Code of Business Conduct - Leighton Asia

Code of Business ConductThe responsibilities of the Business Conduct Representative include:• Providing high-level guidance on the operation and applicability of this Code,including the standards of ethical behaviour expected under the Code• Dealing with business conduct concerns and breaches of the Code• Dealing with allegations of victimisation following a concern being raised• Reporting serious business conduct concerns to the Reportable Conduct Group(see following section), where appropriateReportable Conduct GroupLAIO has a Reportable Conduct Group (LAIO RCG) comprising LAIO ManagingDirector, LAIO Chief Financial Officer, LAIO General Manager People, Safety andEnvironment and LAIO General Manager, Risk & Governance, operating under acharter.The purpose of the LAIO RCG is to:• Address serious breaches of this Code which are referred to it, includingescalation through the relevant reporting hierarchy• Provide governance and oversight in relation to LAIO’s, ethics and complianceframeworkIts responsibilities include:• Monitoring the progress of investigations into serious breaches of this Code• Determining appropriate action where serious breaches are substantiated• Monitoring the implementation of such action, including referral to externalresponsible investigatory and enforcement authorities• Identifying enhancements or modifications to LAIO’s ethics and complianceframework, as appropriateQuestions about this Code or any particular behaviourIf you are unsure about the meaning of any part of this Code, or have any concernsabout how you should behave in a particular circumstance, you should:• Immediately raise this with your supervisor or manager, or• Where this is not possible (e.g. your concern involves your manager orsupervisor), speak with your manager once removed (i.e. your manager’smanager), or• Contact the LAIO Business Conduct Representative or his delegate, orLeighton Asia, India and Offshore Revision 430 November 2014 Page 10 of 46