McConnell Dowell Code of Business Conduct

36 MCCONNELL DOWELL CODE OF BUSINESS CONDUCT 4.1 POLITICAL CONTRIBUTIONS AND ACTIVITIES Our approach is straightforward and applies wherever we operate in the world: we do not make political contributions or offer cash or in-kind services. The McConnell Dowell Anti-Corruption Operating Standard states that under the terms of employment, employees cannot hold political office. Employees have an obligation to comply with this requirement in terms of their individual political contributions and activities. We do not make political contributions or offer cash or in-kind services REFERENCES: • Anti-Corruption Operating Standard • Anti-Fraud Operating Standard

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