McConnell Dowell Code of Business Conduct

40 MCCONNELL DOWELL CODE OF BUSINESS CONDUCT 4.3 COMPETITION AND ANTI-TRUST Most countries have laws, often known as antitrust, competition or unfair competition laws, which are designed to promote free and fair competition. Generally speaking, these laws prohibit arrangements with competitors that restrain trade in some way, abuse of intellectual property rights, and use of market power to unfairly disadvantage competitors. In all dealings with our competitors (including competing joint venture partners), customers, suppliers and business partners, behave in a manner that does not breach competition laws as this can result in serious consequences (including fines and imprisonment) for you and our company. We regard any breach of competition laws as serious misconduct, which may lead to disciplinary action and ultimately termination of your employment. If you suspect anticompetitive behaviour by an employee, contractor or third party, report it immediately to your manager or leader.

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