PIH Code of Ethics 2024

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Phillips Infrastructure Holdings / PIH / Code of Ethics and Business Conduct

Asking Questions and Reporting Concerns If you see or suspect any violation of our Code, our policies, or the law, or if you have a question about what to do, talk to your Supervisor. If you’re uncomfortable speaking with your Supervisor, there are other resources available to help you:

• Contact another member of management.

• Contact our Human Resources Director.

• Contact our Compliance and Ethics Officer.

• Contact our Ethics Helpline at (844) 286.6021 or file a report online at pandj.ethicspoint.com. We will make every reasonable attempt to ensure that your concerns are addressed appropriately and are handled discreetly, to the furthest extent possible.

What to Expect When You Use the Helpline

The Helpline web portal and phone line are available 24 hours a day, seven days a week. Trained specialists from an independent third-party provider of corporate compliance services, will answer your call, document your concerns, and forward a written report to the Corporate Compliance and Ethics Officer for further investigation. When you contact the Helpline, you may choose to remain anonymous where allowed by local law. All reports will be treated equally whether they are submitted anonymously or not. After you make a report, you will receive an identification number so you can follow up on your concern. Following up is especially important if you have submitted a report anonymously, as we may need additional information in order to conduct an effective investigation. This identification number will also enable you to track the resolution of the case; however, please note that out of respect for privacy, we will not be able to inform you about individual disciplinary actions. Any report you make will be kept confidential by all individuals involved with reviewing and, if necessary, investigating it.

Remember, an issue cannot be addressed unless it is brought to someone’s attention.

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