McConnell Dowell Code of Business Conduct

35 MCCONNELL DOWELL CODE OF BUSINESS CONDUCT ALWAYS • Comply with McConnell Dowell’s Anti-Corruption Operating Standard. • Report requests for any improper payments such as bribes or facilitation payments to your HR Manager without delay • If you have any doubt about the legitimacy of a payment or gift that you have been requested to make, immediately seek the advice of your HR Manager or Legal. • Ensure all transactions are accurately recorded in reasonable detail in the books and records of the McConnell Dowell Group • Plan against circumstances where bribery or corruption may occur. • Report any bribery or corruption concerns immediately so that appropriate action can be taken. NEVER • Engage in any form of bribery or corruption. • Authorise any facilitation demand or payment. • Authorise, undertake or participate in schemes to give any improper benefit, kick-back or secret commission to anyone. • Offer, promise or give a cash or cash equivalent payment of any kind to a government official or to any other person for the purpose of obtaining improper advantage. • Use any third party to do something that The McConnell Dowell Group is prohibited from doing itself. • Give anything of value to any third party when there is any suspicion that the third party will engage in bribery, corruption or other prohibited conduct.

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