WSP USA

wsp.com

2019

YOUR
EMPLOYEE
HANDBOOK
TABLE OF CONTENTS
INTRODUCTION............................... 6
1. EQUAL EMPLOYMENT
OPPORTUNITY.............................. 8
Employment and Accomodation
of the Disabled................................................................ 10
 mployment of Protected Veterans
E
and Disabled Veterans.................................................. 10
Anti-Harassment, Non-discrimination,
and Non-Retaliation...................................................... 10
Discrimination Defined................................................ 11
Harassment Defined....................................................... 11
Sexual Harassment Defined......................................... 11
Retaliation Defined........................................................ 12
Reporting Procedures................................................... 12
Investigation Procedures.............................................. 13
Equal Pay.......................................................................... 14
Pay Transparency........................................................... 14
2. WORKPLACE HEALTH
AND SAFETY............................... 16
Substance Abuse............................................................. 17
Smoking and Tobacco-Free Workplace.................... 18
Workplace Violence........................................................19
Security Inspections ......................................................19
Occupational Health and Safety................................ 20
Hazard Recognition and Reporting.......................... 20
Workplace Hazards........................................................ 20
Reporting of Workplace Hazards............................... 21
Stop Work......................................................................... 21
Workplace Injuries and Illness................................... 21
Serious Injury or Death............................................... 22
OSHA Reporting Requirements................................ 22
“Near Hit or Miss”.......................................................... 22
Failure to Report............................................................. 22
Safety Training................................................................ 22
3. EMPLOYMENT............................ 24
Employee Categories.................................................... 25
Full-time Exempt (Salaried)........................................ 25
Non-Exempt (Hourly)................................................... 25
Non-Exempt Full-Time................................................ 26
Non-Exempt Part-Time
Benefits Eligible.............................................................. 26
Non-Exempt Part-Time
Benefits Ineligible.......................................................... 26
Temporary........................................................................ 26
Project Employee........................................................... 27
Occasional Employee.................................................... 27
Intern................................................................................. 27
Employment Agencies.................................................. 27
Background Checks....................................................... 27
During the Recruitment Process............................... 28
Security Clearance......................................................... 28
Client Request................................................................. 28
MVR Verifications for Drivers
of Company Vehicles.................................................... 29
Rehire................................................................................. 29
Immigration..................................................................... 29
Employment of Relatives............................................. 30
Furlough............................................................................ 30
Departures......................................................................... 31
Benefits Upon Departure.............................................. 31
Employment Verification/References...................... 31
4. STANDARD WORK
WEEK/DAY................................... 32
Work Week........................................................................33
Meal & Rest breaks.........................................................33
Exempts.............................................................................33
Non-Exempts................................................................... 34
Break Time for Nursing Employees ........................ 34
Attendance and Absences............................................35
Inclement Weather..........................................................35
Non-Exempt Employees...............................................35
Exempt Employees........................................................ 36
Temporary Employees.................................................. 36
5. COMPENSATION....................... 38
Overtime eligibility ...................................................... 39
Exempt Employees (Salaried):
Not Legally Entitled to Overtime............................. 39
Non-Exempt Employees
(Hourly Employees): Legally Entitled
to Overtime...................................................................... 39
Advance Approval for Overtime............................... 39
No Time Off in Lieu of Overtime Pay..................... 39
Time Spent Commuting...............................................40
Pay Periods.......................................................................40
Deductions for Exempt Employees.......................... 41
Timesheets....................................................................... 42
Bonus Programs............................................................. 42
Merit Bonus..................................................................... 42
Spot Award...................................................................... 42
Employee Referral bonuses........................................ 43
Project Incentive Plans................................................. 43
Professional
Licensure Program......................................................... 43
Essential Licenses.......................................................... 44
Enhancing Licenses....................................................... 44
Exclusions........................................................................ 44
Reimbursement of costs.............................................. 44
Exam Day......................................................................... 44
Performance and
Compensation Reviews............................................... 45
Performance Reviews................................................... 45
Compensation Reviews............................................... 45
Promotions and Open Positions................................ 45
Internal Transfers........................................................... 45
Relocation......................................................................... 45
Relocation packages...................................................... 46
Employee-Requested Transfers................................. 46
Bring Your Own Mobile
(BYOM) Stipend.............................................................. 46
Automatic BYOM Stipend Enrollment................... 47
Enrollment Upon Request Based on
Business Necessity......................................................... 47
No BYOM Stipend for Convenience
Based Use of Personal Mobile Device..................... 47
Supervisor Responsibilities........................................ 47
Employee Responsibilities.......................................... 48
Timing of BYOM Stipend............................................ 48
Reporting BYOM Related Concerns........................ 48
6. BENEFITS...................................... 50
Eligibility...........................................................................51
Health and Welfare Benefits........................................51
Workers' Compensation................................................51
Retirement Benefits....................................................... 52
401(K) Savings Plan................................................ 52
Deferred Compensation Plan..................................... 52
Professional Development........................................... 52
Continuing Education
(Tuition Reimbursement)............................................. 52
Professional Training & Development......................53
Internal Training
Requirements & Tracking............................................ 54
Professional Memberships...........................................55
Service Awards................................................................55
7. WORKPLACE
EXPECTATIONS.......................... 56
Professional Conduct.................................................... 57
Reporting Corrupt
or Unethical Behavior................................................... 57
Conflict of Interest......................................................... 58
Concurrent Employment............................................. 58
Confidential and Protected Information................. 59
Data Privacy.....................................................................60
Updating Personal Information.................................60
Reporting Any Actual
or Suspected Data Breach............................................60
Gifts, Entertainment and Hospitality....................... 61
Dress Code....................................................................... 61
Office.................................................................................. 62
Field.................................................................................... 62
Inappropriate Clothing................................................. 62
IT Acceptable Use Policy.............................................. 62
E-mail Use........................................................................ 63
Network Access.............................................................. 64
Unacceptable Use........................................................... 64
Instant Messaging..........................................................66
Web Browsing.................................................................66
Copyright Infringement...............................................66
Streaming Media............................................................ 67
Monitoring and Privacy............................................... 67
Personal Use.................................................................... 67
Remote Desktop Access............................................... 67
Circumvention of Security.......................................... 67
Use for Illegal Activities............................................... 67
Personal Storage Media................................................68
Software............................................................................68
Security Incident Reporting........................................68
Enforcement....................................................................69
Exception Management...............................................69
IT Mobile Device Policy
(a.K.A. BYOM Policy)....................................................69
Eligibility & Access.......................................................69
Security............................................................................. 70
Device Locking............................................................... 70
Device Timeout............................................................... 70
Jailbroken or Rooted Devices..................................... 70
Lost or Stolen Devices.................................................. 70
Employee Offboarding................................................. 70
Technical Support.......................................................... 70
Policy Enforcement....................................................... 70
Exception Management................................................71
Social Media and Web
Communications Policy................................................71
Global Website.................................................................71
Social Media.................................................................... 72
Official Communications
on Social Media.............................................................. 72
Joining a Conversation
as an Employee............................................................... 72
Employee Personal Use of
Social Media: Publicly Accessible
Profile Affiliation........................................................... 73
Social Media Guidelines.............................................. 73
Corporate Internet Presence....................................... 74
Press Inquiries................................................................ 74
Company Equipment Policy........................................75
Business-Related Events Policy..................................75
8. TIME OFF....................................... 78
Paid Time Off (PTO)...................................................... 79
Years of WSP Service Completed............................. 79
Bi-Weekly Accrual Rate................................................ 79
Annual Accrual Rate..................................................... 79
Maximum Accrual Rate............................................... 79
Notice and Scheduling..................................................80
Borrowing of PTO.........................................................80
Holidays.............................................................................80
Legacy Non-PTO Sick Time........................................80
Jury Duty........................................................................... 82
Crime Victim, Domestic Violence
& Witness Leave............................................................. 82
Voting Leave.................................................................... 83
Other Civic Duty Leave............................................... 84
Bereavement Leave........................................................ 84
Parental Leave................................................................. 85
Naturalization Leave..................................................... 85
Personal Leave of Absence:......................................... 85
Disability Leave.............................................................. 86
Medical Certification....................................................88
Benefits During Leave..................................................88
Job Protection..................................................................88
Short-term Disability (STD):.......................................88
Reporting a STD claim: ...............................................88
Charging Time during STD:....................................... 89
Long-term Disability (LTD):........................................ 89
Partial Disability (PSTD/PLTD):................................ 89
Family and Medical Leave...........................................90
Eligibility Requirements..............................................90
Basic Leave Entitlement...............................................90
Job Benefits and Protection.........................................90
Definition of Serious
Health Condition........................................................... 91
Use of Leave..................................................................... 91
Substitution of Paid
Leave for Unpaid Leave................................................ 91
Employee Responsibilities.......................................... 91
Employer Responsibilities.......................................... 92
Unlawful Acts by Employers...................................... 92
Enforcement.................................................................... 92
Military Family
Leave Entitlements........................................................ 92
WSP Responsibilities.................................................... 93
Allowable Maximum Duration
for Leaves of Absense-Long
Term Disability............................................................... 93
Respecting unpaid Leave............................................. 93
Returning to Work......................................................... 93
Timesheets While
on Intermittent Leave................................................... 93
Military Leave................................................................. 94
State/Local Mandated Leaves.................................... 94
Project................................................................................ 94
Task..................................................................................... 94
Type.................................................................................... 94
9. BUSINESS TRAVEL .................96
Authorization and Responsibility............................. 97
Receipts............................................................................. 97
Air Travel.......................................................................... 97
Economy Class................................................................98
Economy Plus Class .....................................................98
Business Class ................................................................98
Rail Transportation........................................................98
Ground Transportation................................................98
Courtesy Cars.................................................................98
Public Transit
(Subway, Metro, Ferry, etc.)..........................................98
Rental Cars.......................................................................98
Taxis...................................................................................99
Car Service.......................................................................99
Personal Cars...................................................................99
Parking/Tolls................................................................ 100
Lodging (Commercial)............................................... 100
Per Diem........................................................................ 100
Relocation Expenses.................................................. 100
TDY (Temporary Duty)............................................... 101
Meals................................................................................ 101
Personal Meals During Travel.................................. 101
Business and Group Meals........................................ 101
Cell Phone Charges.................................................... 102
Other Business Expenses......................................... 102
Vacation in Conjunction
with Business Travel ..................................................103
Spouse or Other Dependent Expenses................. 104
Meeting and Conference Planning........................ 104
Charitable Contributions/Donations................... 104
Capital Expenditures &
Payment of Vendor Invoices ................................... 104
Sponsorships (Golf, Gala Tables,
Award Ceremonies, Etc.)............................................105
General Business Travel Restrictions....................105
RECEIPT & ACKNOWLEDGEMENT
OF WSP USA EMPLOYEE
HANDBOOK....................................... 106
RECEIPT & ACKNOWLEDGEMENT
OF ANTI-HARASSMENT,
NON-DISCRIMINATION, AND
NON-RETALIATION POLICY............ 108
 INTRODUCTION
The WSP USA Employee Handbook (“Employee Handbook”) presents WSP USA's (“WSP” or the
“Company”) core Human Resources (“HR”) related policies and practices in one reference source. This
document is posted and available on WSP’s intranet, along with global and other regional policies. This
Employee Handbook applies to U.S. employees and to WSP’s locations in the United States and the
following notice applies to all U.S. employees regardless of hire date:
employees are advised to regularly refer to the Company intranet for the latest version. Revised policies
and procedures will modify, supersede, or eliminate existing policies. No oral statements or promises can
change or modify WSP policies. Only WSP’s President and CEO may alter WSP’s policies or benefits. Only
WSP’s Senior Vice President of Human Resources may issue interpretations of this Employee Handbook.
No other employees have the authority to change policies or to make promises or commitments that
exceed or differ from what is stated in this Employee Handbook. Nothing in any WSP policy is intended to,
or should be construed, to violate any federal, state, or local law or regulation.

U.S. employees are expected to familiarize themselves with and to follow WSP’s U.S. and global polices,
practices, and procedures. This includes both those policies and procedures set forth in this Employee
Handbook and the U.S and global policies available on intranet. The global policies and procedures are
established by our parent company, WSP Global, Inc. and include, but are not limited to, the WSP global ABOUT WSP
Code of Conduct; Gifts, Entertainment and Hospitality Policy; Privacy Policy; and Anti-Corruption Policy.
WSP is one of the world’s leading engineering • W
 e value our people
The contents of this Employee Handbook supersede any previously issued employee handbooks and and professional services consulting firms, and our reputation.
inconsistent verbal or written policies issued by WSP or by companies acquired by and integrated into providing services to transform the built
WSP. An employee’s continued employment with WSP indicates their agreement to abide by all of WSP’s environment and restore the natural one. • W
 e are locally dedicated
U.S. policies, practices, and procedures, including the policies established in this Employee Handbook, Our expertise ranges from environmental with international scale.
and with the global policies set forth by WSP Global Inc. Violation of any of these policies, practices, or remediation and urban planning, to
procedures may result in disciplinary action, up to and including termination of employment. The policies engineering iconic buildings and designing • W
 e are future-focused and
included in the Employee Handbook are guidelines only and are subject to change as the Company deems sustainable transport networks, to developing
challenge the status quo.
appropriate or necessary. the energy sources of the future and enabling
• W
 e foster collaboration in
new ways of extracting essential resources.
NEITHER THIS EMPLOYEE HANDBOOK NOR ANY OTHER COMPANY GUIDELINES, POLICIES, OR everything we do.
PRACTICES CREATES AN EMPLOYMENT CONTRACT, BARGAIN, OR AGREEMENT OR CONFERS WSP’s Guiding Principles define the culture
ANY CONTRACTUAL RIGHTS WHATSOEVER. EMPLOYMENT WITH THE COMPANY IS AT-WILL, of the company, motivating our employees to • W
 e have an empowering
AND EITHER THE EMPLOYEE OR THE COMPANY MAY TERMINATE EMPLOYMENT AT ANY give their best, and instilling confidence to culture and hold ourselves
TIME, WITH OR WITHOUT CAUSE OR REASON. NO REPRESENTATIVE OF THE COMPANY IS our clients that we will deliver solutions of accountable.
AUTHORIZED TO PROVIDE ANY EMPLOYEE, INDIVIDUALLY OR ON A COLLECTIVE BASIS, WITH the very highest quality.
AN EMPLOYMENT CONTRACT OR SPECIAL ARRANGEMENT CONCERNING THE TERMS OR
CONDITIONS OF EMPLOYMENT UNLESS THE CONTRACT OR AGREEMENT IS IN WRITING AND
SIGNED BY WSP’S U.S. SENIOR VICE PRESIDENT OF HUMAN RESOURCES AND APPROVED BY Watch our Year in Review
WSP’S U.S. GENERAL COUNSEL.

WSP strives to comply with all federal, state, and local laws. To achieve such compliance, WSP treats
this Employee Handbook as a living document and the policies expressed herein are periodically
reviewed and may be changed, suspended or canceled, and/or new policies added, at any time, with or
without notice. If the Employee Handbook fails to expressly address an applicable law, the omission
does not imply noncompliance; rather, compliance with such laws may be handled by separate policy,
practice, or procedure. Moreover, revisions to this Employee Handbook shall not be construed as an
admission of previous noncompliance with applicable laws. Rather, revisions are often made to enhance
communications. A new Employee Handbook may not be formally distributed for every change, so
6 7
 WSP firmly commits itself to Equal of minority groups, women, individuals with
Employment Opportunity (EEO) and to disabilities and covered veterans for positions

1.
compliance with applicable laws that prohibit
employment discrimination on the basis of
race, religion, color, creed, national origin,
ancestry, citizenship status, sex (including
pregnancy, childbirth breastfeeding and
in all job categories and at all levels. All
supervisory employees should make a distinct
effort to oversee that all employees reporting
to them understand and uphold our Equal
Employment Opportunity policy.

EQUAL
medical conditions related to pregnancy,
If any employee has questions or concerns
childbirth or breastfeeding), age, marital
about the Affirmative Action program or
or registered domestic partnership status,
the Equal Employment Opportunity policy,
military or veteran status, mental or physical

EMPLOYMENT
the employee is encouraged to discuss any
disability, medical condition (including
concerns with the employee’s HR Business
cancer and genetic characteristics), genetic
Partner or the Company’s Equal Employment
information, sexual orientation, gender,

OPPORTUNITY
Opportunity Officer. Employees with
gender identity or expression (including
complaints related to WSP’s Affirmative
transgender status), political affiliation, or
Action program or Equal Opportunity policy
other legally protected classes or any other
may pursue action through the Complaint
characteristics protected by federal, state,
Process outlined below.
or local laws. Our management team is
dedicated to ensuring the fulfillment of this For additional information, see the WSP
policy with respect to recruitment, hiring, USA Equal Opportunity and Affirmative
placement, promotion, transfer, training, Action Program and the WSP USA Non-
compensation, benefits, employee activities, Discrimination Policy—Title VI, available on
access to facilities and programs, and general the intranet.
treatment during employment.

WSP is committed to a diverse workforce

and will make reasonable accommodations
for known physical or mental limitations of
qualified employees with disabilities, without
regard to any protected classifications, unless
the accommodation would impose an undue We work diligently to
hardship on the operation of our business. attract, retain, and promote
Any employee who needs assistance to
qualified members of
perform the employee’s job duties because of
minority groups, women,
a physical or mental condition should contact
their HR Business Partner.
individuals with disabilities
and covered veterans for
We expect all employees in management and positions in all job categories
supervisory positions to work diligently to
and at all levels."
attract, retain, and promote qualified members

8 9
 1.1
–––––
EMPLOYMENT AND
ACCOMODATION OF
THE DISABLED
WSP’s Affirmative Action and non-
discrimination program encourages the
employment and advancement in
employment of qualified persons with
disabilities. Employees who believe that they
require a reasonable accommodation in order
to perform their essential job functions may
complete the Reasonable Accommodation
Request Form, available on the intranet, and
return the form to the contact designated
on the form. The request will be reviewed
and a determination will be made on a case-
by-case basis considering each employee’s
individual limitations and accommodation
needs. Submission of disability information
is strictly voluntary and will be treated
in accordance with the Health Insurance
Portability and Accountability Act of 1996
(HIPAA).
While employees are not required to
disclose medical information to supervisors
or co-workers, medical documentation
(or additional medical documentation)
may be requested by HR to process an
accommodation request. It is the employee’s
responsibility to obtain information from the
healthcare provider and to submit it to their
HR Business Partner in a timely manner.
10
1.2
–––––
EMPLOYMENT OF PROTECTED
VETERANS AND DISABLED
VETERANS
WSP has an Affirmative Action program
for the employment and advancement in
employment of qualified protected veterans
under U.S. federal law. Persons who
would like to participate in this program
may identify themselves to their HR
Business Partner or the Equal Employment
Opportunity Officer. Submission of this
information is strictly voluntary.
1.3
–––––
ANTI-HARASSMENT,
NON-DISCRIMINATION,
AND NON-RETALIATION
WSP does not tolerate and prohibits
discrimination or harassment of or against
our job applicants, contractors, interns,
volunteers, or employees by another
employee, supervisor, vendor, customer, or
any third party on the basis of race, color,
creed, religion, national origin, ancestry,
citizenship status, age, sex or gender
(including pregnancy, childbirth and related
medical conditions), gender identity or
gender expression (including transgender
status), sexual orientation, marital status,
military service and veteran status, physical
or mental disability, protected medical
condition as defined by applicable state or
local law, genetic information, or any other
characteristic protected by applicable federal,
state, or local laws and ordinances (referred
to as “protected characteristics”).  WSP also
prohibits retaliation as defined below.
WSP is committed to a workplace free of
discrimination, harassment and retaliation.
These behaviors are unacceptable in the
workplace and in any work-related settings
such as business trips and Company
sponsored social functions, regardless of
whether the conduct is engaged in by a
supervisor, co-worker, client, customer,
vendor or other third party. In addition
to being a violation of this policy,
discrimination, harassment or retaliation
based on any protected characteristic
pursuant to applicable federal, state,
or local laws and ordinances also
is unlawful.  For example, sexual
harassment and retaliation
against an individual because the
individual filed a complaint of
sexual harassment or because an
individual aided, assisted or testified
in an investigation or proceeding
involving a complaint of sexual
harassment are unlawful.
Discrimination Defined
Discrimination under this policy means
treating differently or denying or granting
a benefit to an individual because of the
individual’s protected characteristic.  Sexual harassment can include any of the
Harassment Defined
Harassment generally is defined in this policy
as unwelcome verbal, visual or physical
conduct that denigrates or shows hostility or
aversion towards an individual because of any
protected characteristic when:
•• Submission to that conduct is made either
explicitly or implicitly a term or condition
of an individual’s employment;
•• Submission to or rejection of the conduct
by an individual is used as the basis
for employment decisions affecting the
individual; or
•• The conduct has the purpose or effect
of unreasonably interfering with an
individual’s work performance or creating
an intimidating, hostile, or offensive
working environment.
Harassment can be verbal (including slurs,
jokes, insults, epithets, gestures or
teasing), visual (including offensive
posters, symbols, cartoons,
drawings, computer displays,
text messages, social media posts
or e-mails) or physical conduct
(including physically threatening
another, blocking someone’s way,
etc.).  Such conduct violates this
policy, even if it is not unlawful.  Because
it is difficult to define unlawful harassment,
employees are expected to behave at all times
in a manner consistent with the intended
purpose of this policy.
Sexual Harassment Defined
above actions, as well as other unwelcome
conduct, such as unwelcome or unsolicited
sexual advances, requests for sexual favors,
conversations regarding sexual activities and
other verbal or physical conduct of a sexual
nature when:
•• Submission to that conduct or those
advances or requests is made either
11
 explicitly or implicitly a term or condition
of an individual’s employment;
•• Submission to or rejection of the conduct
or advances or requests by an individual is
used as the basis for employment decisions
affecting the individual; or
•• The conduct or advances or requests have
the purpose or effect of unreasonably
interfering with an individual’s work
performance or creating an intimidating,
hostile, or offensive working environment.
•• Examples of conduct that violates this
policy include:
•• Unwelcome sexual advances, flirtations,
advances, leering, whistling, touching,
pinching, assault, blocking normal
movement;
•• Requests for sexual favors or demands
for sexual favors in exchange for favorable
treatment;
•• Obscene or vulgar gestures, posters, or
comments;
•• Sexual jokes or comments about a person’s
body, sexual prowess, or sexual deficiencies;
•• Propositions, or suggestive or insulting
comments of a sexual nature;
•• Derogatory cartoons, posters, and drawings;
•• Sexually-explicit e-mails or voicemails;
•• Sharing or sending sexually explicit media
(or links thereto);
•• Uninvited touching of a sexual nature;
•• Unwelcome sexually-related comments;
•• Conversation about one’s own or someone
12
else’s sex life;
•• Conduct or comments consistently targeted
at only one gender, even if the content is not
sexual; and
•• Teasing or other conduct directed toward a
person because of the person’s gender.
Retaliation Defined
Retaliation means adverse conduct taken
because an individual reported an actual or
perceived violation of this policy, opposed
practices prohibited by this policy, or
participated in the reporting and investigation
process described below.  “Adverse conduct”
includes but is not limited to:  any action
that would discourage an employee from
reporting discrimination, harassment or
retaliation; shunning and avoiding an
individual who reports discrimination,
harassment or retaliation; express or implied
threats or intimidation intended to prevent
an individual from reporting discrimination,
harassment or retaliation; and denying
employment benefits because an applicant
or employee reported discrimination,
harassment or retaliation or participated
in the reporting and investigation process
described below.
Reporting Procedures
The following steps have been put into place
to provide a work environment at WSP
that is respectful, professional, and free of
discrimination, harassment and retaliation.  If
an employee believes someone has violated
this policy or our Equal Employment
Opportunity Policy, the employee should
promptly bring the matter to the immediate
attention of their supervisor(s), to their HR
Business Partner (by making the report in
person, over the phone, or through email), or
to WSP’s confidential whistleblower hotline
by calling (1-877-533-5310) or by emailing
(wsp@expolink.co.uk). Additional details
about WSP’s whistleblower hotline, known
as “Expolink”, are available on the intranet. 
If the complaint is about an employee’s HR
Business Partner or supervisor, the employee
should contact any higher-level manager in
their reporting chain. If the employee makes
a complaint under this policy and has not
received a satisfactory response within five
(5) business days, the employee should contact
WSP’s EEO Officer immediately.
Every supervisor who learns of any
employee’s concern about conduct in violation
of this policy or our Equal Employment
Opportunity Policy, whether in a formal
complaint or informally, or who otherwise
is aware of conduct in violation of this
policy, must immediately report the concern,
complaint or conduct to senior management
or to their HR Business Partner.
Investigation Procedures
Upon receiving a complaint, WSP will
promptly conduct a fair and thorough
investigation into the facts and circumstances
of any claim of a violation of this policy or
our Equal Employment Opportunity
policy to provide due process for
all parties.  To the extent possible,
WSP will endeavor to keep the
reporting employee’s concerns
confidential. However, complete
confidentiality may not be possible
in all circumstances. Employees
are required to cooperate in all
investigations conducted pursuant to this
policy and a failure to cooperate may result
in disciplinary action, up to and including
termination.
During the investigation, WSP generally
will interview the complainant and the
accused, conduct further interviews
as necessary and review any relevant
documents or other information.  Upon
completion of the investigation, WSP
will determine whether this policy or our
Equal Employment Opportunity policy has
been violated based upon its reasonable
evaluation of the information gathered during
the investigation.  WSP will inform the
complainant and the accused of the results of
the investigation.
*****
WSP will take corrective measures against
any person who it finds to have engaged in
conduct in violation of this policy.  These
measures may include, but are not limited
to, counseling, suspension, or immediate
termination.  Anyone, regardless of position
or title, whom WSP determines has engaged
in conduct that violates this policy or our
Equal Employment Opportunity policy will
be subject to discipline, up to and including
termination. This includes individuals
engaging in discrimination, harassment
or retaliation, as well as supervisors
who fail to report violations of
this policy, or knowingly allow
prohibited conduct to continue.
Individuals who engage in
conduct that rises to the level
of a violation of law can be held
personally liable for such conduct.
13
 1.4 another employee who has access to salary
information as part of their job duties, may
–––––
only do so to fulfill a legitimate business need
EQUAL PAY
or legal duty; employees who request salary
For all its employees, WSP is committed to information without a legitimate underlying
the principle of equal pay for work of equal business or legal reason may be subject
value and to work rated as equivalent. WSP to disciplinary action, up to and including
recognizes the importance of, and commits termination, unless otherwise permitted by
to, providing a fair, objective and transparent applicable law.
pay system which is free from any form of
gender bias or other form of unlawful bias
prohibited under applicable laws. As a good
business practice and in the interest of equity
and fairness, WSP is committed to providing
equal pay for all members of its workforce
including those in protected classes. As
such, WSP will not ask job applicants to
WSP recognizes
disclose their current or prior compensation
history. Upon the request of a job applicant,
the importance
in accordance with applicable law, WSP will of, and commits
provide the applicant with a pay range for
the job for which they are applying or as to, providing a
otherwise required by applicable law.

1.5
fair, objective and
––––– transparent pay
PAY TRANSPARENCY
WSP will not discharge or in any other
system which
manner discriminate against employees or
applicants because they have inquired about,
is free from any
discussed, or disclosed their own pay, or form of gender
the pay of another employee or applicant.
However, employees who have access to the bias or other form
compensation information of other employees
or applicants as part of their essential job of unlawful bias
function cannot disclose the pay of other
employees or applicants to individuals who prohibited under
applicable laws"
do not have a business or legal need for such
information. Any employee who requests the
salary information of a WSP employee from
14 15
 WSP places a high value on the health and
safety of our employees and is committed
2.
to providing a workplace that is free of
recognized hazards while providing the
necessary training to understand the
potential risks of our tasks. All WSP
employees are responsible for the
WORKPLACE
safety of the workplace and must
continuously monitor for unsafe
work conditions and unsafe
actions by coworkers, and
HEALTH AND
promptly notify their supervisor
of any hazards. Our Zero Harm
Vision focuses on reducing risk
SAFETY
in our activities by seeking new and
innovative solutions through our Zero
Harm Pillars. Everywhere WSP operates,
WSP strives to achieve:
•• Zero fatalities
•• Zero permanently disabling injuries
•• Zero injuries to members of the public
•• Zero long-term harm to health
The U.S. region has a Safety Team led by the
national U.S. Corporate Safety Director. The
Safety Team is responsible for monitoring and
setting standards for the safe implementation
of all work conducted in the U.S. region.
These standards and other Health and Safety-
related policies are available via WSP’s
intranet.
2.1
–––––
SUBSTANCE ABUSE
WSP is firmly committed to providing
a safe, healthy, productive, and efficient
work environment for our employees. As
16
an organization, WSP is dedicated to the
integrity of our work and to the safety of
our employees, our clients, and the public in
general. The Company has established the
WSP USA Employee Substance Abuse and
Drug Testing Manual (the “Drug Policy”) as
part of that commitment. The Drug
Policy applies to all employees and
is available on WSP’s intranet.
Employees are expected to
familiarize themselves, and
to comply with the Drug
Policy. Failure to comply with
WSP’s Drug Policy can result
in disciplinary action, up to and
including termination.
WSP is a drug- and alcohol-free workplace.
The use of illegal substances, or the improper
use of alcohol, medication, or unauthorized
legal substances by WSP employees could
potentially impair their judgment or work
performance and subject themselves and
others to unacceptable safety risks, and
therefore undermines WSP’s ability to operate
safely, effectively, and efficiently. Accordingly,
employees are also prohibited from reporting
to work or working while they are using or
under the influence of alcohol, any drugs
as well as any controlled substances which
may impact an employee’s ability to perform
the employee’s job or otherwise pose safety
concerns, (except when the use is pursuant to
a licensed medical practitioner’s instructions
and the licensed medical practitioner
authorized the employee to report to work).
You must notify the U.S. Corporate Safety
Director of any criminal drug statute
conviction for a violation occurring within
the workplace within five (5) days of such
17
 conviction. Within ten (10) days of such
notification or other actual notice, the
Company will advise, as applicable, the
appropriate contracting agency of such
conviction.
Violation of this policy may result in
disciplinary action, up to and including
termination.
As a government contractor, WSP follows
federal law relating to the use of marijuana.
As such, under no circumstances are
employees permitted to perform work for
or represent WSP while under the influence
of marijuana. This prohibition remains
in effect regardless of whether the drug
was prescribed by a medical doctor, and is
unaffected by the legality of the substance
(whether for medical or recreational use)
under any state law.
WSP maintains a policy of non-discrimination
and will endeavor to make reasonable
accommodations to assist employees
recovering from or seeking to recover from
substance abuse. WSP encourages employees
who are struggling with substance abuse or
addiction issues to seek assistance from their
HR Business Partner. If an employee is facing
such issues, it is important to seek assistance
for their own welfare and to do so long
before those issues render them ineffective
or unable to properly perform their essential
job functions, or places them in a situation
that could jeopardize the health and safety
of themselves or others. Additionally, in the
discretion of the Company, any employee
who violates this policy may be required, in
connection with or in lieu of disciplinary
sanctions, to participate, to the Company’s
satisfaction, in an approved drug assistance or
18
rehabilitation program. However, employees
may not request an accommodation to avoid
discipline for a policy violation.
In order to maintain a drug-free workplace,
the Company has: (1) a drug-free awareness
program to educate employees on the dangers
of drug abuse in the workplace; (2) a drug-free
workplace policy; (3) made available drug-
free counseling, rehabilitation and employee
assistance programs; and (4) imposes
penalties for violations of our drug-free
workplace policy.  policy, a threat includes, but is not
2.2
–––––
SMOKING AND TOBACCO-FREE
WORKPLACE
In the interest of providing a healthy working
environment, all areas of the workplace are
smoke-free without exception. Tobacco use
of any kind, e-cigarettes, vaping devices
and similar electronic devices are strictly
prohibited at all times anywhere within
WSP’s owned or leased spaces, and are
not permitted anywhere in the workplace,
including any room or space in our indoor
facilities or within company-owned or
leased vehicles, except in designated areas.
Such activities in many locations are also
not permitted within a certain distance of
entry access points. Any disputes involving
smoking and any employees with questions
should discuss their issues/concerns with
their HR Business Partner. Employees will
not be subject to retaliation for reporting
violations of this policy.
2.3
–––––
WORKPLACE VIOLENCE
WSP strongly commits to providing a safe
workplace.
Threats, whether explicit or implied, and any
threatening language or any other act of
aggression or violence made toward,
or by, any WSP employee will not
be tolerated. For purposes of this
limited to, any verbal or physical
harassment or abuse, any attempt
at intimidating or instilling
fear in others, menacing gestures,
flashing of weapons, stalking, or any
other hostile, aggressive, injurious and/or
destructive action undertaken for, or which
has the foreseeable effect of, domination or
intimidation.
Weapons, including, but not limited
to, firearms, explosives, and knives, are
prohibited on Company premises unless such
prohibition is restricted by applicable law.
All potentially dangerous situations,
including threats by co-workers or an outside
party, should be reported immediately to
an employee’s supervisor, HR Business
Partner, or to WSP’s whistleblower hotline,
Expolink. Reports of threats may be treated
confidentially to the extent feasible and
allowable under applicable law. All threats
will be promptly investigated. No employee
will be subjected to retaliation, intimidation,
or disciplinary action because of reporting
a threat under this policy. The investigating
party will determine the severity of the
incident and pursue a corrective course of
action to address the immediate or perceived
danger.
Employees threatened by an outside
party should follow the steps detailed in
this section, but should also contact law
enforcement at their discretion. Even if
the threat involves an outside party, it is
important for WSP to be aware of any
potential danger in our offices.
Indeed, WSP wants to take effective
measures to protect everyone from
the threat of a violent act by an
employee or by anyone else.
Employees should call 911 for
all situations that pose immediate
safety threats.
Questions about this policy should be
directed to the U.S. Corporate Safety Director.
2.4
–––––
SECURITY INSPECTIONS
In the interest of safety, third parties
working with WSP, and to protect WSP’s
property and assets, WSP reserves the right
to conduct personal searches and workplace
inspections consistent with applicable law,
and to inspect any packages, parcels, purses,
handbags, briefcases, lunchboxes, or any other
possessions or articles carried to and from
WSP’s premises.
Additionally, WSP reserves the right to
inspect any employee’s office, desk, files
(both physical and electronic), emails, locker,
equipment, or any other area or article on our
premises. In this regard, it should be noted
that all offices, desks, files, lockers, equipment,
and other storage devices are the sole and
19
 exclusive property of WSP, and are issued
to employees for their use only during their
employment. Security inspection may be
conducted at any time at WSP’s discretion,
without prior notice.
WSP may also inspect persons (including any
packages or other belongings) entering and/
or leaving the premises. Any employee who
wishes to avoid inspection of any articles or
materials should not bring such articles or
materials onto WSP’s premises. Any illegal
drugs or drug paraphernalia will be turned
over to an appropriate law enforcement
agency and may result in criminal
prosecution.
WSP requires the cooperation of its
employees in discouraging theft or
unauthorized possession of WSP’s property
or the property of its employees, visitors,
and customers. Theft, or the unauthorized
possession of WSP’s property, its employees’
property, or the property of third parties
working with WSP will result in disciplinary
action, up to and including immediate
termination.
Persons entering WSP’s premises who refuse
to cooperate or submit to an inspection
conducted pursuant to this policy
may not be permitted to enter the
premises. Employees working on,
entering, or leaving WSP’s premises
who refuse to cooperate in an
inspection, as well as employees
who are found to be in possession
of stolen property, illegal substances,
firearms (except as otherwise provided by
applicable law), explosives, or other prohibited
materials, will be subject to disciplinary action,
up to and including termination.
20
2.5
–––––
OCCUPATIONAL HEALTH
AND SAFETY
The U.S. region has a Safety Team responsible
for monitoring and setting standards for the
safe implementation of all work conducted.
These standards will be communicated to
all employees through written plans and
programs, WSP’s intranet, and training. All
employees are responsible for familiarizing
themselves with the safety plans and
programs that apply to their position, role,
project, and/or workplace.
2.6
–––––
HAZARD RECOGNITION AND
REPORTING
2.6.1 WORKPLACE HAZARDS
All WSP employees are required to
immediately report any condition that
may result in an injury or other workplace
hazard to their supervisor and/or a member
of the Safety Team. A qualified member of
management or the Safety Team will
determine the best course of action
to eliminate the hazard. If the
hazard presents an imminent
threat to the health of any person
or property, employees should,
where possible, use their best
judgment to eliminate the danger
or remove themselves and any other
person from the danger, and notify emergency
response as needed.
Reporting of Workplace Hazards
After the immediate threat to any person
or property is eliminated, the employee or
supervisor must report the incident via iSMS
at zeroharm.onepb.net/publicforms. This link
is available via WSP’s intranet; however, the
system can be accessed from any web-enabled
device at any time and you do not need to
be connected to WSP’s network to submit
a report. The Safety Team will investigate
the incident and issue recommendations for
avoiding any similar hazard in the future.
If a WSP employee is found to be the cause
of a safety hazard, they may be subject to
disciplinary actions, up to and including
termination of employment.
Stop Work
It is the responsibility of all WSP employees
to conduct their assigned tasks safely and in
a professional manner. It is WSP’s policy that
any employee may stop work on a site where
they feel that their assigned task, or the tasks
assigned to WSP-retained contractors, may
result in an injury, illness, or loss to WSP
employees, visitors, contractor employees, or
property, including client property. This “stop
work” must be immediately reported to the
employee’s supervisor, and through iSMS.
It is the employee’s responsibility to work
with their supervisor, the contractor, and/
or the Safety Team to evaluate the task and
determine a safe means of completing the
required work.
2.6.2 WORKPLACE INJURIES
AND ILLNESS
All WSP employees are required to
immediately report any injury or work-related
illness to their supervisor, HR Business
Partner and the US Health & Safety Team
(SafetyTeam@wsp.com).  This applies even if
the injury or illness is minor and no medical
attention is needed. 
•• Injury or illness requiring medical attention
– immediately call or email the supervisor,
HR Business Partner, and US Health &
Safety Team.  Injured employee can have
others notify those identified if needed. 
Employee shall report the incident in iSMS
within 24 hours or upon return to work
unless directed otherwise.
•• Injury or illness that is minor in nature, not
requiring medical attention – employee shall
report the incident in iSMS within 24 hours.
If deemed appropriate the, the Safety Team
may investigate the incident and issue
recommendations for avoiding any similar
incident in the future.  If a WSP employee
is found to be the cause of an injury or is
categorized as an employee with a “safety
sensitive” position, the employee is subject
to Drug and Alcohol post-accident testing
requirements and may be subject to
disciplinary actions, up to and including
termination.
The US Health and Safety Team will
coordinate worker’s compensation reporting
and assist in obtaining a WC claim for the
employee, if appropriate.  The WC claim will
be needed to obtain any necessary medical
attention and/or to take a leave of absence
21
 because of the injury or illness.  The US
Health and Safety Team will work with the
supervisor to determine whether an alcohol
and/or drug screen is required in accordance
with WSP’s Drug Policy.   
Serious Injury or Death
Whenever there is an incident that results in
a death or serious injuries, such incident must
be immediately reported to the U.S. Corporate
Safety Director. A preliminary investigation
of the worksite must be conducted; to initiate
such an investigation, contact Health &
Safety for guidance. The investigator should
take written statements from witnesses
and photograph the incident scene and
any equipment and safety gear used. The
investigator should also document, as soon
as possible after the incident, the condition of
equipment and anything else at the worksite
that might be relevant. The investigator must
submit a written report to the Safety Team as
soon as possible for further investigation.
OSHA Reporting Requirements
The Occupational Safety and Health
Administration (OSHA) requires mandatory
reporting of any serious injury or death. The
U.S. Corporate Safety Director is responsible
for submitting any required report to
OSHA; however, it is the responsibility
of all employees and WSP supervisors to
immediately report all such incidents to the
U.S. Corporate Safety Director and to make all
known information readily available.
Please note:
•• An injury resulting in inpatient
22
hospitalization, an amputation, or loss of an
eye must be reported to OSHA within 24
hours of the incident.
•• An incident resulting in a fatality must
be reported to OSHA within 8 hours of
the incident.
2.6.3 “NEAR HIT OR MISS”
A “near hit or miss” is an undesired event
which, but for a fortunate break in the chain
of events, would have resulted in injury,
illness, or loss. So-called “near hits” or “near
misses” must be reported to the Safety Team
via iSMS within 24 hours of the incident.
2.6.4 FAILURE TO REPORT
Failure by an employee or manager to report
workplace injuries and illnesses in a timely
manner may result in disciplinary actions up
to and including termination of employment.
2.7
–––––
SAFETY TRAINING
WSP will provide all training deemed
necessary by the Company, federal, state,
or local regulations. All affected employees
are required to attend necessary training as
assigned by their supervisor or the Safety
Team. Additionally, WSP encourages all
employees to obtain additional training in
health and safety matters that may benefit
employees exposed to potential hazards
related to site-specific work. All voluntary
safety training must be pre-approved by
the employee’s supervisor and, if approved
by the employee’s supervisor, will be
reimbursed by WSP.
23
 3.1
–––––
3. EMPLOYEE CATEGORIES
The Company designates whether an
employee is classified as full-time, part-time,
or temporary, and whether an employee is
EMPLOYMENT
exempt from particular employment laws,
which is conveyed to the employee in the offer
letter. If an employee’s status changes during
the employee’s employment with WSP, the
employee will be notified of the change by the
employee’s supervisor or HR Business Partner.
3.1.1 FULL-TIME EXEMPT (SALARIED)
Exempt employees are those employees
whose compensation is based upon
an established salary and whose
job duties qualify them for an
exemption under applicable
wage and hour laws. Exempt
employees include the executive,
administrative, and professional
positions, which by nature of scope
of duties or educational requirements,
meet the general and technical exemption
requirements under applicable wage and
hour laws.
Throughout the year, exempt employees
may work different schedules and/or extra
hours due to workload, special projects, or
unexpected emergencies. WSP recognizes
this and therefore allows for year-round
flexibility in an exempt employee’s work
schedule, when appropriate, with supervisor
approval, and if the employee’s performance/
production requirements and client/project
needs are met.
Federal and state wage & hour laws do not
24
mandate that exempt employees receive
overtime pay.
Full-time exempt employees will be paid on a
salary basis, where such salary is intended to
cover all hours worked, including any hours
worked in excess of 40 in a workweek or in
excess of 8 hours in a day.
While exempt employees are afforded some
flexibility with respect to hours worked,
generally, to be categorized as “full-time,”
the employee is expected to work Monday
through Friday, and it is anticipated that
the employee will work at least 40 hours a
week to meet the employee’s performance/
production requirements and client/
project needs. The employee’s weekly
pay is intended to cover all hours
worked, but working less than
40 hours in a week may result
in disciplinary action, up to
and including termination, if
the employee fails to work the
necessary hours needed to meet
performance/production goals and
client/project needs.
Regular full-time employees are eligible to
participate in WSP’s benefits as well as other
benefits provided under applicable law.
3.1.2 NON-EXEMPT (HOURLY)
Non-exempt employees are those employees
who are paid on an hourly basis. For
business reasons, at its discretion, WSP may
categorize employees as non-exempt whose
job duties qualify them for an exemption
where WSP chooses to pay such employees
on an hourly basis.
Federal law requires that non-exempt
25
 employees be paid overtime at a rate of time
and one-half for all hours worked over 40
in the work week, but state or local law may
require that overtime be paid more frequently
(for example, for all hours worked over 8 in
a day) or at greater rates (for example 2 times
the employee’s rate of compensation, only
where mandated by applicable law). Where
state or local overtime requirements are
more generous to employees than the federal
law, WSP will pay employees in accordance
with state or local law. See the State-Specific
Appendix for additional information
regarding your state.
Non-exempt employees must be paid for all
hours worked. For example, if a non-exempt
employee’s normal 8-hour day runs from 8:30
AM to 5:00 PM with a 30-minute unpaid
lunch break, and the employee works through
lunch, the employee must be paid 8.5 hours
for the day.
Non-Exempt Full-Time
Employees who generally work on a regularly
scheduled basis of 40 hours per week are
considered full-time employees. Regular
Full-time employees are eligible to participate
in WSP’s benefits as well as other benefits
provided under applicable law.
Non-Exempt Part-Time
Benefits Eligible
Employees who generally work on a regularly
scheduled basis less than 40 hours a week,
but at least 24 hours a week are considered
Part-Time Benefits Eligible employees.
Part-time Benefits Eligible employees may
be eligible to participate in WSP’s benefits
26
available for part-time employees as well as
any other benefits provided by applicable
law. Regular Part-time employees must, on
average, work a minimum of 24 hours a week
to be eligible for WSP benefits.
Non-Exempt Part-Time
Benefits Ineligible
Employees who generally work on a regularly
scheduled basis less than 24 hours a week are
considered Non-Exempt Part-Time Benefits
Ineligible employees.
Regular Non-exempt Part-Time Benefits
Ineligible employees are ineligible for health
& welfare benefits, but will be eligible to
participate in WSP’s 401k plan and to receive
PTO, holiday, and recognition for their service
time/tenure. Further, Non-exempt Part-Time
Benefits Ineligible employees may be entitled
to receive additional benefits under applicable
law, such as state-specific sick leave. See the
State-Specific Appendix.
3.1.3 TEMPORARY
Temporary employees may be classified by
WSP, in accordance with the law, as exempt/
non-exempt, and full/part time. Temporary
employees are not eligible to participate in
WSP benefits, unless otherwise required by
applicable law. Temporary employees are
employees who are either hired for a specific
purpose or time period, which generally does
not exceed 90 days. A temporary employee
may work a full-time or part-time schedule.
WSP uses the three temporary employment
categories set forth below. If an employee is
not classified as a “Temporary” employee, they
are considered a “Regular” employee.
Project Employee
Employees who are hired for a specific project
and time period. The Temporary Project
Employee status will be evaluated every 90
days to re-establish the expected duration
of the project. If the expected duration of
the project extends beyond 90 days or is
unclear, the employee should be re-assigned
as a regular full-time or regular part-time
employee based on the employee’s schedule.
This employment is considered “at will,” and
both the employee and WSP retain the right to
end the employment relationship at any time
for any reason, with or without prior notice.
Occasional Employee
Employees who work on an “as needed” basis
without a regular schedule are considered
occasional employees. Occasional Employees
cannot work more than 1,000 hours per year.
If employees work more than 1,000 hours
per year, they are classified as Regular Part-
Time employees, provided they meet the
requirement of that employment status as
detailed in section 3.1.2.2.
Intern
An intern is a full-time or part-time student
who is hired to work for a semester(s), or
semester break(s), while matriculating in an
accredited degree program relevant to their
work assignment.
Interns are treated as non-exempt and will
be paid no less than the applicable minimum
wage. In advance of the internship, the intern
will be notified of how many anticipated
hours of work WSP has for the intern.
Although there is no cap on the number of
hours that an intern may work in a week, the
intern must be paid for all hours worked and
must receive overtime in accordance with
applicable overtime regulations. However,
interns must obtain supervisor approval in
advance of working any overtime. Overtime
worked without prior authorization from
WSP may result in disciplinary action, up
to and including possible termination of
employment. Interns under the age of 18
are subject to federal and state child labor
laws and additional restrictions may apply.
Consult your HR Business Partner for more
information. See also, the State-Specific
Appendix.
3.2
–––––
EMPLOYMENT AGENCIES
If a staffing or employment agency seeking
to work with WSP contacts an employee,
the employee must refer the staffing or
employment agency to the Vice President
of Talent Management. Only the Vice
President of Talent Management and the
Senior Vice President of HR are authorized
to sign agreements with outside staffing or
employment agencies. Agreements signed
by anyone else are invalid and will not be
recognized by WSP. Unsolicited resumes sent
by any staffing or employment agency will
NOT be accepted by WSP.
3.3
–––––
BACKGROUND CHECKS
WSP conducts lawful background checks,
when applicable, with the assistance of a
consumer- reporting agency. A background
27
 check, to the extent permissible under
applicable law, may be used to retrieve
information, (relating to past activities
pertaining to an applicant’s or employee’s
background), from: (1) personal references;
(2) educational institutions; (3) government
agencies; (4) businesses; (5) credit reporting
agencies; and (6) law enforcement agencies
at the federal, state or local level. In
implementing and maintaining this policy,
WSP will adhere to individuals’ rights under
the federal Fair Credit Reporting Act (FCRA)
and any applicable state and local regulations.
See State-Specific Appendix for additional
information regarding your state.
In the following circumstances, background
checks may be conducted:
During the Recruitment Process
WSP performs a background check on all
candidates who have accepted an offer of
employment from WSP. Any returning
WSP USA employee with a break in service
greater than 6 months, will need to complete
a background check.
It is clearly stated in the offer letter presented
to the candidate that the offer of employment
is contingent upon a satisfactory background
check. WSP may withdraw a job offer, after
giving the candidate a reasonable opportunity
to respond to an adverse background
check, where the adverse background
check is: (1) related to the job description or
evidences conduct that calls into question
the candidate’s ability to comply with WSP’s
Code of Conduct; and (2) evidences that
the candidate either cannot meet a job
requirement or that hiring the candidate
will pose an increased risk to WSP from
28
a job-related ethical or safety perspective.
Background checks that reveal materially
false statements on the candidate’s application
will be grounds for WSP to cease any further
employment negotiations, after the candidate
is given a reasonable opportunity to respond
to the alleged falsehood.
Security Clearance
If necessary to obtain a security clearance
required for government projects, a
background check may be conducted, or
information such as citizenship status
verified. If security clearance is required,
additional background checks may be
completed to meet required compliance.
If the employee cannot obtain a security
clearance required for the employee’s
assignment, depending on the nature of the
adverse background check, WSP will strive to
identify another assignment for the employee,
but if transfer to another project is not
possible, the employee may be terminated.
Client Request
Upon client request, either specified in the
project requirements or upon written request
from a client representative, to the extent
allowable by law, WSP will conduct applicable
background or reference checks, which may
include drug/alcohol tests.
In such cases, if the employee’s background
check does not satisfy project or client
requirements, thereby making the employee
ineligible to work on the project, depending
on the nature of the adverse background
check, WSP will strive to identify another
assignment for the employee, but if transfer to
another project is not possible, the employee
may be terminated.
If an employee refuses to submit to such a
background check, and a transfer to another
project is not possible, the employee may
face disciplinary action up to and including
termination.
MVR Verifications for Drivers
of Company Vehicles
Employees who drive Company-leased
vehicles through the Company’s nationwide
”Fleet Management” program will be
subject to a pre-assignment Motor Vehicle
Record (MVR) verification, as well as annual
MVR verifications for the duration of their
employment, or until their duties change and
they are no longer assigned or authorized to
drive the Company-leased vehicles. Employees
who complete the Vehicle User Agreement
& MVR Authorization will be required to
complete US Drivers: Defensive Driving
Course on MyLP. Employees who frequently
drive their personal vehicle in the line of duty
and report their mileage through expense
reporting may also be subject to annual MVR
verifications. Where applicable, if an employee
refuses to consent to MVR verification, the
employee may be subject to disciplinary action,
up to, and including, termination.
Employees whose verifications produce
adverse results may have training
requirements imposed upon them, face
restrictions related to the use of company
vehicles, or may be terminated.
3.4
–––––
REHIRE
Employees who return to WSP after a
break in service of less than five years, and
which does not exceed their original tenure,
are considered a returning employee. For
example, where Employee A worked for
WSP for 3 years and returns after a 4-year
absence, Employee A may not be considered
a returning employee, but where Employee
B worked for WSP for 2 years and returned
after a 1-year absence, Employee B may be
considered a returning employee.
Where the above conditions are met, a
returning employee’s prior employment with
WSP will be considered part of the employee’s
total length of service for seniority purposes
and benefits accruals where applicable.
Employees who are rehired after five years
are considered new hires and the re-hire
date will be considered the employee’s date
of hire for seniority purposes and benefits
accruals where applicable. Employees who
are hired as regular full-time or regular part-
time employees after serving the company
as a temporary employee are considered new
hires, and the date upon which they become
a regular full or regular part time employee
will be considered the employee’s date of hire
for seniority purposes and benefits accruals
where applicable.
3.5
–––––
IMMIGRATION
All offers of employment are contingent on
verification of an employee’s right to work
in the United States. In compliance with
the Immigration Reform and Control Act of
1986, each new employee, as a condition of
employment, must complete the Employment
29
 Eligibility Verification Form I-9 and present
appropriate documentation establishing
identity and employment eligibility within
three (3) business days of commencing
employment.
For more information on our Immigration
program, please refer to the Immigration
Compliance Plan & Policy, and accompanying
guidance and forms, available on the intranet.
3.6
–––––
EMPLOYMENT OF RELATIVES
No individual may report, directly or
indirectly, to a person who is a relative or a
person with whom the individual has
an intimate personal relationship.
All individuals involved must
disclose any such relationship to
their supervisors above the level
at which the relationship exists
and to the employee’s HR Business
Partner, to allow for transfers and/
or reassignments as needed.
Warning: Employment of relatives or
individuals with whom an employee has
a romantic relationship, even outside of
direct or indirect reporting lines poses the
risk of potential conflicts of interest; dating
colleagues outside of an employee’s direct or
indirect reporting line poses similar risks.
Such relationships should be disclosed to
the employee’s supervisor and HR Business
Partner. Employees are also encouraged to
review the U.S. Region Personal Conflicts of
Interest Policy, available on the intranet, and
to consult with the U.S. Conflicts of Interest
Officer (available at ethics@wsp.com) if they
have conflicts questions.
30
Where familial or romantic relationships
create a conflict of interest that cannot be
adequately mitigated or where WSP discovers
that individuals failed to disclose such
relationships, WSP may take disciplinary
action, up to and including termination.
3.7
–––––
FURLOUGH
If there is no immediate work for an
employee, but there is a reasonable
expectation that work will develop within
three months, the employee may be placed
on furlough.
During the furlough, employees will
be paid through the last day worked.
Employees will have the option to
cash out all or a portion of their
accrued but unused Paid Time Off
(PTO) at the beginning of their
furlough; however, PTO cannot
be used to postpone a furlough and
employees do not continue to accrue
PTO while on furlough unless hours are
worked during furlough.
If the employee is enrolled in Medical, Dental
and/or Vision insurance prior to going on
furlough, the Company will continue these
benefits during the three-month furlough
period providing the employee continues to
pay the employee portion of the premiums.
During a furlough, an employee is responsible
for all elected benefit premiums, and will be
sent a letter by The HR HUB instructing the
employee on how to pay the premiums.
Corporate cards will be suspended while an
employee is on furlough. Prior to the furlough
start date, the manager will collect expense
reports for outstanding expenses.
Approximately two weeks prior to the
employee reaching three months on
furlough, the HR Business Partner will
contact the employee’s manager to discuss
the next course of action for the furloughed
employee. The employee’s manager must
take one of two actions:
•• Return Employee to Active Status – If the
work is available.
•• Layoff – Convert the furlough to a layoff.
In the event of a conversion from furlough
to layoff, the employee is only entitled to
one additional month from the end of the
month of layoff for medical, dental and vision
benefits.
HR Business Partners can provide additional
information about furloughs.
3.8
–––––
DEPARTURES
Because employment with WSP is “at will,”
as defined above, and except where formal
employment agreements or applicable
law may limit such status, WSP and the
employee have the right to terminate the
employment relationship, at any time, with
or without cause.
Where an employee is exercising their right
to terminate the employment relationship,
WSP asks that employees submit a written
notice of resignation to their supervisor at
least 10 working days before their anticipated
last day of employment. WSP reserves the
right, upon receipt of notice, and at its sole
discretion, to terminate the employee’s
employment immediately with no obligation
to pay wages for any days following the date
of termination.
If business needs dictate a need to involuntarily
terminate an employee as part of a layoff or
reduction in force, the affected employee will
be given advance notice, to the extent possible,
and as required by applicable law.
3.8.1 BENEFITS UPON DEPARTURE
Upon the voluntary or involuntary
termination of employment all employees
will be paid through the end of their last day
worked. Any accrued but unused PTO will
be paid out, less required deductions, on the
next available payroll following the last day
worked, unless state law requires otherwise.
Following the termination, all benefits will
cease at the last day of the month in which
the termination occurred; however, employees
may be eligible to continue some benefits
through COBRA and will receive appropriate
information within 44 days of leaving WSP,
unless state law requires otherwise. All other
benefits (commuter, life insurance, etc.) will
end on the date of termination.
3.9
–––––
EMPLOYMENT VERIFICATION/
REFERENCES
Any request for employment verification
or references must be forwarded to your
HR Business Partner. It is the policy of
WSP to confirm only job title and dates of
employment. Any additional information may
be released only upon written authorization
from the employee, or as required by law.
31
 4.1 schedules from the standard office hours to
a flexible schedule must request and receive
–––––

4.
WORK WEEK
The standard work week for all employees
begins at 12:00 a.m. Saturday and ends
at 11:59 p.m. Friday. For regular full-time
written approval for their proposed flextime
schedule from their supervisor. A request
that includes authorization to work remotely,
must also receive written approval from the
employee’s HR Business Partner.

STANDARD
employees, generally, standard office hours run
A flextime schedule should not negatively
from 8:30 AM to 5:15 PM, Monday through
affect the workload or productivity of
Friday, with daily lunch breaks of 45-minutes,
coworkers either by shifting burdens, creating
but may vary by office; furthermore, standard

WORK
delays or additional steps in work flow.
office hours vary in accordance with
Employees should not assume or expect that
WSP’s Summers Hours and Holiday Hours
flexible work hours are available upon request
Programs, which are published annually. See

WEEK/DAY
Employment Section above for definitions of
“full-time,” “part-time,” “exempt,” and “non-
exempt” employees. Non-exempt lunch breaks
are unpaid, as discussed below.
Supervisors are responsible for establishing
the standard work week for regular part-time
employees and temporary employees, to the
extent feasible.
Where the demands of the business can
accommodate such options, WSP allows
managers and employees to explore flextime
options to meet family or other personal
needs. Flextime options may include
permitting an employee to work
remotely, subject to supervisor
approval, written approval
from your HR Business
Partner, and adherence to
any telecommuting policies,
guidelines, and practices
established by WSP.
or irrevocable, if granted. WSP reserves the
right to revoke flexible work schedules or
to immediately suspend the arrangement in
the event of unanticipated circumstances
regarding employee performance or
operational needs.
At WSP’s discretion, employees who
have a history of poor attendance and/or
performance may be ineligible for a flexible
work schedule.
4.1.1 MEAL & REST BREAKS
Exempts
Exempt employees are afforded some degree
of flexibility to take meal and rest breaks
of varying durations, if performance/
production requirements and client/
project needs are met. While taking
meal or rest breaks will not alter an
exempt employee’s pay, meal and rest
breaks are non-billable and employees

Full-time employees who are in

good standing with WSP are eligible
to be considered for a flexible work schedule.
Employees who wish to change their
32 33
 should never bill a client for non-working
time. Unlike non-exempt employees, exempt
employees may also skip meal and rest breaks
without supervisor approval.
Non-Exempts
Except where a supervisor approves a flexible
work schedule, WSP’s standard office hours,
generally, include an unpaid 45-minute lunch
break or as otherwise required by applicable
law. See State-Specific Appendix.
Non-exempts must be relieved of all work
during such breaks and permitted to leave
the premises. If non-exempts are asked to
perform work during an unpaid meal break,
they must be paid for such time. For example,
if a non-exempt employee’s normal 8-hour
day runs from 8:30 AM to 5:00 PM (under
a flexible work schedule), with a 30-minute
unpaid lunch break, and the employee works
through lunch, the employee must be paid
8.5 hours for the day. Note that state or
local law may require an employer to pay
additional compensation to an employee who
is not provided with a lunch break. For this
reason, non-exempt employees wishing to
work through lunch, must receive advanced
written approval from their supervisor.
Moreover, employees entitled to meal or rest
periods under state/local law should not feel
pressured, discouraged, or coerced to skip
their meal or rest breaks.
Employees who work through meal and,
where applicable, rest breaks, without
supervisor approval, may be written up by
the supervisor, and disciplinary action, up
to and including termination, may be taken
where the employee repeatedly skips their
mandated meal or rest breaks, without
34
supervisor permission. Supervisors may also
face disciplinary action, up to and including
termination, for pressuring, discouraging, or
coercing non-exempts to skip their meal, or
where applicable, rest breaks.
If an employee feels that they are unable to
take a meal or, where applicable, rest break,
the employee should promptly report the
situation to their HR Business Partner or to
Expolink. Similarly, if supervisors observe
non-exempt employees working through meal
and, where applicable, rest breaks, supervisors
should address such matters with their non-
exempt employees or if the non-exempt
employee does not work for the supervisor
with the non-exempt employee’s supervisor,
HR Business Partner, or through Expolink.
4.1.2 BREAK TIME FOR
NURSING EMPLOYEES
WSP will provide non-exempt employees
reasonable unpaid break time, or permit
employees to use paid break time, meal time,
or both to express breastmilk for 3 years
after a child’s birth, each time an employee
has need to express the milk. If possible,
the break time must run concurrently with
rest and meal periods already provided to
the employee. Break time that cannot run
concurrently with rest and meal periods
already provided to the employee is unpaid,
to the extent permitted by applicable law. See
State-Specific Appendix.
Exempt employees are afforded some degree
of flexibility to take breaks to express
breastmilk, but such time is non-billable and
employees should never bill a client for non-
working time.
The Company will make reasonable efforts
to provide an employee with use of a private,
secure and sanitary room or location, other
than a bathroom stall, for an employee to
breastfeed or express milk. This location may
be the employee’s private office, if applicable
or the location may include a childcare
facility in close proximity to the employee’s
work location.
WSP is not required to provide break periods
for expressing milk if it would impose an
undue hardship on business operations.
Employees can contact their HR Business
Partners with questions regarding this policy.
4.2
–––––
ATTENDANCE AND ABSENCES
WSP employees are expected to be at
work regularly and on time. If, for
any reason, employees cannot
report to work, they must notify
their supervisor prior to their
regular start time unless there
are extenuating circumstances (at
which time they must notify their
supervisor as soon as possible) or
are otherwise excused by applicable
law. Absences of more than one day must
be reported daily, unless other arrangements
have been made with the supervisor or HR In
the event an employee misses five consecutive
days due to illness, they should contact their
HR Business Partner to request short-term
and/or long-term disability leave.
Excessive or chronic unexcused absenteeism
or tardiness may be grounds for disciplinary
actions, up to and including termination. An
employee’s failure to notify their supervisor
or HR Business Partner for three consecutive
days will be considered an abandonment of
the job, and a voluntary termination, unless
otherwise excused by applicable law.
In enforcing and evaluating employee
compliance with this policy, the Company
does not count absences/tardiness protected
by applicable federal, state, or local law against
the employee.
4.3
–––––
INCLEMENT WEATHER
During inclement weather, WSP offices are
open unless employees are notified otherwise.
Office closings should be rare and occur only
during a severe weather emergency affecting
the area where the office is located, or when
recommended by federal, state or local
government. During an office closing,
whether it is a partial or full day
closing, employees should attempt
to work from another WSP
location or seek permission from
their supervisor to work remotely.
During inclement weather, regular
full-time and regular part-time
employees will be paid based on their
exemption status. See the Employment
Section for the definition of exempt/non-
exempt.
Non-Exempt Employees
Non-exempt employees will be paid for their
hours worked. If they are unable to perform
work from another WSP location or remotely
with manager approval, employees may use
PTO time or take time off without pay during
the office closing.
35
 Exempt Employees
If WSP decides to close its offices for
weather-related reasons or when otherwise
required by federal, state, or local law, exempt
employees should attempt to perform their
work from another location. If the closure is Full-time employees
only for a portion of the workweek, exempt
employees will be paid for the days WSP has who are in good
closed the office. If the office remains open
during inclement weather, exempt employees standing with
who are unable to perform work for a full
workday either from another WSP location or WSP are eligible
remotely due to personal reasons may use PTO
time or otherwise take time off without pay. to be considered
If WSP decides to close its offices for an for a flexible work
entire workweek, and an exempt employee
does not perform any work during that week schedule. Employees
(including answering emails, calls, etc.), the
employee will not be paid for that week. who wish to change
Temporary Employees their schedules from
Temporary employees will not be paid and
should not perform any work during an
the standard office
office closing. hours to a flexible
schedule must
request and receive
written approval
for their proposed
flextime schedule
from their supervisor."

36 37
 WSP is committed to providing a fair and
competitive compensation package to all
5.
employees. Decisions about compensation,
promotions and transfers are made based on
performance and level of experience, without
regard to an employee’s status in one or more
Protected Classes.
COMPENSATION
5.1
–––––
OVERTIME ELIGIBILITY
WSP pays overtime to non-exempt employees
in accordance with applicable law and to
exempt employees under the conditions
set-forth below. See Employment Section for
definitions of exempt/non-exempt.
Exempt Employees (Salaried):
Not Legally Entitled to Overtime
Regular full-time exempt employees will
be paid on a salary basis. Although exempt
employees are not legally entitled to receive
any overtime, WSP may, on a discretionary
basis, pay overtime to exempt P-Grade
employees only where such overtime payments
are approved by the employee’s supervisor.
However, exempt employees with a grade of
X-11 and above, a P-grade of P-15 and above,
and all E grades will not be paid overtime.
Non-Exempt Employees (Hourly
Employees): Legally Entitled to
Overtime
It is expected that non-exempt employees
can complete their job assignments within
the time allotted by a standard work week;
however, overtime is sometimes required to
meet project deadlines.
Non-exempt employees will be paid overtime
38
at a rate of time and one-half for all hours
worked over 40 in the work week, but state
or local law may require that overtime be
paid more frequently (for example, for all
hours worked over 8 in a day) or at greater
rates (for example, 2 times the employee’s
regular rate of compensation). See State-
Specific Appendix for additional information
regarding your state.
5.1.1 ADVANCE APPROVAL
FOR OVERTIME
All overtime work must be authorized in
advance by an employee’s supervisor and
approved on a timesheet by an employee’s
supervisor. No unauthorized overtime should
be worked. Working overtime without
authorization may result in disciplinary
action, up to and including termination.
However, all overtime worked (regardless of
whether authorized) must be recorded on the
employee’s timesheet. All employees must
accurately record their time worked, and
overtime will be paid in accordance with this
Employee Handbook and applicable law.
5.1.2 NO TIME OFF IN LIEU OF
OVERTIME PAY
If non-exempt employees work overtime,
they must be paid overtime pay in accordance
with applicable law and WSP policies;
exempt employees may be paid overtime on
a discretionary basis and in accordance with
WSP policies. Under no circumstances may
a supervisor promise or agree to provide
employees unpaid time off as a substitute
for overtime pay. In addition, WSP strictly
prohibits all employees, regardless of their
exempt/non-exempt status, from recording
their work time, or billing a client for work,
39
 inaccurately. For example, to avoid the
appearance of overtime.an employee may not
wait until a subsequent week to record hours
worked during a previous week.
Time spent commuting
Time spent commuting to and from work is
not considered time worked and is not counted
as part of the employee’s regular workday,
nor is it considered in the computation of
overtime. Time spent traveling to client sites,
other WSP offices, or other outside locations
is considered travel time. In accordance with
applicable law, non-exempt employees will
be paid for all travel time and any overtime
hours worked. If travel begins at the employee’s
residence, travel time is measured less the
employee’s regular commuting time, unless
applicable law requires otherwise. If the
employee is traveling on an overnight
assignment to an off-site location,
the employee will be paid for time
spent traveling in accordance with
the above and applicable law. As
allowable by law, the employee will
be paid their regular rate of pay for
any time worked while at the off-site
location; time not worked at the off-site
location (e.g., after hours and nights) will not
be paid.
5.2
–––––
PAY PERIODS
WSP follows a biweekly payroll schedule. For
purposes of payroll, the workweek begins at
12:00 AM on Saturday and ends at 11:59 PM
on Friday. Employees are paid biweekly (by
check or direct deposit) on Friday for all time
40
worked during the previous two weeks. The
biweekly payroll schedule is made up of 26
pay periods per year. Changes will be made
and announced in advance when holidays or
closings will interfere with the normal pay
schedule. All employees are paid with a one-
week lag, for hours worked in the previous
two-week period.
Paychecks are distributed to individual
employees unless they request that paychecks
be mailed to their home address. Employees
may also authorize, in writing, that another
person has permission to accept their
paycheck(s). Direct deposit is available upon
an employee’s consent.
Employee payroll stubs itemize deductions
made from gross earnings. The Company is
required by law to make deductions for
Social Security, federal income tax
and any other appropriate taxes.
These required deductions include
any court-ordered garnishments.
Payroll stubs also itemize any
voluntary deductions such as an
employee’s portion of health, dental,
or other insurance premiums and/or
voluntary contributions to a 401(k) plan,
to the extent applicable. If applicable, payroll
stubs will also differentiate between regular
and overtime pay received.
Employees who believe there is an error
in their pay should bring the matter to the
Payroll department (uspayroll@wsp.com)
immediately, so that the Company can
investigate and resolve the matter quickly
and amicably.
5.3
–––––
DEDUCTIONS FOR EXEMPT
EMPLOYEES
Exempt salaried employees receive a salary
that is intended to compensate for all hours
worked for the Company. This salary is
established at the time of hire. The salary
may be subject to review and modification
from time to time, such as during salary
review times.
Under federal and state law, exempt salaried
employees’ salaries are subject to certain
deductions. For example, absent contrary
state law requirements, exempt salaried
employees’ salaries are subject to reduction
for the following reasons:
•• Full day absences for personal reasons;
•• Full day absences for sickness or disability
in accordance with our PTO policy;
•• Full day disciplinary suspensions for
infractions of our written policies and
procedures;
•• Family and Medical Leave absences (either
full or partial day absences);
•• To offset amounts received as payment for
jury and witness fees or military pay; or
•• The first or last week of employment in the
event of less than a full week worked.
Exempt salaried employees’ salaries are also
subject to reduction for their portion of
health, dental, or other insurance premiums;
federal, state, or local taxes; social security; or
voluntary contributions to a 401(k) plan.
In any workweek in which exempt salaried
employees perform any work, their salary
is not subject to reduction for any of the
following reasons:
•• Partial day absences for personal reasons,
sickness, or disability;
•• Absence due to the Company’s decision to
close a facility on a scheduled work day;
•• Absences for jury duty, attendance as a
witness, or military leave in any week in
which any work is performed; or
•• Any other deductions prohibited by state or
federal law.
However, subject to state law, it is not an
improper deduction to reduce exempt salaried
employees’ accrued vacation, personal, or
other forms of paid time off banks for full
or partial day absences for personal reasons,
sickness, or disability.
Employees who believe they have been
subject to an improper deduction should
report the matter to their supervisor
immediately. If the supervisor is unavailable
or is an inappropriate person to contact, or if
a prompt and fully acceptable reply has not
been received within five (5) business days,
the employee’s HR Business Partner should be
contacted.
Every report of improper deductions will be
fully investigated and corrective action, up
to and including discharge, will be taken, as
appropriate, for any employee(s) who violates
this policy. In addition, the Company will
not allow any form of retaliation against
individuals who report alleged violations
of this policy or who cooperate in the
Company’s investigation of such reports.
Retaliation is unacceptable, and any form
of retaliation in violation of this policy
may result in disciplinary action, up to and
41
 including discharge.
5.4
–––––
TIMESHEETS
Employees are responsible for accurately
recording time worked in Oracle Time &
Labor (OTL). Timesheets must be completed
weekly and formally submitted and approved
each week by end of business each Friday.
Changes will be made and announced in
advance whenever holidays or closings
interfere with the normal timesheet schedule.
Although full-time exempt employees are
salaried, for administrative purposes, full-
time exempt employees are expected to
work a minimum of 40 hours a week and
record a minimum of 40 hours a week on
their timecard. Employees are only allowed
to charge client projects for hours that are
worked on client projects on a specific day.
5.5
–––––
BONUS PROGRAMS
WSP has established several bonus programs
aimed at incentivizing performance and
encouraging professional development. The
decision to award any bonus, the amount
of any bonus, and the timing of any bonus,
is purely discretionary, and based on
the sole discretion of WSP. The bonuses
awarded under these bonus programs are
not earned until the time of payment, and
only employees who are active employees in
good standing at the time of payment will be
eligible to receive a bonus.
Unless otherwise indicated, all bonus
42
payments are subject to taxes and other
withholdings. For additional information,
employees may contact their HR Business
Partners.
5.5.1 MERIT BONUS
Regular full-time and regular part-time
employees with a grade of P-11 and above, and
all X grades, are eligible to participate in the
WSP’s discretional Merit Bonus Program. This
program will be implemented based on WSP’s
performance against financial targets, with
consideration to individual performance.
5.5.2 SPOT AWARD
The Spot Award Program is intended to
provide the opportunity for immediate
recognition of a specific action or
achievement beyond what is normally
expected of an employee. The Spot award
may be used to reward a wide range of
contributions by performance or actions in
how WSP achieves success, consistent with
our core values.
Employees with a grade of P-10 or below may
be nominated for a Spot Award. Managers
and employees with first-hand knowledge
of an employee’s contribution may email
their HR Business Partner to nominate an
employee for the Spot Award program. The
Award includes recognition of a one-time
bonus up to $1,000. All Spot Awards must
also have the appropriate business approval.
5.5.3 EMPLOYEE REFERRAL BONUSES
WSP encourages, recognizes and rewards
employees for recommending and recruiting
high quality talent to the organization. All
employees may participate in this program,
with the exception of: the Hiring Manager,
anyone in a direct reporting relationship with
the new hire, family members of the new hire,
all employees in Human Resources, and all
employees with a grade of P-14 and above.
To receive an Employee Referral Bonus, the
following criteria must be met:
•• Candidates may not be current WSP
employees;
•• Candidates who are former employees must
not have been employed by WSP during the
5 years preceding rehire;
•• Candidates must be hired as regular, full-
time employees;
•• Candidates must complete 6 months of
continued employment; and
•• Referring employee must be an active WSP
employee at time of payment.
The $1,500 referral bonus will be paid after
the candidate has completed 6 months
of continued employment. To receive the
referral bonus, the referring employee should
complete the Employee Referral Program
Bonus Form within one year of the hire. HR
will confirm the source of the referral prior
to payment of the bonus. Referral bonuses
are not paid if any recruitment agency
fee is involved in hiring the employee’s
recommended individual or knowledge of
the individual has come through any other
source. The referral bonus is paid through
regular payroll and subject to standard
deductions. The employee referral bonus
is unearned until the time of payment and
both employees must be employed in good
standing with WSP at the time the referral
bonus is paid.
5.5.4 PROJECT INCENTIVE PLANS
In the case where a Project Manager or a
Client wishes to establish a bonus plan for a
specific project, a Project Incentive Plan may
be developed in collaboration with the U.S.
CFO and the Director of Total Rewards.
Project incentive plan bonuses are intended
to incentivize and reward specific project
performance or target goals. Each project
incentive plan is designed specifically for
the particular project – including the metrics
and calculations, incentive pool amount,
participants, individual award determination
and payout dates. Final bonus determinations
under the plan must be approved, in advance,
by the U.S. CFO.
5.5.5 PROFESSIONAL
LICENSURE PROGRAM
WSP recognizes the value professional
licenses and certifications add to the business.
To encourage employees to obtain licenses,
registrations and certifications (hereafter
licenses) applicable to their position, WSP
has established a Professional Licensure
Reward Program. All employees are
eligible to participate in this program. WSP
maintains a list of approved licenses which
may be recognized, however the employee’s
supervisor may deny a request for reward
if the license the employee obtained is not
relevant to their role with WSP.
Essential Licenses
A license required by code or regulation
43
 to perform a certain task that is key to the
employee’s work (e.g. signing and approving
engineering drawings) is considered an
Essential license. The first time an employee
obtains an eligible Essential license, they
will receive a one-time increase to base
pay of approximately $2,500 ($1.21 per
hour). To receive this increase, the employee
must submit a copy of the attained license
or document of completion reflecting the
license number to your HR Business Partner.
The increase will be effective on the start
of the pay period following the receipt of
the documentation. If the employee obtains
additional licenses that are considered
Essential, they may be rewarded as an
Enhancing license.
Enhancing Licenses
A license or certification which adds
value to a majority of projects or helps the
employee perform better in the employee’s
role, but that is not required by code or
regulation to perform a certain task (e.g.
LEED) is considered an Enhancing license.
When obtaining an Enhancing license, the
employee will receive a one-time $500
bonus, which is discretionary and subject to
manager approval. Employees who obtain
multiple Enhancing licenses are able to
receive multiple rewards, subject to manager
approval, up to a lifetime maximum of
$2,500. To receive the bonus, the employee
must submit a copy of the attained license or
document of completion reflecting the license
number, along with manager approval, to an
HR Business Partner. The bonus will be paid
on the next payroll following the receipt of
the documentation.
44
Exclusions
Employees will be rewarded for licenses only
the first time they are obtained. For licenses
that have multiple levels (i.e. LEED), the
employee will be rewarded upon completion
of one level, but not for obtaining any of
the other levels, unless specific business
requirements warrant an exception. For
state-specific licenses, the eligible employee
is able to receive a reward the first time the
employee obtains the license, but not for
extending the license through reciprocity to
subsequent states (e.g. employees who first
obtain a PE license in one state will not be
rewarded for obtaining additional PE licenses
in any other state). License renewals and re-
certifications will not be rewarded.
Reimbursement of costs
In addition to the rewards outlined here, WSP
may reimburse the employee for the cost of
preparatory classes, exam fees and/or re-
certification fees. In general, the Company
will cover the expenses related to Essential
licenses; however, reimbursement for all
licenses may be approved or denied at the
discretion of the employee’s supervisor.
Expenses related to the completion and
receipt of an essential license should be
submitted through iExpense.
Exam Day
The first time an employee obtains an
Essential or Enhancing license, the employee
may be excused from work on the day of the
exam without using PTO, providing it falls on
a regular weekday. If a non-exempt employee
is obtaining a job-related Essential or
Enhancing license with supervisor approval,
on a non-workday, the non-exempt employee
will be paid for time spent taking the exam
and for travel time to and from the exam.
5.6
–––––
PERFORMANCE AND
COMPENSATION REVIEWS
5.6.1 PERFORMANCE REVIEWS
WSP has a formal Performance Management
Program (PMP) which includes an annual
performance review. A performance review
may also be conducted in anticipation of or in
the event of a promotion or change in duties
and responsibilities. A good performance
review does not guarantee a pay increase,
nor is it a promise of continued employment.
Annual evaluations are not intended to
discourage feedback sessions or delay
discussion of any performance issues that
may occur at any given time.
5.6.2 COMPENSATION REVIEWS
WSP has an Annual Merit Increase Program,
where regular full-time and regular part-time
employees’ salaries are reviewed company-
wide. Merit increases are based on individual
and Company performance and are not
guaranteed.
5.6.3 PROMOTIONS AND
OPEN POSITIONS
WSP has a policy of providing our employees
with every opportunity for advancing to
other positions within WSP. Promotion from
within is an important part of recognizing
and rewarding capable employees. A
promotion is an upward movement within
the Company as a result of a different, but
clearly higher, level of responsibility such
as increased job complexity, increased and
broader supervisory or managerial duties
over employees or a function, and/or
expanded budgetary authority. An individual
who is promoted has met the minimum
requirements for education, registration
(where applicable) and experience for the
new job and has demonstrated performance
in their current position that warrants
consideration for a promotion.
5.6.4 INTERNAL TRANSFERS
WSP will, at its discretion, post open
positions internally via WSP’s intranet prior
to general release. Additionally, international
and intercompany positions are posted online.
Employees who meet the qualifications for
job vacancies may apply for the position
online to be considered for promotion or
transfer. The employee must be in good
standing and employed by WSP for at least
three months. If an employee feels that
they are qualified to perform a posted job,
they should speak with their supervisor
and/or their HR Business Partner, prior to
application, and request consideration for the
open position.
5.7
–––––
RELOCATION
Employees may sometimes be asked to
relocate on a temporary or permanent basis
to assume a different position in another WSP
location in the U.S. or worldwide. Employees
will have no adverse treatment because of
declining such a request if they are unable
to travel due to personal obligations, if the
employee’s current position is not being
45
 relocated in its entirety. Employees who accept
the request to relocate may be eligible for one
or more of the below relocation benefits. The
details of an employee’s relocation package
are determined by the supervisor of the
receiving location. Unless directed by special
circumstances, the receiving location will fund
the relocation package.
5.7.1 RELOCATION PACKAGES
Relocation packages, consisting of various
payments, reimbursements, and allowances
are available to employees relocating at WSP’s
request. An employee’s supervisor and HR
Business Partner will present a relocation
package to the relocating employee,
which will set-forth specific details
of payments, reimbursements,
allowances, and tax implications.
Relocation packages will be
designed in accordance to WSP’s
Permanent Domestic Relocation
Policy, Temporary Assignment
Policy, and/or project specific
requirements. Reimbursement of
relocation is handled through the Payroll
department. Employees should contact their
HR Business Partner if they have questions.
5.7.2 EMPLOYEE-REQUESTED
TRANSFERS
Employees interested in a change in location
or practice area are required to discuss their
wishes with their supervisor and HR Business
Partner. WSP will attempt to accommodate
transfer requests after considering staffing
needs at both locations/areas.
A moving allowance or cost of living
adjustment is typically not provided for
employee-requested transfers, however, the
46
receiving location may, at their discretion,
choose to offer such allowance or adjustment.
5.8
–––––
BRING YOUR OWN MOBILE
(BYOM) STIPEND
This section addresses the BYOM stipend and
payment details. The terms and conditions
related to accepting the BYOM stipend are
discussed later in the Employee Handbook
under WSP’s IT’s Mobile Device Policy and
the U.S. IT Acceptable Use Policy. Employees
must familiarize themselves with and
comply with the aforementioned policies as
a condition of accepting the stipend;
if an employee accepts payment of
the BYOM stipend, it is assumed
that the employee has agreed to
the terms and conditions of use
set forth in the aforementioned
policies.
WSP provides a $60 monthly
stipend to help offset the costs of
approved employees, with an acknowledged
business need to do so, using their personal
mobile devices for telephone calls, to connect
to and access work email, contact lists and
calendars and to use the internet through
their mobile devices for work related
purposes.
5.8.1 AUTOMATIC BYOM STIPEND
ENROLLMENT: P-13 AND ABOVE (OR
EQUIVALENT GRADES)
Full time exempt employees who are grades
P-13 and above (or equivalent grades) will
automatically receive the monthly stipend
because WSP recognizes the business need for
such employees to use their mobile devices as
inherent at such grade levels.
5.8.2 ENROLLMENT UPON REQUEST
BASED ON BUSINESS NECESSITY: ALL
GRADES P-12 AND BELOW (EXEMPT &
NON-EXEMPT)
For all lower grades (including exempt and
non-exempt positions), enrollment in the
BYOM stipend program is considered on a
discretionary basis. An employee seeking
the BYOM stipend must obtain advance
supervisor approval and show that use of
their personal mobile device for work-related
purposes, during normal working hours or
outside of normal working hours, is primarily
triggered by business necessity as opposed to
employee convenience.
BYOM stipend requests can be made through
the IT Service Desk Portal. With supervisor
approval, an employee who establishes
that use of their personal mobile device
is a business necessity and not merely a
convenience to the employee, should receive
the BYOM stipend.
5.8.3 NO BYOM STIPEND FOR
CONVENIENCE BASED USE OF
PERSONAL MOBILE DEVICE
Employees who do not receive the BYOM
stipend, but who voluntarily elect to use
their mobile devices to access WSP email and
systems, may do so for their convenience, so
long as they properly record all hours worked
in accordance with WSP policies and federal,
state, and local wage-and-hour laws.
Employees who elect to access WSP’s email or
systems through their personal mobile devices
for their own personal convenience are still
obligated to abide WSP’s IT’s Mobile Device
Policy and the U.S. IT Acceptable Use Policy.
5.8.4 SUPERVISOR RESPONSIBILITIES
If a supervisor is requiring an employee
to use their personal mobile device to
satisfy legitimate business needs, the
supervisor should assist the employee with
obtaining the BYOM stipend and approve
BYOM stipends where business necessity
demands the use of the employee’s personal
mobile device. However, the supervisor
should not abuse the BYOM program and
approve the stipend in situations where use
of a personal mobile device is merely for
the employee’s convenience.
If an employee is not receiving the BYOM
stipend, WSP expects that supervisors will
not communicate with such employees,
about work-related matters, in a manner
that requires such employees to use their
personal mobile device. If supervisors are
aware of an employee being forced to use
their personal mobile device, out of business
necessity as opposed to electing to use their
personal mobile device for convenience, the
supervisor should assist the employee with
obtaining the BYOM stipend or report the
situation to the employee’s HR Business
Partner for proper handling.
47
 5.8.5 EMPLOYEE RESPONSIBILITIES the employee should speak with their HR
Business Partner.
Employees are responsible for completing
the necessary paperwork for the stipend, A failure to adhere to the procedures set
for obtaining the proper approvals, and forth here or in WSP’s Mobile Device Policy
for informing their HR Business Partner (set forth below) may result in disciplinary
if they believe they are being forced to action, up to and including termination.
use their mobile device for work related
activities, but denied the stipend. Also, if an
employee believes that the BYOM stipend
does not fully cover the portion of their
mobile device used for work purposes, the
employee should promptly notify their HR
Business Partner of the perceived shortfall.

WSP provides a $60

If an employee who is otherwise eligible
to receive the BYOM stipend voluntarily
chooses not to participate in the program, monthly stipend to
such an employee must send an email to
their HR Business Partner stating that they help offset the costs of
do not wish to receive the BYOM stipend. approved employees,
5.8.6 TIMING OF BYOM STIPEND
with an acknowledged
The BYOM stipend is paid the second Friday
business need to do
of each month for the previous months’ usage.
The stipend is a non-taxable payment and so, using their personal
therefore it will not be grossed up. The stipend
will be paid separately by Accounts Payable
mobile devices for
and is not included in the employee’s paycheck. telephone calls, to
5.8.7 REPORTING BYOM connect to and access
RELATED CONCERNS
work email, contact
If an employee is using their personal
mobile device out of business necessity as lists and calendars
opposed to convenience, but the employee and to use the internet
is not receiving the BYOM stipend, the
employee should seek BYOM approval through their mobile
from their supervisor and submit a BYOM
devices for work
request through the IT Service Desk Portal.
If an employee feels that their supervisor is related purposes."
wrongfully withholding BYOM approval,

48 49
 WSP is committed to offering a
comprehensive benefits program to all
eligible employees. WSP will periodically
6. review these benefits and reserves the right
to modify, add or delete the benefits offered.
6.1
–––––
BENEFITS
ELIGIBILITY
Unless otherwise noted, benefits are provided
to employees who have a regular schedule
of at least 24 hours per week. Some benefits
are reduced or prorated for regular part-time
employees with a schedule of at least 24
hours but under 40 hours per week.
6.2
–––––
HEALTH AND WELFARE
BENEFITS
Regular full-time and regular part-time
employees are eligible to participate in WSP’s
Health & Welfare Benefits (including
medical, dental, vision, disability, life
insurance, health savings and flexible
spending account options).
Newly hired employees will be offered
coverage effective on their date of hire,
and must make their benefit elections
within 31 days of their date of hire. If no
elections are made within the 31 days, new
hires are defaulted into waived coverage.
Once their benefits elections are submitted,
employees cannot terminate coverage, change
coverage options or add dependents except:
(1) during the annual open enrollment, or (2)
within 31 days of a qualifying life event (e.g.
marriage, birth of a child, or loss of other
50
coverage). Details on benefits coverage levels,
employee premiums, enrollment instructions
and more are available in the Benefits Guide.
6.3
–––––
WORKERS’ COMPENSATION
All employees are covered under our Workers’
Compensation policy which is paid for by the
Company. Accidental injuries which occur
during the course and scope of employment
or conditions caused by work activities are
covered under our Workers’ Compensation
policy. This insurance provides for the
payment of medical expenses and statutory
weekly compensation payments (after the
applicable waiting period is exhausted) during
a period of lost time due to an employee's
work-related injury or illness.
Employees must report all injuries, no matter
how slight, to management as soon
as possible. Claim forms must
be filed promptly. Failure to
follow Company procedures
may affect employees’
eligibility to receive Workers’
Compensation benefits.
All employees also may be
entitled to receive statutory
short-term disability payments for
non-occupational injuries or illnesses
depending on their work location.
Workers’ compensation and short-term
disability are solely monetary benefits and not
leaves of absence.
51
 6.4
–––––
RETIREMENT BENEFITS
6.4.1 401(K) SAVINGS PLAN
WSP offers all regular full-time and regular
part-time employees an opportunity to
participate in a 401(k) Savings Plan. Employees
may elect to contribute a percentage of their
earnings, up to the maximum allowable
contribution per IRS regulations, on a
pre- or post-tax basis. WSP will match
employee contributions as defined in the
plan documents, available on the intranet.
Employees can contact Human Resources with
questions regarding this policy.
6.4.2 DEFERRED
COMPENSATION PLAN
All regular full-time or regular part-time
employees with a grade of P-14 and above
are eligible to participate in WSP’s Deferred
Compensation Plan. This is a non-qualified
benefit plan that allows participants to defer
above and beyond the annual IRS deferral
limits for 401(k) plans.
6.5
–––––
PROFESSIONAL DEVELOPMENT
WSP encourages employees to seek to
enhance the competencies required
for their current roles, as well as
improve future potential through
education and seminars. WSP
provides a variety of options, as
outlined below, to assist employees
52
with their development and growth.
6.5.1 CONTINUING EDUCATION
(TUITION REIMBURSEMENT)
Regular full-time and regular part-time
employees are eligible to apply for tuition
reimbursement provided they meet the
following requirements:
•• Employee has worked for WSP for at least
twelve (12) month.
•• Employee is pursuing an undergraduate or
graduate degree, from an accredited college
or university, that will have a direct impact
on improving the employee’s ability to
perform the employee’s current job and/or
foster the employee’s career growth at WSP.
The company will determine, in its sole
discretion, whether a degree program or
course meets this requirement.
•• All courses must be pre-approved by the
employee's cost center/department manager,
in the manager’s sole discretion and on a
case-by-case basis, prior to commencement
of the course.
•• The employee must remain employed with
WSP for at least 12 months after completing
the course for which the employee received
tuition reimbursement. If the employee
voluntarily resigns within 12 months of
completing the course, the employee
will be required to refund the
amount received for tuition
reimbursement, in full, to WSP
immediately upon termination
of employment. This refund will
be deducted from the employee's
final compensation (except when
prohibited by law), and to the extent
the employee's final compensation is
insufficient to satisfy the full amount of the
tuition reimbursement, the employee will
remain obligated to repay the balance to
WSP via personal check within 30 days of
the termination of their employment.
•• Eligible employees will become ineligible
for tuition reimbursement in the event
of disciplinary action taken at any time
during the semester or period for which
reimbursement is sought.
If reimbursement is approved for a degree
program, the following criteria apply:
•• Course work must meet requirements for
the degree being pursued.
•• Employees must have a passing grade of C
or better to be reimbursed.
•• Classes must be scheduled to not interfere
with normally scheduled working hours.
The employee must submit the written
Tuition Reimbursement Request Form,
written pre-approval, all supporting
documentation, evidence of a grade of at
least C, and appropriate proof of payment
to Human Resources no later than 30
days after completion of the course. The
employee assumes financial responsibility
for the employee’s educational costs. Up
to the maximum pre-tax amount allowable
per IRS regulation (currently $5,250) in
tuition reimbursement per calendar year,
the company will reimburse up to 100% of
cost of tuition, university mandated fees, and
required course books/materials, based on
the following scale:
•• Grade of A or Pass in Pass/Fail course:
100%
•• Grade of B: 90%
•• Grade of C: 80%
•• Grade of D or below, or Fail in Pass/Fail
course: 0%
Tuition reimbursement will be paid
directly to the employee through payroll
after all supporting documentation noted
above has been received and processed.
Reimbursement requests must be received
by Human Resources within 30 days of
completion of the pre-approved course.
Under no circumstances will WSP provide
reimbursement for any course that was not
pre-approved in writing by the employee's
manager prior to commencement of the
course. Following course completion, the
employee must submit the written pre-
approval, all supporting documentation, along
with evidence of a grade of at least C and
appropriate proof of payment to their HR
Business Partner.
6.5.2 PROFESSIONAL
TRAINING & DEVELOPMENT
Professional development opportunities
allow employees to add to their knowledge
and acquire new skills for improved job
performance, benefitting themselves and WSP
through greater productivity, performance,
and engagement. This section excludes degree
programs through accredited colleges or
universities covered under section 6.5.1.
Both employees and managers are responsible
for continuous learning. They should work
together to set training and development
goals, and to identify development needs and
53
 related learning opportunities. Professional
training and development may come in the
form of:
•• Conferences, seminars, workshops;
•• Formal training sessions;
•• Coaching and mentoring;
•• On-the-job training; and
•• Job shadowing or rotation.
Regular full-time and regular part-time
employees may participate in professional
development activities. WSP reimburses for
related expenses for professional training and
development when an employee meets the
following criteria:
•• The employee has been with the company
for at least 6 months: and
iExpense, following company policies and
procedures for expense submission and
reimbursement.
Professional development activities may also
include technical training. Where applicable,
reimbursement of costs for technical training
follow the guidelines outlined above.
Technical training can be accomplished by:
•• On-the-job project exposure.
•• Formal in-house sessions led by either WSP
employees or outside trainers.
•• Informal in-house sessions (lunch & learns
or brown-bags) devoted to discussions of
specific projects, tasks, or issues.
•• Reviewing reports, plans, drawings,
photographs, or films representing work
done within the firm.
required and assigned through the LMS.
Employees are responsible for completing
assigned training by the deadline provided,
and managers are responsible for monitoring
status for their employees and enforcing
training deadlines with support from HR.
For formal, scheduled training sessions,
whether in person or online, attendance is
recorded by registering for the training in
the learning management system prior to the
training date. For informal in-house training
sessions, the recording of attendance is not
mandatory, but is strongly encouraged and
can be captured by having attendees register
via the learning management system prior to
the training date. Training completed outside
the company can be added to the employee’s
transcript by submitting a request to your HR
Business Partner.
employee’s cost center/department manager.
Membership fees are reimbursed through
Accounts Payable or on the corporate travel
and expense card.
6.6
–––––
SERVICE AWARDS
WSP values our long-term employees and
recognizes them for their contribution to
the organization. As such, employees will
be recognized for every five years of service
provided to WSP. WSP has contracted with a
third-party vendor to provide service awards.
During the month of their 5 year anniversary,
employees will receive a catalogue which
contains information for the employee to
make an award selection.

•• The employee has received pre-approval
from their cost center/department manager
to complete the training and/or professional
development opportunity.
If reimbursement of training or professional
development opportunity is pre-approved,
WSP will pay 100% of:
•• Tuition/registration fees.
•• Continuing education training, seminars,
webinars, or other approved trainings
needed to maintain professional licenses.
•• Books, supplies, and training materials.
•• Cost of exams, provided the employee
passes and receives certification (if
applicable).
Expenses related to completion of continuing
education should be submitted through
•• Completing online training modules
accessed through the learning management
system.
•• Attendance at external functions, including
conferences, seminars, site visits or formal
educational courses.
6.5.3 INTERNAL TRAINING
REQUIREMENTS & TRACKING
All new employees are assigned an
orientation and initial training through
WSP’s learning management system, in
addition to position-related training and office
orientation by their immediate manager.
The list of required initial and supplemental
training for each employee is available
through WSP’s learning management system
(LMS).
Periodically, additional training will be
Courses developed for internal use may be
evaluated for continuing education units,
as determined by the subject matter of the
course. Human Resources will work with
subject matter experts during the design and
development process to identify these courses.
Human Resources will follow the process WSP encourages
employees to seek
established by IACET Certification Procedures
to enhance the
to apply the ANSI/ IACET standards for
program development of the course.
6.5.4 PROFESSIONAL MEMBERSHIPS
competencies required
WSP encourages participation in professional
for their current roles,
organizations and will reimburse as well as improve
membership fees for full-time employees,
future potential
provided the membership is relevant to
the employee’s specific position, and/or through education
the betterment of WSP. Membership fee and seminars."
reimbursements must be approved by the

54 55
 7.1 •• Soliciting or accepting gratuities from
customers or clients in violation of
–––––

7.
WSP’s global Gifts, Entertainment, and
PROFESSIONAL CONDUCT
Hospitality Policy and U.S. regional
Whether in a WSP office, on a client site, or guidelines related thereto.
in the field, WSP employees are expected
•• Failing to maintain confidentiality of
to observe the highest standards of
business information or trade secrets.

WORKPLACE
professionalism always.
•• Violating any rule or policy discussed in
Certain behaviors may conflict with our
this Employee Handbook.
Code of Conduct and its U.S. Supplement,
as well as our Core Values, and may result Behavior which is inconsistent with

EXPECTATIONS
in disciplinary action up to and including professional conduct or our Code of Conduct
termination of employment. Such behavior and its U.S. Supplement should be promptly
includes, but is not limited to: reported to an employee’s supervisor, an
employee’s HR Business Partner, WSP’s
•• Falsifying information on any WSP
whistleblower hotline, Expolink, or the U.S.
documents, forms, reports or records,
Senior Compliance & Ethics Officer, where
including time cards, files, or expense
the latter is appropriate.
reports, etc.
In the event an employee is arrested or
•• Removing or using property, records, or
charged with a crime, the organization
other materials, whether owned by WSP, co-
reserves the right to suspend an employee
workers, clients or other persons, without
without pay until a conviction or acquittal has
expressed, prior authorization.
been secured consistent with applicable law.
•• Fighting, assaulting, threatening,
7.1.1 REPORTING CORRUPT
intimidating, harassing, or coercing any co-
OR UNETHICAL BEHAVIOR
worker, supervisor, client, or visitor.
Any suspected corrupt or unethical
•• Being under the influence of, or impaired by,
business dealings which are, or appear to
alcohol, any controlled substance or drug,
be, inconsistent with professional conduct
or the misuse of prescription or over-the-
or our Code of Conduct and its U.S.
counter drugs.
Supplement, should be reported to the U.S.
•• Violating any safety, health, or security Senior Compliance & Ethics Officer or to
policy, rule or procedure of WSP. WSP’s confidential whistleblower hotline
(“Expolink”) by calling (1-877-533-5310) or by
•• Violating WSP’s anti-harassment,
emailing(wsp@expolink.co.uk). Please refer
nondiscrimination, and/or
to the WSP’s intranet for additional details;
anti-retaliation policy.
Expolink is managed by a third-party vendor
and is a free service available to for use
24-hours a day, 7 days a week.

56 57
 Reports of infractions will be investigated
promptly, regardless of how the report is
submitted.
Anyone making a report will receive a
follow-up response within 30-days of the
initial report.
7.2
–––––
CONFLICT OF INTEREST
A conflict of interest exists when an employee,
who is in a position to make or influence a
material decision in a matter, has self-interests
that conflict with the interests of WSP. Refer
to the U.S. Personal Conflicts of Interest Policy
(available on the intranet) for guidance on
conflicts of interest. A conflict of interest may
occur, for example, if an employee maintains
an outside business that is in competition
with, or performs work for, third parties in
competition with WSP, or if the employee
maintains a romantic or close personal
relationship with a WSP client or vendor.
Conflicts of interest, whether actual,
perceived, or potential, undermine WSP’s
decisions and may jeopardize our
relationships with employees,
clients, and other stakeholders.
As such, employees should
never make or try to influence
a decision on any matter in
which they or a member of their
immediate family has a potential
conflict of interest.
Further, all WSP employees have an
obligation to disclose any actual, perceived,
or potential conflicts of interest to their
supervisor, HR Business Partner, or the U.S.
58
Conflicts of Interest Officer (ethics@wsp.com)
and to register such conflicts in the Conflicts
of Interest Register available on WSP’s
intranet. Where a conflict of interest may
exist, an employee’s failure to disclose the
conflict of interest may result in disciplinary
actions, up to and including, termination of
employment.
7.2.1 CONCURRENT EMPLOYMENT
Performing work for other employers or
for your own business, also referred to as
“moonlighting” or “outside employment”,
represents a potential conflict of interest.
As such, employees must consult with their
supervisor, receive approval from their
supervisor, and obtain written approval from
their HR Business Partner or Conflicts of
Interest Officer (ethics@wsp.com) prior to
accepting or engaging in any outside work.
Employees who fail to receive such approval
are subject to disciplinary action, up to and
including, termination.
Employees will not receive approval to engage
in outside work, on behalf of themselves or
other employers, that involves the same
or similar services that WSP offers.
To the extent permissible by law,
outside employment cannot in
any way be in competition with
WSP’s business. Such work
cannot, in any way, jeopardize
WSP’s relationship with its clients,
subcontractors, or other third
parties, or compromise, in any way,
the integrity of the employee’s timecards,
including creating an appearance of potential
impropriety. Such activities, if approved, must
not interfere with the employee’s ability to
fully perform the employee’s job duties during
the employee’s daily work hours, if applicable.
Employees cannot use WSP’s proprietary
information (including project details, data,
forms, templates or confidential information),
office telephone, fax, e-mail, or WSP supplies
or equipment for outside business activities.
It is the employee’s responsibility to remain
vigilant for and to self-report any conflicts
of interest and to reduce the risk of use
or appropriation of WSP’s information in
connection with the employee’s outside
employment or business activities. In
addition, all concurrent employment must be
recorded in the Conflicts of Interest Register,
available on WSP’s intranet.
7.3
–––––
CONFIDENTIAL AND PROTECTED
INFORMATION
The protection of our business information
and trade secrets is vital to the interests and
the success of WSP. The protection and careful
handling of confidential information, client
and project information, personal information
in any form, and WSP trade secrets is the
responsibility of every WSP employee.
WSP’s confidential business information
(“Confidential Information”) can be
classified as all and any information that
is not generally known or available to the
general public. Confidential Information
includes, but is not limited to:
•• Information that is protected by contractual
requirements, internal policies or
legislation;
•• “Personal Information”, which is all
information that relates to an individual that
could be used to discern that individual’s
identity;
•• “Sensitive Personal Information”, which
is a subset of Personal Information that
contains either information about, or from
which one can infer, a person's racial or
ethnic origin, political opinions, religious
or philosophical beliefs, data about physical
or mental health or condition, genetic and
biometric data, sex life, or criminal record.
•• Financial and business information, such
as information with respect to costs,
commissions, fees, profits, sales, markets,
mailing lists, strategies and plans for future
business, new business, product or other
development, potential acquisitions or
divestitures, and new marketing ideas;
•• Product and technical information, such as
formulae, specifications, designs, drawings,
component lists, databases, software (or pre-
cursor documents), Manuals, instructions
and catalogues held in any form relating
to the production, creation, supply or
provision of the products or services for the
Company or any affiliate;
•• Marketing information, such as information
relating to the marketing or sales of any
products or services of the Company and
any affiliate, including without limitation,
lists of customers and suppliers’ names,
addresses and contacts, sales targets and
statistics, market share and pricing statistics,
marketing surveys, research reports and
advertising and promotional material;
•• Client, partner and subcontractor
information, such as the names and
addresses of the Company’s clients,
subcontractors and partners, the identity
59
 of representatives responsible for entering
contracts with or purchasing services
from the Company leads and referrals to
prospective clients; and
•• Any documents, data or information that
contains or comprises “Proprietary and
Confidential Information” as defined in the
Company’s Invention and Non-Disclosure
Agreement.
WSP is engaged in a highly competitive
business and our competitive position
depends upon our ability to maintain
the confidentiality of the Confidential
Information and trade secrets which WSP as
an organization has an obligation to protect.
Any unauthorized disclosure, release or
use of any of WSP business information,
Confidential Information or trade secrets,
could be highly detrimental to the company,
and may result in disciplinary action, up to
and including termination of employment.
Nothing in this policy is designed to
interfere with, restrain, or prevent employee
communications regarding wages, hours, or
other terms and conditions of employment.
7.3.1 DATA PRIVACY
WSP handles Personal Information in
accordance with its Global Privacy Policy and
the Privacy Principles set forth therein.
Employees are responsible for compliance
with all WSP policies and procedures related
to Privacy and the handling of Personal
Information. These include, but are not
limited to, the Global Privacy Policy, the
Information Classification and Handling
Policy and Guidelines, the Employee
Privacy Notice, and WSP’s Data Subject
Request Procedures.
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All employees who access or handle
Personal Information have additional
responsibilities and will be subject to
additional training related to their handling
of Personal Information.
7.3.2 UPDATING PERSONAL
INFORMATION
The HR department maintains the Human
Resources Information System (“HRIS”)
database with the requisite Personal
Information needed to process Payroll and
Benefits and to meet government reporting
obligations.
An Employee’s HRIS Information, which
includes address, phone number, marital
status, emergency contact, etc., must always
be up-to-date and accurate. Each Employee
is responsible for promptly updating their
information in HRIS through the Oracle
Self- Service tool following any change in
personal information.
Unreported changes of address, marital
status, etc. can affect withholding tax and
benefit coverage. Further, “out of date”
emergency contact information or the
inability to reach an employee in a crisis
could be extremely problematic.
7.4
–––––
REPORTING ANY ACTUAL OR
SUSPECTED DATA BREACH
Employees have an obligation to internally
report actual or potential data breaches and
failures to comply with WSP’s policies. This
allows WSP to investigate and take remedial
steps if necessary and, in the case of a data
breach, to report the breach to the authorities
and notify affected individuals as appropriate.
Data breaches are to be reported to the IT
Service Desk in accordance with WSP’s Data
Breach Procedure.
7.5
–––––
GIFTS, ENTERTAINMENT AND
HOSPITALITY
Employees must adhere to the global Gifts,
Entertainment, and Hospitality Policy and
regional guidelines related thereto, which can
be found on WSP’s intranet. As expressed
in those policies, “employees may
not solicit, give or receive, either
directly or indirectly, gifts,
gratuities, special allowances, a
favor or an unreasonable benefit
in relation to an individual or
company with which WSP does
business or seeks to do business,
if the benefit could unduly influence
the judgment of the recipient by creating
a disproportionate obligation to return
the favor or by creating an appearance of
impropriety.”
However, WSP also recognizes and accepts
that the occasional offer/acceptance of a
modest gift, entertainment or hospitality
can make a valuable contribution to the
development and maintenance of good
business relationships. In the business world,
it is important to build up good personal
relationships with clients. As part of this
process, employees may meet for lunch or
dinner and want to pay the bill. Sometimes,
you may wish to exchange token seasonal
gifts. While many exchanges are harmless,
employees need to be vigilant, particularly
when these exchanges involve employees who
work for a governmental agency at the federal,
state or local level, as many governmental
agencies have strict gift policies, with some
prohibiting the exchange of anything of value.
WSP’s policies, guidance, and reporting
requirements related to giving and receiving
gifts, entertainment, and hospitality are
detailed in the global Gifts, Entertainment
and Hospitality Policy and the U.S. Regional
Guidelines for Gifts, Entertainment, and
Hospitality available on the intranet. It is
the responsibility of each employee to
familiarize themselves with these
documents as well as local legal
requirements, and to comply with
the requirements detailed therein.
Moreover, employees must
register the exchange of gifts,
entertainment, and hospitality,
with third parties, in the online Gift
Registry, available on WSP’s intranet, in
accordance with the U.S. Regional Guidelines
for Gifts, Entertainment, and Hospitality.
All gifts to employees that are submitted for
corporate reimbursement must be approved
in advance by the purchaser’s supervisor.
Corporate reimbursement of gift cards and
cash equivalent given to employees and/or
clients/vendors/contractors is prohibited.
Any exceptions regarding gift cards or cash
equivalents given to employees will require
CFO approval and will be taxable to the
employee regardless of the amount.
7.6
–––––
DRESS CODE
All employees should present a professional,
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 neat and clean appearance at all times.
Apparel should be suitable for meeting clients
as well as the general public.
Office
Attire appropriate for the office includes
blazer or jacket; dress pants or slacks; dress
shirt or other collared shirt; blouse; skirt;
dress; turtleneck; casual dress pants; sweater;
dress shoes or loafers.
Field
Neat and clean khaki pants or blue jeans in
good condition without holes or tatters may be
worn. Shirts shall have a collar. Safety t-shirts
(orange/yellow) may be worn. Appropriate
safety clothing shall always be worn.
Inappropriate Clothing
WSP relies upon the sound judgment of our
employees to dress appropriately for work,
with an understanding that appropriate attire
may vary based upon the formality of a work
event. For example, employees may dress
differently when presenting at an industry
conference than when attending a sporting
event with a client, but, in both instances,
employees are expected to dress in accordance
with the formality of the event.
At no time are sweatpants, shorts, T-shirts
(except safety shirts in the field), hats (except
for when required for weather or protective
purposes), tank tops, midriff tops, low cut
tops/dresses, flip flops or rough terrain sport
sandals permissible. As a general policy, attire
that is revealing or inappropriately tight does
not meet WSP’s professional standard.
If an employee’s appearance fails to meet the
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standards outlined above, as determined in the
Company’s sole discretion, the employee may
be sent home (without pay, if applicable and
permitted by applicable law). Further violation
of this policy may result in to disciplinary
action, up to and including discharge.
Nothing in this policy is intended to
discriminate against an employee’s sincerely-
held religious beliefs or practices. Employees
who may need an accommodation based on a
sincerely-held religious belief or practice can
contact Human Resources.
7.7
–––––
IT ACCEPTABLE USE POLICY
WSP employees are provided access to the
WSP network (“the Network”) to allow them
to perform their job functions. All WSP
employees who are granted access to the
Network have responsibilities and obligations
to operate within the parameters of acceptable
use of the corporate Network. This policy
explains how corporate information
technology resources are to be used and
specifies what actions are prohibited. While
this policy is as complete as possible, no
policy can cover every situation, and thus
the user is asked additionally to use common
sense and good judgement when using
company resources. Questions on what
constitutes acceptable use should be directed
to IT Service Desk.
Since inappropriate use of corporate systems
exposes the company to risk, it is important
to specify exactly what is permitted and
what is prohibited. The purpose of this policy
is to detail the acceptable use of corporate
information technology resources for the
protection of all parties involved.
The Policy applies to U.S. WSP employees
and anyone using the WSP email systems or
network
E-mail Use
WSP provides an email system to assist
employees in the performance of their
duties, and no business correspondence
should ever be sent via text, chat
or any personal email account.
WSP employees should have no
reasonable expectation of privacy
when using Company email or
other electronic communication
methods. Under no circumstances
should any company or client
documents be attached to messages
associated with your personal email
accounts external to WSP.
WSP reserves the right to purge
inappropriate emails to preserve the integrity
of the email systems.
Email is not a secure form of communication
and all WSP employees communications
should take the security of any information
to be transmitted into account when utilizing
our email systems. Any messages sent will be
passed over networks owned by other parties.
If the content of the message could contain
privileged or confidential information, the
WSP Information Classification and Handling
Policy must be followed.
Email should not be used to send large
attached files. Many email systems will not
accept large files, which are returned and
may result in overloading the Company's
own email system. Other approaches e.g.,
Newforma Info Exchange, FTP or digital
media should be used for large file transfers,
and employees may contact the US IT Service
Desk for assistance.
Email should not be used as a backup or
archiving solution. As such, information
and files that WSP employees wish to retain
should be moved to appropriate file storage
(project folder, network share, etc.).
Limited personal use of company
email systems is permitted as
long as: (A) such use does not
negatively affect the corporate
computer Network, and (B) such
use does not negatively affect the
user’s job performance.
The following is never permitted:
spamming, harassment, communicating
threats, solicitations, chain letters, or pyramid
schemes. This list is not exhaustive, but is
included to provide a frame of reference for
types of activities that are prohibited.
The user is prohibited from forging email
header information or attempting to
impersonate another person or role.
Email is an insecure method of
communication, and thus information that
is considered confidential, proprietary or
restricted must be handled according to the
WSP Information Classification and Handling
Policy.
It is company policy not to open email
63
 attachments from unknown senders, or when
such attachments are unexpected.
Network Access
The Network is the property of WSP and
is to be utilized for the business-related
activities of the company. WSP employees are
provided access to the Network to assist in
the performance of their jobs. The Network
represents a useful tool for the company to
conduct its business, but like any other tool,
it must be used properly and in connection
with legitimate business purposes.
WSP employees have a responsibility to use
the Network in a professional, lawful and
ethical manner.
Limited personal use is acceptable as long as
it complies with company policies and does
not adversely impact the user’s productivity or
the Network itself. Incidental and occasional,
limited, appropriate personal use of the
Network is permitted if such use does not:
•• Interfere with the user’s or any other
person’s job performance;
•• Have an undue effect on
Network performance;
•• Restrict, inhibit, interfere with,
or otherwise disrupt or cause
a performance degradation,
regardless of intent, purpose,
or knowledge, to the Network or
any server, backbone Network node, or
service, or otherwise cause a performance
degradation to any facilities used to
maintain or deliver the Network services; or
•• Violate any other policies, provisions,
guidelines or standards of this or any other
company policy or any applicable state or
federal law.
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WSP employees should take reasonable
efforts to avoid accessing Network data, files,
and information that are not directly related
to their job function. Existence of access
capabilities does not imply permission to use
this access.
Unacceptable Use
Unacceptable use of the corporate Network
includes, but is not limited to, the following
actions. This list is not exhaustive, but is
included to provide a frame of reference
for types of activities that are deemed
unacceptable. The user may not use the
corporate Network and/or systems to:
•• Engage in activity that is illegal under local,
state, federal, or international law
•• Engage in any activities that may cause
embarrassment, loss of reputation, or other
harm to the company
•• Disseminate defamatory, discriminatory,
vilifying, sexist, racist, abusive, rude,
annoying, insulting, threatening, obscene
or otherwise inappropriate messages
or media. This includes, but is not
limited to, ethnic or racial slurs
or any other message that can be
construed to be harassment or
disparagement of others based
on their sex, race, disability,
marital status, age, national origin,
religious or political beliefs or any
other protected characteristic or status
••  end or solicit inappropriate, vulgar
S
or sexually explicit messages, images,
cartoons, or jokes
•• Engage in activities that cause or involve an
invasion of privacy
•• Engage in activities that cause disruption
to the workplace environment or create a
65
 hostile workplace
•• Make fraudulent offers for products or
services
•• Perform any of the following: port scanning,
security scanning, Network sniffing,
keystroke logging, or other IT information
gathering techniques when not part of
employee's job function
•• Install or distribute unlicensed or "pirated"
software
content: Streaming Media
•• Pornography Streaming media can use a great deal of
•• Hate/violence network resources and incur additional
cost to the company and thus must be used
•• Illegal activities
carefully. Streaming media is allowed for job-
•• Hacking related functions only. The streaming of music
or non-business media is permitted over
•• Peer-to-peer
guest wireless networks only using personal
•• Redirectors (sites that allow users to bypass owned devices.
the company’s URL filtering)
justification, may only be achieved using
company-provided laptops/computers using
IT-approved software or services.
Circumvention of Security
Using company-owned or company-provided
computer systems to circumvent any security
systems, authentication systems, user-based
systems, or escalating privileges is expressly
prohibited. Knowingly taking any actions to

•• Disclose or share your Network and
business-related passwords with anyone
•• Accessing the Network or any other IT
resources using the credentials (password,
PIN, passcode, etc.) of another employee
Instant Messaging
Business information generally, and
certain specific types and classifications of
information should not be communicated by
chat or instant messaging. Please refer to the
WSP Information Classification and Handling
Policy and the U.S. Acceptable Use Policy for
details.
•• Remote access (sites that offer services to
remotely access computers)
The company may at any time block
additional categories of content without
notice.
Copyright Infringement
The WSP computer systems and networks
must not be used to download, upload, or
otherwise handle illegal and/or unauthorized
copyrighted content. Any of the following
activities constitute violations of this policy:
•• Copying and sharing images, music, movies,
or other copyrighted
Monitoring and Privacy bypass or circumvent security is expressly
prohibited and can result in disciplinary
As stated in the Code of Conduct, the
action up to and including termination of
Company reserves the right to block, track,
employment or contract. Users may not
monitor and disclose traffic flowing through
install antivirus or other security software or
the Network for network management
utilities not authorized by IT.
security purposes. Therefore, WSP employees
should have no expectation of privacy with
Use for Illegal Activities
regard to their use of the Internet, including
No company-owned or company-provided
e-mail messages. The company reserves
computer systems may be knowingly used
the right to monitor any and all use of the
for activities that are considered illegal under
computer Network. Subject to applicable
local, state, federal, or international law. Such
laws, regulations and procedures, suspected
actions may include, but are not limited to,
violations of this policy will be investigated.
the following:
Personal Use •• Unauthorized port scanning

Web Browsing
The company recognizes that the Internet
can be a tool that is useful for both personal
and professional purposes. Personal use of
company computer systems to access the
Internet is permitted as long as such use is
in accordance with the guidelines set forth
in this policy and with the WSP Code of
Conduct, and with the requirement that it
does not have a detrimental effect on the
company or on the user's job performance.
The company will automatically block the
following categories of non-business-related
66
•• Material using P2P file sharing or
unlicensed CD's and DVD's
•• Posting or plagiarizing copyrighted material
•• Downloading copyrighted files which
employee has not already legally procured.
This list is not meant to be exhaustive,
copyright law applies to a wide variety of
works and applies to much more than is
listed here.
Limited personal use of company computer
systems is permitted as long as such use
follows all pertinent guidelines elsewhere
in this document and does not have a
detrimental effect on WSP the company or on
the user's job performance.
Remote Desktop Access
Use of remote desktop software and/
or services not specifically provided by
IT is prohibited. (Examples of prohibited
software include, but are not limited to:
VNC, GoToMyPC, TeamViewer, etc.) Remote
Desktop Access, with sufficient business
•• Unauthorized Network hacking
•• Unauthorized packet sniffing
•• Unauthorized packet spoofing
•• Unauthorized denial of service
•• Unauthorized wireless hacking
•• Any act that may be considered an
attempt to gain unauthorized access to or
escalate privileges on a computer or other
electronic system
•• Acts of Terrorism
•• Identity Theft
67
 •• Misuse or publication of employee personal
information
•• Espionage
•• Downloading, storing, or distributing
violent, perverse, obscene, lewd or offensive
material as deemed by applicable statutes
•• Downloading, storing, or distributing of
copyrighted material
The company will take all necessary steps to
report and prosecute any violations of
this policy. Non-company Owned
Equipment
Personal owned devices laptops
and computers not owned or
provided by the Company should
not be connected directly to the
company Network. Personal devices
may only access the guest network.
The IT Service Desk will not support non-
company laptops, computers or network
devices (networking equipment such as
routers, switches, etc.) of any type.
Personal Storage Media
The company does not restrict the use of
personal storage media, which includes
but is not limited to: USB or flash drives,
external hard drives, personal music/
media players, and CD/DVD writers, on
the corporate Network except as specified
in the WSP Information Classification and
Handling Policy.
Software
WSP employees may not use any software
not approved by WSP’s IT management on
Company computers or laptop. This includes,
68
but is not limited to the loading of third party
applications, Freeware, Shareware, Games and
Screen savers.
Company software may not be taken home
and loaded onto a home computer. If an
employee has to use software while working
remotely for Company business, a loaner
system will be provided.
Software, information and programs
developed for and/or on behalf of WSP
by WSP employees during the course
of their employment remain
the property of the Company.
Duplication or sale of these
without prior consent of the
Company will be an infringement
of the Company’s copyright policies
and result in disciplinary action.
The use of unlicensed or improperly
licensed software is not permitted. WSP
employees that install software are
responsible for providing evidence of the
right to use.
The company may remove unlicensed or
improperly licensed software from company
owned computers and laptops. The IT Service
Desk will not provide technical support for
non-company provided software.
Security Incident Reporting
If a security incident or breach of any
security policies is discovered, suspected, or
witnessed, WSP employees must immediately
notify the IT Service Desk and/or follow
any applicable guidelines as detailed in the
WSP Incident Response and Reporting
Policy. Examples of incidents that require
notification include:
•• Suspected compromise of login credentials
(username, password, etc.)
•• Suspected virus/malware/Trojan or
ransomware infection
•• Loss or theft of any device that contains
company information
•• Loss or theft of ID badge or keycard
•• Any attempt by any person to obtain a user's
password over the telephone or by email
•• Any other suspicious event that may impact
the company's information security
WSP employees must treat a suspected
security incident as confidential information,
and report the incident only to his or her
supervisor. WSP employees must not
withhold information relating to a security
incident or interfere with an investigation.
Enforcement
All US Region WSP employees must comply
with applicable laws and regulations in the
jurisdictions in which WSP operates, including
and without limitation, any and all privacy and
related legislation and any security obligation
requirements including the IT security policies,
processes and procedures.
Any violation of the Policy may result in
administrative and/or disciplinary action by
WSP, including those leading to dismissal or
termination of employment or contract.
Exception Management
Exceptions to the Policy due to specific
business, security or technical requirements
or constraints must be managed by an
exception handling process. Exceptions to
policy must be approved by the Regional
Head of Compliance.
7.8
–––––
IT MOBILE DEVICE POLICY (A.K.A.
BYOM POLICY)
This policy (also known as Bring Your Own
Mobile – BYOM) establishes the guidelines
for employees to access company e-mail,
contact lists and calendars through their
personal mobile device. Acceptance of the
BYOM stipend reflects agreement to abide
by the terms and conditions set forth in
this policy. For those employees who do
not receive a BYOM stipend, the affirmative
act of voluntarily accessing WSP’s email
and systems from their personal mobile
devices, for the convenience of the employee,
reflects agreement to abide by the terms
and conditions set forth in this policy. If
employees do not agree to abide by this policy,
they should not accept the BYOM stipend or
access WSP email or systems through their
personal mobile devices for their convenience.
The policy applies to all WSP employees in the
U.S. Region accessing WSP email and systems
through their personal mobile devices.
Eligibility & Access
All full and part time WSP employees
receiving the BYOM stipend in the U.S. may
access their WSP email, contact lists, and
calendars on their personal mobile devices.
Work-related communications made using
a personal mobile device must be limited
69
 to telephone calls and emails. Employees
are prohibited from sending work-related
communications via text message, except for
in emergency situations.
Security
Mobile devices represent a risk to information
security and data security. If the appropriate
security applications and procedures are not
applied, the device can become a conduit for
unauthorized access to the organization’s data
and IT infrastructure. This can subsequently
lead to data leakage and system infection.
WSP employees using their personal devices
to access their WSP email, contact lists and
calendars must adhere to the following
security requirements:
Device Locking
Devices that access company e-mail, contact
lists and calendars must be locked and
accessed only when provided authentication
(such as by a passcode, fingerprint or facial
recognition) to unlock the device or the e-mail
application.
Device Timeout
The device or the e-mail application will be
set to timeout after a period of inactivity.
If there has been no activity within this
timeframe, the passcode will be required to
resume use.
Jailbroken or Rooted Devices
Jailbroken or rooting (i.e. compromising the
inherent security protocols of the mobile
device) is prohibited.
70
Lost or Stolen Devices
In the event of a lost or stolen mobile device,
it is imperative the employee reports this
to the IT Service Desk immediately. Upon
confirmation, IT will perform a partial wipe to
remove the corporate data only on the device.
Employee Offboarding
IT will deny access and wipe company email,
contacts, and calendar information on the
mobile device just prior to or upon learning
the employee, contractor or consultant has left
the company. WSP employees should have no
expectation of recovering, obtaining copies, or
accessing personal information or email that
was stored within the company email system
after leaving the company.
Technical Support
The IT Service Desk will only provide support
related to actual access of email by approved
methods and does not include support related
to stipends or financial reimbursements
which are outside the scope of IT Services.
Policy Enforcement
WSP and all US Region employees and
users must comply with applicable laws and
regulations in the jurisdictions in which WSP
operates, including and without limitation,
all privacy and related legislation and any
security obligation requirements.
Any violation of the Policy may result in
administrative and/or disciplinary action by
WSP, including those leading to dismissal or
termination of employment or contract.
Exception Management
Exceptions to the Policy due to specific
business, security or technical requirements
or constraints must be managed by an
exception handling process. Exceptions to
policy must be approved by the Regional
Head of Compliance.
For further information, please see the
“Technology Control Plan” located on the
WSP intranet.
7.9
–––––
SOCIAL MEDIA AND WEB
COMMUNICATIONS POLICY
WSP’s Global Digital Communications and
Marketing team uses the company website
and various social media outlets to inform
and engage employees, potential employees,
clients, potential clients, the media, investors
and the public about company news,
community involvement, financial reporting
and major projects, as well as to support our
sector growth efforts, trade organizations and
events affiliated with the firm.
The purpose of this Policy and the Social
Media Guidelines is to protect WSP’s brand
and reputation, to provide processes that
help promote the integrity and accuracy
of company-related information shared
on the internet, and to provide additional
information and guidance to assist
our employees in navigating both the
opportunities as well as the potential risks
that accompany social media.
This Policy and the accompanying WSP Social
Media Guidelines apply to all employees
and those of our affiliates and subsidiaries.
It applies whether an individual is using
WSP’s network and equipment or a personal
network or equipment. This Policy applies to
the use of any existing or future social media
channels and networking services including,
but not limited to blogs, Facebook, Twitter,
LinkedIn, YouTube, Google+, SlideShare,
Instagram, Flickr, wikis, webcasts and
podcasts. It includes the sharing of pictures
and videos and also covers WSP’s internal
social networking platforms.
Global Website
The WSP global website is managed by the
Global Digital Marketing Team (refer to the
Global Digital Governance).
•• Requests for new content, changes or
support with bug fixes or digital platforms
must be submitted by global, country or
regional marketing and communications
teams, via the Requests tool (requests.
wspgroup.com).
•• Regional websites are managed by country/
region Marketing Communication teams
working with the Global Digital Marketing
Team. Changes to the content of these
sections follow the policy set out in our
Global Digital Governance.
Design changes to the global website are
also under the direction of the Global Digital
Marketing team. “Independent” websites or
any sites illegally bearing WSP’s name and
71
 brand are not permitted. Any content that
needs to be promoted through or by the firm
must be included on our official platforms,
with the URL wsp.com. Existing content that
currently lives on other platforms is being
migrated onto the company URLs.
All requests for microsites, campaign
or additional content pages to support a
specialized service or promote a special study,
event, etc., must be submitted to the Global
Digital Marketing Team at digitalmarketing@
wspgroup.com.
Please contact your national or regional
marketing and communications team if you
have any questions or suggestions of content
for the website or social media channels.
Social Media
WSP recognizes the numerous benefits
of taking part in social media and
encourages employees to get
involved – WSP already has
some great ambassadors for our
business. However, WSP asks
that you apply the same common
sense, logic and sound judgement
in the online world as you would in
the physical one.
Official Communications on
Social Media
U.S. Communications manages all WSP USA
social media accounts. You can contact the
team at USComms@wsp.com.
The links to WSP USA social media
accounts are:
Twitter: @wspusa
72
LinkedIn: WSPusa
YouTube: WSPusa
Facebook: WSP usa
Instagram: @wsp.usa
YouTube: WSPUSA
Be aware that fake social media accounts may
appear, for example, impersonating WSP and
its management, particularly on Twitter. These
accounts may seem to be legitimate and can be
hard to identify, but look for these signs:
•• They sometimes tweet about political and
social matters outside the purview of WSP.
WSP never comments on political matters
or views.
•• The subscription ration is disproportionate.
These accounts follow unusually large
numbers of other accounts on Twitter
••  ey follow accounts that are of
Th
no interest to our firm.
Please ignore these fake accounts
and avoid following them; it may
make them seem legitimate in the
eyes of colleagues and clients.
When in doubt about the authenticity
of a social media post or account,
please contact the US Communications at
USComms@wsp.com.
Joining a Conversation
as an Employee
Employees are encouraged to voluntarily
subscribe, comment on, and share
information posted on the official company
accounts. Employees are welcome to
suggest news or content for distribution via
USCommssocialmedia@wsp.com.
There is a big difference between speaking
about WSP versus on behalf of. The U.S.
communications team manages all U.S. social
media accounts and therefore should be the
only one communicating on behalf of WSP, or
making decisions about the logo’s application.
Only the Global Communications or regional
marketing and communications teams
should set up new social media accounts,
following the approval of the Global Digital
Marketing and Communications team.
Account names should include WSP, as well
as the country/region (for example: WSP in
Canada or WSP – Sweden).
Employee Personal Use
of Social Media: Publicly
Accessible Profile Affiliation
•• The WSP Code of Conduct applies to
everything you publish on social media or
through other digital communications.
•• Everything you publish online has an
audience. Be mindful of your privacy
settings and the resulting scope of your
audience on all and any social media
accounts you may use. For each of these
sites and services, privacy settings and
policies are constantly changing.
WSP recommends that you review
your
personal accounts and their
privacy
settings periodically.
•• Protect information about
our clients and the firm. As a
professional services firm, WSP is
charged with overseeing a great deal
of sensitive and confidential information
belonging to clients and prospective
clients. Matters concerning proposals,
client pricing, and design are examples of
information which WSP as a company has
an obligation to guard and protect. Please
be mindful of our obligations to our
clients at all times when making decisions
about what to post online.
•• Please be aware that there are numerous
laws governing privacy of information
pertaining to individuals, such as protected
health information.
•• WSP encourages employees to publicly
affiliate themselves with the company
in social media. When you display the
company name in your social media
profiles you should follow the Social Media
Guidelines below.
Social Media Guidelines
•• WSP employees are personally responsible
for the content they publish online, whether
in a blog, social media page, or any other
form of user-generated media. Be mindful
that what you publish will be public. Please
use the sentence “Views expressed here are
my own” in your LinkedIn, Twitter and any
other social media account that has room
for personalized profile text.
•• Please refrain from posting, retweeting, or
otherwise sharing information about
WSP, its employees, and/or potential
employees without being certain
of the context and veracity of
the story. If in doubt, email
socialmedia@wsp.com.
•• I nformation from official WSP
accounts is safe to share.
••  espect copyright, fair use, and
R
financial disclosure laws. Do
not use copyrighted materials,
whether written, audio, video,
or any other electronic form,
73
 without license or permission.
It is always good practice to
provide a link to another’s work
with a short excerpt, rather
than copying any material in its
entirety.
•• Be aware of your association with WSP
in online social networks. If you identify
yourself as an employee, you may want
to assess whether your profile and related
content is consistent with how you wish to
present yourself with colleagues and clients.
•• Please refrain from adding the WSP logos or
trademarks, unless through affiliation or by
sharing official social media content.
 lease feel free to forward via email any
P
online comments about WSP, its employees,
or projects to your regional/country
marketing and communication team, or to U.S.
communications at USComps@wsp.com.
•• Refer any global business-related media
inquiries you may encounter to Isabelle
Adjahi, Senior Vice President, Investor
Relations and Communications.
•• Be mindful of the time you spend on social
networks during business hours.
•• WSP suggests you consider using LinkedIn
for maintaining professional contacts and
using Facebook for your personal life.
•• Remember that anything you post may be
stored electronically forever.
Nothing in this policy is designed to
interfere with, restrain, or prevent employee
communications regarding wages, hours, or
other terms and conditions of employment.
Corporate Internet Presence
74
The firm reserves the right to demand the
removal of unauthorized pages or accounts
bearing the company name. For the creation
of regional presence on social media sites,
approval is required from the regional/country
head of marketing and communications.
When you, as an employee of WSP, are
writing or posting on behalf of the company,
WSP owns your content, including, without
limitation, an authorized business account set
up by you under this Policy. WSP monitors
and tracks content on the internet related to
its business and reserves the right to remove
content on its own social media networking
pages that violate this Policy.
7.10
–––––
PRESS INQUIRIES
WSP has built its reputation on a framework
that sets us apart from our competitors,
aligns us with our customers, and helps us
succeed as an organization. Building our
brand and managing our reputation are
critical components of our business strategy.
Media relations requires special knowledge
and skill; therefore, U.S. communications
should always be consulted prior to any
dealings with the press.
The U.S. Communications Director serves as
WSP’s official spokesperson and only those
individuals expressly authorized by the
Office of the U.S. Communications Director
may speak on behalf of the Company. All
media inquiries regarding WSP should
be referred to the Office of the U.S.
Communications Director.
While WSP does not restrict the right of
employees to communicate with the media
as individuals, (i.e. not in their official
capacity as a WSP employee) such contacts
carry the potential for misrepresentation,
dissemination of incorrect information,
disclosure of confidential matters, violation
of privacy, and the misinterpretation of
the comments of an individual as being
representative of the policy or viewpoint
of WSP. Therefore, employees are advised
to consult with the U.S. Communications
Director prior to interacting with the media.
7.11
–––––
COMPANY EQUIPMENT POLICY
Depending on their role and assignments, WSP
employees may be authorized to use various
types of equipment. As used in this policy,
“Equipment” includes any piece of equipment,
machinery, vehicle or tool that belongs to WSP
(whether owned, leased, donated, or otherwise
in the custodial care of WSP or any of the
Company’s authorized agents), and includes
heavy machinery, office equipment and all 3D
printers (regardless of additive manufacturing
process). Under this policy:
•• No employee may access or use WSP
Equipment unless the employee is an
“authorized user” of the Equipment. To
qualify as an “authorized user” under this
policy, an employee must:
o B
 e properly trained and qualified (and, if
applicable, certified) to use the Equipment;
o P
 ossess all necessary access credentials
(e.g., user ID, passwords, access codes, etc.)
to access and use Equipment;
o B
 e expressly permitted by the employee’s
manager to use the Equipment for an
authorized work assignment; and
o U
 tilize the Equipment only in connection
with the specifically-authorized work
assignment.
•• WSP Equipment may only be used by the
specific employee assigned to, or authorized
to use, the Equipment (e.g., an employee
may not use the access credentials of
another “authorized user” to gain access to
or otherwise use Equipment).
•• WSP Equipment may be used only for
Company-approved projects. Employees are
not allowed to access or utilize Equipment
for personal, non-business and/or non-
approved reasons.
WSP equipment may not be accessed or
used for any purpose that is illegal or in
contravention of any other WSP policy.
WSP also maintains a U.S. IT Acceptable
Use Policy (available on the intranet) that
employees are expected to familiarize
themselves with and to comply with. Failure
to do so may result in disciplinary action, up
to and including, termination.
7.12
–––––
BUSINESS-RELATED
EVENTS POLICY
WSP may occasionally sponsor business-related
events during or outside of working hours.
All WSP policies relating to employee conduct
– including the Code of Conduct (and the U.S.
Supplement to the Code of Conduct) and the
WSP Employee Substance Abuse and Drug
75
 Testing Policy – apply to these events. The
reasonable and moderate consumption of
alcohol provided by WSP or its authorized
vendor (e.g., venue or catering service) during
a Company-sponsored business-related social
event by employees of legal age is allowed.
All employees who attend these events are
responsible for their choices and behavior
regarding the consumption of alcohol, and
employees should be aware they may be
held personally responsible for any incidents
arising from their improper, excessive or
illegal consumption of alcohol. Accordingly,
each employee is expected and required to
behave professionally in accordance with
usual business standards and to comply with
Company policies at all times during any
business-related social event.
A WSP manager will attend and observe the
event to monitor adherence to WSP policy and
standards. Transportation home from any such
event may be provided by WSP upon request
made to the supervising WSP manager.
Additional guidelines for business-related
social events are as follows:
•• Employees will be notified of an event
by written invitation (e.g., e-mail). The
invitation will include a firm start and
ending time, as well as other pertinent
event details.
•• The event will be held for the purpose of
celebrating or recognizing a professional
occasion, accomplishment or achievement.
•• Alcoholic beverages may be provided
by WSP or its authorized vendor, for
consumption “on premises” (i.e., at the event
location) during the event. In addition:
o O
 nly alcoholic beverages provided by WSP
or its authorized vendor are permitted;
76
consuming alcoholic beverages from other
sources is prohibited.
o I f alcoholic beverages are provided at the
event, WSP or its authorized vendor will
also provide food for attendees.
•• Business-related events may not take place
in active worksites, but will be restricted to
designated non-work areas that are suitable
and safe for the occasion. Alcohol is not
permitted on WSP worksites or work areas,
and employees who attend the event are
prohibited from returning to work while
under the influence of alcohol. Consuming
alcoholic beverages during lunch is
prohibited.
•• Unless the invitation expressly states that
attendance at the business-related event is
strictly voluntary for all employees, then
non-exempt employees attending the event
must be paid their regular hourly rate (or, if
applicable, overtime).
•• In addition, non-exempt employees
attending a business-related event must
be paid their regular hourly rate (or, if
applicable, overtime) in the following
circumstances:
o Th
 e event occurs during regular working
hours;
o Th
 e event takes place on Company property
and starts immediately after regular
working hours;
Whether
o The non-exempt inemployee
a WSP office,
is asked to help,
assist or otherwise work at the event.
on a client site, or in the
field, WSP employees
are expected to observe
the highest standards of
professionalism always."
77
 8.1
–––––

8.
PAID TIME OFF (PTO)
All regular full-time and regular part-time employees will accrue PTO that can be used for vacation,
personal reasons and illness. PTO is accrued biweekly, based on actual paid time, excluding overtime.
The maximum PTO accrual is two times the employee’s annual accrual rate, up to 52 days. Subject to state

TIME OFF
law, if an employee reaches this maximum accrual, no further PTO will be accrued until the employee has
used some of the accrued PTO to again take the balance below the maximum cap.

PTO is service-based. The greater the length of service with WSP, the greater the PTO accrual rate as
shown below:

YEARS OF
WSP SERVICE BI-WEEKLY ANNUAL MAXIMUM
COMPLETED ACCRUAL RATE ACCRUAL RATE ACCRUAL RATE

Fewer than 5 years 4.923 hours 16 days 32 days

5-15 years 6.462 Hours 21 days 42 days

Over 15 years 8 hours 26 days 52 days

PTO is not considered time worked for purposes of calculating overtime eligibility. Employees may
request and utilize PTO in minimum increments of 15-minutes unless otherwise required by law.

PTO is paid at the employee’s normal rate of pay at the time of absence, unless otherwise required by
applicable law. 

Before taking unpaid time off work for reasons unrelated to medical or disability leave, (for example, for
vacation), employees must first use all accrued PTO, unless applicable law prohibits the forced use of PTO
under the conditions for which the employee seeks such unpaid leave.

78 79
 Notice and Scheduling
Unless the need to use PTO is unforeseen
(e.g., illness), employees are required to notify
their supervisors in advance of their intent
to take PTO and get approval for the time off.
The request may be denied or postponed to a
later time if business reasons dictate, so long
as denying or postponing the request is in
accordance with applicable law.
Borrowing of PTO
Each participating employee is responsible
for managing their paid time off. At the
discretion of their supervisor and subject
to business needs, eligible employees may
borrow up to a maximum of five PTO days
in advance of actually accruing those days.
Supervisors are responsible for reviewing the
employee’s PTO balance prior to approving
time off and for not allowing the employee
to borrow more than 40 hours of PTO
total. If an employee requires time
off in excess of their PTO balance,
they should discuss options
for unpaid leave with their
supervisor and their HR Business
Partner.
Borrowing PTO time is taking
unearned PTO before accruing it;
therefore, this is considered a wage advance
and a debt to be repaid to WSP. Should the
employee’s employment with WSP end
before the outstanding PTO hours have
been accrued, to the extent allowable by
law, WSP will deduct from the employee’s
final paycheck the salary equivalent of any
remaining PTO advance that has not yet been
earned or repaid to WSP. In instances where
such deductions from final paychecks are not
80
permitted, employees must repay their debt
to WSP via personal check within 30 days of
the termination of their employment, unless
otherwise required by applicable law.
To the extent any applicable paid sick time/
leave law or ordinance provides any greater
rights than set forth in this policy, such
provisions are incorporated by reference
and/or addressed in a WSP’s State-Specific
Appendix. To the extent an employee uses PTO
for reasons other than sick time/leave, they
will not be provided with additional paid time
off for sick time/leave purposes irrespective of
any applicable sick time/leave law/ordinance,
unless otherwise required by law.
8.2
–––––
HOLIDAYS
Annually, WSP typically provides
holiday pay for the eight holidays
outlined below. When the holidays
fall on weekends, WSP may, at
its discretion, offer holiday pay
on the Friday preceding or the
Monday following the holiday.
See State-Specific Appendix for
information regarding your state.
•• New Year’s Day
•• Martin Luther King Jr. Day or President’s
Day (Specific California restrictions are
addressed in the State Specific Appendix)
•• Memorial Day
•• Independence Day
•• Labor Day
•• Thanksgiving Day
•• Day after Thanksgiving
•• Christmas Day
HR will notify employees of any variations
to the holiday schedule via its intranet. If a
holiday occurs during an employee’s scheduled
PTO leave, they may receive the day as a
paid holiday, and they do not have to use
accrued PTO time for that day. Employees are
ineligible for paid holidays when the holiday
occurs during an unpaid leave of absence.
Regular full-time employees will be paid
for an eight-hour day for any WSP holiday.
Regular part-time employees are entitled
to four hours of holiday pay on those
holidays which fall on a day when they
would otherwise be regularly scheduled and
required to work. Temporary employees are
ineligible to receive paid time off on holidays.
Holiday pay is not considered time worked for
the purposes of calculating overtime eligibility.
All employees must be in an active, paid
status by WSP on the day before and the day
after the holiday to receive the paid holiday.
Some states require different paid or unpaid
holidays. See the State-Specific Appendix for
additional information.
Additionally, where applicable, employees
actively working on federal, state, or local
public contracts (“public contracts”) shall
receive holiday pay in accordance with the
holiday schedule dictated by such contracts.
For example, employees who meet the
definition of “Service Employees” under the
Service Contract Act must be paid for the
federal holidays listed in their project-specific
wage determination. 
Where feasible, holidays mandated by public
contracts may be exchanged for the above
WSP holidays. For example, if a public
contract mandates that a WSP employee
receive holiday pay for Veterans Day, but not
the day after Thanksgiving, WSP reserves the
right to substitute Veterans Day for the paid
WSP holiday on the day after Thanksgiving.
However, if under the public contract, the
WSP employee is entitled to holiday pay for
the eight WSP holidays listed above, plus
additional days, such employees may receive
more than eight days of holiday pay. 
Project Managers should inform their HR
Business Partners if federal, state, or local
contracts call for holiday schedules and holiday
pay that differ from WSP’s standard holidays.
8.3
–––––
LEGACY NON-PTO SICK TIME
WSP does not maintain a separate paid sick
leave outside of WSP’s PTO policy outlined in
this Employee Handbook. However, as a result
of legacy sick leave programs no longer offered
(e.g., by WSP or through prior employers
acquired by WSP), certain employees (a “legacy
employee”) may have a historical bank of
“Non-PTO Sick Time” hours available.
The Non-PTO Sick bank was a grandfathered
program established for those times when an
employee is ill or disabled and unable to work.
All employees who go on a Disability
leave and have Non-PTO Sick hours will
be required to charge the Non-PTO sick
hours before receiving disability pay, unless
otherwise prohibited by law. Those who have
81
 the Non-PTO Sick hours and want to use them
otherwise, must have an approved FMLA or
STD claim. Non-PTO Sick hours will not be
replenished once they have been exhausted.
The FMLA or STD claim must be approved
by the Disability or Leave Carrier to charge
Non-PTO Sick. If the claim is not approved,
any Non-PTO Sick hours charged will be
transferred to the employee’s PTO bank. If the
employee does not have enough PTO hours
available, the PTO bank will reflect a negative
balance. The employee should not charge PTO
until his negative balance is satisfied.
Terminated employees will not be paid any
unused Non-Sick time and the account will be
zeroed out, unless otherwise required by law.
See also, the State-Specific Appendix for
state-specific sick leave policies.
8.4
–––––
JURY DUTY
WSP recognizes that participation as a juror
is a civic responsibility. As such, unless state
or local law requires more, an employee will
receive full pay during the time they spend in
jury service or as a subpoenaed trial witness,
for a period not to exceed 10 business days
per year. Regular part-time employees will
be paid for these days on a pro rata basis.
Employees are entitled to jury duty pay only
when jury duty falls on a day when they
would otherwise be regularly scheduled
and required to work. Exempt employees
will receive their full salary while serving
on a jury for any work week in which they
perform any work for WSP, less compensation
received from the court. Any pay provided
82
for time spent on jury duty leave is not
counted as hours worked for purposes of
calculating overtime.
For the purposes of workforce scheduling,
employees must notify their supervisor
immediately when they receive a notice
to appear for examination for jury duty,
a summons for service on the jury, or a
witness subpoena. If job schedules are such
that the jury date will interfere with WSP’s
contractual obligations, the employee, upon
consultation with their supervisor, should
request a postponement. While serving
jury duty, employees are required to keep
their supervisor apprised of their status. If
an employee is excused from jury duty or
witness service during their regular shift,
they are expected to return to work for the
remainder of their scheduled shift. Upon
completion of jury duty, employees should
present a court-issued statement of jury
service to Human Resources. The employee
is expected to return to work on the next
regular workday after being dismissed from
jury duty.
Where state law does not require WSP to
pay the employee more than 10 days for
jury duty leave and the employee’s jury duty
lasts more than 10 days, employees may use
available PTO.
8.5
–––––
CRIME VICTIM/DOMESTIC
VIOLENCE/WITNESS LEAVE
An employee who is the victim of a crime,
witness to a crime, or the immediate family
member of a crime victim is entitled to be
absent from work if they are required by
law to assist with a police investigation, to
serve as a witness in any criminal or civil
proceeding if the employee is subpoenaed,
or if their reasonable participation in the
preparation of a civil or criminal proceeding
is required.
Similarly, employees are entitled to be
absent from work to address issues related
to domestic violence and stalking such as:
(1) seeking or obtaining protection orders
or injunctions against harassment or any
other similar relief to secure their safety or
the safety of an immediate family member;
(2) obtaining medical or psychological care
for the employee or an immediate family
member; (3) securing legal assistance or
participate in related court proceedings; (4)
securing the home from the perpetrator; or (5)
seeking alternative housing. Employees are
also entitled to be absent from work to attend
a court proceeding involving a juvenile in
their care or custody, including custody and
child welfare proceedings.
Immediate family members include parents,
stepparents, children, stepchildren,
siblings, spouses/domestic partners,
grandparents, grandchildren, legal
guardians, or any person involved
in an intimate relationship with
the employee and residing in the
same household
If the employee is subpoenaed to
testify in an action or proceeding
as a result of a crime against WSP or an
incident involving the employee during the
course of their employment, leave is paid.
Otherwise, all such leave is unpaid, unless
otherwise required by law; employees may
elect to use accrued PTO for such purposes.
An employee should advise their supervisor
or HR Business Partner that crime victim/
domestic violence/witness leave is required,
if possible, prior to the day leave is needed.
Employees may be required to provide
reasonable proof that such leave was needed.
WSP reserves the right to limit the amount
of leave taken by an employee if such leave
would create undue hardship for WSP, unless
otherwise required by state law. To the
extent allowed by law, WSP will maintain the
confidentiality of any employee requesting
leave for the purposes outlined in this section.
To the extent applicable state or local law
provides greater rights than set forth in this
policy, such provisions are incorporated by
reference for covered employees, and are
delineated in the State-Specific Appendix.
8.6
––––––
VOTING LEAVE
Employees are encouraged to vote before or
after working hours. However, if an election
occurs on a day in which the polls are
not open a sufficient time outside
of the employee’s scheduled
working hours, an employee
who has provided the employee’s
supervisor with advance notice
will be granted a reasonable period
of time off with pay, not to exceed
two hours unless state or local law
requires more, in which to vote.
Employees should request time off to vote
from their supervisor at least one working
day prior to the Election Day, or as otherwise
permitted by law. Time off will be scheduled
83
 at the beginning or end of the workday;
whichever provides the least disruption to
the normal work schedule, unless otherwise
agreed to by WSP and employee.
WSP will not terminate or threaten to
terminate any employee for voting or
not voting in an election, for a particular
candidate, or for a specific ballot measure.
To the extent applicable state or local law
provides additional rights or entitlements, see
the State-Specific Appendix.
8.7
–––––
OTHER CIVIC DUTY LEAVE
Employees may engage in other civic duties
such as: (1) serving as a volunteer emergency
services employees (firefighter, rescue squad/
team, emergency medical responder, EMT,
first responder, ambulance driver, reserve
police officer, volunteer police officer, etc.);
(2) serving in a civil air patrol or state
guard/reserve; (3) serving in state or local
government as a public official, legislator,
election officer, voting machine technician,
or other position; or (4) attending town
meetings or participating in organized
political activities. To the extent allowable by
applicable law, WSP will permit employees to
take unpaid leave to perform civic duties so
long as the leave does not impose an undue
burden on WSP. To the extent allowable by
applicable law, such employees may elect to
use accrued PTO before taking unpaid leave.
Employees should make reasonable efforts
to notify their supervisors or HR Business
Partner in advance, if possible, of the need
for such leave. WSP may require written
84
verification from the employee that the leave
was related to the employee fulfilling a civic
duty. Such leaves of absence will not cause
loss of job status, seniority, or the right to
participate in insurance and other employee
benefits during the leave of absence, vacation
accrual, or other rights, privileged, and
benefits of employment.
To the extent applicable state or local law
provides greater rights than set forth in this
policy, such provisions are incorporated
by reference for covered employees and
delineated in the State-Specific Appendix.
8.8
–––––
BEREAVEMENT LEAVE
Employees will be allowed Bereavement
Leave upon notifying their supervisor and
HR Business Partner. Up to three days of paid
Bereavement Leave will be granted to plan for
and attend funeral services of an immediate
relative or members of the extended family:
•• Spouse or Domestic Partner
•• Child, Stepchild, Child of Domestic Partner
•• Parent, Parent-in-law, Stepparent
•• Sibling, Sibling-in-law, Stepsibling
•• Grandchild, Grandparent, Grandparent-in-law
•• Aunt or uncle
•• Niece or Nephew
Should additional time be necessary,
employees can elect to use their PTO time,
or time without pay can be granted with the
approval of their supervisor and HR Business
Partner. Bereavement leave is paid at the
employees ‘s base rate of pay at the time of
absence for the number of hours the employee
otherwise would have worked that day.
Bereavement leave is not counted as hours
worked for purposes of calculating overtime.
8.9
–––––
PARENTAL LEAVE
WSP provides new parents with paid Parental
Leave to care for and bond with their new
child. Regular full-time and regular part-
time employees who become parents of a
biological or adopted child are eligible for
two weeks (80 hours) of paid leave within
12 months following the birth or placement
of the child. The amount of leave paid will
be pro-rated (up to 40 hours per week) based
on the employee’s current schedule. The Paid
Parental Leave can be used for a continuous
period, or intermittently – provided hours are
charged to the last full day.
For parents coming back from family leave,
WSP also offers flexible “returnship” options,
including working at reduced hours or
telecommuting where possible within the
first 90 days of your return. Please make sure
to discuss your options with your manager as
early as possible.
The Company Paid Parental Leave is charged
as the project ‘Excused Absence’ and task
‘Parental Leave’. Parental Leave will run
concurrently with any applicable federal or
state leave law.
*Helpful Tip*: Employees receiving Short
Term Disability for Child Birth are advised
not to use the Company Paid Parental Leave
during their Short Term Disability period,
as it will not extend out the Disability time,
and would instead substitute for one week of
payment from Short Term Disability.
See State-Specific Appendix for additional
state-specific parental leave policies.
8.10
–––––
NATURALIZATION LEAVE
WSP will provide up to eight hours paid
leave for employees attending to their
Naturalization Proceedings.
8.11
–––––
PERSONAL LEAVE OF ABSENCE:
WSP is aware that an employee may need
some time off from work to attend to personal
situations that do not qualify as a Family and
Medical Leave or any other leave provided
by the Company. In such circumstances,
employees may apply for Unpaid Personal
Leave of Absence.
A personal leave may be granted for up to
three months. When an employee wishes
to take a personal leave, they must get
approval from their manager. An employee
on a personal leave is not guaranteed a
position upon return. The Personal Leave of
Absence may be denied, granted, modified or
extended, at the Company’s sole discretion,
and on such terms as the Company may
85
 impose, taking into consideration the staffing
needs of the Company.
For an employee to be eligible to apply for a
Personal Leave of Absence, the employee must:
•• Have been employed by WSP for at least 12
months as of the date the Personal Leave of
Absence would start
•• Be a regular full-time or regular part-time
employee
•• Have used all accumulated PTO days
•• Have a bona fide intention to return to WSP
following the leave
•• Be in good standing with WSP. The
employee cannot take leave if the Employee
is on a Performance Improvement Plan or
has other performance issues.
Employees who are granted an unpaid
personal leave of absence will not
accrue PTO or be eligible for
Holiday pay while on leave.
During such time, Employees
cannot contribute to the 401k
plan, DCFSA and HAS. The
employee is also responsible for
making their HCFSA contributions,
if applicable.
An employee cannot drop their benefit
coverage during a leave period and will
continue to be responsible for the premiums.
Employees on Personal Leave are responsible
for the full premium of coverage (i.e., both
the employee and employer portion of the
premium) on their Medical, Dental and Vision
coverage, and the regular premiums for any
other applicable benefits. Employees are
responsible for coordinating with the HR
86
HUB at US-HRHUB@wsp.com regarding
payment of premiums. Basic Life insurance
is continued for a limited period (not to
exceed three months). At that point, the
employee’s Basic Life Insurance is terminated
and they will be given a chance to Port
and Convert their Life Insurance by the
Company’s Life Insurance Carrier.
8.12
–––––
DISABILITY LEAVE
Employees who need to take time off because
of their own serious health condition should
contact The HR HUB at US-HRHUB@wsp.
com to request short-term and/or long-
term disability leave as soon as practicable
upon becoming aware of the need to take
leave. WSP has contracted with a third-party
Disability and FMLA Leave Carrier (the
“Leave Carrier”) for the administration
and recordkeeping associated with
employees’ disability leaves. The
HR HUB will refer the employee
to the Leave Carrier, who will
determine whether the leave
qualifies as leave under the Family
Medical Leave Act (“FMLA”), see
FLMA section below.
Regardless of whether the leave qualifies
under the Family Medical Leave Act, the
employee may be entitled to file a disability
insurance claim under the Short-Term
Disability (STD) coverage available to all
benefit eligible employees or Long-Term
Disability (LTD) coverage, the latter of which
is only available to employees who voluntarily
elected such coverage. The employee may
also have state disability insurance coverage
87
 depending upon the state in which the
employee works. The Leave Carrier will
assist the employee in determining to which
insurance the claim should be submitted.
See the State-Specific Appendix for state-
specific disability leave policies.
8.12.1 MEDICAL CERTIFICATION
The employee will be required to submit
medical certification within 15 days of
filing a leave claim with the Leave Carrier
or The HR HUB at US-HRHUB@wsp.com.
Recertification will be required every 30 days.
8.12.2 BENEFITS DURING LEAVE
Disability leave may be considered an unpaid
leave from WSP, regardless of whether the
employee is eligible for claims payments
from an STD or LTD insurance carrier. As
such, WSP may not be able to make regular
deductions for benefits such as medical,
dental, and vision insurance. Employees may
continue to participate in WSP’s benefits for
up to 12 months from the start date of the
disability leave, providing they continue to
pay the employee portion of the premium and
remain a current employee. For employees
participating in the STD/ LTD insurance,
WSP will deduct the employee’s portion of
the premium from the claims payment made
from the disability carrier. If the employee
is not participating in these insurances, or if
premiums cannot be deducted, the employee
is responsible for coordinating with the HR
HUB at US-HRHub@wsp.com regarding
payment of premiums. If the employee’s leave
extends beyond 12 months, the employee
will be eligible to continue participation
in the medical, dental and vision insurance
through COBRA.
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8.13
–––––
JOB PROTECTION
Short-Term or Long-Term Disability leave
is not, in and of itself, considered a job
protected leave, however the leave may be
determined protected under certain state or
federal regulations such as the Family Medical
Leave Act or the Americans with Disabilities
Act. The Leave Carrier is responsible
for determining whether the leave is job
protected and notifying the employee of such
protection. The employee can also contact a
member of the HR HUB with any questions
relating to job protection. See also, WSP’s
State-Specific Appendix.
8.14
–––––
SHORT-TERM DISABILITY (STD):
Short-term Disability (STD) applies to all
regular full-time and regular part-time
employees. An employee must be in active
status prior to the medical leave. STD
payments begin on the seventh consecutive
calendar day (waiting period) after the
employee’s disability starts, or immediately if
the employee is hospitalized as an inpatient,
and can continue up to 13 weeks.
8.14.1 REPORTING A STD CLAIM:
The employee must contact the Disability
Carrier to initiate the claim process. The
Disability Carrier will contact the employee’s
physician for medical information. The
Disability Carrier will also contact the HR
HUB at US-HRHUB@wsp.com for the
last day worked, last day paid and salary
information. Once approved, the employee
will receive a letter from the Disability
Carrier certifying a period of disability and an
expected return to work date. The employee
may also receive a letter from the HR HUB
providing instructions for payment of benefit
premiums as necessary.
If the claim is denied, the employee will
receive a letter from the Disability Carrier
providing specific reasons for denial and how
to appeal the denial.
8.14.2 CHARGING TIME DURING STD:
During the waiting period an employee must
charge Non-PTO sick hours if they have any.
If they do not have Non-PTO sick hours,
they may choose to charge PTO Sick or take
the time unpaid. After the waiting period,
has been satisfied, if the employee has any
remaining Non-PTO Sick hours, those must
be exhausted to the last full day before they
receive any Disability payment.
While on STD, “Holiday” is charged if an
employee has enough Non-PTO sick hours
or PTO hours to charge before and after the
holiday and has been previously charging
hours. Only charging hours for the Holiday
and no other time before or after will not
be accepted. If an employee is charging any
hours these are submitted via the electronic
time sheet system. If no hours are being
charged, no time sheet needs to be submitted.
Charging any time – be it PTO or Non-PTO
sick does not extend out the period for
Disability, merely changes the method of
payment.
8.15
–––––
LONG-TERM DISABILITY (LTD):
Long-term disability (LTD), if elected, applies
to all regular full-time and regular part-time
employees.
An employee may be eligible for benefits
from the LTD program if they are disabled
beyond 13 weeks and have enrolled in the
LTD program. The Disability Carrier will
prepare a LTD notification letter to be sent
to the employee informing the employee of
their LTD status (approved or denied) and the
company policy on terminating employees
who have been on Medical leave for 12
months. If the LTD claim is approved, the
employee’s status will be changed to LTD in
our systems.
Employees on leave for 6 months or more may
be subject to analysis for Waiver of Premium
in regards to their Basic Life Insurance benefit.
If they are denied, the employee’s Basic Life
Insurance through the Company is terminated
and they will be given a chance to Port and
Convert their Life Insurance by the Company’s
Life Insurance Carrier.
8.16
–––––
PARTIAL DISABILITY
(PSTD/PLTD):
Employees on a Disability Leave may end
up returning to the company in a Partial
Disability state as directed by their doctor.
Those employees who were being paid by
Disability benefits through the Company may
be entitled to Partial Disability benefits, as
determined by the Disability Carrier.
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 To receive Partial Disability an employee must:
•• Have been on a continuous Disability Leave
for a period of more than a week prior to
starting Partial Disability.
•• Have Disability benefits (either STD, LTD or
both) through the company
•• Be approved by the Disability Carrier for
Partial Disability
An employee whose Company Life Insurance
was terminated while on Disability does not
immediately have the coverage reinstated on a
partial return.
8.17
–––––
FAMILY AND MEDICAL LEAVE
The Family and Medical Leave Act of 1993
(“FMLA”) entitles eligible employees to take
unpaid, job-protected leave in a defined
12-month period for specified family and
medical reasons. WSP has contracted with
a leave carrier for the administration and
recordkeeping associated with the employee’s
leave under the FMLA. Employees are
responsible for familiarizing themselves with
WSP’s FMLA Policy.
Eligibility Requirements
Employees are eligible for FMLA if:
•• At least fifty (50) or more employees are
employed within a 75-mile radius of the
employee’s work site;
•• The employee has been employed for at least
12 months; and
•• The employee has worked at least 1,250
hours within the previous twelve (12)
90
months.*
*Special hours of service requirements apply
to airline flight crew employees.
Basic Leave Entitlement
The FMLA requires covered employers to
provide up to twelve (12) weeks of unpaid,
job-protected leave in a 12-month period
to eligible employees for certain family
and medical reasons. The 12-month period
is determined on a “rolling” 12-month
period measured backwards from the date
an employee first uses any FMLA leave.
Leave may be taken for any one, or for a
combination, of the following reasons:
•• To care for the employee’s child after birth,
or placement for adoption or foster care;
•• To care for the employee’s spouse or
domestic partner, child, child of domestic
partner, or parent (but not in-law) who has a
serious health condition; and/or
•• For the employee’s own serious health
condition (including any period of
incapacity due to pregnancy, prenatal
medical care or childbirth) that makes the
employee unable to perform one or more of
the essential functions of the employee’s job.
Leave to care for the employee’s child after
birth, or placement for adoption or foster
care must be taken within one (1) year of the
child’s birth or placement.
See also, State-Specific Appendix for state-
specific family and medical leave policies.
Job Benefits and Protection
If applicable, during FMLA leave, the
Company must maintain health coverage
under any “group health plan” on the same participating in school or other daily activities.
terms as if the employee had continued to
Subject to certain conditions, the continuing
work. If paid time off is substituted for
treatment requirement may be met by a
unpaid leave, the Company will deduct the
period of incapacity of more than three (3)
employee’s portion of any applicable health
consecutive calendar days combined with
plan premium as a regular payroll deduction.
at least two visits to a health care provider
If the employee’s leave is unpaid, the employee
or one visit and a regimen of continuing
must make arrangements with the HR HUB at
treatment, or incapacity due to pregnancy,
US-HRHUB@wsp.com prior to taking leave
or incapacity due to a chronic condition.
to pay their portion of any applicable health
Other conditions may meet the definition of
insurance premiums each month.
continuing treatment.
The Company’s obligation to maintain
health care coverage ceases if an employee’s Use of Leave
premium payment is more than 30 days late. An employee does not need to use this leave
For purposes of this paragraph, an employee entitlement in one block. Leave can be taken
will be considered to have returned to work intermittently or on a reduced leave schedule
if the employee returns to work for at least 30
when medically necessary. Employees must
calendar days, or the employee retires at the make reasonable efforts to schedule leave
end of the FMLA leave period or within 30
for planned medical treatment so as not to
days thereafter.
unduly disrupt the Company’s operations.
Upon return from FMLA leave, most Leave due to qualifying exigencies may also
employees must be restored to their original be taken on an intermittent basis.
or equivalent positions with equivalent pay,
benefits, and other employment terms. Substitution of Paid
Leave for Unpaid Leave
The use of FMLA leave cannot result in the
Employees may use accrued paid time off
loss of any employment benefits that accrued
while on unpaid FMLA leave. The substitution
prior to the start of an employee’s leave.
of paid time for unpaid FMLA leave time does
not extend the length of FMLA leaves and
Definition of Serious
the paid time will run concurrently with an
Health Condition
employee’s FMLA entitlement.
A serious health condition is an illness, injury,
impairment, or physical or mental condition Employee Responsibilities
that involves either an overnight stay in a
Employees must provide thirty (30) days’
medical care facility, or continuing treatment
advance notice of the need to take FMLA
by a health care provider for a condition that
leave when the need is foreseeable. When
either prevents the employee from performing
thirty (30) days’ notice is not possible, the
the functions of the employee’s job, or
employee must provide notice as soon as
prevents the qualified family member from
practicable and generally must comply with
91
 the Company’s normal call-in procedures.
Employees must provide sufficient
information for the Company to determine
if the leave may qualify for FMLA protection
and the anticipated timing and duration of
the leave. Sufficient information may include
that the employee is unable to perform job
functions; the family member is unable
to perform daily activities, the need for
hospitalization or continuing treatment by
a health care provider, or circumstances
supporting the need for military family leave.
Employees also must inform the Company
if the requested leave is for a reason for
which FMLA leave was previously taken or
certified. Employees may also be required
to provide medical certification and periodic
recertification supporting the need for leave.
Employer Responsibilities
Covered employers must inform employees
requesting leave whether they are eligible under
the FMLA. If they are, the notice must specify
any additional information required as well as
the employees’ rights and responsibilities. If
they are not eligible, the employer must provide
a reason for ineligibility.
Covered employers must inform
employees if leave is designated as
FMLA-protected and the amount
of leave counted against the
employee’s leave entitlement. If
the employer determines that the
leave is not FMLA-protected, the
employer must notify the employee.
Unlawful Acts by Employers
FMLA makes it unlawful for the Company to:
92
•• Interfere with, restrain, or deny the exercise
of any right provided under the FMLA;
•• Discharge or discriminate against any person
for opposing any practice made unlawful
by the FMLA or for involvement in any
proceeding under or relating to the FMLA.
Concerns regarding a possible violation
with respect to either of these obligations
should be reported to the Company’s Human
Resources Department.
Enforcement
Employees may file a complaint with the U.S.
Department of Labor or may bring a private
lawsuit against an employer.
FMLA does not affect any Federal or State
law prohibiting discrimination, or supersede
any State or local law or collective bargaining
agreement, which provides greater family or
medical leave rights.
8.17.1 MILITARY FAMILY
LEAVE ENTITLEMENTS
Eligible employees whose spouse, domestic
partner, child, child of domestic partner, or
parent is on covered active duty or called to
covered active duty status may use their
12-week leave entitlement to address
certain qualifying exigencies.
Qualifying exigencies may include
attending certain military events,
arranging for alternative childcare,
addressing certain financial and
legal arrangements, attending
certain counseling sessions,
and attending post-deployment
reintegration briefings. FMLA also includes a
special leave entitlement that permits eligible
employees to take up to 26 weeks of leave
to care for a covered service member with
a serious injury or illness during a single
12-month period. For more details, see WSP’s
FMLA Policy available on the intranet. See
also, the State-Specific Appendix.
The FMLA definitions of a “serious injury or
illness” for current Armed Forces members
and covered veterans are distinct from the
FMLA definition of “serious health condition”
applicable to FMLA leave to care for a covered
family member.
8.18
–––––
WSP RESPONSIBILITIES
Supervisors and the HR Business Partner
have the responsibility to keep each other
apprised of any employee request for a leave
of absence at the time the request is made.
8.19
–––––
ALLOWABLE MAXIMUM
DURATION FOR LEAVES
OF ABSENCE-LONG TERM
DISABILTIY
Employee benefits will continue for up to 12
months on an approved leave (other than a
military leave), and to the extent permitted
by the carriers and applicable law. Business
Travel Accident and any Dependent Care
FSA will be suspended during the employee’s
leave. If the employee does not return to
work, benefits may be terminated to the
extent permitted by law. COBRA will
be offered for medical, dental and vision
benefits in effect at that time. The duration
of employee’s Long Term Disability benefit
is based on the employee’s age at the onset
of disability. If the employee is on a military
leave, they may elect to continue group health
plan benefits for up to 24 months.
8.20
–––––
RESPECTING UNPAID LEAVE
As a general rule, an employee on any type
of unpaid leave should be fully relieved of
their work and not asked to perform work
while on leave. If supervisors need to contact
employees on leave, they should consult
with their HR Business Partner in advance
of contacting the employee. Additionally,
if supervisors become aware of employees
performing work while on leave, they should
promptly notify their HR Business Partner.
8.21
–––––
RETURNING TO WORK
Upon returning to work from a disability leave,
the employee must provide their manager and
the HR Business Partner with a doctor’s note
stating they can return to work, detailing any
applicable restrictions and time periods for
those restrictions. This note must be presented
on employee’s first day back to work. If an
employee fails to present such a note, the
employee must not start work and will be sent
home until a note is obtained.
8.22
–––––
TIMESHEETS WHILE ON
INTERMITTENT LEAVE
93

PROJECT Excused Absence
[Applicable
TASK
Leave Type]
TYPE Regular Hours
WSP does not track leave hours on timecards
unless an employee is being paid by the
company during that leave – such as through
PTO usage or Paid Parental Leave. If an
employee is on an intermittent leave of absence,
the hours worked should be reported on the
employee’s timecard.
Hours used for FMLA are reported to the Leave
Carrier within 5 days of use and only logged on
the timecard if they are being covered by PTO,
as FMLA leave is unpaid.
On a timecard the employee charges the
following:
8.23
–––––
MILITARY LEAVE
A military leave of absence will be granted
to employees who are absent from work due
to service in the U.S. uniformed services in
accordance with the Uniformed Services
Employment and Reemployment Rights Act
(USERRA) and/or applicable state laws.
Advanced notice of military service is required,
94
unless military necessity prevents such notice
or it is otherwise impossible or unreasonable.
Employees must provide the HR HUB at
US-HRHUB@wsp.com with a copy of their
military papers as soon as they receive them.
Military leave is unpaid. However, employees
may elect to use any available PTO during this
leave. Use of PTO time in these cases must
still comply with WSP’s normal PTO Policy.
Provided an employee’s absence does not exceed
applicable statutory limitations, he or she will
retain reemployment rights and accrue seniority
and benefits in accordance with applicable
federal and state laws.
Employees who currently have benefits with
WSP and will be covered by Military or
other insurance coverage can initiate a “gain
of coverage” life event to remove themselves
from WSP benefits coverage while the other
insurance is available. If or when this other
insurance coverage becomes no longer available,
the employee can initiate a “loss of coverage” life
event to be added back to WSP’s benefits. The
life events must be initiated within 31 days of
the gain or loss of coverage.
8.24
–––––
STATE/LOCAL MANDATED
LEAVES
For some locations, local or state mandates
may be in place that are supplemental to those
provided under federal law. In these cases,
WSP will honor whichever mandate is more
generous. See State-Specific Appendix for
state-specific policies As these mandates are
frequently changing, please contact a member
of the HR HUB at US-HRHUB@wsp.com for
additional information.
95
 It is WSP’s policy to reimburse employees for
reasonable and necessary expenses incurred
9.
in connection with approved travel on behalf
of WSP. All business travel must be booked
through the Corporate Travel Department
using the approved travel agency and a failure
to do so may result in disciplinary action, up
BUSINESS
to and including termination.
9.1
–––––
TRAVEL
AUTHORIZATION AND
RESPONSIBILITY
All business travel must be approved in
advance by the employee’s supervisor. All
international travel requires advance approval
using the International Travel Authorization
Form. An individual may not approve their
own travel and/or reimbursement. Travel
must be approved by their supervisor.
Employees who frequently travel on behalf
of the Company (once per month or more)
must use a corporate credit card for all
allowable company-related travel expenses.
These employees must apply for and will then
be issued a corporate credit card. This card
is for the individual employee’s allowable
company business related travel expenses. It
is not for personal use nor should it be used
to pay for another employee’s travel expenses.
Employees who travel less frequently
than once per month should contact
the Travel Department to set up
a “ghost account” to book any
travel. Employees that do not
use either the corporate credit
card or a properly authorized
“ghost account” for company travel
96
will not be reimbursed and may be subject
to disciplinary action, up to and including
termination.
Upon completion of the trip, and within 30
days, the employee must submit expense
reports and supporting documentation to
obtain reimbursement of expenses. The
employee must take the iExpense training
before submitting their first expense report.
Failure to comply with this policy may result
in discipline, up to and including termination.
9.2
–––––
RECEIPTS
Original receipts ARE REQUIRED for ALL
charges of $75 or more (except for business
mileage incurred during the use of a personal
vehicle). Where required, itemized receipts
must be submitted. It is unethical to manually
reproduce a receipt when the original or a
copy of the receipt is not available; doing so,
may lead to disciplinary action, up to and
including termination.
Project contract requirements concerning
receipts will take precedence over WSP policy.
9.3
–––––
AIR TRAVEL
Air travel reservations should be made
as far in advance as possible in order
to take advantage of reduced fares.
A traveler cannot choose to fly on
a specific airline based on frequent
flier miles.
Air travel must be booked through
the approved travel agency. If the
97
 employee finds lower airfare on any internet
site than that suggested by the travel agency,
the employee should contact the Travel
Department with the exact details of the flight
before booking.
Economy Class
Economy tickets must be purchased for
domestic flights in the U.S.
Economy Plus Class
Economy Plus tickets may be purchased for
international travel to the U.K. on preferred
carriers.
Business Class
Business Class tickets may be purchased for
international flights of eight hours or longer,
including stops but not including layovers.
Business Class tickets may also be purchased
if travel time is less than eight hours
when the traveler is flying internationally
overnight to attend a meeting immediately
upon arriving, or when the traveler is only
on the ground for one day. Upgrades and
deviations from lowest logical airfare are
non-reimbursable. Upgrades to business class
or first class may be accomplished using
frequent flier miles only if there are no costs
incurred by the Company.
9.4
–––––
RAIL TRANSPORTATION
Rail transportation can be used as an
alternative means of travel. In these cases, the
most economical seating must be used. Coach
class is the standard for all trains that operate
with coach and business class. Business fare
98
is the standard for train travel on Acela or
Acela Express trains, which operate with
business and first class.
9.5
–––––
GROUND TRANSPORTATION
Employees are expected to use the most
economical ground transportation appropriate
under the circumstances and should generally
use the following:
Courtesy Cars
Many hotels have courtesy cars, which will take
travelers to and from the airport/rail station at
no charge. Employees should take advantage of
this free service whenever possible.
Public Transit
(Subway, Metro, Ferry, etc.)
Many cities have their own systems of
public transit available, which can be faster
and more economical than other forms of
ground transportation.
Rental Cars
If a rental car is required, it should be
procured at a preferred rate in the most
economical way possible and must be
reserved from the Company’s preferred
suppliers. The car’s gas tank should be
returned full unless the rental company offers
a competitive rate that costs less than local
gas stations. Employees should not select the
option of pre-paying for a full tank of gas
unless it is available at a reduced price than
local gas stations. The Company supports a
rental for a standard intermediate car, but
whenever feasible a fuel efficient hybrid
may be used. If 3 or more employees are
traveling together, a larger class of vehicle
will be authorized and the employee making
the reservation should provide a list of
employees to ride in the car. Employees
should not purchase any insurance beyond
what is automatically provided with the
rental. Unauthorized insurance will not
be reimbursed. Insurance CDW (Collision
Damage Waiver) should be declined as it is
provided by the Corporate Credit Card (LDW)
or the company umbrella insurance when
paying cash.
Taxis
Taxis should be used only when other forms
of group transportation are not available,
when time constraints dictate or when the
cost of the taxi is less than an alternate form
of transportation.
Car Service
Car services (through private companies
or ride-sharing services such as “Uber”
or “Lyft”) are expensive so other forms of
transportation should be considered when
practical. Car services can be used when the
cost of the service is more economical than a
taxi or public transportation or taxi service is
not readily available.
9.5.1 PERSONAL CARS
Employees are compensated for use of
their personal cars when used for company
business (but not commuting to, or from,
work) When individuals use their personal
car for such travel, including travel to and
from the airport, mileage will be allowed
at the currently approved IRS rate per mile.
This covers gas and maintenance and those
will not be reimbursed separately; however,
parking and tolls may be reimbursed. In the
case of individuals using their personal cars
to take a trip that would normally be made
by air, the total reimbursement should not
exceed the sum of the lowest available round
trip coach airfare. Excessive mileage claims
will be reviewed by Corporate Accounts
Payable on a periodic basis. When a client
authorizes the use of a personal vehicle and
the contract states reimbursement at a rate
less than the IRS rate, the Company will
reimburse at the IRS rate. The difference
should be noted on the Employee’s expense
report and separated between reimbursable
and non-reimbursable expenses.
To use a personal vehicle for company
business, employees must (1) maintain
a valid driver’s license issued within the
United States, (2) have taken the WSP US
Health & Safety Orientation and Defensive
Driver Awareness Training, and (3) maintain
bodily injury and property damage liability
insurance that complies with local laws but
in all instances, carry minimum liability
coverage of $100,000 per person/$300,000
per incident. Employees are solely responsible
for their personal automobile insurance
premiums and deductible obligations. 
Employees should be aware of the extent of
coverage (if any) provided by their automobile
insurance policy for travel that is business or
non-personal in nature.  In claims involving
employees driving their own vehicles for
business purpose, the employee’s automobile
insurance policy provides primary coverage
and the Company’s Automobile Insurance
Policy will act as secondary insurance.  
The Company does not maintain physical
99
 damage insurance coverage (comprehensive
& collision) for owned, leased or non-owned
vehicles (including employee vehicles).
Employees involved in an automobile
accident while using their personal vehicle
for company business will be reimbursed for
damages to the vehicle for up to $300, or the
amount of the employee’s physical damage
insurance deductible, whichever is less.
Any accidents occurring while driving a
personal car on company business must
be reported immediately to the Risk &
Insurance Manager.
9.5.2 PARKING/TOLLS
Actual and reasonable parking and toll
expenses, including charges for hotel parking,
incurred by employees traveling on company
business will be reimbursed. Employees are
encouraged to take the lowest cost option;
factors such as time, weather, safety and
luggage should be part of the decision-
making process.
The costs of traffic and parking tickets, fines,
etc., are the responsibility of the employee
and will not be reimbursed.
9.6
–––––
LODGING (COMMERCIAL)
All lodging for overnight stays must be
booked through WSP’s travel agency and use
the Company’s preferred hotels and failure to
do so may result in disciplinary action, up to
and including termination. If the employee
is attending a conference or similar event
which has associated lodging, they may stay
at the conference hotel but must notify the
travel agency for record keeping purposes.
100
Where client contracts require adherence
to U.S. Federal Travel Regulations (FTR)
or International Joint Travel Regulations
(JTR), employees should be mindful of the
recommendations for the respective city
when making reservations. Employees should
take advantage of government or client rates if
available and appropriate.
Employees requiring long-term lodging (over
14 days) must use WSP’s designated long-
term accommodations.
Employees are responsible for all
cancellations. No Show charges will be the
employee’s responsibility.
9.7
–––––
PER DIEM
Certain projects require that the employee be
reimbursed according to approved per diem
rates. Per Diem reimbursements must include
prior authorization and a per diem document
detailing the daily rate must be included with
each expense report submission showing the
reimbursement date(s).
9.8
–––––
RELOCATION EXPENSES
Because of tax implications, relocation
expenses are required to be reported on a
“Relocation Expense Report,” and submitted
to the Payroll Department for processing.
Please contact your HR Business Partner for
details.
9.9
–––––
TDY (TEMPORARY DUTY)
There are instances where employees are
sent on assignments away from their home
office for a duration of less than one year
(these assignments are not normal business
travel). Employees on these temporary
assignments will receive a temporary duty
(TDY) agreement. The TDY agreement must
be included in the documentation with every
expense report submission.
9.10
–––––
MEALS
9.10.1 PERSONAL MEALS
DURING TRAVEL
WSP’s policy is to conform to the U.S. FTR
rates for travel meals whenever possible.
Employees will be reimbursed for actual
and reasonable expenses incurred for meals,
except in cases where client contracts dictate
that per diem rates are mandatory and
applicable.
While WSP will not set a firm
maximum amount, it is expected
that the employee be prudent
and conservative, and a daily
meal expense of about $50 per
day is a reasonable guideline.
Managers should use discretion
before approving amounts in excess
of $50 per day. When clients require
adherence to the FTR rates for travel meals,
the Company will not be reimbursed beyond
those rates. When per diem rates apply to
project billable expenses, reimbursement
over the per diem rates will be paid only
when specifically authorized by the Project
Manager for the contract. The employee’s
expense report should include the detailed
meal receipt as well as credit card receipt for
each meal expenditure. Employees who are
issued a corporate credit card should always
use this card to purchase meals during travel,
and need only to include these receipts for
expenses in excess of $75; a failure to do so
may result in disciplinary action, up to and
including termination.
9.10.2 BUSINESS AND GROUP MEALS
Business meals are meals for a group of
people, including external stakeholders,
where business is discussed. Business meal
expenses are not subject to federal per diem
rates; however, to qualify as allowable under
FAR, such expenses must be adequately
supported. Regardless of whether the project
is for a government client or not, business
meals must be reported in accordance with
FAR regulations and must be supported by
detailed documentation on the employee’s
expense report. The detailed meal receipt
as well as credit card receipt for the
business meal is required. Expense
reports must include the names
of all attendees (including WSP
employees), titles and respective
organization(s), and the business
topic(s) discussed must be
specified. The approving manager
must review and verify that all attendees
are in compliance with company policy when
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 approving business meals.
Meals attended by multiple company
employees that do not constitute a business
meal as defined above shall be paid by the
most senior employee present in the party
(defined as the highest-ranking individual by
job title in the cost center) and reported on
the employee’s expense report as “Breakfast,”
“Lunch” or “Dinner.” The names of those for
whom the bill was paid should be provided.
As with a business meal, detailed receipts are
required for expenses of $75 or more.
If the employee has tried but failed to
secure a detailed receipt for a business meal
expenditure of $75 or more, the expense type
must read “Unallowable FAR Costs” in lieu
of “Business Meal.” When using the expense
type “Unallowable FAR Costs,” the names
of all attendee’s (including WSP employees),
their titles, respective organization(s), and
business topic of discussion must be specified
in either the justification field or as a separate
attachment with your scanned documents.
Employees should avoid, to the extent feasible,
accepting reimbursement from a guest for
a meal; if it is unallowable for the guest to
accept a paid meal from WSP, the employee
and the guest should ask for separate
checks at the start of the meal; employees
should also request separate checks over
split checks. In rare and unavoidable cases
where an employee is reimbursed by a guest
for a portion of the meal, the employee
should show the offset on their expense
report; employees should not accept cash
reimbursement from government/public
agency employees and should document
reimbursement for a meal in writing with the
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reimbursing party in an effort to avoid the
appearance of impropriety.
Costs incurred by non-essential business
meal attendees (e.g., clients’ spouses, domestic
partners, etc.,) must be segregated.
Tips for all meals should be a reasonable
amount currently at the recommended 20% rate.
9.11
–––––
CELL PHONE CHARGES
Cell phone charges are reimbursed through
the BYOM (Bring Your Own Mobile) Program
and should not be included on an expense
report. Any exceptions require approval from
the US Financial Services Manager. The US
Financial Services Manager’s approval e-mail
must be included with the expense report
when submitted for processing.
If traveling outside the United States,
the employee will need to contact their
wireless provider in advance and enroll in
international temporary roaming services.
If inside a WSP facility, the international
call should be dialed from the facility and
data usage should be restricted to WiFi to
minimize use of roaming services. Fees for
international charges may be submitted
through an expense report and must include a
receipt. The expense type “Telephone Roaming
Charge” should be used.
Purchases of mobile devices and accessories
are generally not reimbursable, and any
business need outside of the BYOM program
must be submitted to the purchasing
department including the specific reasons the
device/accessory is required. Connectivity
to our corporate accounts requires approval
from the US Financial Services Manager.
9.12
–––––
OTHER BUSINESS EXPENSES
Employees will be reimbursed for the cost
of Wi-Fi access (if no free access is available)
where the employee documents that the wi-fi
was needed to perform work for WSP. If the
employee is traveling internationally, and
the employee’s cell phone contract does not
support international calls, the employee may
use a pay phone, purchase a local cell phone
or use the phone at the hotel to make business
calls and necessary calls to maintain contact
with their immediate family. The cost for
these calls will be reimbursed, as will costs
for faxes, photocopies and other business-
related expenses.
The employee will be reimbursed for the cost
of visa fees and recommended immunizations
for international travel.
It is the responsibility of the employee to
promptly notify their HR Business Partner
of any costs the employee has incurred
to perform work for WSP for which
reimbursement has not been offered by WSP.
WSP will review such costs and, if WSP
deems the costs to be reasonably related
to work performed for WSP, WSP will
reimburse the employee for all or a reasonable
proportion of the cost. If an employee feels
that the amount offered as reimbursement
is insufficient, the employee most promptly
inform their HR Business Partner. A failure to
promptly notify WSP of such costs may result
in disciplinary action, up to and including
termination. Whenever possible, the employee
should seek approval from their HR Business
Partner before the cost is incurred.
Employees temporarily working remotely, as
a convenience to the employee, will not be
reimbursed for costs associated with their
remote workspace.
9.13
–––––
VACATION IN CONJUNCTION
WITH BUSINESS TRAVEL
When an employee plans to combine
personal travel with a business trip, the
personal travel must be accomplished
without additional cost to WSP. Employees
are expected to avoid commingling non-
business travel costs with company costs.
Should this occur, all personal costs during,
preceding or following authorized business
travel must be clearly identified on the
expense report and supporting documents,
and must be excluded from the amount
for which reimbursement is claimed. Any
savings resulting from personal travel are to
be passed on to WSP. WSP encourages taking
advantage of lower costs if flying is less
costly on a weekend rather than a weekday
provided the associated total costs do not
exceed the differential between airfares. WSP
will not prepay any personal expenses with
the intention of being “repaid” later, nor will
any personal expenses be reimbursed.
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 9.14
–––––
SPOUSE OR OTHER DEPENDENT
EXPENSES
If a spouse or dependent (including domestic
partner) accompanies an employee on a
business trip, any additional incremental
cost for travel, lodging, meals or other travel
expenses for the spouse/dependent will not
be reimbursed by the Company. Under special
circumstances, spouse/dependent travel
could be approved by the Regional Business
Manager or Sector President and your HR
Business Partner. For example, this may apply
for a spouse accompanying the employee to
an awards ceremony where the employee will
receive recognition or the spouse/dependent
participates in activities deemed to be for
the benefit of WSP. For such authorized
spouse/dependent travel, the expenses will
be reimbursed via iExpense, with appropriate
taxes withheld, and reported on the
employee’s W-2. Spousal expenses are always
taxable to the employee unless an exception is
approved by HR in consultation with Finance.
9.15
–––––
MEETING AND CONFERENCE
PLANNING
The planning for all meetings or conferences
for six or more participants, which will
require external location rental and/or travel
for any WSP employee, must be coordinated
with the Corporate Travel Department and
WSP’s travel agency. All related services
should be billed to the appropriate cost center
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and paid through the cost center’s purchasing
card or by direct bill. Meeting and conference
expenses should not be paid with a corporate
or personal credit card and a failure to follow
this policy may result in disciplinary action,
up to and including termination.
9.16
–––––
CHARITABLE CONTRIBUTIONS/
DONATIONS
Charitable contributions and donations
should not be processed through an expense
report and a failure to follow this policy
may result in disciplinary action, up to and
including termination. Please contact the Tax
department for directions on how to proceed
with these types of requests.
9.17
–––––
CAPITAL EXPENDITURES &
PAYMENT OF VENDOR INVOICES
All capital expenditures should be purchased
through the corporate IT/Purchasing
department. Any capital expenditure that is
bought using your corporate travel card will
NOT be reimbursed. Under no circumstances
should an employee pay for vendor invoices.
To facilitate accurate 1099 tax reporting,
all vendor invoices must be paid through
Accounts Payable.
9.18
–––––
SPONSORSHIPS (GOLF,
GALA TABLES, AWARD
CEREMONIES, ETC.)
Sponsorships require a separate pre- approval
from the Regional Business Manager (or
Sector President).
9.19
–––––
GENERAL BUSINESS
TRAVEL RESTRICTIONS
The following items that may be associated
with business travel will NOT be reimbursed
by WSP, unless otherwise required by law:
•• Eligible expenses not submitted for
reimbursement within 30 days
•• Unexplained or undocumented expenses
•• Costs incurred by employee’s failure to
cancel travel or hotel reservations in a
timely fashion
•• Unauthorized upgrade charges for airline,
hotel and car rental
•• Personal credit card late fees/finance
charges
•• Travel accident insurance premiums and/or
purchase of additional travel insurance
•• Repairs, insurance and maintenance of
personal cars
•• The costs of traffic or parking tickets,
fines, etc.
•• Personal entertainment expenses including
in-flight movies, headsets, health club
facilities, hotel pay-per-view movies, in-
theatre movies, social activities, sporting
events, personal reading material, and
related incidental costs
•• Country club dues/personal
membership fees
•• Unauthorized gifts, entertainment,
hospitality, or travel
•• Airline club memberships
•• Child-care, babysitting, house-sitting, pet-
sitting/ kennel charges
•• Commuting between home and
the work location
•• Personal grooming or hygiene expenses
•• Laundry, dry cleaning and service tips (i.e.
meal, housekeeping, porters, etc.) if the trip
lasts less than 4 days
•• Loss or damage of personal property
•• Residential internet
•• Items entered on an expense report using a
future date
•• TSA pre-check expenses
Exceptions to the items listed above will
be reviewed on a case by case basis and
will require executive approval. The email
approval must be included with the expense
report backup documentation. Failure to
comply with this policy or to timely submit
expenses for reimbursement may result in
discipline, up to and including termination.
For additional iExpense procedures and
guidelines, please refer to the iExpense page
on the Company Intranet.
105
 RECEIPT & ACKNOWLEDGEMENT OF
Company is authorized to set-off and deduct from my final compensation the amount of the reimbursement.

•• If WSP under any circumstance pays any insurance premiums or retirement system contributions on my
WSP USA EMPLOYEE HANDBOOK behalf that I am obligated to make under the applicable benefit plan, the Company is authorized to set-
off and deduct from my compensation the value of any such payments, which constitute an advance of
future wages.
Please read the WSP USA Employee Handbook in its entirety, sign below, and return only this page to your
•• If I voluntarily resign from WSP within one year of receipt of a non-immigrant visa or permanent
HR Business Partner.
residency under conditions where WSP paid for fees related to obtaining a non-immigrant visa or
permanent residency status, then WSP may deduct and/or recover fees, paid on my behalf, to the extent
that such fees were in excess of fees that WSP was required to pay by law.
I ______________________________ hereby acknowledge that I received and read the WSP
USA Employee Handbook. I am aware that as an employee of WSP USA Inc., WSP USA Buildings Inc. or In the event that I receive from WSP any excess or unearned compensation of the kind described above,
WSP USA Services Inc. (“WSP” or the “Company”) it is my obligation to comply with any and all WSP I agree to repay the Company the amount of any such excess or unearned compensation, and further
policies. I understand that WSP’s policies can change at any time at the sole discretion of WSP’s President acknowledge the Company’s right of set-off.
and CEO. I understand that my employment with WSP is at-will (except where formal employment
agreements, state or local law may limit such status) and that nothing in the WSP USA Employee
Handbook should be construed as an expressed or implied employment contract between me and WSP Employee's Printed Name: ____________________ Position: ___________________
regarding the terms, conditions or duration of my employment. I understand that both I and WSP have the
Employee's Signature: _______________________ Date: ___________________
right to end my employment any time, with or without cause and with or without advance notice.
The signed original copy of this receipt should be given to management - it will be filed in your employees file
I am aware that during the course of my employment, confidential information will be made available to
me, including but not limited to technical standards, tools and information, client drawings, marketing
strategies, customer lists, pricing policies, and other related information. I understand that any such
information is proprietary and that maintaining the integrity of confidential and Company information
is critical to the success of WSP. Under no circumstances should Company information be distributed to
any third parties or stored outside of prescribed company storage parameters without authorization. In
the event of termination of employment, whether voluntary or involuntary, I understand that I must return
to WSP all Company information and property in any electronic or hard copy form and that I am under
obligation not to disclose, utilize, distribute, compromise or exploit any such information by any means.

I understand and agree that in addition to any deductions or withholdings the Company makes from my
earned compensation in accordance with applicable law or to which I have otherwise agreed, and unless
otherwise prohibited by law, the Company may deduct funds as a set-off from my earned compensation,
including my final paycheck, for the following reasons:

•• If I receive an overpayment of compensation for any reason, WSP is authorized to set-off and deduct
from my compensation an amount equal to any such overpayment.

•• If I take any advanced or borrowed paid time off, and by employment with WSP separated prior to the
date that I would have normally accrued the advanced PTO, the Company is authorized to set-off and
deduct from my final compensation the value of the advanced-but-not-accrued PTO.

•• If my employment with WSP separates within 12 months after I have received tuition reimbursement, the

106 107
 RECEIPT & ACKNOWLEDGEMENT OF ANTI-
HARASSMENT, NON-DISCRIMINATION, AND
NON-RETALIATION POLICY
WSP does not tolerate and prohibits discrimination or harassment of or against our job applicants, contractors,
interns, volunteers, or employees by another employee, supervisor, vendor, customer, or any third party on the
basis of race, color, creed, religion, national origin, ancestry, citizenship status, age, sex or gender (including
pregnancy, childbirth and related medical conditions), gender identity or gender expression (including
transgender status), sexual orientation, marital status, military service and veteran status, physical or mental
disability, protected medical condition as defined by applicable state or local law, genetic information, or any
other characteristic protected by applicable federal, state, or local laws and ordinances (referred to as “protected
characteristics”).  WSP also prohibits retaliation as defined below.
WSP is committed to a workplace free of discrimination, harassment and retaliation. These behaviors are
unacceptable in the workplace and in any work-related settings such as business trips and Company sponsored
social functions, regardless of whether the conduct is engaged in by a supervisor, co-worker, client, customer,
vendor or other third party. In addition to being a violation of this policy, discrimination, harassment or
retaliation based on any protected characteristic pursuant to applicable federal, state, or local laws and ordinances
also is unlawful.  For example, sexual harassment and retaliation against an individual because the individual
filed a complaint of sexual harassment or because an individual aided, assisted or testified in an investigation or
proceeding involving a complaint of sexual harassment are unlawful.
Discrimination Defined
Discrimination under this policy means treating differently or denying or granting a benefit to an individual
because of the individual’s protected characteristic.  •• Propositions, or suggestive or insulting comments of a sexual nature
Harassment Defined
Harassment generally is defined in this policy as unwelcome verbal, visual or physical conduct that denigrates or
shows hostility or aversion towards an individual because of any protected characteristic when:
•• Submission to that conduct is made either explicitly or implicitly a term or condition of an individual's
employment; or
•• Submission to or rejection of the conduct by an individual is used as the basis for employment decisions
affecting the individual; or
•• The conduct has the purpose or effect of unreasonably interfering with an individual’s work performance
or creating an intimidating, hostile, or offensive working environment.
108
Harassment can be verbal (including slurs, jokes, insults, epithets, gestures or teasing), visual (including offensive
posters, symbols, cartoons, drawings, computer displays, text messages, social media posts or e-mails) or physical
conduct (including physically threatening another, blocking someone’s way, etc.).  Such conduct violates this
policy, even if it is not unlawful.  Because it is difficult to define unlawful harassment, employees are expected to
behave at all times in a manner consistent with the intended purpose of this policy.
Sexual Harassment Defined
Sexual harassment can include any of the above actions, as well as other unwelcome conduct, such as unwelcome
or unsolicited sexual advances, requests for sexual favors, conversations regarding sexual activities and other
verbal or physical conduct of a sexual nature when:
•• Submission to that conduct or those advances or requests is made either explicitly or implicitly a term or
condition of an individual's employment; or
•• Submission to or rejection of the conduct or advances or requests by an individual is used as the basis
for employment decisions affecting the individual; or
•• The conduct or advances or requests have the purpose or effect of unreasonably interfering with an
individual’s work performance or creating an intimidating, hostile, or offensive working environment.
Examples of conduct that violates this policy include:
•• Unwelcome sexual advances, flirtations, advances, leering, whistling, touching, pinching, assault, blocking
normal movement
•• Requests for sexual favors or demands for sexual favors in exchange for favorable treatment
•• Obscene or vulgar gestures, posters, or comments
•• Sexual jokes or comments about a person’s body, sexual prowess, or sexual deficiencies
•• Derogatory cartoons, posters, and drawings
•• Sexually-explicit e-mails or voicemails
•• Sharing or sending sexually explicit media (or links thereto)
•• Uninvited touching of a sexual nature
•• Unwelcome sexually-related comments
•• Conversation about one’s own or someone else’s sex life
•• Conduct or comments consistently targeted at only one gender, even if the content is not sexual
•• Teasing or other conduct directed toward a person because of the person’s gender
109
 Retaliation Defined WSP will take corrective measures against any person who it finds to have engaged in conduct in violation of
this policy, if WSP determines such measures are necessary.  These measures may include, but are not limited
Retaliation means adverse conduct taken because an individual reported an actual or perceived violation of this
to, counseling, suspension, or immediate termination.  Anyone, regardless of position or title, whom WSP
policy, opposed practices prohibited by this policy, or participated in the reporting and investigation process
determines has engaged in conduct that violates this policy or our Equal Employment Opportunity policy will
described below.  “Adverse conduct” includes but is not limited to:  any action that would discourage an employee
be subject to discipline, up to and including termination. This includes individuals engaging in discrimination,
from reporting discrimination, harassment or retaliation; shunning and avoiding an individual who reports
harassment or retaliation, as well as supervisors who fail to report violations of this policy, or knowingly allow
discrimination, harassment or retaliation; express or implied threats or intimidation intended to prevent an
prohibited conduct to continue. Individuals who engage in conduct that rises to the level of a violation of law can
individual from reporting discrimination, harassment or retaliation; and denying employment benefits because
be held personally liable for such conduct.
an applicant or employee reported discrimination, harassment or retaliation or participated in the reporting and
investigation process described below. *  *  *  * *

Remember, WSP cannot remedy claimed discrimination, harassment or retaliation unless you bring these claims
Reporting Procedures
to the attention of management.  Please report any conduct which you believe violates this policy or our Equal
The following steps have been put into place to provide a work environment at WSP that is respectful, Employment Opportunity policy. 
professional, and free of discrimination, harassment and retaliation.  If an employee believes someone has
violated this policy or our Equal Employment Opportunity Policy, the employee should promptly bring the I have read and understood the Company’s Anti-Harassment, Non-Discrimination, and Non-Retaliation Policy.
matter to the immediate attention of their supervisor(s), to their HR Business Partner (by making the report in
person, over the phone, or through email), or to WSP’s confidential whistleblower hotline by calling (1-877-533-
5310) or by emailing (wsp@expolink.co.uk). Additional details about WSP’s whistleblower hotline, known as Employee’s Printed Name: ____________________ Position: ___________________
“Expolink”, are available on the intranet.  If either of these individuals is the person toward whom the complaint Employee’s Signature: _______________________Date: ___________________
is directed, the employee should contact any higher-level manager in their reporting chain. If the employee
makes a complaint under this policy and has not received a satisfactory response within five (5) business days, The signed original copy of this receipt should be given to management - it will be filed in your employees file.
the employee should contact WSP’s EEO Officer, Martha Alongi, by phone or email EEO@wsp.com immediately.

Every supervisor who learns of any employee’s concern about conduct in violation of this policy or our Equal
Employment Opportunity Policy, whether in a formal complaint or informally, or who otherwise is aware of
conduct in violation of this policy must immediately report the issues raised or conduct to senior management or
Human Resources.

Investigation Procedures
Upon receiving a complaint, WSP will promptly conduct a fair and thorough investigation into the facts and
circumstances of any claim of a violation of this policy or our Equal Employment Opportunity policy to provide
due process for all parties.  To the extent possible, WSP will endeavor to keep the reporting employee’s concerns
confidential. However, complete confidentiality may not be possible in all circumstances. Employees are required
to cooperate in all investigations conducted pursuant to this policy.

During the investigation, WSP generally will interview the complainant and the accused, conduct further
interviews as necessary and review any relevant documents or other information.  Upon completion of the
investigation, WSP will determine whether this policy or our Equal Employment Opportunity policy has been
violated based upon its reasonable evaluation of the information gathered during the investigation.  WSP will
inform the complainant and the accused of the results of the investigation.

110 111