PILLAR 5: INTERNAL CONTROLS

Having systems at every level of our operations to help recognize and prevent unethical behavior reminds us all—our employees, our clients, and our partners—that our culture of integrity is integrated into our business. These systems include proprietary project management software to track expenditures; a robust third-party due diligence and prequalification process; an anonymous, independent helpline; and a fully integrated compliance audit.

Third party due diligence. STOBG implements a multi-tiered and risk-based approach to prequalification and due diligence, which increases the company’s visibility into our business partners and reduces regulatory and reputational risk. STOBG partners with multiple third-party vendors to maximize data assessment. Based on their overall risk, subcontractors are continuously monitored through Exiger’s 3PM platform, which refreshes nightly and alerts in-house regulatory counsel to any potentially adverse information in real-time.

PILLAR 6: MONITORING & RISK ASSESSMENT

Our Compliance & Ethics program implements and assesses compliance with systems controls that are tailored specifically to the construction industry. These controls are regularly evaluated and tested to ensure they are calibrated to address specific risks we face, including through internal compliance audits, collaboration with our external ethics and compliance counsel and other subject matter experts, and benchmarking of our program through Ethisphere, a global leader in defining and advancing the standards of ethical business practices.

We also implement a regular enterprise risk assessment —a critical component to gauging corporate risk from macro, industry-wide issues down to specific business unit operational matters. The process includes approximately 200 indepth interviews with leaders across the organization and the creation of a heat map of potential risks found in the construction industry.

ETHISPHERE’S COMPLIANCE PROGRAM BENCHMARKING PROCESS

STOBG is a proud member of Ethisphere’s Business Ethics Leadership Alliance (BELA), a 300+ member strong, globally recognized organization of leading companies collaborating to share best practices in governance, risk management, compliance, and ethics. As a member, we benchmark key elements of our compliance program, including governance, third parties, and other risk topics, and monitor their maturity.

As builders, our role in shaping the environment is critical. That’s why we are looking to the United Nations’ Sustainable Development Goals as a guide and benchmark for our social and environmental efforts. The following pages indicate how the programs and actions described in this report support these goals.