To our stakeholders:

The immediate horizon for Swinerton looks solid and bright in a year that has been anything but predictable. This year has been groundbreaking and highly transformational as we responded to the COVID-19 pandemic. We swiftly evolved our health and safety protocols, communications and technology infrastructure, market focus, and how we work to keep our organization moving forward. Despite the challenges that 2020 put in our path, Swinerton was able to achieve major milestones across our lines of business.

However, in this moment, the United States is experiencing great tension between a diversity of viewpoints. The reality is that our nation may face some challenging days of unrest ahead. Part of our responsibility as builders is to work toward improving both the physical and psychological safety of our communities, including our offices and jobsites. Our goal is to ensure that our working environments remain safe and respectful places for all.

As we start a new year, Swinerton will continue to support the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labor, Environment, and Anti-Corruption. We remain committed to working together with our stakeholders to further the UN’s mission to advance societal goals and are encouraged by the dedication our employees, business partners, and communities have shown.

Swinerton prohibits discrimination against any applicant or employee based on any legally-recognized basis, including, but not limited to: race, color, religion, sex (including pregnancy, lactation, childbirth, or related medical conditions), sexual orientation, gender identity, age (40 and over), national origin or ancestry, physical or mental disability, genetic information (including testing and characteristics), veteran status, uniformed servicemember status, citizenship status, or any other status protected by federal, state, or local law. In conjunction with this Equal Employment Opportunity (EEO) policy, the Company has adopted an Affirmative Action Plan (AAP) to further promote diversity as a valued strategic initiative. The AAP and EEO policy are distributed and posted on an annual basis.

The Company is committed to providing a work environment that is free of harassment and bullying. As a result, the Company maintains a strict policy prohibiting sexual harassment and harassment against applicants and employees based on any legally-recognized status. The Company’s anti-harassment policy applies to all persons involved in its operations, regardless of position. It also protects employees from prohibited harassment by third parties. Any applicant or employee who believes that he or she has been subjected to prohibited harassment, discrimination, or retaliation, or who believes another individual has been subject to such conduct are encouraged to report it immediately. Employees are not required to make such complaints to their direct supervisor or follow any chain of command for this purpose. After a report is received, a thorough and objective investigation is undertaken. All employees in supervisory and non-supervisory roles are required to take a preventing harassment discrimination training course.

In order to educate employees and encourage a more culturally inclusive environment, an Equity & Inclusion Council (“Council”) was established, which reports directly to the Executive Committee. The Council’s mission is to set clear diversity, equity, and inclusion goals and strategic actions; recommend modifications to policies and practices; accomplish organizational objectives and remove barriers in recruiting, retaining, and developing the best talent; provide oversight, strategic guidance, and direction for Business Resource Groups and other internal efforts; ensure internal learning and teaching opportunities; act as change agents and disrupt the status quo; and hold the organization accountable.

Employees can submit their good faith questions or concerns about conduct they believe may violate Swinerton’s Code, policies, or the laws and regulations under which it does business to their supervisor or manager; any Company leader; Human Resources; the Ethics and Corporate Responsibility Committee; Legal/Compliance; or Swinerton’s anonymous and confidential Ethics hotline.

Healthy and Safe Workplace
Goal: Zero lost time and recordable incidents.

Frequency of reporting: Monthly.

2020 Progress (as of May 2020):

Swinerton General Building Industry Average
Recordable Rate 1.72 3.10
Lost Time Rate 0.36 1.20

This statistic measures the duration of restricted and loss time work days per 100 workers. The calculation is as follows:

(Number of Restricted and Loss Time Days) x 100 x 2,000 Man-Hours
Total Number of Man-Hours Performed

Swinerton’s overall Experience Modification Rating (EMR) as of December 2020 is 0.50 in California.

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.

Swinerton and its Partners are required to adhere to specific requirements to ensure a working environment free of recognized hazards, including: develop and maintain safety programs and procedures to meet or exceed federal, state, and local laws, regulations, and standards; ensure employees are properly trained and provided with the proper equipment to perform safe work; and encourage employees to stop any unsafe work, act, or condition.

Swinerton employs over 50 safety professionals throughout the United States and employees complete over 10,000 hours of health and safety training each year.

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 Legal Department and dedicated EEO Officer respond to all reports.

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.

In 2020, a Swinerton Sustainability Working Group was formed to identify opportunities to reduce the Company’s environmental footprint and provide a recommendation to the Executive Committee. A recommendation will be presented in March 2021.

Goal: Assess the Company’s current environmental footprint and establish environmental goals.

Frequency of reporting: To be determined.

2020 Progress: Established working group.

Swinerton conducts its business with absolute honesty and integrity. Every Swinerton employee must adhere to Swinerton’s Code of Business Ethics (the “Code”). In its Code, the Company outlines its standards of conduct pertaining to false claims and accuracy in records; gifts, gratuities, and kickbacks; and conflicts of interest. In 2020, the Swinerton Ethics & Social Responsibility Committee chose a leading consultant in business ethics to begin developing a new Code of Conduct. The new Code will help advance business integrity within the Company and is expected to be published in 2021.

Swinerton requires all its business partners to sign the Contractor’s Code of Conduct, which is included in its Master Service Agreement. 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 expects all 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.

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.