Ch2m International Employee Privacy Policy

DEN/INTL_EMP_PRIV_POL.DOC 1 COPYRIGHT 2007 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL

International Employee Privacy Policy

CH2M HILL respects employee privacy and is committed to protecting employee information it obtains and maintains. We intend to comply with all applicable privacy and data protection laws worldwide. For example, we annually certify with the U.S. Department of Commerce that we are in compliance with the European Union’s approved safe harbor provisions, and compliance with these safe harbor provisions demonstrates adequate privacy protections as required under the European Union’s Directive. This compliance is consistent with our wish to keep our employees informed and to recognize your privacy rights, including your rights of notice, choice, external transfer, access, security, data integrity, and enforcement. The following Employee Privacy Policy applies only to CH2M HILL employees outside of the United States.

Notice: We maintain records that contain your personal information and use this information to administer your compensation and benefits (payroll, insurance, retirement, incentive programs, travel, etc.), comply with legal requirements, and to provide reports to management regarding operations of the company. We do not obtain any personal information about employees unless the employee has provided that information to us by completion of a written employment application, employee benefits application, insurance form, consent form, survey, or completion of an on-line or hard copy form. Employees may choose to submit personal, private information by facsimile, regular mail, e-mail, or electronic transmission over our internal web site, interoffice mail, or personal delivery. In connection with these activities, we may transmit your personal information outside of your country to: a) the computer database located at the data center at our world headquarters in Denver, Colorado, United States of America, b) our administrative offices, c) our benefits advisers and administrators or travel professionals, d) clients to illustrate experience and qualifications for our business purposes or promotion, or e) regulatory authorities. Once transferred, we cannot guarantee the information will be maintained in a manner that meets minimum adequacy standards of your country. Personal information is stored in our computer database (including on a global human resource information system) as well a hard copy in your personnel file.

As permitted by local laws, the personal information we collect may include your:

• Name

• Home Address and Telephone Number

• Date of Birth

• Gender

• Ethnicity

• Language Skills

• Marital Status


• Emergency Contact Information

• Dependent Identification

• Education Level

• Training Levels

• Salary/Payroll

• Hours of Employment

• Vacation and other Leave Time

• Insurance Information

• Benefits and Retirement Plan

• Performance Information

• Membership in Professional or Trade Associations

• Travel Preferences

• Curriculum Vitae or Resume

• Other information you have provided us

If you have any inquires or complaints about the use or limitation of use of your personal information, you may contact your local or regional human resource (“HR”) department or the HR department at corporate headquarters:

Asia Pacific Region:

Mr. Timothy Cheong

150 Beach Road

Level 34

Gateway West

Singapore, 189720

Republic of Singapore

65 6391 0350

65 6299 4739 Fax

[email protected]

Canada:

Mr. David Larter

255 Consumers Road

Suite 300

Toronto, Ontario M2J 5B6

Canada

(416) 499-9000

(416) 499-9441 Fax

[email protected]

Europe-Middle East:

Mr. Rick Scholes Avon House

Kensington Village

Avonmore Road

London, United Kingdom

W14 8TS

44 0 207 471 6100

44 207 471 6101 Fax

[email protected]

Latin America and

Corporate Headquarters:

Mr. Todd Day

9191 South Jamaica Street

Englewood, CO 80112

USA

(303) 771-0900

(720) 286-9250 Fax

[email protected]

Choice: Any employee may refuse (opt out) to provide consent to transmit his/her personal information if the purpose for transmission is not compatible with the original purpose of submitting the information.


External Transfer: We will not disclose or share an employee‘s personal information with any external entity or third party, except to an employee’s designated insurance provider, employee benefits administrator, travel professionals, clients to illustrate experience and qualifications for business purposes or promotion, or as an employee designates.

Access: All employees have access to their own personal information to correct, amend, or delete that information. Only those employees in the HR department who need access to employee personal information in order to perform their job have access to view that information that is stored in our database. An employee may view their own personnel record upon request by contacting the local or regional HR department or accessing certain information on our intranet.

Security: The importance of security for all personally identifiable information associated with our employees is of utmost concern. We have taken several steps to safeguard the integrity of personal information and prevent unauthorized access to information maintained in our database. These measures are designed and intended to prevent corruption of data, block unknown and unauthorized access to our computerized system and information, and to provide reasonable protection of private, personal information in our possession. All employee files are confidentially maintained in the HR department in secured and locked file cabinets or rooms. Access to the computerized database is controlled by a log-in sequence and requires users to identify themselves and provide a password before access is granted. Users are limited to data required to perform their job function. Security features of our software and developed processes are used to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Data Integrity: We only intend to maintain personal information that is accurate, current, and only for use as originally intended. Personal information is initially collected at the time an employee is hired. The HR department annually requests active employees to review their personal information to determine its accuracy. If any information is incorrect, employees are asked to correct and update it and return the information to the HR department. Upon receipt of this information, we make the appropriate changes in the database.

Enforcement: Any employee who violates our privacy and/or security policies is subject to disciplinary action, including termination and civil and/or criminal prosecution. Annual reviews of this policy and principles will take place. We will include internal compliance reviews as part of our internal self-audit process. Employees should forward any complaints or disputes regarding personal data protection to their local or regional HR department listed above. Complaints or disputes that cannot be resolved by the local or regional HR department should be forwarded to the corporate headquarters HR department listed above.

If problems still cannot be resolved at the corporate headquarters in Denver, Colorado, we will resolve the dispute according to local law. For example, in Europe we will attempt to resolve disputes first with the European data protection authorities, and if unresolved, then with the United States of America Federal Trade Commission. In Canada we may work


with the procedures of the Privacy Commissioner of Canada or the responsible privacy office of each province (each office’s contact information listed at www.privcom.gc.ca). In the US and elsewhere, we desire resolve disputes through private means. If you have any questions concerning your local governing privacy office, please contact your local or regional HR department or Ms. Amy Seath listed above, and we will provide you with that information.

Documents

Ch2m International Employee Privacy Policy