PIH Code of Ethics 2024

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

We Are Good Partners

Subcontractor Relations We evaluate and engage with qualified subcontractors (including vendors) on an objective basis grounded in fairness. When selecting subcontractors or vendors, we assess each company’s ability to satisfy our business and technical needs and requirements. We also make purchasing decisions based on the long-term cost and benefit to our Company. All agreements are negotiated in good faith and must be fair and reasonable for both parties.

Commitment to Small and Disadvantaged Business Programs

How We Promote Diversity We are committed to partnering with small businesses (SB) and certified small disadvantaged businesses, including: • Historically black-owned colleges and universities (HBCU).

We believe that partnering with small and disadvantaged business partners benefits both our Company and our communities. That is why we are committed to complying with government-sponsored opportunity programs and maximizing the opportunities of these businesses.

• Minority institutions (MI).

• Women-owned small business (WOSB).

• HUBZone small businesses (HUBZone SB).

• Veteran-owned small business (VOSB).

• Service-disabled veteran-owned businesses (SDVOSB).

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