CH2M HILL was founded by remarkable professionals who put honesty and integrity above all else. Each generation since has built on that solid footing. CH2M HILL’s unwavering commitment to management with integrity and corporate responsibility dates back to the early days in our history, when the company’s co-founder, Jim Howland, authored the Little Yellow Book. The Little Yellow Book, known and beloved throughout the organization for its commonsense advice and simplicity, is legendary among CH2M HILL’s current and former employees. Its simple wisdom is often quoted in company meetings and casual conversations as a way to confirm the core values of how CH2M HILL does business.
As a companion to the Little Yellow Book, we developed our Employee Ethics & Business Conduct Principles (our employee code of conduct). This work builds on simple and lasting concepts of the Little Yellow Book and translates them into clear policies and aspirational, value-based guidance for behavior that is expected from those who work for CH2M HILL. The Principles guide our employees through complex ethical decisions that must be made every day in the ever-changing global marketplace.
Our Employee Ethics & Business Conduct Principles is a living document that is periodically updated to reflect our changing business and evolving regulatory environment. It combines all CH2M HILL ethics and compliance policies and offers tools and practical advice on what to do when an employee encounters all too common ethical dilemmas in the workplace. Our new and seasoned employees, wherever they are based, are required to review the Principles annually and take a training course and quiz on the key components embedded in the document. As a condition of employment at CH2M HILL, our employees are also required to affirmatively attest their commitment to follow these Principles. The standards encompassed in the Employee Ethics & Business Conduct Principles are published in the nine languages most commonly used by CH2M HILL employees and are available on our intranet and on our Web site.
In 2011, we established and implemented a set of ethics and conduct principles for our suppliers, subcontractors and our business partners that are complementary to the employee ethics and conduct principles. The new Supply Chain Ethics & Business Conduct Principles and a companion Supplement for U.S. Government Work serve as the standard of expectations for entities that wish to work with CH2M HILL. Our suppliers, subcontractors and business partners must agree to comply with Our Supply Chain Ethics & Business Conduct Principles when registering and submitting their qualifications as a potential business affiliate. The terms and conditions of agreements to perform work with us for our U.S. Government customers directly incorporate the Supply Chain Principles.
Knowing that vigilance, transparency, access without fear of retribution, and oversight are imperative to ensuring that our employees around the world have the information and support they need to make difficult ethical decisions, we have instituted a variety of tools and educational programs.
The GuideLine, our confidential hotline, is a versatile phone- and web-based tool that employees and members of our supply chain can use to seek guidance, discuss ethical concerns, or report potential violations or laws or policies. The GuideLine is available 24 hours a day, 7 days a week, 365 days a year, anywhere in the world and offers users the choice of complete anonymity without fear of reprisals. The web‑based hotline tool is also available in a smart-phone mobile app version and can be accessed in more than 75 languages. All contacts through The Guideline are investigated and addressed by a team of trained professionals whose objective is to make sure that the company does the right thing and deliver services to our clients with integrity.
In 2011, we received 213 contacts via The GuideLine, which is an increase of 22 percent year over year. Of the 213 matters reported, 44 percent were Human Resources-related (categorized as harassment, discrimination, or employee relations), down from 56 percent of the year’s total for 2010. We believe this drop results from the partnership between our Human Resources and Legal teams to upgrade our employee relations practices and processes as well as our renewed focus on proactive performance management and employee communication. This group actively trained managers and supervisors to recognize and address problems early, before the issues escalated, and communicated clearly to employees around the world.
By increasing employee awareness of our expectations on how CH2M HILL does business with integrity and by including open discussions about importance of ethics and integrity as a marketplace differentiator for CH2M HILL, we are seeing greater employee engagement in how we do business all over the world. This employee engagement is evidenced by an increase in the use of The GuideLine, for example, to report concerns and ask questions on the best way to address ethical challenges. We are encouraged by these increases, as they speak to greater awareness among our employees about CH2M HILL’s expectations in the ethics and compliance arena and the confidence employees have in our confidential reporting system. Moreover, the rise in contacts to The GuideLine gives us an opportunity to assist our employees in making sound decisions before any action is taking instead of expanding time and energy on damage control after a wrong decision is made.
Regular messaging from senior leaders in the firm about our business ethics and expectations on how CH2M HILL does business—including featured news stories, reminders, links, in-house social media, and face-to-face and e-mail-direct communications—keeps our Ethics program highly visible every day. In addition, CH2M HILL has declared May as Ethics Month, and we take the opportunity through increased communication to heighten awareness among our employees about our expectations relating to how business is done at CH2M HILL, such as through this video to employees. As CEO Lee McIntire has said, "How we do business is just as important as how much business we do."
Another important component of the ethics program at CH2M HILL is our Ethics Ambassador program, launched in December 2010. It provides employees with direct access to local senior leaders who understand how business is done in local geographies and are able to translate our expectations about doing business with integrity into the local commercial context. Our Ethics Ambassadors are respected by their local peers and are perceived as safe and reliable sources of information and guidance. Today we have over 175 of these critically important subject matter experts who serve in more than 90 locations throughout our vast international footprint. They are present in every major office and at every major project site and are an additional resource for ethics questions and guidance, offering a reliable way to connect our employees in the field to the home office, where ethics policies are set and preventive measures are enforced to ensure compliance. One of our Ethics Ambassadors, Tom Searle, cites his family history in Belize as the source for his ethical compass, and has presented corporate social responsibility perspectives at international forums.
“Ethics and integrity are essential to who we are as a company. These core values were established by our company founders in 1946 and have been continuously championed by every generation of leaders since. Common sense tenets, like ‘Integrity is the all-important prerequisite to employment; the person must be honest with himself and others or we have no foundation on which to build,’ are woven into the fabric of our culture and guide the actions of our employees. At CH2M HILL, being ethical is not about checking the box or filling out a form, it is who we are and how we do business.”
— Margaret McLean, Senior Vice President, Chief Legal & Ethics OfficerRead more
CH2M HILL has operations in more than 50 countries on 5 continents, where we support private and public customers and do work for U.S. and other national and local governments. Since we do business in some of the most difficult places on the planet (as rated by Transparency International), our anti-corruption program is a cornerstone of our Employee Ethics & Business Conduct Principles and we train our employees and educate our supply chain on how to avoid corruption pitfalls that are common in many places around the globe. Wherever our work takes us, we follow our company’s core values for ethics and integrity. As a matter of principle, we neither seek nor are interested in attracting business through corrupt means. CH2M HILL conducts rigorous legal, ethical, and risk-based assessments as part of our standard procurement selection process. Our procurement procedures and policies on gifts, entertainment, and hiring political consultants govern how we engage with anyone who potentially could provide access or influence in helping us secure work. Before a political consultant is hired, we require thorough due diligence and senior executive review.
As part of our risk management process, we engage with each of our business units to keep them aware of the risks of corruption in jurisdictions where they work. This process includes training and providing easy access to tools and advice. For those business units with extensive project commitments in countries known for high corruption risk, we perform specialized training and periodic audits. We routinely engage with our business units in open and frank communication about the risk of corruption, how to recognize red flags that might be evidence of possible corrupt business activities, and what to do when employees become aware of corruption risk. CH2M HILL’s anti-corruption policies are reviewed and updated periodically to reflect the latest developments in laws and best practices on the subject. This is particularly important in countries that rank high on the Transparency International Corruption Perceptions Index.
We provide training on issues raised in the US Foreign Corrupt Practices Act, United Kingdom’s Bribery Act, and other similar anti-corruption mandates from jurisdictions where we do business. Additional anti-corruption training is provided as part of our project-specific risk management and mitigation planning. All senior employees also receive training focused specifically on corruption, conflicts of interest, and ethics and compliance in general.
When a corruption-related allegation is reported through our hotline or other tools, it is investigated by a multi-disciplinary team that includes representatives of legal, internal controls, and when necessary, forensic accounting staff. The investigation team obtains the relevant facts through document review, in-person interviews, and review of available computer data and arrives at an independent unbiased conclusion regarding the veracity of the complaint. Disciplinary and re-training actions are taken quickly by management, if necessary, based on the recommendations made by this specialist team.
Public policy creates business opportunities and challenges that affect CH2M HILL and our customers. Our Government Affairs team promotes the business and professional interests of CH2M HILL and its employees and customers at national (including U.S. federal), state, provincial, and local levels. The team focuses on our business interests, important issues to the engineering and construction industry, and issues that affect the general quality of our communities. These government affairs professionals are responsible for managing firm-wide legislative initiatives, educating our employees about our ethics and compliance programs associated with political advocacy, supporting business development, managing the company’s political action committees, and working with leading professional societies and relevant nongovernmental organizations.
CH2M HILL is actively engaged in staff-level briefings and consultations in the U.S. Congress, executive branch agencies, and state and local governments that address the realities of resource limitations and sustainable solutions to our communities’ needs. Our Government Affairs team actively tracks key legislation and regulatory efforts in the areas of water, wastewater, and water resources. Our staff also serves in leadership positions in professional organizations that take positions on these issues, as described in the Public Water Policy section.
The Government Affairs team, in coordination with the Legal Department, carefully evaluates all political consultants with whom the company partners. We are cautious and conservative when selecting individuals to perform a lobbying or business development role on our behalf. We will do business only with those who share our zero tolerance policy for corruption.
To promote ethics principles as our business imperative and to provide industry leadership on this important issue, CH2M HILL became a founding signatory of the World Economic Forum’s Partnership Against Corruption Initiative (PACI), a member of the UN Global Compact Working Group on the 10th Principle, and a member of the Construction Industry Ethics and Compliance Initiative. Recently, re-enforced our commitment to doing business with integrity by joining more than 480 other leading multi-national companies that are evaluated, ranked and assessed by Swiss-based Covalence, an independent ethics and reputation analyst.
As a testament to these proactive measures and the quality and ethical commitment of our dedicated employees, Ethisphere® Institute has named CH2M HILL one of the World’s Most Ethical Companies for the fourth consecutive year.