26
Phillips Infrastructure Holdings / PIH / Code of Ethics and Business Conduct
Do What’s Right
Imagine This...
• Only provide and accept gifts and entertainment that are reasonable complements to business relationships. • Exchange gifts and entertainment that foster goodwill in business relationships, but never provide or accept gifts or entertainment that obligate or appear to obligate the recipient. • Never accept gifts of any kind from a business partner with whom you are involved in contract negotiations. • Understand and comply with the policies of the recipient’s organization before offering or providing gifts, favors, or entertainment.
When traveling, I received a gift from a business partner that I believe was excessive. What should I do? You need to let your Supervisor and our Corporate Compliance and Ethics Officer know as soon as possible. We may need to return the
gift with a letter explaining our policy. If a gift is perishable or impractical to return, another option may be to distribute it to employees or donate it to charity, with a letter of explanation to the donor.
During contract negotiations with a potential new supplier, the new supplier mentioned that they had a complimentary registration to a local business seminar. They are unable to attend and asked if I would like to go in their place. I had been thinking of attending the seminar anyway, since the subject of the seminar applies to my work. There’s no personal gain to me, it would be good for the Company, and it would be a shame to waste the registration. I planned on saying “yes,” but now I wonder if that would be the right decision. You should decline the offer. If you are involved in contract negotiations, you must never accept any gifts while the negotiation process is ongoing. Accepting gifts during
• Never accept cash or cash equivalents.
• Do not request or solicit personal gifts, favors, entertainment, or services. • Raise a concern whenever you suspect that a colleague, third party, or other agent of the Company may be engaged in any attempt to improperly influence a decision of a client or government official.
Be Aware Of
• Situations that could embarrass you or our Company, including entertainment at sexually oriented establishments. • Gifts, favors, or entertainment that may be reasonable for a privately owned client but not for a government official or agency.
negotiations can give the appearance of something improper and is always inappropriate.
Made with FlippingBook - Online catalogs