PIH Code of Ethics 2024

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Phillips Infrastructure Holdings / PIH / Code of Ethics and Business Conduct

We Are Accountable

Cooperating With Investigations and Audits All employees are expected to fully cooperate with internal and external investigations and audits that are conducted by our Company. In addition, in the course of business, you may receive inquiries or requests from government officials. You are expected to fully cooperate and ensure that any information you provide is true, accurate, and complete. If you learn of a potential government investigation or inquiry, immediately notify your Supervisor, Human Resources, and our Corporate Compliance and Ethics Officer before taking or promising any action.

Data Privacy We respect the personal information of others. Follow our policies and all applicable laws in collecting, accessing, using, storing, sharing, and disposing of sensitive information. Only use it – and share it with others outside of the Company – for legitimate business purposes. Make sure you know the kind of information that is considered personal information. It includes anything that could be used to identify someone, either directly or indirectly, such as a name, email address, phone number, or credit card number.

Be Aware Of

• Sending sensitive information to unattended fax machines or printers. • Failing to shred or securely dispose of sensitive information. • Using “free” or individually purchased internet hosting, collaboration, or cloud services.

Be Aware Of

• Falsified information. Never destroy, alter, or conceal any document in anticipation of or in response to a request for these documents. • Unlawful influence. Never provide or attempt to influence others to provide incomplete, false, or misleading statements to a Company or government investigator.

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