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Phillips Infrastructure Holdings / PIH / Code of Ethics and Business Conduct
Do What’s Right
Imagine This... I received sensitive pricing information from one of our competitors. What should I do? You should contact our Corporate Compliance and Ethics Officer without delay and before any further action is taken. It is important, from the moment we receive such information, that we demonstrate respect for antitrust laws, and we make it clear that we expect others to do the same. This requires appropriate action that can only be decided on a case-to-case basis and may include sending a letter to the competitor.
• Let our reputation for quality, service, and fair pricing speak for itself. Never discredit or disparage our competition. • Do not enter into agreements with competitors or others to engage in any anti-competitive behavior, including setting prices or dividing up clients, suppliers, or markets. • Do not engage in conversations with competitors about competitively sensitive information. • Immediately notify your Supervisor or our Corporate Compliance and Ethics Officer if you think you may have received another organization’s confidential or proprietary information.
Be Aware Of
• Collusion – when companies secretly communicate or agree on how they will compete. This could include agreements or exchanges of information on pricing, terms, wages, allocations of markets, or levels of performance. • Bid-rigging – when competitors or service providers manipulate bidding so that fair competition is limited. This may include comparing bids, agreeing to refrain from bidding, or knowingly submitting noncompetitive bids. • Tying – when a company with market power forces customers to agree to services or products that they do not want or need. • Predatory pricing – when a company with market power sells a service below cost to eliminate or harm a competitor, with the intent to recover the loss of revenue later by raising prices after the competitor has been eliminated or harmed.
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