McConnell Dowell Code of Business Conduct

24 MCCONNELL DOWELL CODE OF BUSINESS CONDUCT 2.4 PERSONAL INFORMATION AND PRIVACY We respect your personal information and privacy and expect you to do the same with others. Only collect such information as necessary for legitimate business purposes, and do so in a lawful manner. Protect such documents and information and, unless otherwise agreed by an individual, not disclose it for any purpose other than the purpose for which it was collected, or as required by law. WE WILL: Documents or information (including data) created on behalf of the McConnell Dowell Group, stored in hard copy or on computers and other electronic devices are the property of the McConnell Dowell Group. We therefore may have the right to access this information for legal or other reasons and may be required by law (in response to a subpoena or warrant) to monitor, access, and disclose the contents of corporate email, voicemail, computer files, and other materials on our electronic facilities or on our premises.

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