McConnell Dowell Code of Business Conduct

7 to impair their independence • Employees will not accept gifts, hospitality or other favours from suppliers or potential suppliers which, in the view of their immediate line superior or colleagues would be unwise, potentially sending the wrong message to subordinates and/or placing the recipient or the Group under perceived obligation. • Group funds, property and assets will be used only for legitimate business purposes. Strict internal controls and governance procedures of the highest standard will be enforced to discourage fraud and safeguard the Group. • Accurate and reliable records will be kept which fairly reflect all business transactions in terms of statements of International Financial Reporting Standards, for the Group to properly manage its affairs and meet its legal, financial and reporting obligations. Personal and business information gained in the course of business dealings will be safeguarded and its privacy respected. • The Group will uphold its diversity and inclusion policy which requires that equal opportunity be offered to all employees. The individuality of each person, their right to freedom of association and to absolute privacy in this regard will be respected. Harassment of any form, including sexual harassment, will be viewed in a very serious light and appropriate disciplinary action taken. • McConnell Dowell’s people are unquestionably its most important asset. Through careful selection, on-going development, performancebased management and fair reward, every person in our Group will be encouraged to realise their full potential. Exceptional commitment to the Group’s core Values of integrity, quality and entrepreneurship will be appropriately rewarded. • McConnell Dowell will strive to be a leading corporate citizen working with employees, their families, local communities and society at large to improve the overall quality of life and to achieve sustainable economic development at all levels. • The Group will promote policies and operating procedures that conserve resources and minimise the environmental impact of its business activities. • Finally, McConnell Dowell, its subsidiaries and officers will seek to build an atmosphere of openness and trust through regular, timely and courteous communication with all stakeholders. This Code applies to all of us. If you have a question or ever believe that our Code may have been breached, please don’t be silent. Talk to your manager, leader or HR representative. Scott Cummins Chief Executive Officer McConnell Dowell Corporation Limited

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