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STO Building Group | Compliance & Ethics Policy
At STO Building Group, we’re guided by the principle Clients first. Integrity always. We provide best in class service to our clients while upholding the highest ethical standards, recognizing that how we build is just as important as what we build. We strive to provide our employees with the tools they need to perform their jobs with integrity and in accordance with our legal obligations, to work with likeminded clients and partners that share our values, and to preserve our good standing in the marketplace and the communities in which we build.
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COMPLIANCE

Compliance & Ethics

Clients first. Integrity always.

At STO Building Group, we’re guided by the principle Clients first. Integrity always. We provide best in class service to our clients while upholding the highest ethical standards, recognizing that how we build is just as important as what we build. We strive to provide our employees with the tools they need to perform their jobs with integrity and in accordance with our legal obligations, to work with likeminded clients and partners that share our values, and to preserve our good standing in the marketplace and the communities in which we build.

Our industry-leading compliance and ethics program helps ensure that we do the right thing, for every client, on every jobsite, every day, from top-level executive strategy to day-to-day operations. The program is built around the six integrated pillars described below, but at the heart of our program is maintaining a culture of integrity—where the right kind of behavior is incentivized, where employees feel empowered to voice their concerns, and where there is alignment between what we say as an organization and what we do.

1. Strong corporate leadership

Compliance can’t rely on policy alone. Our 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 our 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 concerns through various methods, including our anonymous third-party helplineGo to https://stobuildinggroup.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, approach to compliance, and how we intend to do business. Our formal policies include our Code of Conduct and Business EthicsGo to https://stobuildinggroup.com/compliance/code-of-conduct/, Supplier Code of Conduct and EthicsGo to https://stobuildinggroup.com/compliance/supplier-code/, and our Global Anti-Corruption Policy.

4. Training, communications and awareness

Through regular, required training, we make sure our employees understand our standards of conduct and the legal requirements applicable to their job functions and geographic area. Employees receive a custom training curriculum that covers of range of topics from anti-corruption and appropriate gifts and entertainment, to accurate recordkeeping and overseeing third parties. Awareness campaigns and communications keep compliance topics top-of-mind and translate ethical principles into real world applications.

5. Internal controls

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 to track expenditures, third party due diligence, an anonymous, independent helplineGo to https://stobuildinggroup.com/compliance/helpline/, and a fully integrated compliance audit.

6. Monitoring and risk assessment

We actively monitor our compliance program to ensure that it is calibrated to address the 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, a nationally renowned accounting firm. We also implement a regular enterprise risk assessment—a critical component to gauging corporate risk from macro, industry-wide issues down to specific business unit operational matters.

Leaders

Brian Fields

Chief Ethics & Compliance Officer

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Christopher Barbee

Independent Board Member

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Michael Hourihan

Vice President
Compliance & Ethics

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Monty Alexander

Director of Internal Audit

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Leah Ramos

Regulatory Compliance Counsel

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Danielle Simone

Regulatory Compliance Counsel

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Jason Herman

Compliance Counsel

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