MODERN SLAVERY ACT STATEMENT INFRASTRUCTURE MINING & METALS Financial Year NUCLEAR, SECURITY & ENVIRONMENTAL OIL, GAS & CHEMICALS 1 January 2020 - 31 December 2020

Level 4 - Bechtel Public i Modern Slavery Contents Cross Referenced to MSA Reporting Criteria. . .. 1 Act Statement The Reporting Companies...... 2 Our Business ...... 3 Due Diligence, Risk Assessment & Management. . . . . 3 1 . Our Commitment...... 4 a . Policies Against Human Trafficking and Slavery. . . . 4 b . Ethics & Compliance...... 5 c . Training & Awareness ...... 5 d . Upfront Risk Assessment & Mitigation Planning . . . 6 2 . Foreign Migrant Workers...... 6 3 . Supply Chain...... 7 a . Setting Clear Expectations...... 7 b . Identifying, Selecting and Contracting with Suppliers...... 8 c . Assessing Effectiveness by Managing & Monitoring Supplier Relationships & Performance ...... 8 4 . Assessing Effectiveness by Audit and/or Adoption of Compliance Plans...... 9 a . Corporate Internal Audit...... 9 b . Project Self-Assessments and Audits of Suppliers. . . 10 c . Project Compliance or Management Plans...... 10 A Project Case Study ...... 11 Industry Engagement...... 11 Process of Consultation...... 12

ii Modern Slavery Act Level 4 - Bechtel Public Contents Cross Referenced The Reporting Companies The Bechtel group of companies or Bechtel refers to Bechtel Group, Inc. and its direct and indirect to MSA Reporting Criteria subsidiaries collectively. Bechtel’s principles, policies, management instructions and functional procedures apply across the Bechtel group of companies and its organizations, including the following reporting UK Modern Slavery Act Australia Modern Slavery Sections addressing commercial organisation and reporting entities.

2015, Section 54(5)’s Act 2018, Section 16(1)’s criteria 1 recommended reporting mandatory reporting UK Modern Slavery Act 2015 Reporting “Commercial Organisation” criteria criteria This statement is made on behalf of Bechtel Limited (“BLTD”), a member of the Bechtel group of ƒ the organisation’s structure, ƒ identify the reporting ƒ The Reporting Companies companies, pursuant to the reporting requirements of Clause 54, Part 6 of the UK Modern Slavery Act 2015, its businesses and its supply entity and constitutes its Modern Slavery Act statement for the financial year 1 January 2020 – 31 December 2020. chains ƒ Our Business ƒ describe the structure, BLTD is a private company limited by shares, registered in England & Wales (company number 506133) with operations and supply ƒ Process of Consultation its registered office at 2 Lakeside Drive, Park Royal, London NW10 7FQ, England. BLTD’s board of directors chains of the reporting approved this statement on 7 June 2021. entity 2 ƒ describe the process of Australian Modern Slavery Act 2018 “Reporting Entities” consultation with (i) any entities that the reporting This statement is also made on behalf of Bechtel Australia Proprietary Limited (“BAPL”) and Bechtel entity owns or controls (Western Australia) Pty Ltd (“BWAPL”), both members of the Bechtel group of companies, pursuant to and, (ii) for joint modern the reporting requirements of Part 2 of the Australia Modern Slavery Act 2018, and constitutes their Modern slavery statements, the Slavery Act statement for the financial year 1 January 2020 – 31 December 2020. BAPL is a proprietary entity giving the statement company, registered in Australia (company number ACN 006 334 505) with its registered office at Level 3, ƒ its policies in relation ƒ Our Commitment 540 Wickham Street, Brisbane, QLD, 4006, Australia. BAPL’s board of directors approved this statement on 28 to slavery and human (and subsections) April 2021. BWAPL is a proprietary company, registered in Australia (company number ACN 147 531 226) with trafficking its registered office at Level 25, 140 St. Georges Terrace, Perth, WA 6000, Australia. BWAPL’s board of directors approved this statement on 16 June 2021. ƒ its due diligence processes ƒ describe the risks of ƒ Due Diligence, in relation to slavery and modern slavery practices Risk Assessment & human trafficking in its in the operations and Management (and This statement reports on the risks of modern slavery in Bechtel’s operations and supply chains and the businesses and supply supply chains of the subsections) actions it has taken in the last financial year (1 January 2020 – 31 December 2020) to address those risks. chains reporting entity, and any entities that the reporting ƒ A Project Case Study ƒ the parts of its business and entity owns or controls supply chains where there is a risk of slavery and human ƒ describe the actions taken trafficking taking place, and by the reporting entity the steps it has taken to and any entity that the assess and manage that risk reporting entity owns or controls, to assess and address those risks, including due diligence and remediation processes ƒ its effectiveness in ensuring ƒ describe how the ƒ Foreign Migrant Workers that slavery and human reporting entity assesses trafficking is not taking the effectiveness of such ƒ Assessing Effectiveness place in its business or actions by Audit and/or Adoption supply chains, measured of Compliance Plans (and against such performance subsections) indicators as it considers ƒ A Project Case Study appropriate 1Clause 54(1)-(3), Part 6 of the UK Modern Slavery Act 2015 defining a “commercial organisation” required to ƒ the training about slavery ƒ Training & Awareness prepare a Modern Slavery Act statement. and human trafficking ƒ A Project Case Study available to its staff 2Section 5, Part 1 of the Australia Modern Slavery Act 2015 defining a “reporting entity” required to prepare a ƒ Include any other ƒ Industry Engagement Modern Slavery Act statement. information that the reporting entity, or the entity giving the statement, considers relevant

Modern Slavery Act Level 4 - Bechtel Public Level 4 - Bechtel Public Modern Slavery Act 22 1 3 Modern Slavery Act Our Commitment is low. andprocesses.policies Thus,theoverall riskofmodernslavery inBechtel’s permanentoffices professional employees applyingBechtel’s robust setofcorporate andhumanresources Slavery Index—for example, Bechtel’s employ officeinNew offices Delhi,India—these skilled office islocatedwhere inacountry riskofmodern slavery ismoderate according to theGlobal modern slavery riskislower according to theGlobalSlavery Index. Even where apermanent Australia; Santiago, Chile—with strong worker welfare andemployment laws andwhere areoffices located primarilyincountries—e.g., London, UK; Reston &Houston, USA; Brisbane, temporary projects them.For andtheglobalsupplychainserving instance, ourpermanent for modernslavery ofour andhumantraffickingbutincertain notinourpermanentoffices lies andsitesareoffices geographically dispersed and,insomecases, remote. Muchoftherisk day work neededto manage, andbuildourcustomers’ design complex projects. Ourproject orsites.The offices temporary project andsites offices provide theon-the-ground day-to- core support offices functionsandprovide business centralized to ourproject services support Bechtel and hasbothpermanentoffices temporary project orsites. The permanent offices & Management Due Diligence, RiskAssessment partners,contractors,business andsuppliers to dothesame. everywhere we operate andtreating peoplewithdignityandrespect, andwe expect our with Bechtel’s Vision, Values &Covenants, we are committed to respecting humanrights They are whatwe believe, whatcustomers canexpect, andhow we deliver. Consistent and sustainability, andourcovenants –integrity, respect, collaboration, trust,anddelivery. Core to Bechtel are ourvalues –ethics,safety, quality, people, culture, relationships, innovation GBUs during2020. during 2020. BAPL andBWAPL operated across theOil,Gas&Chemicals,andMiningMetals BLTD operated across theInfrastructure, GBUs Oil,Gas&Chemicals,andMiningMetals ƒ ƒ ƒ ƒ We operate through four units(“GBUs”): globalbusiness the world asafer, place. cleaner infrastructure, increase responsible to access energy, resources andmake services, andvital them, we are helpingto create jobs,grow improve economies, theresiliency oftheworld’s all seven continents.Ourcustomers’ projects are aninvestment inthefuture. Together with we have helpedcustomers complete more than 25,000 projects across 160 on countries Bechtel isaglobalengineering,construction,andproject managementcompany. Since1898, Our Business

East. and ithasprojects andSouthAmerica,Australia, inNorth andstudies Europe andtheMiddle are Itsmainoffices Mining &Metals. inSantiago, ChileandBrisbane, Queensland, Australia the globe. Oil, Gas&Chemicals.ItsmainofficeisinHouston, Texas, USA andithasprojects across Ridge, Tennessee, USA andithasprojects intheUnited andtheUnited States Kingdom. Nuclear, Security&Environmental. are Itsmainoffices in Reston, Virginia, USA andOak the United Kingdom,Europe, theMiddleEast andAustralia. Infrastructure. Itsheadquarters are inLondon, Englandandithasprojects America, inNorth Level 4-Bechtel Public Level 4-Bechtel Public or slavery. practice thatconstitutes humantrafficking and processes to avoid complicityinany systemsHuman Rights;andmaintaining onBusiness and Nations GuidingPrinciples with thespiritandintent oftheUnited everywhere we operate inaccordance labor;compulsory respecting humanrights trafficking, slavery, servitude, and forced or a work environment free from human reflect ourcommitmentto maintaining and Slavery andSustainability Policies and BWAPL. Bechtel’s HumanTrafficking includingBLTD,of companies, BAPL Bechtel’s applyacross policies itsgroup 1. OurCommitment wereconditions assessments conductedsupplier’s ateach facility in2019. then reviewed withthesuppliers andcorrective actionplanswere undertaken in2019. Follow-on workplace weighted composite score andareport Thereports identifiedduringtheassessments. oftheissues were and Indiathatwere riskacross identifiedasbeingthehighest oursupplychain.Each supplierreceived a engaged athird-party provider to conductworkplace ofsix(6)key conditionsassessments suppliers inChina electrical works, structural/steel works, andfreight. Following over thisassessment, 2018 and2019, Bechtel five China,India,Mexico, countries: SouthAfrica, andThailand,whoprovide for: goodsorservices civilworks, indicatedThe assessment ahigherriskofmodernslavery orhumantrafficking insuppliers from the following search available information sources (e.g., news, videos,blogs,forums, socialmedia)inmultiplelanguages. restricted movement, unethicalrecruitment, worker to documents,access grievance mechanisms,etc.) to associated withagreaterof activities riskofmodernslavery andhumantrafficking (e.g., underage workers, country, andsector. goodsandservices, Theframework alsoused key terms related to ninered flagsigns Index, ofState, theUSDepartment andtheInternational Labor Organization, suchrisks to identify related to sources thatprovided information onmodernslavery andhuman trafficking suchastheGlobalSlavery risk, ourglobalsuppliersassessing andsubcontractors againstariskframework. Theframework usedexternal Bechtel conducted amodernslavery andhumantrafficking riskanalysisofitsprocurement supplychain by from andissued50,000 65countries transactions withtotalcommitmentsexceeding $6 billion.In2018 and contracts group worked withapproximately 6,000 suppliers ofequipment,materials, andservices With respect to thesupplychain,across Bechtel’s four GBUs duringfinancialyear 2020,Bechtel ’s procurement because ofthecomplexity andscaleofthesupplychains. neededto constructlarge thematerialsobtaining andservices and/or complex projects are higherrisk slavery thanprojects usinglocalconstructionlabour. Finally, projects withlarge procurement involving scopes those projects. Projects usingforeign migrant labourfor theconstructionscopehave ahigherriskofmodern Bechtel visibilityinto hasless customer procurement supplychainsortheconstructionlabourforce usedin however,services, may involve helpingourcustomers managetheirprocurement orconstructionprojects and (“FEED”),engineering anddesign studyorproject/programme PMC managementconsulting(“PMC”)services. haveconstruction scopeofservice ahigherriskofmodernslavery thanproject involving services front end withahigherprevalencein countries orvulnerability to modernslavery are Projects higherrisk. thatinvolve a scope, andwhethertheconstructionscopewillinvolve foreign migrant labor. For example, projects located are ofexecution, thecountry provided whethertheservices includeadirect procurement orconstruction and buildourcustomers’ projects. Factors affecting theriskofmodernslavery inourproject operations and subcontractors across theglobeto deliver neededto theequipment,materials,engineer andservices of authority, control andinfluence, may employ foreign migrant workers, andrely onthousandsofsuppliers On theotherhand,ourprojects may have complex arrangements partnering thatpermitBechtel different levels a. Policies Against HumanTrafficking andSlavery Modern Slavery Act Our Commitment 4 4 5 Modern Slavery Act Foreign Migrant Workers in Supply Chains initiative. Slavery” course, aswell asavideoproduced by theStronger Together Tackling ModernSlavery the United Nations’ website, Bechtelouronline“HumanTrafficking policies, andModern Day an internal news entitled“July article 30 istheUNWorld Day Against Trafficking” andlinked to In addition,to raise general awareness oftheissueinInfrastructure, communicationsreleased that theteamunderstood therisks andpotential indicators ofhumantrafficking andslavery. of BLTD’s projects located inthe United Kingdomconducted five training to sessions ensure continue to applyto theproject teamsthroughout theirsecondmentto thecustomer. Another how Bechtel’s own againsthumantrafficking Codeof Conductandpolicies and slavery would United Kingdom,whichincludedcontent onthecustomer’s ModernSlavery Act and policies a commercial awareness training was conducted for oneofBLTD’s projects located inthe red flagsituationsto watch outfor, andreporting and mechanisms.More duties specifically, commitments andlegalrequirements surrounding humantrafficking andmodernslavery, commercial awareness trainings for several projects, reminders whichcontained oftheGBU’s rest are scheduledfor completion infinancialyear 2021. Inaddition,Infrastructure conducted Approximately 56% ofthosepersonnel completed thecourse infinancialyear 2020 andthe Trafficking andModern Day Slavery” course for completion over financial years 2020-2021. In 2020, ourInfrastructure GBU assignedallcontracts andprocurement the“Human staff higher riskontheirproject sites. available to project managementteamswhere humantrafficking and forced labormightbea andrisks localissues particular andshare practices onhow best to managethem, isalso broader populationofemployees. Aworkshop format, withtheflexibility designed to address the course into Spanishandcompleted translation 2021 inearly sothat itisnow available to a encounter thesignsofmodernslavery. In2020, we took theinitialsteps neededto translate of employees whodueto thenature oftheirwork,function,orlocationmay bemore likely to knowledge to potential real-world scenarios.Thecourse ismandatoryfor specificpopulations slavery andhow to manageit,andincorporates mini-testsrequiring theapplicationoftraining available to allBechtel employees. Itfocuses onhow thewarning to identify signsofmodern Our onlineandinstructor-led course entitled “HumanTrafficking andModernDay Slavery” is the Ethics &ComplianceOfficersofour four GBUs. trafficking, orchildlabour to Bechtel’s Ethics HelpLine. Similarly, there were nosuchreports to manner. Duringfinancialyear 2020, there were noreports concerningmodernslavery, human concerns, andwe are committed to addressing concerninaprompt each andresponsible anonymity. We donottolerate threats oractsofretaliation againstanyone for raising legitimate and1-800-316-704the UK, from Australia. Where allowed by law, theEthics HelpLineallows com, orby phoneat1-800-BECHTEL (1-800-232-4835) from theUSA, 0800-206-1009 from confidential resource ontheinternet atHelpLine.Bechtel.com, by emailatethics@bechtel. suspicions ofmodernslavery orhumantrafficking. We have an Ethics HelpLine available asa partners toaboutourCodeofConductand askquestions report any concerns,or issues, We encourage ouremployees, suppliers, subcontractors, andotherthird-party business subject to discipline, upto andincludingtermination. andCodeofConduct,violationthemis with ourpolicies the Ethics HelpLine. Ouremployees are responsible for complying supervisor, Ethics &Compliance Officer, the or Legal Department, issue orsuspicionofmodernslavery orhumantrafficking to their instructs employees to immediately report any concernsaboutany employees, ourcontractors, partners,orsuppliers. business It the useofeitherinperformance ofBechtel contracts by our or inany andthatBechtelnottolerate ofourbusiness does part form ofmodernslavery orhumantrafficking inoursupplychain makes thatwe clear are committed to ensuringthatthere isno Bechtel c. b. Training & Awareness Ethics & Compliance ’s CodeofConduct,whichispublishedinsixlanguages, OIL, GAS &CHEMICALS GAS OIL, ENVIRONMENTAL & SECURITY NUCLEAR, &METALS MINING I NFRASTRUCTURE Level 4-Bechtel Public Code of Conduct Ethics Bechtel Business

i Level 4-Bechtel Public the useofslavery, forced labor, childlabor, orhumantrafficking, and require thecontractor to represent it statethatBechtel nottolerate clearly does traffickingservices thatsupport activities inpersons, including On projects inwhich Bechtel controls therecruitment andemployment process, ourcontracts for recruitment ƒ ƒ ƒ ƒ ƒ ƒ ƒ ƒ ƒ ƒ providePrinciples that: workers, andcommunicatingourstandards to customers andotherexternal stakeholders. TheGuiding workers, engagingourjointventure partnerswhomay beresponsible for recruiting andmanagingmigrant Migrant Workers helps ensure aconsistent approach to ethicalrecruiting andmanagingofforeign migrant through relationships. these Bechtel’s on theRecruitment GuidingPrinciples andEmployment ofForeign partners andsubcontractors whoshare ourvalues andpromotes globalstandards conduct ofethicalbusiness responsibility over theprocess. But regardless ofwithwhomtheresponsibility Bechtel lies, seeks customers, project. Bechtel, ajointventure partner, orsubcontractors may have varying levels ofresponsibility orshared of foreign migrant workers. Therecruitment andemployment process ofcraft persons varies from project to skilled craft persons inmany thatsomeofourcustomers’ means countries projects require therecruitment The technicaloflarge challenges engineeringandconstructionprojects combinedwiththelackofsufficiently 2. Foreign Migrant Workers andproactiveearly riskmitigationplanningandactions. laws, safety, health, theenvironment development. andsustainable Thisupfront encourages riskassessment andtheproposedissues associate’s commitmentto Bechtel’s standards regarding ethics,compliancewith Specifically, jointassociationapproval requests mustaddress any character, reputation, ethicsorcompliance associations to ensure thattheproposed third-party associate hasethicalstandards compatiblewithourown. Similarly, Bechtel policy requires duediligencebefore substantial entering project specificormulti-project joint match ourown. performance for ofservices acustomer whosereputation orpartner for practicesnot business andethicsdoes being ofpeoplewhocanbeaffected by ourprojects, or risksreputational arisingfrom associationwithor risks, sustainability whichincludenotonlyenvironmentalidentifying risks butrisks to thesafety andwell- Bechtel policy requires anupfront before riskassessment commitmentto acustomer’s project. Thisincludes

d. able to return to orseekotheremployment theirhomecountry ofwork inthecountry without restrictions. Upon completionofwork, orunderspecialcircumstances percontract terms, migrant workers should be workers withoutfear ofretaliation ordismissal. Access to legitimate grievance mechanismsandresolution processes shouldbeprovided to migrant matters.disciplinary Migrant workers shouldnotbesubjected to any form ofintimidationorinhumantreatment, includingin and transportationbetween thework site andlivingquarters. Migrant workers shouldbeprovided withhumane, safe, andsecure working conditions,accommodations, Freedom to joinworker associationsandbargain collectively shouldbeavailable to migrant workers. Wages shouldbepaidregularly anddirectly to migrant workers percontract terms. identityandresidencyNational passports, freely document shouldbeaccessed by migrant workers. No recruitment orplacementfees shouldbecollected. work. migrant workers, andemployment should bewitharecognized andauthorized employer of inthecountry Contract terms andconditionsshouldbewritten andcommunicated inamannerthatisunderstood by Relevant andprocedures policies should treat migrant workers fairly andwithoutany form ofdiscrimination. Upfront &MitigationPlanning RiskAssessment Foreign Migrant Workers Modern Slavery Act 6 6 7 Modern Slavery Act Supply Chain equipment that contain conflictminerals.equipment that contain expected to conduct duediligenceto preclude ofany orinstallation thesales materials or and tin)from theDemocratic Republic Suppliers oftheCongooradjoining countries. are Protection Act, whichaimsto prohibit theuseofconflict minerals (gold,tungsten, tantalum, our suppliers to adhere to Section1502 oftheDodd-Frank Wall Street Reform andConsumer In addition,althoughBechtel isnotamanufacturer andisaprivately heldcompany, we expect ƒ ƒ ƒ ƒ ƒ ƒ ƒ subcontractors to: labor, orhumantrafficking, publicationsprovide these thatBechtel expects suppliers and thatBechtelnottoleratestating does theuseofslavery, servitude, forced orcompulsory and Bechtel Suppliers &Contractors Portal, ourSupplier Guide:Executing Work with Bechtel 2020 We humanrightsandanti-slavery setclear expectations for oursupplychainthrough our performance potential to issues. identify in awarded contracts, andconductingin-shopordesktopreviews ofsuppliers during incorporating terms andconditionsrelating to modern slavery andhumantrafficking expectationsclear withoursupplychain,conductingduediligencereviews ofsuppliers, We managemodernslavery andhumantrafficking risks inoursupplychain establishing by 3. Supply Chain Foreign Migrant Workers. practicesthe best reflected ontheRecruitment initsGuidingPrinciples andEmployment of Bechtel itsinfluenceandavailable uses leverage to helpsteer thecontrolling toward party On projects notcontrol inwhichBechtel does therecruitment andemployment process, required into itscandidate interviews. the candidate worker haspaidany suchfees andastatementthatnosuchfees are allowed or effectiveness ofsuchprohibition, to Bechtel incorporate isstarting aboutwhether aquestion accepting orrequesting any payment ofany kindfrom any potential worker. To the assess In addition,Bechtel’s contracts specificallyprohibit recruitment contractors services from relating to theagreement intheworker’s languageto ensure fullunderstandingbefore signing. the agreement to theworker intheworker’s language andanswer alltheworker’s questions toopportunity read theentire agreement. Whenneeded,therecruiter isalsorequired to read contract, recruitment contractors services are required to provide workers sufficienttimeand contracts usedinproviding therecruitment Regarding services. theworker’s employment slavery orhumantrafficking. They also require anidentical representation inany third-party will adhere to standards these andnotuseany form offorced, labor, bonded,compulsory

a. standards. suchpractices; andContractuallyidentify require theirsuppliers to conform to thesame Develop prohibiting policies slavery andhumantrafficking andtrain on theirstaff how to Provide workers aprocess for andreporting escalating concernswithoutretaliation; Not withholdaworker’s orimmigration passport documents; utilize fraudulent recruitment ormisleading practices; Not charge workers’ recruitment fees orutilize firmscharging workers suchfees, andto not transportation costsfor workers recruited from outsidethecountry; Comply withapplicablewage laws and,uponendofemployment, pay for return fails to respect thesafety anddignityoftheworker; aworkplaceMaintain free from threats of violence, physical abuse, orotherconductthat Employ workers above theapplicable minimumagerequirement; Setting Expectations Clear ’s for Expectations Suppliers’ andSubcontractors’ Conduct.Inadditionto Level 4-Bechtel Public , Level 4-Bechtel Public subcontractors targeted for review are sent asurvey andtheirresponses are scored. For responses deemed approaches to many areas of sustainability, includingmodern slavery andhumantrafficking. The suppliers and andconduct a desktopreviewcritical equipmentorservices ofaselectgroup ofthosesuppliers’ and policies Along withsupplierqualitysurveillance, weourkey annuallyidentify suppliers basedonspendandprovision of remote surveillance andsurveys where was access restricted. located inlieuoftravel incountry whenneeded,anddeveloping protocols andtestingtechnology allowing for and quarantine requirements. BSQE adapted by adjustingitsmode oftravel, relying onthird providers party BSQE surveillance assignment.In2020, COVID impacted BSQE’s usualwork practices dueto travel restrictions conduct aworkplace orinitiate aninvestigation conditionsassessment ifapositive flagisidentifiedduringa projectssupplier qualitydatabase. withBSQE, Inconsultation may chooseto engage athird provider party to representative andBSQEmanagementfor supervisor review andfollow-up, andallrecords are kept inour reporting ofgrievances orconcerns.Ifany are issues flaggedby theassessor, directly itgoes to theproject involuntary labor, orworker any abuseandto identify indicationsofworker restrictions thatmightprevent aSustainabilitySectionrequiringincludes andreport to theassessor identify any signsofunderage workers, with approved qualitysurveillance plans.Ourqualitysurveillance checklistandreport for oursuppliers’ facilities with purchase order requirements andspecifications,supplierqualitysurveillance isperformed inaccordance whichhelpssuppliersissues, deliver consistent value to thecustomer inatimelymanner. To verify compliance communication withandvisitsto suppliers’ facilities reinforcing ourproactive approach to resolving potential relationships andsupplierperformance. Bechtel Supplier Quality&Expediting’s (“BSQE”) functionis primary In additionto upfront vetting andcontract requirements, Bechtel andmonitors manages itssupplier and conditionsonthissubject. human trafficking andslavery. For instance, a BWAPL project inSouth Australia isusingitscustomer’s terms terms they andconditionsinothercases are ourcustomers’ standard terms andconditionsrelating to terms andconditionsinto theirpurchase orders andcontracts.are these Insomecases, Bechtel’s standard In financialyear 2020, projects GBU inourMining&Metals worked oncascadinghumantrafficking andslavery toand health ensure allworkers –bothBechtel’s anditssupplychain’s –adhere to ourzero-accident values. comply withBechtel’s rigorous safety Bechtel plan.Thisplanincludes ’s andhealth core processes for safety Our standard terms andconditionsalsoprovide that,attheproject site, allsuppliers andsubcontractors must terms andconditions. regulations, andwe have therightto terminate contracts withsuppliers andsubcontractors thatbreach our slavery. Oursuppliers andsubcontractors agree to complywithallapplicablelocalandnationallaws and Bechtel seeks to implementitsstandard terms andconditionsorequivalent terms onhumantrafficking or subcontractors initsown terms supplychain.These and conditionswere updated duringfinancialyear 2020. or slavery isusedanywhere inthesupplier’s orsubcontractor’s orby business any ofthesuppliers or Once vetted andselected, Bechtel’s standard contract terms andconditionsrequire thatnohumantrafficking and humantrafficking. due diligencereview thatinvolves screening for any ethicsandcompliancered flags,includingmodernslavery subcontractors before bid submittal. Before contractingundergo companies withthem,these anenhanced Depending onvarious commercial factors, Bechtel may engagejointventure partnersorexclusive modern slavery orhumantrafficking andconductadditional andmedia reputation screenings.report ofwork,andthenatureon locations,scopes andvalue oftheproducts thathave orservices ahigherriskof of priorwork withBechtel. Next, we applyarisk-based duediligencevetting process ofsuppliers focusing all suppliers againstourinternal warnings concernsraised whichidentifies andadvisories, intheperformance suppliers across 40 different withahumantrafficking companies history, identifying databases, and we review Suppliers managedby ourprocurement functiongothrough arestricted listreview parties thatvets the c. b. Identifying, SelectingandContractingIdentifying, withSuppliers Assessing Effectiveness Assessing by Managing &Monitoring Supplier Relationships &Performance Modern Slavery Act Supply Chain 8 8 9 Modern Slavery Act Effectiveness projects didnotfall withinInternal Audit’s work planfor 2020. execution, andprocurement ofwork.BLTD’s, andconstructionscopes BAPL’s andBWAPL’s of active projects. Theriskattributes thatoverlap withmodernslavery riskare of country projectsidentifies for inclusioninitsannual work planthrough ofriskattributes anassessment worked by project personnel are potentially atriskofviolatinglocallaborlaws. Internal Audit and subcontracts. Inaddition,for project payroll audits,Internal Audit monitors whetherhours terms andconditionsare incorporated inproject pro formas and insampledpurchase orders With respect to modernslavery, Bechtel’s Internal Audit functionverifies thathumantrafficking provided to management;and(iii)processes whichsafeguard thegroup ofcompanies’ assets. andprocedures;(i) compliancewithpolicies (ii)thereliability andintegrity ofinformation Bechtel’s Internal Audit functionprovides anindependent evaluation ofinternal controls over: are beingcompliedwith. throughout theBechtel group andthatcontract ofcompanies provisions relating to thesame procedures relating to humantrafficking andslavery are beingimplemented andcascaded Audit andcomplianceplansare tools inensuringthatcorporate important and policies and determined thatthere was none. procurement thesupplychainandpotential assessed exposure andsustainability to thisrisk Xinjiang Uyghur Autonomous Region ofthePeoples Republic ofChina.Inresponse, Bechtel ofpotentialBusiness forced alertedcompanies inthe labourandotherhumanrightsabuses In 2020, theUnited ofStateandUnited Department Councilfor States States International and how they mightbeimproved. a university to facilitate research ontheeffectiveness ofcurrent humantrafficking campaigns risk ofhumantrafficking inthetransportationandlogisticsindustry. BGL is alsoengagingwith providers to share information, andmethodsthey learned are lessons employing to reduce the in Transportation” event virtual inDecember2020, andencouraging BGL’s logisticsservice (ECMC), attending ofTransportation’s theUSDepartment “Combating HumanTrafficking panel discussiononthesubjectwithUSExporters Competitive MaritimeCouncil and across oftransportation(e.g., multiplemodes roads, ports, etc.) by sponsoringa BGL worked to raise awareness ofhumantrafficking withinthetransportationindustry risk ofmodernslavery andhumantrafficking inthissector. reviews suggestedthere was for additionaleducationalopportunities raising awareness ofthe addressing modernday slavery intheiroperations andsupplychains.Theoutcome ofthe in2020,trucking companies includingwhethertheyprocedures hadpolicies, orprograms effective delivery ofmaterials andequipment,conducted desktop reviews oftwelve ofits key addition, Bechtel GlobalLogistics (“BGL”), adisciplinefocusing onthesafe, timelyandcost- taken. Infinancialyear 2020, procurement conducted seven key supplierdesktopreviews. In are needed,we willbriefthesupplier, andconductafollow-on review ofcorrective actions third-party entityto conductareview ofthesupplier’s facility. Where we findcorrective actions without strong laborlaws oridentifiedmodernslavery we issues, have aprocess for engaginga areplace untilthedeficiencies rectified. Where we have higherrisksuppliers, e.g., countries beingissuedtoadvisory Bechtel’s procurement andcontracts personnel, whichremains in deficient, they are provided acure period.Failure to cure results deficiencies inasupplier 4. Effectiveness Assessing by Audit and/ a. orAdoption of CompliancePlans Corporate Internal Audit Level 4-Bechtel Public Level 4-Bechtel Public Section 54 oftheUKModernSlavery Act 2015, training, andworker rightsandwelfare. including butnotlimited to suchsubjectsasorganisational approach, recruitment, policies, applicabilityof with thesameprovisions. Inpreparation for audit,itdeveloped itssubconsultant anextensive auditchecklist contractual obligationsrelating to UKModernSlavery Act 2015andaudited for itssubconsultant compliance In 2020, oneofBLTD’s projects located intheUnited Kingdomconducted aself-assessment againstits “A Project Study.” Case compliance. Additional information regarding BWAPL’s ModernSlavery ManagementPlanisprovided below in furtherance ofitsModernSlavery Act ComplianceStrategy, theactionsto whichdetailed betaken to assess Similarly, BLTD’s UKproject thatconducted aself-assessment in2020 andauditofitssubconsultant didsoin Persons CompliancePlanthatwas flowed down from theprimecontractor. compliance. In2020, anew Nuclear, Security&Environmental project adopted aCombatting Trafficking in b. Project Self-Assessments andAudits ofSuppliers housing, asapotential methodfor ensuring reporting, monitoring, recruiting and addressing suchsubjectsasawareness, in person complianceplans, identifies in Persons.” Itspolicy to combattrafficking 52.222-50 regarding “Combating Trafficking Acquisition Regulation (FAR) ClauseFAR contracts thatmay incorporate theFederal work underUnited Government States Security &Environmental GBU performs and slavery. For instance, ourNuclear, provisions relating to humantrafficking effectiveness andcontract ofpolicies Compliance plansare atool for ensuring orManagementPlans c. Project Compliance Modern Slavery Act Effectiveness 10 10 11 Modern Slavery Act Consultation environment for allworkers intheengineeringandconstruction sector andother industries. We willcontinue to engagewithdiverse organizations to helpadvance asafer, healthier prevent modern slavery to andengagecompanies share theirexperiences practices. andbest strengthen governments’ responsibilities to develop andenforce legislationandregulation to The Committee promotes andpractices policies to international standard-setting to bodies Council for, anassociationof300U.S. InternationalBusiness multinationalcompanies. Bechtel alsoserves asvicechairoftheCorporate Responsibility CommitteeoftheU.S. actionstoandhelpfultheir challenges, meetsuchchallenges resources. andsafetyas health Thewebinar issues. provided to withtheopportunity share participants webinar to flagthepotentialthatcouldariseduringpandemicaswell humanrightsissues andstakeholderscompanies to use. InMarch 2020, Building Responsibly heldaCOVID-19 GuidanceNotes, whichwere andimplementation Principles publishedin2019 for all industry. We serve onitssteering committee andhelpedto develop itsten Worker Welfare workingcompanies together to raise thebarinpromoting thewelfare ofworkers across the the founding members ofBuildingResponsibly, agroup ofengineeringandconstruction standards to prevent forced laborandhumantrafficking. That’s why Bechtel was oneof andacrossand constructionindustry to industries promote practices best andelevate We ofengagingandcollaborating understand theimportance withthebroader engineering Engagement Industry projects inAustralia andelsewhere. construction projects andprovide atemplate for thedevelopment ofsuchplansonfuture This work canserve asamodelfor modernslavery andduediligenceonmajor riskassessment risk management,supplychainverification andtraining. Plan covers topics includingbutnotlimited tocompliance, policies, duediligenceprocesses, to befollowed to mitigate againstmodernslavery duringtheconstructionofproject. The prepared andissuedaModernSlavery ManagementPlanoutliningthesystems andprocesses theproject’sis usedto support supplierqualityauditprocess. In2020 theBWAPL project team modern slavery intheproject supplychain,whichidentifiedpotential higherrisksuppliers and in aproject located inWestern Australia. In2019 theBWAPL project theriskof team assessed BWAPL isworking withitsCustomer to ensure modernslavery andmitigated riskisassessed Early Project Development Planning,Western Australia A Project Study Case

includes themodern slaveryincludes awareness module. of theirworkforce training completing the orientation which 2021 asplanned,BWAPL’s project teamanticipatesthousands human trafficking orslavery. IftheProject moves forward in subcontractors to report any real orperceived concernsof by developing anonlineproject for portal employees and it hasrefreshed itsProject grievance managementsystem is mandatorypriorto provision ofsiteInaddition, access. slavery intheProject Thistraining supplychainandbusiness. module focusing ontheprevention ofhumantrafficking and the Project training orientation amodernslavery awareness slavery andcompliance. issues Andithasincorporated into Houston, andWestern Australia to raise awareness ofmodern Toolbox Talks to itsproject teammembers inNew Delhi, flow down requirements to itssupplychain.Ithaspresented project team hasimplemented modernslavery compliance In furtherance ofitsModernSlavery ManagementPlan, BWAPL’s

Level 4-Bechtel Public Level 4-Bechtel Public Ailie MacAdam, Director ______For andonbehalfofBechtel (Western Australia) Ltd Pty R. Leigh Clifford, Director ______For andonbehalfofBechtel Australia Proprietary Limited John M.Williams, Director ______For andonbehalfofBechtel Limited and BWAPL. members oftheBoards ofBLTD, andBWAPL BAPL, priorto review andapproval by theBoards ofBLTD, BAPL, Sustainability, theCorporate Legal oflegalfor theheads Department, oftheGBUs, each andwithselect was prepared withthiscross-GBU inconsultation andcross-functional group, theCorporate Managerof over, thekey regions inwhichBechtel operates, includingtheUnited KingdomandAustralia. ThisStatement This group representatives includes ofthefour GBUs andrepresentatives located in,orwithresponsibility delivery andprevent ofmaterials andservices, modernslavery, includingwithintheirown supplychains. Bechtel’s 2030 enterprise goalto engage100percent ofourkey suppliers to promote inthe sustainability ofrelevantimplementation processes, principles, policies, andlegislation.Inaddition,thegroup supports modern slavery across theBechtel group andtothedevelopment ofcompanies support ofgoalsandthe functional group was created to share andgoodpractices updates, ideas relating to humantrafficking and for applyingBechtel’s againsthumantrafficking policies andmodernslavery, across-GBU andcross- human resources andGlobalWorkforce ethics&compliance, are Services, sustainability) responsible Because employees, OfficersandGBU Managers andseveral functionalgroups (e.g., contracts &procurement, Process ofConsultation Modern Slavery Act Consultation 12 12 bechtel.com