Modern Slavery Act Statement 2024

Jacobs or the Jacobs group of companies refers to Jacobs Solutions Inc. and its direct and indirect subsidiaries collectively. Jacobs’ values, global policies, management instructions, and functional procedures apply across the Jacobs group of companies, including the following reporting commercial organizations and reporting entities:
U.K. Modern Slavery Act 2015 Reporting “Commercial Organizations” (collectively, “Jacobs U.K.”), including but not limited to:
  • Jacobs U.K. Limited
  • Jacobs Field Services Limited
  • CH2M HILL United Kingdom
  • Halcrow International Partnership
  • Jacobs Clean Energy Limited
  • Energy, Safety & Risk Consultants (U.K.) Limited 
  • Jacobs Stobbarts Limited
Australia Modern Slavery Act 2018 “Reporting Entities” (collectively, “Jacobs Australia”), including but not limited to:
  • Jacobs Group (Australia) Pty Ltd
  • Jacobs Australia Pty Ltd.
This global statement is being made by Jacobs, inclusive of Jacobs U.K. and Jacobs Australia, in accordance with the reporting requirements of Section 54, Part 6 of the U.K. Modern Slavery Act 2015 (for Jacobs U.K.) and section 16 of the Australian Modern Slavery Act 2018 (for Jacobs Australia) for the financial year ended 30 September 2023.

 

 

Our commitment

At Jacobs, we’re challenging today to reinvent tomorrow by solving the world’s most critical problems for thriving cities, resilient environments, mission-critical outcomes, operational advancement, scientific discovery and cutting-edge manufacturing, turning abstract ideas into realities that transform the world for good. At Jacobs, we do things right. We always act with integrity – taking responsibility for our work, caring for our people and staying focused on safety and sustainability. In alignment with our values, we are committed to respecting the human rights and dignity of individuals within our operations, supply chain and communities where we do business.

Our structure, operations and supply chain

Jacobs Solutions Inc. is a publicly held corporation, headquartered in the U.S. and incorporated in the State of Delaware. Leveraging a talent force of approximately 60,000, we provide a full spectrum of professional services including consulting, technical, scientific and project delivery for the government and private sector. With US $16.4 billion in revenue, we operate in over 40 countries and engage over 20,000 suppliers worldwide. The services we provide to our markets fall into the following two lines of business (LoBs): Critical Mission Solutions (CMS) and People & Places Solutions (P&PS). Our LoBs, our business unit Divergent Solutions (DVS), which operates as an integrated offering to both LoBs, and a majority investment in PA Consulting, constitute the Company’s reportable segments and are the foundation for how Jacobs helps create a more connected, sustainable world. For more information on our company, see our Annual Report on Form 10-K for the fiscal year ended September 29, 2023, our Quarterly Report on Form 10-Q for the fiscal quarter ended December 29, 2023, and our other filings with the U.S. Securities and Exchange Commission. Jacobs’ operations are located primarily in North America, Europe, the Middle East and Asia Pacific, with detailed location information available on Jacobs.com.

Risks of modern slavery in our operations and supply chains

We are committed to identifying possible modern slavery risks in our operations and supply chains. Jacobs conducts human rights risk assessments, including periodic support from third-party consultants who have supported risk assessment efforts. As a result, we update and improve our understanding of our risk areas for human rights violations and modern slavery exposure.

Jacobs has considered risk factors in evaluating its risk of modern slavery in its global operations and supply chain, including but not limited to:

  • Sector and industry risks: as a professional services company that provides solutions to a diverse range of clients, in some countries some business engagements identify us with a higher risk sector or industry. 
  • Geographic risks: some of the countries in which we operate have higher risks of modern slavery due to poor governance or socio-economic factors.
  • Product and services risks: in some countries some products and services used in our supply chain are identified as higher risk, such as services that involve manual labor or foreign migrant workers.

Jacobs U.K. and Jacobs Australia primarily provide professional services to clients in their respective countries. Jacobs’ supply chain primarily consists of the following categories: 1) corporate suppliers which may include external advisors, cleaning services, training providers, general goods and services for used in day-to-day operations; 2) IT suppliers such as providers of IT equipment; and 3) project subconsultants to provide professional services. Jacobs is committed to continually improving its approach to identifying modern slavery risks in its supply chains and operations around the globe, including further engagement of third parties to conduct reviews and provide expertise on enhancing our approach.

Our actions to assess and address modern slavery risks

Policy

Jacobs’ Human Rights Policy details our commitment to respecting the human rights and dignity of individuals within our operations, supply chain and communities where we do business around the world. This policy is guided by international principles including those encompassed in the United Nations Guiding Principles on Business and Human Rights, Universal Declaration of Human Rights, International Bill of Rights, and the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work.

Updated in 2022, Jacobs’ Supplier Code of Conduct prohibits the use of any form of modern slavery, including forced labor, child labor, and human trafficking. It includes additional requirements including those addressing freedom of association and collective bargaining, recruitment fees, fair wages, non-discrimination, grievance, provision of remedy, and access to personal identification documents. This Supplier Code of Conduct applies to all our suppliers, vendors and subcontractors.

Due diligence

We conduct due diligence to avoid complicity in human rights abuses, and we seek to avoid causing or contributing to adverse human rights impacts through our own activities and business relationships. Supporting our Human Rights Policy, Jacobs has integrated a human rights questionnaire into its supplier pre-qualification process. Enhanced assessment occurs for suppliers based on risk triggers, which can include geography, activity type and other risk factors.

Contracting and certification

Our standard contracts stipulate that suppliers will comply with all applicable laws, rules and regulations including those related to human trafficking, worker welfare and modern slavery. We also require that suppliers certify compliance with our Supplier Code of Conduct, including its human rights provisions.

Auditing and assessment

As outlined in our Supplier Code of Conduct, we reserve the right to conduct audits and thoroughly investigate possible non-compliance with our requirements. We strive to be prompt and fair in our investigations and, whenever possible, operate in a spirit of continuous improvement – working with suppliers to implement change within specified timeframes. Any violations of our Supplier Code of Conduct or failure to cooperate in an audit or investigation may jeopardize suppliers’ business relationship with us, up to and including termination of contracts.

Training

All employees must complete Jacobs’ Living Our Values training, and the We Do Things Right module includes specific information on Jacobs’  Code of Conduct. It includes information on our commitment to respecting human rights and dignity in accordance with the U.K. and Australian Modern Slavery Acts and the United Nations Guiding Principles on Business & Human Rights, as well as our expectations of employees to act in a manner consistent with our Human Rights Policy. Our training for supply management professionals includes a section on our  Supplier Code of Conduct, which includes human rights requirements. Jacobs is committed to continuously improving modern slavery training offerings for employees. Through our unique employee learning platform, e3, we have several on-demand training modules available addressing the topic of modern slavery. The topics include modern slavery general concepts, how it manifests in the supply chain, as well as how to identify and report such cases. The training modules' difficulty level ranges from beginner to intermediate, reflecting the complexity of the subject. In Australia, Jacobs is engaging with a third party to produce modern slavery training videos; the videos will be accessible to all Jacobs employees with a lens of Australian regulations and drivers. 

Engagement

Jacobs recognizes the importance of stakeholder engagement to create a more connected, sustainable world. Jacobs is a participant in the United Nations Global Compact (UNGC) and is participating in the UNGC Business & Human Rights Accelerator Program to assess most salient human rights risks (including modern slavery risks) and further expand Jacobs’ Human Rights Due Diligence across our value chain. In 2024, Jacobs continued its partnership with Business for Social Responsibility (BSR), via which we engage with third-party experts and engage in cross-industry collaboration to collectively advance our sustainability strategies and impacts, including human rights. Jacobs is proud to have been a founding member of Building Responsibly, an industry group collaborating to promote the rights and welfare of workers globally. BSR provides executive leadership and secretariat support for Building Responsibly

We respond to client surveys in relation to Jacobs’ policies and processes and share strategies and control measures to reduce human rights and modern slavery risks within our clients’ operations and supply chains.

Our approach to assessing effectiveness

Key performance indicators

We are committed to continual improvement in managing human rights and modern slavery risk in Jacobs’ supply chain. To evaluate our performance, we consider both qualitative and quantitative global indicators, including but not limited to those related to supplier qualification and certification, audits and assessments, training, client engagement, and external benchmarking.

Reporting

We encourage our employees, suppliers and stakeholders to speak up, without retribution, about any concerns regarding human rights and modern slavery in our operations or supply chain. As detailed in our Jacobs Code of ConductSupplier Code of Conduct, our Whistleblower Protection policy, and on our website, anyone can submit a report anonymously through the Jacobs Integrity Hotline at integrity.teacherswhocoach.com or by calling 844.543.8351 (U.S.), 1.800.316.728 (Australia) and 0808.234.6029 (U.K.). We are committed to investigating reports in an appropriately robust and timely manner.

Our consultation process

We communicated our commitments and actions in combatting modern slavery to the relevant entities in our Jacobs group of companies, inclusive of Jacobs U.K. and Jacobs Australia. We have ensured that relevant areas of Jacobs’ operations are aware of what actions need to be taken to identify, assess, and address modern slavery risks in our operations and supply chains.

This statement was approved by Jacobs Group (Australia) Pty Ltd on 20 March 2024.

This statement was approved by Jacobs Australia Pty. Ltd on 15 March 2024.

This statement was approved by the boards of the Jacobs U.K. entities (including but not limited to Jacobs U.K. Limited, Jacobs Field Services Limited, CH2M HILL United Kingdom, Halcrow International Partnership, Jacobs Clean Energy Limited, Energy, Safety & Risk Consultants (U.K.) Limited, and Jacobs Stobbarts Limited) on 27 March 2024.

Joanne Caruso
EVP, Chief Legal and Administrative Officer