McConnell Dowell Code of Business Conduct

6 MCCONNELL DOWELL CODE OF BUSINESS CONDUCT The Group’s directors and senior employees have given their absolute commitment to upholding our Values and following both the spirit and letter of the following code of business conduct: • The law will not be violated when conducting business for or on behalf of the Group. • Safety is paramount, never to be compromised in pursuit of any other objective. • McConnell Dowell has a zero tolerance towards bribery and any unethical payments to customers or business associates will result in disciplinary action. Efforts to manipulate the markets in which the Group is active, including collusion with competitors, will be dealt with similarly. • Any possible conflict of interest in handling Group affairs will be avoided and employees are expected to perform their duties conscientiously, honestly and in accordance with the best interests of the Group and its shareholders. • We will protect the intellectual property of the organisation, customers and subcontractors. • Employees will not derive personal advantage from their position in the Group, nor will they acquire any business interest which could divert their energy from Group responsibilities. They will not participate in an activity that is potentially in conflict with Group interests or which could be perceived CODE OF BUSINESS CONDUCT THE MCCONNELL DOWELL GROUP IS PROUD OF ITS REPUTATION FOR INTEGRITY AND IS COMMITTED TO CONTINUALLY AND WITHOUT COMPROMISE REINFORCING THIS REPUTATION IN THE WAY IT CONDUCTS BUSINESS.

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