1. Strong corporate leadership
Compliance can’t rely on policy alone. The company’s 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 the 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 issues through various methods, including an 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 and approach to compliance and ethical behavior. Our formal policies include our Code of Conduct and Business EthicsGo to https://structuretone.com/compliance/code-of-conduct/, Supplier Code of ConductGo to https://structuretone.com/compliance/supplier-code/, Construction Management Guidelines, and Global Anti-Corruption Manual.
4. Training, communications and awareness
By hosting regular, mandatory training for staff, we make sure everyone understands STO Building Group’s standards of conduct and the legal requirements relevant to their job function and geographic area. Employees receive an individualized training curriculum that covers a range of topics from anti-corruption and appropriate gift and entertaining practices to accurate record-keeping and overseeing third parties.
5. Internal controls
We want to do the right thing. So 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 that tracks expenses, third-party due diligence, an anonymous, independent reporting hotlineGo to https://structuretone.com/compliance/helpline/, and a fully integrated compliance audit.
6. Monitoring and risk assessment
Our executive staff actively monitors the compliance program to ensure it is calibrated to address 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, itself a nationally renowned accounting firm. The compliance program also implements a regular enterprise risk assessment. Our risk assessment is 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