39 MCCONNELL DOWELL CODE OF BUSINESS CONDUCT ALWAYS • Comply with McConnell Dowell’s Anti-Corruption Operating Standard and Conflicts of Interest Operating Standard. • Consider the Anti-Corruption Operating Standard when deciding to offer or accept gifts, hospitality and entertainment and obtain approvals where required. Use our Gifts Register to obtain approval for receipt of goods or entertainment when required. For additional guidance, talk to your HR Manager. • Advise your HR Manager in writing of any outside activities, financial interests or relationships that may involve you in a conflict of interest or the appearance of one by completing the Conflicts of Interest Register. • Obtain appropriate approval from your HR Manager before accepting an officer or director position with another company or organisation. • Excuse yourself from any decision-making process where you have an interest that influences, or is perceived as influencing, your ability to make an objective decision and to fulfil your responsibilities to The McConnell Dowell Group. NEVER • Hire, promote or directly supervise a relative, unless this has been authorised in writing by your manager or leader. • Offer gifts, hospitality or entertainment or accept them from an organisation or individual involved in a bid or tender with The McConnell Dowell Group. • Request a personal gift, hospitality or anything of value from a supplier, customer or partner. This includes both direct requests and giving the impression that the offering of a gift, hospitality or item of value would be appropriate or desirable. • Accept personal discounts or other benefits from suppliers, subcontractors, service providers, customers or other third parties due to your association with The McConnell Dowell Group that the general public or your peers do not receive, unless this has been otherwise approved via the Gifts Register.
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