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Phillips Infrastructure Holdings / PIH / Code of Ethics and Business Conduct
Who Must Follow This Code All employees of PIH and its subsidiaries, including corporate officers and members of our Board of Directors, are required to read, understand, and meet the standards and obligations in this Code. All members of our family including consultants, agents, suppliers, contractors, and other third parties, serve as an extension of PIH. They are expected to follow the spirit of our Code, as well as any applicable contractual provisions, when working on behalf of PIH. If you supervise our business partners or temporary employees, you are responsible for communicating our standards and ensuring that they are understood. If a business partner fails to meet our ethics and compliance expectations or their related contractual obligations, it may result in the termination of their contract. Our Responsibilities Each of us must take responsibility for acting with integrity, even when this means making difficult choices. Meeting our responsibilities is what enables us to succeed and grow. • Always act in a professional, honest, and ethical manner when acting on behalf of our Company. • Know the information in the Code and written Company policies and pay particular attention to the topics that apply to your specific job responsibilities. • Complete all required employee training in a timely manner and keep up to date on current standards and expectations.
• Report concerns about possible violations of our Code, our policies, or the law to your Supervisor, an Executive, or any of the resources listed in this Code. • Cooperate and tell the truth when responding to an investigation or audit, and never alter or destroy records in response to an investigation or when an investigation is anticipated. • Remember: No reason, including the desire to meet business goals, should ever be an excuse for violating our Code, our policies, or the law. • All Supervisors are expected to meet the following additional responsibilities: • Lead by example. As a Supervisor, you are expected to exemplify high standards of ethical business conduct. • Help create a work environment that values mutual respect and open communication. • Be a resource for others. Be available to communicate with employees, contractors, suppliers, and other business partners about how the Code and other policies apply to their daily work. • Be proactive. Look for opportunities to discuss and address ethics and challenging situations with others. • Respond quickly and effectively. When a concern is brought to your attention, ensure that it is treated seriously and with due respect for everyone involved. • Be aware of the limits of your authority. Do not take any action that exceeds your authority. If you are ever unsure of what is appropriate (and what isn’t), discuss the matter with your Supervisor. • Delegate responsibly. Never delegate authority to any individual whom you believe may engage in unlawful conduct or unethical activities.
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