PIH Code of Ethics 2024

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

Be Aware Of

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Social Media Be careful when writing communications that might be published online. If you participate in internet discussion groups, chat rooms, bulletin boards, blogs, social media sites, or other electronic communications, even under an alias, never give the impression that you are speaking on behalf of our Company. If you believe a false statement about our Company has been posted, do not post or share nonpublic information, even if your intent is to “set the record straight.” Your posting might be misinterpreted, start false rumors, or may be inaccurate or misleading. Instead, contact the Marketing & Communications Department. • Giving public speeches, writing articles for professional journals or other public communications that relate to our Company without appropriate management approval. • The temptation to use your title or affiliation outside of your work for our Company without it being clear that the use is for identification only. • Invitations to speak “off the record” to journalists or the public who ask you for information about any of the companies or their clients.

At the end of the last quarter reporting period, my Supervisor asked me to record additional expenses, even though I had not yet received the invoices from

Communicating With the Public We are committed to maintaining honest, professional, and lawful internal and public communications. We need a consistent voice when making disclosures or providing information to the public. For this reason, it is important that only authorized persons speak on behalf of our Company. Communications with the media or the public should be referred to the Company’s Marketing & Communications Department. the supplier and the work has not yet started. I agreed to do it, since we were all sure that the work would be completed in the next quarter. Now I wonder if I did the right thing. No, you didn’t. Costs must be recorded in the period in which they are incurred. The work was not started, and the costs were not incurred by the date you recorded the transaction. It was therefore a misrepresentation and, depending on the circumstances, could amount to fraud.

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