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Phillips Infrastructure Holdings / PIH / Code of Ethics and Business Conduct
Competing for Work We succeed when our work reflects our core values and exceeds our clients’ expectations. We’re also proud to be fiercely, but fairly, competitive in all that we do. No matter how hard we compete, we never rely on unfair tactics to gain an unfair advantage. Because our business involves competitive bidding of federal government contracts and routine decisions involving pricing, terms of sale, and interaction with competitors, it’s essential to know and follow antitrust laws, which help promote free and open competition in the marketplace. Antitrust laws are complex and compliance requirements can vary depending on the circumstances, but in general, the following activities are red flags and should be avoided and, if detected, reported to our Corporate Compliance and Ethics Officer: • Sharing our Company’s competitively sensitive information with a competitor. • Sharing competitively sensitive information of business partners or other third parties with their competitors. • Attempting to obtain nonpublic information about competitors from new hires or candidates for employment.
Do What’s Right
• Follow all applicable regulations and obligations for each government-funded contract. • Treat every business partner with respect, trust, honesty, fairness, and dignity. • Practice fairness and focus on diversity when hiring subcontractors or vendors – never discriminate on the basis of race, color, gender, national origin, age, religion, disability, citizenship, veteran status, marital status, or sexual orientation. • Help ensure that we maximize the participation of small or disadvantaged businesses in subcontracts. • Monitor work being done by our business partners to make sure they fulfill their responsibilities.
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