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Phillips Infrastructure Holdings / PIH / Code of Ethics and Business Conduct
Be Aware Of
must never conceal wrongdoing or permit others to do so. Never destroy documents in response to – or in anticipation of – an investigation or audit. If you have any questions or concerns about retaining or destroying corporate records, please contact Human Resources or our Corporate Compliance and Ethics Officer. Remember, everyone at our Company contributes to the process of recording business results and maintaining records. Whether you are filing an expense report, preparing a financial statement, or simply completing a time sheet, be honest, accurate, and complete.
Accurate Recordkeeping The accuracy and completeness of our disclosures and business records are essential to making informed decisions and to supporting investors, regulators, and others. Our books and records must accurately and fairly reflect our transactions in sufficient detail and in accordance with our accounting practices and policies. Some employees have special responsibilities in this area. If you are involved in any aspect of our financial reporting, make sure you meet all applicable procedural and legal requirements. Take care to ensure reports or disclosures about our financial records are full, fair, accurate, complete, objective, and timely, and never falsify or mischaracterize any book, record, account, entry, or transaction that relates to PIH or any of its companies. Records Management Documents should only be disposed of in compliance with Company policies and should never be destroyed or hidden. You • Requests by vendors, subcontractors, or others for confidential information about our Company, clients or about other partners if there is no associated business requirement or authorization. • Unintentional exposure of confidential information about our Company or clients in public settings or through unsecure networks.
Do What’s Right
• Create business records that accurately reflect the truth of the underlying event or transaction. Be guided by the principles of transparency and truthfulness. • Write carefully in all of your business communications. Write as though someday the records you create may become public documents.
Be Aware Of
• Records that are not clear and complete or that obscure the true nature of any action. • Undisclosed or unrecorded funds, assets, or liabilities.
• Improper destruction of documents.
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