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Phillips Infrastructure Holdings / PIH / Code of Ethics and Business Conduct
Do What’s Right
activity does not interfere with your work at the Company. Working for a competitor, supplier, or client may raise conflicts that will need to be resolved. Also, any approved side or personal business should not compete with the Company. Personal investments A conflict can occur if you have a significant ownership or other financial interest in a competitor, vendor, supplier, or client. Make sure you know what’s permitted – and what’s not – by our policies and seek help with any questions. Civic activities Unless Company management specifically asks you to do so, you shouldn’t accept a seat on the board of directors or advisory board of any of our competitors, subcontractors, vendors, clients, or partners, especially if your current job gives you the ability to influence our relationship with them. Gifts and Entertainment A modest gift may be a thoughtful “thank you,” or a meal may be an appropriate setting for a business discussion. If not handled carefully, however, the exchange of gifts and entertainment may appear to create a conflict of interest or other misconduct. This is especially true if it happens frequently, or if the value is large enough that someone may think it can improperly influence a business decision. Proper records of such expenses must also be created and maintained. We do not accept or provide gifts, favors, or entertainment – even if it complies with our policies – if the intent is to improperly influence any decision.
Corporate opportunities If you learn about a business opportunity because of your job, it belongs to the Company first. This means that you should not take that opportunity for yourself unless you get approval from our Corporate Compliance and Ethics Officer. Friends and relatives On occasion, it is possible that you may find yourself in a situation where you are working with a close friend or relative who works for a client, supplier, or competitor. Since it is impossible to anticipate all situations that may create a potential conflict, you should disclose your situation to your Supervisor to determine if any precautions need to be taken. Outside employment To ensure there are no conflicts and that potential issues are addressed, you always need to disclose and discuss outside employment with your Supervisor. If approved, you must ensure that the outside • Avoid conflict of interest situations whenever possible. • Always make business decisions in the best interest of our Company. • Discuss with your Supervisor full details of any situation that could be perceived as a potential conflict of interest. • Think ahead and proactively address situations that may put your interests or those of a family member in potential conflict with our Company.
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