PILLAR 3: POLICIES & GUIDANCE

The keystone to our commitment to doing the right thing is our Code of Conduct & Business Ethics. The Code applies to all STOBG employees and to members of the board of directors, agents, representatives, and others when acting for or on behalf of STOBG. Through our Supplier Code of Conduct, our vendors, subcontractors, suppliers, and other business partners must uphold the same ethical standards.

PILLAR 4: TRAINING, COMMUNICATION, AWARENESS

Having policies is one thing—understanding them is another. By hosting regular, mandatory training for staff, we make sure everyone understands STOBG’s standards of conduct and the legal requirements relevant to their job functions, risk profiles, and geographical area.

Our Code and other compliance and ethics policies are available on our website in English and Spanish. Also, to help employees learn key concepts with ease, each policy is accompanied by a quick reference guide that distills the most critical policy information into a ready-to-use one page sheet.

CODE OF CONDUCT & BUSINESS

Ethics

EQUAL EMPLOYMENT OPPORTUNITY (EEO) & AFFIRMATIVE ACTION POLICY

NON-DISCRIMINATION & ANTI-HARASSMENT POLICY

ANTI-RETALIATION POLICY

As part of our Learning 360° approach, we offer individualized training curriculum that covers topics such as:

• abiding by our code of conduct

ANTI-SLAVERY & HUMAN TRAFFICKING POLICY

• preventing discrimination and harassment and fostering an inclusive workplace

GLOBAL ANTI-CORRUPTION MANUAL

• steering clear of corrupt practices and exercising caution in high-risk areas

• Management Foundations: training for first-line managers focused on how to be an ethical leader, create an inclusive environment, engage employees, handle employee relations issues, and manage performance.

SUPPLIER CODE OF CONDUCT

GIFTS & ENTERTAINMENT POLICY

• selecting and managing third parties

• following our construction management guidelines