Code of Business Conduct - Leighton Asia

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Code of Business Conduct4.7. International trade controlsLAIO will comply with all national and international laws, regulations andrestrictions relating to the movement of materials and services around theworld which are applicable to its business.Our commitmentMost countries have laws and regulations that apply to the movement of goods,services and intellectual property across national borders. Many countries are alsosignatories to international export control treaties which govern the export of goodsand services, including information and technology.Trade restrictions, sanctions and bans may apply to (among other things):• Exports to a particular country• Imports, or dealings in property originating from a particular country• Travel to and from a particular country• New investments and other dealings in a particular country or with designatedindividualsThe consequences of ignoring trade laws and sanctions are serious. Individuals maybe subject to fines and possibly imprisonment. The reputation of the Leighton Groupor LAIO may also be severely damaged, and it may be subject to criminal and civilpenalties.Your responsibilityYou must:• Know and follow the sanctions and international trade control laws andregulations of all countries in which you operate or that apply to transactionsrelevant to your role within LAIO• Ensure that accurate and complete information is provided to governmentauthorities, when required, including import and export declarations• Seek to ensure that all transactions comply with all applicable laws that restrict orprohibit dealings involving particular countries, individuals or entities andprohibited end-uses, and that your actions do not cause violations by otherparties• Never proceed with an export or other business transaction if there is any doubtabout its legality or propriety – contact a legal counsel in your business if in doubt• Never participate or allow LAIO to participate in cross border trade between asanctioned country and the country that has imposed such sanctionsLeighton Asia, India and Offshore Revision 430 November 2014 Page 36 of 46
Code of Business Conduct• When engaging and monitoring subcontractors and other third parties, considerthe risks relating to international trade controls – such as international tradetreaties and sanctioned boycotts, security considerations, prohibited passing ofintellectual property and sensitive informationReferencesLAIO Standards and Procedures are being developed and will be made available inthe LAIO Management System.Leighton Asia, India and Offshore Revision 430 November 2014 Page 37 of 46
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Code of Business Conduct - Leighton Asia

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