Code of Business Conduct - Leighton Asia

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Code of Business ConductWhere a Leighton Group entity or LAIO has a business relationship with anothercompany, you should exercise caution if you wish to trade in that company’ssecurities, since the same insider dealing rules apply as if you were trading insecurities of Leighton Holdings Limited. Investments in securities of a company withwhich the Leighton Group or LAIO does business may also give rise to an actual orperceived conflict of interest.ReferencesLeighton GGS – Securities Trading PolicyLeighton Asia, India and Offshore Revision 430 November 2014 Page 32 of 46
Code of Business Conduct4.6. Anti-competitive ConductLAIO is committed to the principles of free and fair competition. LAIO willalways complete vigorously but fairly, and comply with all applicablecompetition laws.Our commitmentLAIO is committed to not engaging in anti-competitive conduct including:• Behaviour in collusion with competitors referred to as “cartel behaviour” whichincludes:ooooPrice fixing – agreements involving fixing the selling price to a customer orthe buying price to be paid to suppliers, including agreeing maximum orminimum prices formulae for pricing or discounting goods and services andagreed rebates and allowances or credit termsOutput restrictions – agreements between competitors to prevent, restrict orlimit production, capacity or supply of goods or servicesAllocating customers, suppliers or territories – agreements betweencompetitors to divide or allocate customers, suppliers or territories amongthemselvesBid rigging or collusive tendering – agreements between competitors in orderto ensure that bids for a tender are submitted (or withheld) in a manneragreed by the bidding participants• Exclusionary provisions – agreements between competitors which have thepurpose of preventing, restricting or limiting dealings with a particular person orclass of persons (e.g. agreeing not to supply or acquire goods or services from aparticular person)• Arrangements that substantially lessen competition – the making or giving effectto any contract, arrangement or understanding which has the purpose or likelyeffect of substantially lessening competition• Misuse of market power, e.g.:ooTaking advantage of a substantial degree of market power, orHaving a substantial market share and engaging in below cost pricing for asustained period, for the purpose of substantially damaging a competitor,preventing the entry of a person into a market or deterring or preventing aperson from engaging in competitive conduct.• Unconscionable conduct – taking advantage of someone’s inability to look aftertheir own interests, particularly relevant in consumer transactions• Misleading or deceptive conduct – behaviour is misleading or deceptive if it isuntrue or conveys an untrue impression irrespective of what was intended to beconveyedLeighton Asia, India and Offshore Revision 430 November 2014 Page 33 of 46
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Code of Business Conduct - Leighton Asia

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