UN Global Compact Communication on Progress (COP)
January 2017 – December 2017

January 17, 2018

To our stakeholders:

I am pleased to confirm that Swinerton reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labor, Environment, and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture, and daily operations. We also commit to sharing this information with our stakeholders and finding ways to work together to further the UN’s mission to advance societal goals.

Sincerely,

Jeffrey C. Hoopes
Chief Executive Officer

Swinerton supports the principles in the UN Universal Declaration of Human Rights. We agree to a workplace that is free of abuse, bullying, harassment, and discrimination. Swinerton expects our Partners to uphold these same values.

Additionally, Swinerton’s Affirmative Action Program is designed to strengthen and reaffirm its commitment to implement Fair Employment Practices. The Company’s policy is clear with respect to Equal Employment Opportunity for minorities, females, veterans of the Vietnam era, qualified disabled persons, and disabled veterans.

Swinerton has a commitment to provide equal hiring, training, compensation, promotion, transfer, layoff, and recall benefits to all individuals, including qualified veterans and veterans of the Vietnam era, without regard to ancestry, marital status, race, religion, color, national origin, sex, sexual orientation, gender identity, age, or disability or medical condition, except where age and sex are essential bonafide occupational requirements or where handicap or medical condition is a bonafide occupational disqualification.

Swinerton maintains an anti-harassment policy which states that harassment in the workplace, including conduct that demeans another person, will not be condoned. Managers who know of harassment in the workplace, or have received a complaint of harassment in the workplace, have a legal and moral responsibility to report such harassment to Swinerton’s Human Resources Department.

Swinerton does not have an established diversity goal at this time. In 2018, the Company will provide current numbers to establish a benchmark for future years and will report these numbers annually.

Swinerton agrees to a workplace where employment is voluntary and only offered to persons over the age of 16; working hours are not deemed excessive by definition of the law; employees are compensated in a timely manner; and, to the extent permitted by law, respecting employees’ right to freedom of association and collective bargaining.

In accordance with the U.S. Fair Labor Standards Act, Swinerton abides by the federal minimum wage requirement, overtime pay requirement, and child labor regulations. Additionally, Swinerton abides by local and state minimum wage and prevailing wage requirements in all geographies where it does business. These pay requirements are posted in all offices and project locations.

Swinerton’s Safety Department maintains policies and procedures, and provides training to employees, to ensure a safe workplace. Swinerton recognizes there are great hazards in the construction industry and one decision could be the difference between life and death. The Company’s unwavering project performance standards enable it to send everyone home, every day, uninjured. Employees are provided training in, but not limited to: OSHA 10, CPR/First Aid, forklift, crane, rigging, fall protection, and demolition. It is engrained in Swinerton’s culture that all employees and Partners have the authority to stop work when a potential safety hazard is identified.

Swinerton strives for zero lost time and zero recordable incidents. The Company's safety performance is reviewed by executives monthly.

Swinerton protects human health and the environment by meeting applicable regulatory requirements pertaining to air emissions, waste, and water. The Company encourages its Partners to favor the use of non-hazardous products and materials, and choose recycled and reclaimed materials whenever possible.

Swinerton has an established Environmental Policy and Green Office Guide; however, the policies have not been enforced in recent years. It is Swinerton’s intention to review and revise the policies in 2018, as necessary, to ensure the Company adheres to the established policies not only for project sites, but the entirety of its operations.

Swinerton does not have an established waste diversion, emission, or water usage goal at this time. In 2018, the Company will provide current numbers to establish a benchmark for future years and will report these numbers on an annual basis.

Swinerton expects all of its Partners to act in accordance with the highest standards of business ethics and to avoid any appearance of impropriety, including, but not limited to: fraud, deception, and dishonesty; bribery and corruption; and false claims.

In 2018, Swinerton will require all of its business partners to sign a Contractor’s Code of Conduct. The Code of Conduct binds our subcontractors, suppliers, and vendors (collectively “Partners”), and their supply chain, to minimum standards, which are based on the Ten Principles of the UN Global Compact and the UN Sustainable Development Goals (SDGs).

Swinerton employees and Partners have free, unlimited access to our third-party anonymous and confidential incident reporting system. Swinerton encourages those who know of any activity that is in violation of laws, regulations, or contracts to report such activity promptly through this service, which is available 24 hours a day, 7 days a week.

Swinerton maintains records of instances that may be deemed unethical. A formal Ethics & Corporate Responsibility Committee reviews such cases and takes necessary corrective steps including investigations, the provision of additional training to employees and Partners, and disciplinary action.