PIH Code of Ethics 2024

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

Our Non-retaliation Policy We will not tolerate any retaliation against any employee who, in good faith, asks questions, makes a report of actions that may be inconsistent with our Code, our policies, or the law, or who assists in an investigation of suspected wrongdoing. Reporting “in good faith” means making a genuine attempt to provide honest, complete, and accurate information, even if it later proves to be unsubstantiated or mistaken.

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Our Supervisor typically does nothing when concerns about potential misconduct are brought to their attention, and I believe this Supervisor has made things difficult for coworkers who have

raised issues. I have a problem – a coworker is doing something that I believe to be ethically wrong. What should I do? Take action and speak up. You are required to report misconduct. While starting with your Supervisor is often the best way to efficiently address concerns, if you do not believe that it is appropriate or do not feel comfortable doing so, you should talk to another member of management, or any of the resources listed in the Code. Someone misused the Helpline, made an anonymous call, and falsely accused someone of wrongdoing. Experience has shown that the Helpline is rarely used for malicious purposes, but it is important to know that we will follow up on calls, and anyone who uses the Helpline in bad faith to spread falsehoods or threaten others, or with the intent to unjustly damage another person’s reputation, will be subject to disciplinary action.

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