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Phillips Infrastructure Holdings / PIH / Code of Ethics and Business Conduct
Political Activities You have the right to voluntarily participate in the political process, including making personal political contributions. However, you must always make it clear that your personal views and actions are not those of our Company, and never use Company funds for any political purpose without proper authorization.
Do What’s Right
• Ensure that your personal political views and activities are not viewed as those of the Company. • Do not use our resources or facilities to support your personal political activities.
Imagine This... I will be attending a fundraiser for a candidate running for local office. Is it OK to mention my position at the Company as long as I don’t use any Company funds or resources?
Be Aware Of
No. It would be improper to associate our name in any way with your personal political activities.
• Lobbying. Interactions with government officials or regulators that could be seen as lobbying must be discussed in advance and coordinated with our Corporate Compliance and Ethics Officer. • Pressure. Never apply direct or indirect pressure on another employee to contribute to, support, or oppose any political candidate or party. • Improper influence. Avoid even the appearance of making political or charitable contributions in order to gain favor or in an attempt to exert improper influence. • Conflicts of interest. Holding or campaigning for political office must not create, or appear to create, a conflict of interest with your duties at PIH.
I would like to invite an elected official to speak at an upcoming Company event. Would that be a problem? You must get approval from our Corporate Compliance and Ethics Officer before inviting an elected official or other government official to attend a Company event. If the invitee is in the midst of a reelection campaign, the Company event could be viewed as support for the campaign. Depending on local laws, any food, drink, or transportation provided to the invitee could be considered a gift. In most cases, there would be limits and reporting obligations.
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