PIH Code of Ethics 2024

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

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I observed misconduct in an area not under my supervision. Am I still required to report the issue?

You are chiefly responsible for employees, contractors, and other third parties under your supervision, but all employees are required to report misconduct. As

a leader, you are especially obliged to be proactive. The best approach is to talk first with the Supervisor who oversees the area where the problem is occurring, but if this is not feasible or effective, you should use the other resources described in our Code.

I am a Supervisor and not clear on what my obligations are if someone comes to me with an accusation – and what if it involves a Market Lead, Regional Manager, or other senior Executive?

No matter who the allegation involves, you must report it. We provide several avenues for reporting concerns. If for any reason you are uncomfortable making a report to a particular person, you may talk to any of the other resources listed in the Code or another member of management.

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