
potential conflict of interest.
To learn more:
• Discuss with your supervisor or the Office
of General Counsel any questions or
concerns about conflicts of interest.
Q May I serve as an officer in an
industry organization, or would that be
considered an inappropriate conflict?
A Employees are encouraged, with their
supervisor’s permission, to participate at
all levels in industry organizations and
associations that promote professionalism.
Q My spouse is a member of the
board of directors of one of Louis
Berger’s clients and is involved in the
selection process of a contract in which
Louis Berger has a proposal. Is this a
potential conflict of interest? If so, what
must I do?
A Yes, this is a potential conflict of
interest which must be disclosed. A final
determination will be made in coordination
with the Office of General Counsel.
Gifts and business courtesies
It is Louis Berger’s policy that gifts or
entertainment can only be provided or
accepted if they are not intended or do
not create an appearance of having an
inappropriate influence on a business decision.
In the right circumstances, a modest gift may
be a thoughtful thank you, or providing a meal
may be an appropriate setting for a business
discussion with our government, private
or potential clients. Much of Louis Berger’s
business is with governments, governmentowned or government-controlled organizations
and public international organizations. Perfectly
normal and otherwise acceptable gifts and
entertainment when dealing with government
officials who represent these organizations
may be viewed as an inappropriate attempt
to influence their decisions. The exchange of
gifts and entertainment can create a conflict of
interest or the perception of corruption if not
handled carefully. This is true especially if gifts
or entertainment are provided frequently or if
the value is large enough to reasonably create
the impression that the gift or entertainment
is intended to inappropriately influence a
business decision.
Nonetheless, Louis Berger permits employees
to provide (and accept) gifts and entertainment
of nominal value if the gift or entertainment
meets all of these requirements:
• Is not intended to inappropriately influence
a business decision;
• Has a legitimate business purpose;
• Is modest in value;
• Is given or received in an open and
transparent manner;
• Complies with local law and the company
policy of the recipient;
• Is consistent with customary business
practices of the giver and the recipient;
• Is not of a nature so as to obligate or
create the appearance of obligating
the recipient;
• Is offered or accepted infrequently; and
• Is accounted for appropriately in the
Louis Berger books and records.
Government officials are usually subject to
additional restrictions. These restrictions limit
instances when gifts or entertainment are
allowed and how they need to be accounted
for by Louis Berger and the recipient. You must
understand these restrictions prior to offering
any gift or entertainment to such persons.
Prior to giving or receiving any gift or
entertainment, employees are responsible for
determining if the individual is under any legal
or corporate restrictions.
For more specific guidance that more
directly impacts your situation go to the
Louis Berger Global Anti-Corruption Policy
and Procedures document.
The term “government official” applies
to members of a royal family; officials of a
political party; candidates for public office;
political parties; elected or appointed
employees of governments (local, state or
federal); employees of state-owned or statecontrolled commercial enterprises; and
public international organizations (such as
the World Bank).
In some contracts and with some
clients (for example, New York and
New Jersey- area government clients),
we are required to comply with a
zero-tolerance policy, that is, no gifts
or entertainment — to or from the
client — without exception. Any gift
or entertainment offer that violates
these requirements not only puts Louis
Berger and the employee involved at
risk, but it also exposes the client to an
uncomfortable and awkward situation.
Business partners working for Louis
Berger on projects for clients requiring a
zero-tolerance policy must comply with
these restrictions.
LOUIS BERGER CODE OF BUSINESS CONDUCT
23
How can I implement our values?
• Provide or accept only gifts and
entertainment that are appropriate, and
follow the applicable law, the Code, and
policies and procedures.
• Know what entities are government-related
and act appropriately when giving gifts or
providing entertainment.
• Never accept or offer cash or cash equivalents.
• Never offer or accept gifts of any kind
from a business partner with whom you are
involved in contract negotiations.
• Always account for gifts and entertainment
appropriately in Louis Berger’s books and
records to ensure transparency.
• Promptly report to your supervisor gifts
received or gifts offered to you, even those
that you decline.
• Recognize that transactions involving
government officials are higher risk and
act appropriately.
Watch out and speak up
when you observe:
• Gifts or entertainment that could
embarrass you or Louis Berger, including
entertainment at sexually oriented or
other inappropriate establishments; and
• Business partners or clients who may
have stricter gift and entertainment
standards than Louis Berger. You should
always comply with the stricter of the
two standards.
Creating business records
Accuracy and transparency
in financial reporting
Accurate and complete information is essential
so that we can make good decisions on
behalf of our clients and Louis Berger. Our
shareholders, business partners, government
regulators and others rely on the accuracy
and the completeness of our disclosures and
business records.
Moreover, Louis Berger relies on the accuracy
and the completeness of the records of business
24
ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
partners who are working on our projects.
This will ensure that Louis Berger is able to
accurately bill and provide reports to clients in
accordance with contractual obligations.
Louis Berger books and records must be clear,
complete, and in compliance with applicable
laws, the Code, and policies and procedures.
Each of us is responsible for helping ensure
that the information we generate and provide
to management and to employees in finance
and accounting is maintained in a manner
that is consistent with internal policies,
procedures and our system of internal controls.
These actions all contribute to project and
corporate transparency.
Records management
Records management is essential to our
ability to address project contingencies and
meet schedules, supply deliverables, and
communicate effectively with clients and
stakeholders. Louis Berger requires that all
books, business records and correspondence
are maintained, stored in accordance with
our business needs, and are in compliance
with applicable laws, regulations and
contract requirements.
You are responsible for books, business records
and correspondence under your control.
You must be familiar with the recordkeeping
procedures that apply to your job. You
are accountable for the accuracy and the
truthfulness of the books, business records
and correspondence you produce. It is also
your responsibility to retain all books, business
records and correspondence in compliance
with retention requirements and to keep them
organized so that they can be located and
retrieved when needed.
Books, business records and correspondence
should not be destroyed unless the destruction
is in accordance with our records retention
guidance. Documents should never be
destroyed in response to, or in anticipation of,
an investigation, claim, lawsuit or arbitration
proceeding. Contact the Office of General
Counsel if there is any question about the
appropriateness of the destruction of any record
or its retention period.
Accurate time charging and expense
reporting
Our clients rely on Louis Berger to provide them
with accurate and complete bills. For this reason,
you must track time you spend on work-related
projects, as well as overhead projects, so that
our clients can be certain that our billings are
accurate, fair and appropriate.
Employees’ expenditures on behalf of
Louis Berger and our clients must be consistent
with the needs of the business and follow
all applicable laws, the Code, policies and
procedures, and relevant client agreements.
How can I implement our values?
• Always comply with internal accounting
policies and procedures when authorizing
or making payment to business partners.
• Create accounting and business records
that accurately reflect the truth of the
underlying event or transaction.
• Ensure that expenditures are reasonable
and comply with all applicable laws,
the Code, policies and procedures, and
contract terms.
• Do not maintain off-the-books
transactions or undisclosed or
unrecorded funds, assets or liabilities.
• Make payments only to the business
entity listed on the governing agreement
or invoice and make all payments in
accordance with the payment terms as
defined in the agreement or invoice.
• Charge all payments to the right project
and the right client. Do not charge
payments to unrelated accounts.
• Sign only what you have reviewed, are
authorized to sign, and believe to be
accurate and truthful.
• Submit true and accurate timesheets and
expense reports.
Watch out and speak up
when you observe:
• Inaccurate, incomplete, or suspicious
items in books, business records
and correspondence;
• Incorrect recordkeeping by
business partners working on
Louis Berger projects;
• Requests from business partners
or employees to create inaccurate
documents; and
• Any attempt to interfere with an audit.
Q I ran out of budgeted hours for a task. May I charge
another project or overtime for the additional hours
needed to finish the task.
A No, you cannot charge overhead or an unrelated
project for time spent to complete the task. Continuing
to charge time to the project even when you have run out
of budget hours helps provide more accurate information
on the amount of resources needed to complete similar
tasks in the future. If you have questions or are unsure how
to proceed, discuss the issue with your supervisor. If your
supervisor cannot help, contact the division manager or HR
director for guidance.
Q I ran out of vacation and sick leave. May I charge
one of my projects for the time and make it up later?
A No, you may not. You may never charge a project (even
overhead) unless you worked on that project that day. You
should contact your supervisor for guidance.
LOUIS BERGER CODE OF BUSINESS CONDUCT
25
Confidential company
information
Louis Berger’s confidential, proprietary, and
other non-public business information is
a valuable asset. For ease of reading such
information is referred to as “confidential
information” in this section. Our employees,
business partners and clients depend on
discretion. Louis Berger’s commitment to
protecting confidential information reinforces
the trust placed in us, encouragning open and
effective communication.
You must be vigilant and comply with
security policies and procedures to protect
Louis Berger’s confidential information. This
means keeping the information secure, limiting
access only to those who have a legitimate
business need to know, and disposing of the
information properly. The obligation to only
share confidential information with individuals
who have a legitimate business need continues
even after your employment ends. Examples
of confidential information include but are not
limited to client, operations, project, financial
and human resource information.
Louis Berger’s confidential proprietary and
other non-public business information
Examples include:
•Status of operations and equipment;
•Financial, competitive position and business strategies;
•Information relating to negotiations with employees or
business partners;
•Initiatives (existing, planned, proposed or developing);
•Lists of business partners;
•Trade secrets, discoveries, innovations and designs;
•Methods, know-how and techniques;
•Systems, software and technology; and
•Patents, trademarks and copyrights.
You must promptly disclose any new discoveries, innovations
and designs that you create while employed by Louis Berger.
26
ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
How can I implement our values?
• Label information that has been declared
confidential or proprietary. This will
indicate how it should be handled,
distributed, protected and destroyed.
• Always get guidance if you are unclear
as to whether an individual requesting
access to confidential information has a
legitimate business need to know.
• Where Louis Berger confidential information
is a proposal submission requirement,
restrictions on its dissemination by other
parties must be noted on each page to
which the restriction applies and included in
any teaming agreement.
• Take all necessary steps to safeguard
the security of and restrict access to any
government-classified information. Failure
to do so may subject Louis Berger and
individuals to potential penalties. It may
also jeopardize Louis Berger’s ability to
keep its required security clearance levels.
• Avoid discussing confidential, proprietary
and other non-public business information
with unauthorized individuals and in
public areas.
• Use and disclose confidential, proprietary
and other non-public business information
only for legitimate business purposes.
• Promptly report to your supervisor any loss
or inadvertent disclosure of confidential,
proprietary and other non-public
business information.
Competitor information
Information about competitors is a valuable
asset in today’s competitive business
environment. When collecting business
intelligence, you and others who are working
on our behalf must always abide by all
applicable competition laws and the values
and ethics embodied in the Code.
Never exchange competitor information
directly with a competitor for the purpose of
reaching an illegal agreement. Do not engage
in fraud, misrepresentation, or deception to
obtain information; and do not use invasive
technology to spy on competitors. Be
discerning when accepting information from
third parties, know and trust their sources,
and be sure that the knowledge they provide
is not protected by trade secret laws or nondisclosure or confidentiality agreements.
Although Louis Berger employs former
employees of competitors, we recognize and
respect the obligations of those employees not
to use or disclose the confidential information
of their former employers. Likewise, though
Louis Berger often partners with other
companies, those same companies can also be
our competitors on other projects. Never share
or use confidential information obtained about
competitors or business partners.
How can I implement our values?
• Understand and adhere to the competition
laws and Louis Berger policies applicable
to your responsibilities.
• Always ensure that any information about
competitors is collected legally and that
the source of the information is apparent.
• Promptly report to your supervisor if you
receive inadvertently or otherwise any nonpublic information about our competitors.
LOUIS BERGER CODE OF BUSINESS CONDUCT
27
Responsibilities
as Corporate
Citizens
Louis Berger enhances the global physical, social and economic
infrastructure. We operate with integrity and responsibility in all
that we do, adhering to our mission of improving the quality of life
around the world. Our work improves the lives and the communities
of the people we serve, from reconstruction of transportation
networks and economic development to power generation and the
protection of natural resources.
Environmental sustainability
Louis Berger recognizes its responsibility to conduct business in
a manner that protects, preserves and improves the environment
for future generations. Louis Berger is committed to working with
its business partners and suppliers to strengthen environmental
sustainability through infrastructure and services that continue
to improve lives and communities long after assignments are
complete.
We comply with applicable environmental laws and regulations
and cooperate on environmental and sustainability matters with
the communities that host Louis Berger operations. Our goal is
the continuous improvement of our environmental performance
through resource conservation, waste minimization, water and
energy efficiency, and effective use of raw materials.
You should be familiar and comply with environmental standards
applicable to your work activities. If you are unsure of the
requirements, speak with your supervisor.
How can I implement our values?
• Comply with all applicable environmental laws, regulations
and professional standards of good industry practices.
• Promptly report to your supervisor any incidents or
conditions that might result in the risk of an environmental
violation or an actual violation.
• Think ahead and always be proactive. Help identify
opportunities for improving our environmental performance.
28
ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
Human Rights/
Trafficking
Social responsibility
As employees of Louis Berger, you are an
active contributor to the communities in which
we do business. We are committed to using
our resources and expertise to give back in
a wide variety of ways. Louis Berger and our
employees demonstrate our social responsibility
by providing jobs and services, charitable
contributions, pro bono assistance, volunteers,
and partnerships with worthy local charitable and
professional organizations.
While you are encouraged to become
actively involved in efforts to support your
communities, you must not pressure others to
contribute to or participate in your preferred
charitable organizations.
How can I implement our values?
• Ensure that your personal support of
charitable causes is not in conflict with
your responsibilities as an employee of
Louis Berger.
• Follow Louis Berger’s Global AntiCorruption Policy when making and
soliciting charitable contributions.
Watch out and speak up
when you observe:
• Requests from government officials or
business partners to give to charitable
causes as a condition for getting a
favorable business advantage; or
• Employees creating an appearance that
Louis Berger supports their personal
charitable cause.
Q My supervisor often asks me
to support his favorite charities and
sponsor him in fund-raising walks and
races. Sometimes I feel I don’t have a
choice. What can I do?
A If you are comfortable doing so,
talk to him about the problem. As an
alternative, you can contact any of the
resources listed in the Code. Pressuring
others to contribute to or join charities,
groups or political activities is against
our policies.
Fundamental
human rights
Louis Berger treats employees fairly
and complies with all applicable
employment laws in all our
operations. Louis Berger respects
your right of free association and
to freely decide if you wish to be
collectively represented. Louis
Berger will not knowingly use
legally underage workers or forced
labor (including prison, trafficked
or bonded labor), nor condone
physical punishment or other abuse.
Additionally,
Louis Berger will
not associate with business partners
that do.
Louis Berger has a zerotolerance policy regarding
trafficking in persons that
reflects the U.S. government
policy as stated in FAR
Clause 52.222-50.
We do not, nor do we
tolerate, partners who:
• Engage in any trafficking
in persons;
• Procure commercial sex
acts; or
• Use forced labor.
Louis Berger will take action
for violations of this policy.
How can I implement
our values?
• Respect your colleagues, our clients and the
people and the communities we serve.
• Know that Louis Berger policy prohibits human
trafficking within any contract with the public or
private sector.
• Remain vigilant and look out for any signs of
violation of human rights or employment laws.
• If you are responsible for supervising business
partners, ensure that they know our human
rights principles and live up to them.
Watch out and speak up
when you observe:
• Employees whose passports and other official
documents are withheld by their management;
• Workplaces where psychological manipulation
and control are used;
• Employees who are housed in inhumane living
conditions; and
• Employees who have excessively long and
unusual hours, are unpaid or paid irregularly,
have unusual work restrictions or have
unexplained work injuries.
LOUIS BERGER CODE OF BUSINESS CONDUCT
29
Anti-corruption and bribery
Louis Berger is committed in all our operations
throughout the world to conduct business
ethically, with integrity, and in compliance with
applicable laws and regulations prohibiting
bribery and corruption.
Examples of applicable laws and regulatory
organizations include the United States
Foreign Corrupt Practices Act, the United
Kingdom Bribery Act (2010), the Organisation
for Economic Co-operation and Development,
the Convention on Combating Bribery of
Foreign Public Officials, the United Nations
Convention against Corruption, and the
African Union Convention on Preventing and
Combating Corruption.
It is the policy of Louis Berger to accurately
reflect all transactions in its books and records,
and to require any business partners who
conduct business on Louis Berger’s behalf to
comply with the same laws and practices.
Louis Berger prohibits our directors, officers,
managers, employees and business partners
who are authorized to act on our behalf
from engaging in any corrupt conduct. This
prohibition is applicable to government and
private business transactions.
Louis Berger further prohibits our directors,
officers, managers, employees and business
partners who are authorized to act in any way
for or on behalf of Louis Berger to directly
or indirectly offer, promise, give or authorize
anyone to give money or anything of value
to a government official for the purpose of
obtaining a business advantage.
Louis Berger seeks business partners that
share our values. However, their actions can
negatively impact our reputation, financial
interests and affect relationships with our
clients. Therefore, comply with all
procurement and appropriate screening
policies and procedures before committing
Louis Berger to any business relationship.
Always evaluate the reputation, technical
30
ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
abilities and other information carefully before
engaging any business partner to work on a
Louis Berger project.
Never ask a business partner to engage in or
condone any conduct that you are prohibited
from engaging in yourself. Make sure that
when business partners act on behalf of
Louis Berger they understand the need to
maintain accurate and complete records
and that they operate in strict compliance
with applicable anti-corruption laws and our
ethical standards.
Facilitating, expediting or grease
payments
Facilitating payments are small or nominal
payments made to a government official to
speed up and/or secure the performance of a
routine non-discretionary government action.
Examples of routine nondiscretionary government
action for which payments may
be approved
• Obtaining permits, licenses or other
documents to qualify Louis Berger to do
business in a particular country
• Obtaining police protection, phone
service, power and water supply, or mail
pickup or delivery
• Scheduling inspections associated with
contract performance or related to transit
of goods across country
• Processing governmental work papers
such as visas and work orders
Louis Berger does not permit employees
or business partners to make facilitating
payments on behalf of Louis Berger without
prior approval. In limited instances, with prior
approval of your Louis Berger president or
COO and in coordination with the general
counsel and CCEO, an exception may be
authorized in cases where the health and
safety of a Louis Berger employee is at risk.
It is Louis Berger’s policy to approve only
those facilitating payments that do not violate
applicable law.
In cases where the immediate health and safety
of a Louis Berger employee is at risk, prior
approval is not required. However, the episode
must be reported to the Office of Compliance
and Ethics and your Louis Berger president
or COO as soon as reasonably possible when
the employee is out of danger and in a safe
environment. All facilitating payments must be
appropriately accounted for in Louis Berger’s
books and business records.
Please note that a payment to a government
official to influence a decision to award
business or to continue doing business with
Louis Berger is a discretionary decision and
would violate applicable anti-corruption laws
and the Code.
To ensure compliance with anti-corruption
and bribery laws worldwide, it is important
that employees seek guidance before they act
in instances when they are unclear about the
appropriate nature of any conduct or if they
otherwise have any questions.
How can I implement our values?
• Understand and comply with anticorruption prohibitions affecting your
responsibilities at Louis Berger.
• Always follow the Global Anti-Corruption
Policy, relevant procurement policies,
and policies dealing with delegation of
authority before engaging any business
partner to work on Louis Berger’s behalf.
• Do not authorize or condone any
corrupt conduct.
• Avoid providing inappropriate or excessive
business courtesies while negotiating
potential business opportunities.
• Promptly report any actual or suspected
violations of the anti-corruption policy as
soon as you become aware of them.
• Always seek guidance if you have any
questions or are uncertain about the
appropriateness of any conduct.
Political involvement
Louis Berger can make contributions to
political parties and campaigns under limited
circumstances with clearly defined rules.
The Louis Berger policy is that all political
contributions on behalf of Louis Berger must
comply with all applicable laws regulating the
financing of political activities. Campaign and
lobbying laws are complex, they vary from
country to country, and violations may have
significant consequences for Louis Berger
and the individuals involved. For example, in
some jurisdictions political contributions may
disqualify Louis Berger from being awarded
government contracts or from participating
in a bidding process. Therefore, all political
contributions on behalf of Louis Berger must be
pre-approved by your Louis Berger president.
As an employee, you must never use
Louis Berger funds, assets,
services or facilities to support
any political candidate or party
or engage in any lobbying
activity unless specifically
preapproved by your Louis
Berger president or COO.
You have the right as a private
individual to voluntarily
participate in the political
process, including making
personal political contributions.
Q There is a problem
obtaining an environmental
permit to build a road
through a protected wildlife
area. To ensure that the
permit is issued, would
making a nominal payment to
a government official qualify
as a facilitating payment?
A No, the issuance of
an environmental permit
However, you must always
under such circumstances
make it clear that these are
is a discretionary act and
your personal views and
would be a bribe and not a
contributions and are not those
facilitating payment.
of Louis Berger. You must assess
such circumstances to ensure
that your political activities do not create an
actual or apparent conflict of interest with your
Louis Berger duties.
LOUIS BERGER CODE OF BUSINESS CONDUCT
31
How can I implement our values?
• Understand and comply with applicable
legal rules before engaging Louis Berger in
any political activity.
• Receive all necessary approvals before
using any Louis Berger resources to
support political activities.
• Ensure that personal political views and
activities are not construed as those of
Louis Berger.
• Never use Louis Berger resources
or facilities to support your personal
political activities.
• Promptly notify your supervisor if you are
campaigning for or holding political office
in your personal capacity.
Watch out and speak up
when you observe:
• Anyone communicating Louis Berger’s
government policy position to government
representatives without the Louis Berger
president’s approval;
• Direct or indirect pressure being applied
to another employee or business partner
to contribute to, support, or oppose any
political position, candidate, or party; and
• Political contributions made to
gain favor or in an attempt to exert
improper influence.
Insider trading
Our vendors, contractors, subcontractors and
other business partners, as well as our private
sector clients often are companies listed on public
stock exchanges. They rely on us to keep their
information confidential and to not use it for the
personal gain of Louis Berger or its employees.
Unauthorized or premature disclosure of such
information may have a detrimental effect on
the competitive advantage of such business
partners and private sector clients. In addition,
until released to the public, material information
concerning such a publicly listed business
partner or private sector client is considered
“insider” information.
32
ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
The U.S. Securities Exchange Act of 1934, as
amended, and the laws of other countries
governing the trading of capital stock and
other securities make it unlawful for anyone in
possession of material information with respect to
a publicly listed company to use that information
to buy, sell or otherwise trade in the securities
of that company for financial gain when that
information is not public.
Employees are prohibited from passing that
“material non-public information” on to others
(tipping) who then trade on the basis of that
information before it is made publicly available to
ordinary investors. Insider trading undermines the
public securities markets. It is a fraud against the
business partner or private sector client and goes
against the investing public who suffer by trading
in the same market without having the benefit of
such information.
“Material non-public information” in this case
is broadly defined under applicable laws and
means any information in which there is a
substantial likelihood that a reasonable investor
would consider it important in deciding
whether to buy or sell a security. Some
examples of information about one of our
current or future business partners or private
sector clients that you may become aware of as
part of your work for Louis Berger include:
• Proposed acquisition or sale;
• Expansion or cutback of operations;
• Buying shares in your business partner
based on the anticipated announcement
of an award of a major contract to that
business partner prior to the announcement
becoming public; or
• Extraordinary management or
business developments.
Q Doesn’t insider trading apply only to
public companies?
A Though Louis Berger is privately held,
in the course of business employees may
come in contact with material information
about publicly traded business partners. For
this reason it is important to understand the
provisions — and the penalties — involved in
insider trading.
How can I implement our values?
• Do not buy or sell securities of any of
our publicly traded business partners
or private sector clients when you have
material non-public information about
them as a result of your work at, or
position with, Louis Berger. Remember,
this includes employees at all levels,
from an executive in the boardroom to
the assistant who comes across such
information as part of their day-today work.
• Do not communicate such material nonpublic information regarding our business
partner or private sector client to other
people (such as spouses, friends or
brokers). You will have personal liability,
as will those with whom you share such
material non-public information, if those
individuals use the information to buy
or sell securities of the business partner
or client.
Watch out and speak up
when you observe:
• Requests by friends or family for information
about companies that Louis Berger does
business with or has confidential information
about; and
• Casual conversations that could be viewed
as illegal “tipping” of inside information.
Anti-trust and fair competition
Louis Berger believes that free and fair
competition is the key to our long-term
success and to the growth of the economies
in which we operate. You are expected to
treat all competitors, business partners and
clients fairly and ethically and to comply with
applicable anti-trust and fair competition
laws. While you are expected to compete
vigorously for projects, you must do so while
complying with all applicable anti-trust and fair
competition laws.
Performing innovative, client-oriented, highquality, and sustainable work leads to new
business, returning clients, and a reputation
for excellence. By focusing on our core values
and providing the best possible services to our
clients, we ensure financial success.
Anti-trust and fair competition laws have been
enacted by many of the countries in which
we operate. These laws are complex, and
compliance requirements can vary depending
on the circumstances and the jurisdiction in
which we are doing business.
For example, U.S. laws may be violated by
anti-competitive conduct in Germany if that
conduct has an effect in the U.S. To avoid
violating these laws, you must always be
familiar with any anti-trust or fair competition
law requirements applicable to your areas
of responsibility.
Q I heard my officemate on the
phone with his stockbroker and he
mentioned that we were about to
complete the environmental impact
statement for a controversial project
with a private client. Would this be
considered “tipping”?
A If he relayed only information that
is publicly available through the project
website, it is not considered “tipping.”
However, if he provided details of
negotiations or analyses that are not
yet public, the conversation would be
considered inappropriate and should
immediately be reported to the Office of
Compliance and Ethics or the Office of the
General Counsel.
LOUIS BERGER CODE OF BUSINESS CONDUCT
33
How can I implement our values?
• Do not enter into agreements with
competitors or engage in any anticompetitive behavior, including
agreements to prices or to otherwise
affect bidding, production, supply or
client practices.
• Do not engage in practices that
inappropriately interfere with free and fair
market conditions.
• Do not trade current or future information
on pricing, costs or business strategies with
competitors unless legal and approved in
advance by the Office of General Counsel.
• Do not agree with competitors as to which
clients, markets, or products Louis Berger
will deal with.
• Do not participate in a scheme to
manipulate bids.
• Do not engage in inappropriate
conduct deliberately designed to
eliminate or harm a competitor.
• Do not directly, or through business
partners, exchange competitively sensitive
information with a competitor.
• Do not use or disseminate non-public
information about competitors that you
may learn in the course of business or from
new hires or candidates for employment.
• Do not agree with a competitor even in jest
to submit a non-competitive bid or no bid
at all to a client.
• Seek guidance from the Office of
Compliance and Ethics if you perceive a
conflict with a Code from a third party who
Louis Berger is in, or intends to go into,
business with.
• Avoid all conversations with competitors
that could be perceived as limiting
competition. If such a conversation begins,
leave the meeting immediately and
promptly report it to the Office of General
Counsel and the Office of Compliance and
Ethics. A conversation may be a breach
of competition law whether it is formal
or informal.
34
ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
Q I understand that there are special
requirements related to teaming and
joint venture agreements. What are they,
and how do I learn more?
A Prior to engaging in a teaming or
joint venture agreement, the Office of
General Counsel must review the proposed
agreement and your Louis Berger president
or Chief Operating Officer (COO) must
approve it. If we are required to submit
certifications and representations to
the client, we must obtain back-to-back
certifications from other team members,
joint venture partners or consultants. We
must exercise reasonable care to verify the
truthfulness of others’ certifications.
Q I received sensitive pricing
information (unintentionally) from one of
our competitors. What should I do?
A You should report this to the Office
of General Counsel and the Office of
Compliance and Ethics without delay
and before any further action is taken. It
is important that, from the moment we
receive such information, we demonstrate
respect for anti-trust laws and make clear
that we expect others to do the same.
This requires appropriate action that
can be decided only on a case-to-case
basis and may include sending a letter to
the competitor.
Certification Statement
I certify that I have read the Code of Business Conduct and
fully understand the obligations set forth in the Code.
The Code includes a statement of Louis Berger’s policies,
which are designed to ensure that Louis Berger and
all those covered by the Code conduct Louis Berger’s
business in compliance with all applicable laws governing
its operations and that the conduct is consistent with the
highest standards of business and professional ethics.
I understand that the Code obligates me to carry out my
duties for Louis Berger in accordance with these policies
and applicable laws. I further understand that any violation
of these policies and applicable laws, or any deviation
from appropriate ethical standards, will subject me to
disciplinary action. I understand that even a failure to report
such a violation or deviation may, by itself, subject me to
disciplinary action.
I am also aware that in the event that I have any question
about whether an action complies with Louis Berger’s
policies or applicable laws, I should present that question to
any of the resources cited in the Code.
With this understanding of my obligations, I agree to act in
accordance with the policies set forth in the Code. Having
read the Code, I am not currently aware of any matter that
should be brought to the attention of Louis Berger as a
violation or suspected violation of the Code.
LOUIS BERGER CODE OF BUSINESS CONDUCT
35
Index
Abuse, 13, 29
Accounting, 24, 25
Accurate business records, 24, 25, 31
Agents, 7, 10
Alcohol, 14
Anonymous reporting, 9
Anti-competitive practices, 34
Anti-corruption laws, 8, 30, 31
Anti-trust, 33, 34
Audit, 9, 16, 25
Audit Committee, 6, 8
Bad faith reporting, 9
Bidding, 19, 31, 34
Blogs, 17
Board of Directors, 6, 8, 22
Boycotts, 20
Bribery, 11, 30, 31
Business development, 10, 21, 32
Business intelligence, 27
Business records, 24, 25
Chief Compliance and Ethics Officer,
3, 8
Certification, 9, 34, 37
Charities, 29
Civic activities, 21
Communicating with the public, 17
Company assets, 15
Company information, 26
Company property, 15
Competition laws, 27, 33, 34
Competitors, 21, 27, 33, 34
Compliance committee, 7
Confidential information, 15, 16, 17,
19, 26, 27, 33
Conflicts of interest, 15, 21, 22
Contractors, 7, 19, 21, 32
Cooperating with investigations, 10
Copyrights, 26
Corporate Communications, 17
Corporate opportunities, 21
Discrimination, 12, 13, 20
Diversity, 12, 13, 19
Drugs, 14
E-mail, 13, 15, 16, 20
Embargoes, 20, 21
Employee information, 16
Entertainment, 23, 24
36
Environmental sustainability, 28
Equal Opportunity Employer, 12
Exports, 21
Facilitating payments, 30, 31
Fair competition, 33, 34
False Claims Act, 10
Family, 12, 15, 21, 22, 33
Federal Acquisition Regulations
(FAR), 10
Financial reporting, 24
Firearms, 14
Fraud, 10, 15, 27, 32
Friends, 15, 33
Foreign Corrupt Practices Act, 30
Funds, 15, 25, 31
Gifts, 23, 24
Government contracting, 18
Harassment, 11, 12, 13
Health, 14, 16, 30, 31
Helpline, 10, 11
Hiring, 21
Human Resources, 8, 16
Human rights, 29
Human trafficking, 29
Insider information, 32
Insider trading, 32
Intellectual property, 15
Intimidation, 13, 14
Investigations, 7, 8, 9, 10, 11, 16, 24
Investments, 21
Invoices, 25
Lobbying, 31
Misconduct, 7, 13
Non-retaliation policy, 7, 8, 10
Office of Compliance and Ethics, 7,
8, 9, 10, 19, 22, 31, 32, 34
Office of General Counsel, 8, 10, 16,
20, 21, 22, 24, 30, 33, 34
Our Vision and Values, inside front
cover, 6, 19
Outside employment, 15, 21
Passwords, 15
Personal investments, 21
Political involvement, 31
Political contributions, 31, 32
Privacy, 16, 17
Procurement, 8, 10, 19, 20, 21, 30, 31
ACHIEVING SUCCESS BY PUTTING OUR VALUES INTO ACTION
Records management, 24
Regulations, 7, 8, 10, 24, 28, 30
Reporting concerns and violations,
8, 9
Safety, 14, 30, 31
Sanctions, 20, 21
Securities, 22, 32, 33
Security risks, 14
Self-dealing, 21
Social responsibility, 29
Software, 15, 20, 21, 26
Substance abuse, 14
Suppliers, 7, 21, 28
Technology transfers, 20
Third parties, 8, 16, 27, 34
Time and expense reporting, 25
Tipping, 32, 33
Training, 8, 9
Weapons, 14
Work environment, 8, 12, 13, 14
Workplace, 13, 14, 29
Zero-tolerance policy, 23, 29
L
P
I
N
L
E
E
H
If you ever have a question or concern about
potential unethical, illegal or irresponsible
activities, don’t keep it to yourself. Your report
may be made anonymously.
Available 365 days | 24 hours a day | 7 days a week
Report online
www.tnwgrc.com/louisberger
Call toll-free
1.877.315.9932
Thomas Nicastro, Ph.D., CCEP
Senior Vice President | Chief Compliance and Ethics Officer
[email protected] | 1 202 303 2709
1250 23rd Street NW | Washington, DC 20037
38
The Network is an independent reporting service. When you contact
them, you do not have to give your name. A customized Web form or
professional interview specialist will document your concern and relay
information to our organization for follow-up.
ACHIEVING SUCCESS BY PUTTING OUR VALUES INTOthe
ACTION
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