Code of Business Conduct - Leighton Asia

Code of Business Conduct4.0 Ethical Business Practices4.1. Bribery and CorruptionLAIO prohibits bribery and corruption in all forms, whether directly orthrough a third party.Our commitmentLAIO does not permit, or condone, any form of bribery or corruption. “Bribery”involves: The offering, giving, granting, promise or acceptance of any payment, gift,promise, benefit, favour or anything of value, whether directly or through a thirdparty, which is:• To or from any person or entity (whether a government official, a privatebusiness person or an associate of any of them)• For the purpose of improperly securing a private or business benefit oradvantage, or for the improper performance of a function or activity“Corruption” involves the abuse of a position of employment, authority or trust togain an advantage in breach of duty.Such behaviours are illegal in most countries. A breach of anti-bribery or corruptionlaws is a serious offence, which can result in significant fines to the Leighton Group,LAIO and LAIO Employees and/or imprisonment. Even the perception of bribery, orcorruption, can have a serious impact on the reputation of the Leighton Group, LAIOand LAIO Employees.LAIO also prohibits making “facilitation payments”, even where permitted under locallaws. Facilitation payments are typically payments involving small sums to anindividual within government, or other public authority, or within a private entity toobtain routine services that are not related to obtaining an undue advantage.Your responsibilityYou must never:• Engage in any form of bribery or corruption• Make a facilitation payment• Authorise, undertake or participate in schemes to give any improper benefit, kickbackor secret commission to anyone• Offer, promise or give a cash or cash equivalent payment of any kind to agovernment official or to any other person for the purpose of obtaining improperadvantage• Use any third party to do something that LAIO is prohibited from doing itself• Give anything of value to any third party when there is any suspicion that thethird party, will engage in bribery, corruption or other prohibited conduct inrelation to LAIOLeighton Asia, India and Offshore Revision 430 November 2014 Page 23 of 46