A. EQUAL EMPLOYMENT
Black & Veatch Corporation values diversity and believes in freedom of opportunity for every individual to work at a job for which s/he is qualified. Accordingly, the Company has adopted a policy of equal employment opportunity, with the goal that all individuals will be treated with respect and dignity.

B. AFFIRMATIVE ACTION
Black & Veatch develops annual written Affirmative Action Plans for women and minorities, the disabled, disabled veterans, and veterans of the Vietnam era. These plans comply with Federal requirements for government contractors, and serve to help carry out the Company’s equal opportunity policies. These plans are available for review from the Human Resources Department.

C. POLICY AGAINST DISCRIMINATION
Applicants for employment and all employees throughout their careers with the Company will not be subject to discrimination with respect to terms and conditions of employment. Employment actions (including recruitment, hiring, training, development, compensation, transfer, promotion, discipline, and discharge) will be determined without regard to race, color, religion, national origin, age, sex, disability, pregnancy status, or other status protected by law. Similarly, these considerations will be applied in the employment of disabled veterans and Vietnam era veterans.

D. POLICY AGAINST HARASSMENT
Freedom from discrimination includes freedom from any form of discriminatory harassment due to a person’s race color, religion, sex, marital status, age, national origin, disability, veteran status, or other status protected by law. This conduct is prohibited whether committed by managerial or non-managerial employees, contractors, vendors or customers. It is also prohibited whether it is directed against someone of the same or opposite gender.

Examples of prohibited conduct include:
• Verbal conduct (for example, racial or sexual epithets, foul language, unwanted sexual flirtations, commentaries about a person’s body, ethnic jokes, derogatory statements or slurs).
• Physical conduct (for example, improper touching or assault).
• Visual harassment (for example, racially or sexually explicit or derogatory posters, cartoons, drawings, electronic transmissions, or obscene gestures).

In addition, offering or implying to offer employment benefits in exchange for sexual favors is prohibited. Threats or reprisals for a refusal to respond to sexual advances also are prohibited. No manager shall threaten or insinuate, either explicitly or implicitly, that an employee’s submission to or rejection of sexual advances will in any way influence any personnel decision involving that employee.

As stated in the EEOC’s guidelines, unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature constitute sexual harassment when:
1. submission to such conduct is made explicitly or implicitly a term or condition of an individual’s employment, or
2. submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or
3. such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.
Even if such actions do not rise to the level of legally actionable conduct, they nonetheless are unacceptable in the workplace.

E. COMPLAINT PROCEDURES
If employees have a good faith belief that they have been the victim of harassment, discrimination or any other violation of this policy, they are strongly encouraged to report this conduct to management. They may, as they believe appropriate under the circumstances, report incidents directly to any one of the following: their manager, their manager’s manager, a Human Resources Director, the Director of Employee Relations, or the site EEO Coordinator. Any supervisor or manager who becomes aware of any complaint of harassment is required to contact a Human Resources Director immediately. All reports of inappropriate conduct will be promptly and thoroughly investigated, handled with discretion, and dealt with appropriately. The Company will act to ensure that any improper conduct ceases immediately and correct action is taken to prevent a recurrence. The complaining employee will be informed of the resolution of the complaint as appropriate. All complaints will be treated confidentially to the extent practicable for an effective resolution.

F. CONSEQUENCES
Any employee who violates this policy is subject to the full range of corrective action, up to and including termination of employment. Such violations could also lead to personal legal and financial liability. An individual who knowingly alleges a false claim against another will be subject to the full range of corrective action, up to and including termination of employment. Any manager or supervisor who fails to respond to objectionable conduct will be subject to the full range of corrective action, up to and including termination of employment.

G. POLICY AGAINST RETALIATION
The Company prohibits retaliation against anyone for reporting discrimination/harassment, assisting in making a discrimination/ harassment complaint or cooperating in a discrimination/harassment investigation. Retaliation can include any disparaging comments, uncivil behavior, or any other negative treatment of an employee by other employees or members of management that result from the individual’s making a harassment complaint or cooperating in a harassment investigation. If an employee believes he or she has experienced or witnessed retaliation, they should immediately notify any one of the following: their manager, their manager’s manager, a Human Resources Director, or the Director of Employee Relations.

H. MANAGEMENT RESPONSIBILITIES
It is the responsibility of management (1) to bring this policy to the attention of all employees; (2) to ensure that no part of this policy is violated; and (3) to bring to the attention of a Human Resources Director or the Director of Employee Relations any violation of the policy of which they become aware.

I. SCOPE
This policy is founded in United States law, and applies to all employees working in the United States as well as all United States expatriates.


Len C. Rodman, Chairman, President, and CEO