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Phillips Infrastructure Holdings / PIH / Code of Ethics and Business Conduct
Honest and Fair Dealing We treat our clients, subcontractors, and vendors fairly. We work to understand and meet their needs, while always remaining true to our own ethical standards. We tell the truth about our services and capabilities and never make promises we can’t keep. In short, we treat our clients, subcontractors, and vendors as we would like to be treated.
Working With the Government We are committed to meeting the many special legal, regulatory, and contractual requirements that apply to our government contracts. These requirements may apply to bidding, accounting, invoices, subcontracting, employment practices, contract performance, gifts and entertainment, purchasing, and other matters. These requirements may also flow down to individuals and companies working on our behalf. Make sure you know and follow the laws, regulations, our Code, and Company policies as they relate to government-related work. Conflicts of Interest A conflict of interest can occur whenever you have a competing interest that may interfere with your ability to make an objective decision on behalf of our Company. Each of us is expected to use good judgment and avoid situations that can lead to even the appearance of a conflict, which can undermine the trust others place in us and damage our reputation. Conflicts of interest may be actual, potential, or even just a matter of perception. Since these situations are not always clear-cut, you need to fully disclose them to your Supervisor so that we can properly evaluate, monitor, and manage them. Be alert to situations, including the following, which are common examples of potential conflicts of interest:
Do What’s Right
• Obtain competitive information only through legal and ethical means, never through misrepresentation. • Respect the obligations of others to keep competitive information confidential.
Be Aware Of
• Retaining papers or computer records from prior employers in violation of laws or contracts. • Using anyone else’s confidential information without appropriate approvals. • Using job interviews as a way of collecting confidential information about competitors or others. • Receiving suggestions from third parties for new products, product features, or services when the source of the original idea is not fully known.
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