Code of Business Conduct - Leighton Asia

Code of Business Conduct4.5. Insider tradingYou must not use any information about LAIO, a competitor, joint venturepartner, customer or supplier for financial or other personal benefit, or conveythis information to others before it is made public.Our commitmentLAIO does not permit or condone LAIO Employees using inside information toengage in insider trading in respect of securities in Leighton Holdings Limited or anyother entity.In general terms, “inside information” is material information about any company thatis not generally available to the public which would affect a reasonable investor’sdecision about whether or not to trade in securities of the company. Examples ofpossible inside information include:• The financial performance of the Leighton Group or LAIO against its budget orforecasts• Entry into or termination of a significant contract• Actual or proposed mergers, acquisitions, joint ventures or divestmentsIt is an offence in many jurisdictions to use inside information to buy, sell orotherwise deal in securities, to get another person to do so or to communicate insideinformation.LAIO will enforce the Leighton Rules in relation to dealing in Leighton Holdingssecurities (as set out in the Leighton Holdings Securities Trading Policy).Your responsibilityYou must not:• Use inside information to buy, sell or otherwise deal in securities of LeightonHoldings Limited or any other entity• Advise or encourage another person (for example, a family member, a friend orfamily company or trust) to undertake trading using inside information or passsuch information to another person if you know, or ought to know, that he or shemay use the information to deal in securities, or• Trade in securities of Leighton Holdings Limited other than in accordance withthe Leighton Holdings Securities Trading Policy, regardless of whether youpossess inside informationLeighton Asia, India and Offshore Revision 430 November 2014 Page 31 of 46