Introduction
At SOM, our commitment and approach to positively impacting our communities is essential to who we are. Through our policies, our practices, and our projects we work to design and engineer a better world. Our commitment to human rights is inspired by our people and our deep regard for the world in which we operate. We are committed to conducting our business with integrity and transparency, and to working with our consultants and business partners to share our commitment to human rights. We also aim to promote human rights within our industry and to contribute to the wider efforts to advance human rights.
We recognize that this is an ongoing journey and we are committed to continuously improving our practices and performance. We will regularly review and update our policies and practices to ensure that we are living up to our commitment to respect human rights.
Scope
SOM’s consideration of human rights begins with our own people. We pay our people fair wages and strive to offer a safe workplace free of harassment, discrimination, and inequity. We also recognize our role in safeguarding human rights beyond our own offices. We are committed to human rights, anti-discrimination, and international labor standards wherever we operate.
We communicate our human rights commitment to our clients, design partners, consultants, and community stakeholders. We require them, where possible, through contract terms and other means, to commit to the same purpose.
Principles
SOM’s human rights program requires compliance with fundamental human rights. These include both internal and external actions:
Employee Health & Safety
We are committed to safeguarding our people. Whether through employment practices, health & safety metrics such as office air quality and routine wellness checks, or a 24-hour a-day, seven-day-a-week hotline for anonymous reports, SOM takes seriously our role in the lives of our people.
Non-Discrimination, Diversity & Harassment
SOM is committed to fostering a workplace where everyone is treated with dignity and respect. SOM will not tolerate discrimination or harassment, whether based on sex or any other protected characteristic, in any form in the workplace. SOM offers equal employment opportunities for all applicants and equal consideration for employment, regardless of background and never based on any trait protected by law. These protected traits include age, ancestry, color, sex, HIV status, marital status, medical condition, national origin, physical or mental disability, race, religion, sexual orientation, gender identity, and veteran and citizenship status.
Anti-Child Labor
We adhere to individual human rights and follow employment laws in all the locations where we conduct business. Other than through apprenticeship programs or certain educational engagements, SOM does not employ individuals under eighteen years of age.
Forced & Compulsory Labor
SOM prohibits forced or compulsory labor, human trafficking, or any other form of modern slavery. Various internal policies elaborate on our adherence to international labor standards and the eradication of forced labor; they also establish our expectations of our employees and third parties, describe specific prohibited conduct, require that suspected violations be reported and investigated, and state that violations could result in discipline or contract termination.
Working Conditions, Working Hours & Wages
SOM provides reasonable working conditions and hours throughout our firm. Our employees’ wages and salaries meet or exceed minimum wage requirements everywhere we operate, and we comply with all other applicable laws related to working hours and compensation. Meal and rest periods are provided according to local legal requirements and office practices. SOM has also implemented an internal program that gives employees and managers more flexibility in determining working schedules to maximize employee well-being and improve our sustainability goals while still delivering the best solutions to our clients.
Anti-Corruption
Recognizing that many human rights abuses are tied to corruption, SOM views our anti-corruption efforts as critical to our human rights program. SOM’s policies address a variety of anti-corruption issues, including bribery and kickbacks, facilitation payments, gifts and entertainment, hiring concerns, collusion and bid rigging, fraud and misrepresentation, and coercion. They also identify SOM’s global requirements with respect to third-party due diligence and contracting.
Prevention
SOM’s commitment to human rights is incorporated into a variety of policies and processes that help us prevent, detect, investigate, and mitigate any potential violations of fundamental human rights. Prevention starts with the adoption of these policies and processes. These are then communicated to employees through annual safety, Code of Conduct, and other compliance training that are required for all employees.
Our employees are required to annually certify that they have complied with SOM’s Code of Conduct and related policies. Other training courses, ethics and safety moments, and electronic communications on topics including respect in the workplace, non-discrimination, anti-harassment, and modern slavery reinforce our employees’ obligations with respect to our human rights program. Employees who violate these policies are subject to disciplinary action, which may include termination of employment but may also include opportunities for personal coaching, additional training, or other remediation.
For third parties, we conduct appropriate due diligence to help ensure they share SOM’s values and commitment to protecting human rights.
Reporting & Resolution
To detect potential human rights issues, SOM conducts appropriate risk and program assessments on our Ethics and Compliance and Human Rights program to ensure they remain effective. We also provide employees and third parties with multiple avenues for reporting any type of concern and require reporting on misconduct, including potential violations of our human rights commitments. This includes reporting through SOM’s 24/7 Ethics Hotline, which is available to employees and permits anonymous reporting where allowed by law.
SOM has a strict non-retaliation policy to protect employees who make honest and sincere reports of misconduct.
Resolution of human rights concerns is accomplished through SOM’s investigations and remediation process. The relevant functional groups within SOM, including counsel, investigate all complaints that are reported through any reporting channel. If substantiated, necessary remedial measures and required discipline are undertaken at the conclusion of an investigation.