1. Strong corporate leadership
Compliance can’t rely on policy alone. Our leaders need to be driving, assessing, and improving implementation at the highest levels. That commitment starts with the leadership and oversight of our board of directors, compliance department staff, compliance liaisons in offices throughout our organization, external counsel, and internal compliance auditors.
2. Employee engagement
A culture of integrity—one that transcends written policy to influence everyday action—begins and ends with employees who embrace our precept of doing the right thing. We measure success through the ethical actions of our employees and rely on them to speak up when something isn’t right. Employees can raise questions or report concerns through various methods, including our anonymous third-party helplineGo to https://structuretone.com/compliance/helpline/.
3. Policies and procedures
Actions certainly speak louder than words. But clear guidance in the form of written policies provides a documented foundation for educating our employees, partners, and clients on our philosophy, approach to compliance, and how we intend to do business. Our formal policies include our Code of Conduct and Business EthicsGo to https://structuretone.com/compliance/code-of-conduct/, Supplier Code of Conduct and EthicsGo to https://structuretone.com/compliance/supplier-code/, and our Global Anti-Corruption Policy.
4. Training, communications and awareness
Through regular, required training, we make sure our employees understand our standards of conduct and the legal requirements applicable to their job functions and geographic area. Employees receive a custom training curriculum that covers of range of topics from anti-corruption and appropriate gifts and entertainment, to accurate recordkeeping and overseeing third parties. Awareness campaigns and communications keep compliance topics top-of-mind and translate ethical principles into real world applications.
5. Internal controls
Having systems at every level of our operations to help recognize and prevent unethical behavior reminds us all that our culture of integrity is integrated into our business. These systems include project management software to track expenditures, third party due diligence, an anonymous, independent helplineGo to https://structuretone.com/compliance/helpline/, and a fully integrated compliance audit.
6. Monitoring and risk assessment
We actively monitor our compliance program to ensure that it is calibrated to address the specific risks faced by construction companies. Our internal compliance audit, a component of that monitoring, is designed and implemented with construction industry experts from our lead external audit partner, a nationally renowned accounting firm. 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.
Brian FieldsChief Ethics & Compliance Officer
Christopher BarbeeIndependent Board Member
Michael HourihanVice President
Compliance & Ethics
Monty AlexanderDirector of Internal Audit
Leah RamosRegulatory Compliance Counsel
Danielle SimoneRegulatory Compliance Counsel
Jason HermanCompliance Counsel