McConnell Dowell Code of Business Conduct

8 MCCONNELL DOWELL CODE OF BUSINESS CONDUCT WE BELIEVE THAT CONSISTENT AND PROPER CONDUCT IN THE WAY WE CARRY OUT OUR OPERATIONS CREATES THE LOYALTY AND TRUST WITH OUR STAKEHOLDERS AND EACH OTHER THAT IS CRITICAL FOR OUR BUSINESS TO BE SUSTAINABLE AND ACHIEVE LONG-TERM SUCCESS. To help guide you in your daily work, our Code of Business Conduct (“the Code”) sets out our standards and expectations about the manner in which McConnell Dowell’s operations are to be carried out and how to raise concerns relating to the Code. It’s important that you understand where to go for further support and information and to always apply your own common sense. IF IN DOUBT, ASK YOURSELF: • Does this fit with the Values of the McConnell Dowell Group? • Could this action directly or indirectly endanger someone or cause them injury? • Is this legal and in line with the McConnell Dowell Group policies, operating standards and procedures? • If the story appeared in the media or online, would I feel comfortable and what implications could there be for me under my employment contract and for McConnell Dowell as a company? • What would I tell my family or friends to do? • Does it align with my personal Values and the McConnell Dowell Values? • What’s my intuition or ‘gut feel’? (If it doesn’t feel right, then it probably isn’t.) 1. OUR CODE If you have difficulty answering any of these questions, then speak up to your manager, leader or HR representative about your concern.

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