PIH Code of Ethics 2024

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

Imagine This... While on a business trip, a colleague of mine repeatedly asked me out for drinks and made comments about my appearance that made me uncomfortable. I asked him to stop, but he wouldn’t. We weren’t in the office and it was after regular working hours, so I wasn’t sure what I should do. Is it harassment? Yes, it is. This type of conduct is not tolerated, not only during working hours but in all work- related situations, including business trips. Tell your colleague such actions are inappropriate and must be stopped, and if they continue, report the problem. I just learned that a good friend of mine has been accused of sexual harassment and that an investigation is being launched. I can’t believe it’s true and I think it’s only fair that I give my friend an advance warning or a “heads up” so he can defend himself. Don’t I have a responsibility as a friend to tell him? Under no circumstances should you give him a “heads up.” Your friend will be given the opportunity to respond to these allegations and every effort will be made to conduct a fair and impartial investigation. An allegation of sexual harassment is a very serious matter with implications not only for the individuals involved but also for our Company. Alerting your friend could jeopardize the investigation and expose our Company to additional risk and possible costs.

Sexual Harassment A common form of harassment is sexual harassment, which in general occurs when: • Unwelcome actions are made a condition of employment or used as the basis for employment decisions such as a request for a date, a sexual favor, or other similar conduct of a sexual nature. • An intimidating, offensive, or hostile work environment is created by unwelcome sexual advances, insulting jokes, or other offensive verbal or physical behavior of a sexual nature.

Be Aware Of

• Unwelcome remarks, gestures, or physical contact. • The display of sexually explicit or offensive pictures or other materials. • Sexual or offensive jokes or comments (explicit or by innuendo) and leering.

• Verbal abuse, threats, or taunting.

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