McConnell Dowell Code of Business Conduct

41 MCCONNELL DOWELL CODE OF BUSINESS CONDUCT ALWAYS • Consider the appearance and implications of interacting with a competitor, whether in a business or personal setting. • Speak to your manager or leader and if required, obtain the necessary approvals: • before exchanging competitively sensitive information, directly or indirectly, with a competitor • before joining a trade association involving competitors • when inappropriate contact is initiated by a competitor • when considering new cooperation arrangements with a competitor, including joint ventures, joint marketing and shared logistics • when a complaint is made about the competitive behaviour of the McConnell Dowell Group • when you suspect that a third party is acting in an anticompetitive manner towards the McConnell Dowell Group. Your manager or leader must contact Group Legal for additional advice or support on any issues of competition or anti-trust. NEVER • Collude with a competitor by: • fixing, raising, lowering or stabilising prices of goods sold or purchased • fixing other competitive terms such as pricing formulae, discounts, margins, rebates, commissions or credit terms • limiting production or agreeing to reduce or limit production capacity • rigging a bid or otherwise illegally coordinating bidding or tendering activities • allocating markets, customers, suppliers or geographic territories • boycotting any customer or supplier. • Obstruct a competition authority by providing false or misleading information, concealing or destroying documents or alerting any third party to the fact of a competition law investigation. • Accuse a third party of anti-competitive behaviour without first consulting our Legal team.

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