PIH Code of Ethics 2024

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

What Guides Us — Our Code

Purpose and Overview One thing you can say about our Company – hard work is in our blood. At PIH, we have never shied away from a challenge. We’re known as leaders, innovators, and problem- solvers, always willing to do our clients’ heavy lifting. But a reputation like ours is built on more than hard work. It’s built on trust. Every employee helps us build on that foundation – every ethical act and good decision makes it stronger. Together, with our commitment to our core values, we make each company unique and successful. When we bring our best to the job and to our clients each day, we carry on our Company’s legacy for the next generation. To help you along the way, we have created this Code which offers guidance to help you: • Comply with applicable laws, regulations, and Company policies. • Promote integrity and the highest standards of ethical conduct. • Address common ethical situations you could encounter in your work. • Avoid even the appearance of anything improper in connection with PIH business activities.

Complying With Laws and Regulations

PIH is committed to compliance with all laws, rules, and regulations that apply to our business. It is impossible to anticipate every question you may have or situation you might face so, in addition to the Code, PIH also has other resources that can be of help. These additional resources are listed throughout the Code. As always, we rely on you to use good judgment and to seek help when you need it. We operate coast-to-coast in the United States. While we respect the norms of our clients, business partners, and coworkers, all employees must, at a minimum, comply with the standards and principles in this Code. If any provision of our Code conflicts with a local law or requirement, you should seek guidance from our Corporate Compliance and Ethics Officer.

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