Responsible business practice

Establishing a strong ethical culture is vital in promoting integrity amongst employees, gaining trust from key stakeholders as well as protecting business operations, people and the environment from harm. Ethical behaviour demonstrates a commitment to considering the needs of others, fundamental to sustainable development and a fair transition to a low carbon world.

Over and above legal compliance, Wood has a responsibility to ensure we act ethically in all that we do to:

• Provide value to our customers and shareholders
• Invest and support our employees
• Trade ethically and fairly with our suppliers
• Support our communities and protect our shared environment.

Poor ethical decisions can result in reputational harm to our business, increased scrutiny from Wood’s stakeholders and negative financial or legal consequences.

Above all else, ensuring our business acts responsibly in all that we do is simply the right thing to do.

Supporting our Code of Conduct, we operate a suite of business mandatory global E&C policies and procedures, available in multiple languages, covering the following topics:

• Anti-Bribery and Anti-Corruption (ABAC)
• Commercial Intermediaries
• Competition Law
• Conflicts of Interest (COI)
• Data Protection, including Breach Response
• Ethics Investigations
• Ethics Reporting and Anti-Retaliation
• Gifts and Hospitality
• Sanctions, Export Controls and Anti-Boycotts

Compliance with the Code and supporting policies and procedures is mandatory for all directors, officers and employees as well as contractors, consultants, representatives, intermediaries and agents retained by Wood. Any reports of non-compliance are investigated, and appropriate action taken, up to and including termination of employment and or business relationships.

Ethics and Compliance requirements and controls are also embedded in policies and processes owned by other functions within Wood.

Wood contributes to economies and society, both directly and indirectly, through the taxes we contribute, the jobs we create and the part we play in delivering sustainable development and investment.  We commit to being transparent on tax issues and strategic in our efforts to comply with all relevant laws, rules, regulations and reporting and disclosure requirements, wherever we operate.  Our tax strategy aims to ensure we remain consistent with the Group’s overall strategy, its approach to risk, and the Group Core Values.

Our tax strategy is available on our policies and documents page

In 2021, Wood announced a series of sustainability targets.  Our goal to consistently rank in the Top Quartile ESG investment ratings within our sector group by 2025 can only be achieved by our commitment and efforts to advance ethical conduct and transparent disclosures.

Wood has a dedicated global Ethics & Compliance function (“E&C”) led by the Chief Ethics & Compliance Officer (“CECO”). The E&C programme is independent, and risk based. It is overseen by the Audit, Risk and Ethics Committee of the Board, with the CECO reporting into the General Counsel.  The CECO meets regularly with the CEO and the Audit, Risk and Ethics Committee to provide updates on the status of the programme. Implementation of the E&C programme is supported by our network of senior leaders (known as Ethics Responsible Officers) who meet as part of our Business Ethics Forum.

Ethics & Compliance maintains its own risk register, which directs the strategic priorities of the programme. The risk register is reviewed monthly and is supported by our E&C risk assessment activities and supporting policies listed in the key policies and commitments section, reflecting the group’s risk profile.

In addition, Wood operates a global data protection programme with the required local variations.

Delivering an ethical culture

Leaders across the organisation play a key role in delivering Wood’s Ethics & Compliance (E&C) programme by emphasising ethical behaviour to our workforce and supporting those speaking up. The E&C team partners with leaders to further embed ethics throughout the organisation. Alongside regular engagement with our network of ethics responsible officers, the formal Business Ethics Forum provides a mechanism for the E&C team to engage with operational and functional leadership throughout the organisation. During the meetings, E&C provide updates on the status of ongoing ethics and compliance projects; discuss the effectiveness of Wood’s ethics and compliance programme; identify matters of potential or actual ethics and compliance misconduct along with mitigation efforts with respect to unfavourable trends or ethics and compliance risks faced by Wood.

Tackling bribery and corruption

Our Code and Anti-Bribery and Corruption (ABAC) policy sets out our zero-tolerance approach to bribery and corruption, including our definition of bribery and corruption and a prohibition on facilitation payments. The ABAC policy is supplemented by our Conflict of Interest, Gifts & Hospitality and Commercial Intermediary policies and procedures.

Training and communication

Our training and communication efforts are a fundamental component of the E&C programme and help reinforce a strong ethical culture at Wood. Training and communications include:

• Bespoke risk-based training (including mandatory training) directed at either specific business units or certain categories of high-risk employees.
• Training and communications resources delivered at regular intervals and designed to promote cultural change. These includes Ethics Moments, Privacy Moments, Yammer posts, microlearning offerings and promotional infographics.
• Wider training or communications are designed to ensure maximum coverage of our E&C requirements. For example, a prospective employee must read and agree to comply with our Code and other E&C policies prior to receiving their offer of employment, and employees are asked to certify continued compliance with the Code annually. New employees in areas covered by the ongoing deployment of our Oracle People system, including key functional personnel, must complete online privacy training. All new employees receive the Data Protection Policy and a one page “Privacy at Wood” document which refers to our policies, worker privacy notices and other key data protection information.

Wood also operates a global network of data protection ambassadors who provide varying levels of data protection support to our global employee base.

Ethics hotline and case management

We encourage our employees, business partners and stakeholders alike to share ways to improve, as well as report (anonymously if preferred), things they believe are wrong through one of our Speak Up resources as published on our external and internal website.

We encourage employees to use their line manager as a first point of contact to report concerns, with additional “Speak Up” resources available, including another manager, People & Organisation, or Legal. As such, many matters are managed without E&C intervention. However, employees may also contact E&C directly or use our Ethics Helpline.

The Ethics Helpline is available 24 hours, 7 days a week, 365 days a year and allows anyone to raise a concern or ask a question confidentially and anonymously (should they wish to do so) in multiple languages. All concerns are reviewed by a member of the Wood Ethics & Compliance Team and are appropriately investigated to the extent possible in accordance with our procedures. Any person raising a concern, whether via the Helpline or otherwise, is protected by our Ethics Reporting and Anti-Retaliation Policy.

The IT Security helpline is also available 24 hours, 7 days a week, 365 days a year for the reporting of personal data breaches and notifies any breach reports to the Data Protection Team.

Learn more about our evolving approach to ethics in Wood’s Annual Report and Accounts.