Code of Business Conduct - Leighton Asia

Code of Business Conduct - Leighton Asia Code of Business Conduct - Leighton Asia

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Code of Business Conduct6.0 Government, Media and Investors6.1. Working with GovernmentsLAIO respects the authority of governments wherever it conductsbusiness, and will maintain open and constructive relationships withgovernments and their agencies.Our commitmentThe ability of LAIO to conduct business is directly affected by government decisionmaking in the countries in which it operates. As such, LAIO seeks to have open andconstructive relationships with those governmentsYour responsibilityYou must:• Follow the Leighton Rules that set out who is responsible for communicating withgovernments, regulators and public authorities• Ensure that all interactions with governments, regulators and public authoritiesare in the best interests of LAIO, and adhere to high standards of ethics andcomply with the letter and spirit of the law• Ensure that all information provided to governments, regulators and publicauthorities is accurate and appropriate. Errors or omissions may damage thereputation and credibility of LAIO and could be illegal• Cooperate with every legitimate government request for information inaccordance with tendering or contractual obligations or with regulatoryinvestigations, while protecting LAIO’s legal rightsAll regulatory investigations involving LAIO or the Leighton Group must immediatelybe reported to the legal counsel for your business.Speak to your supervisor, manager or the person in your business responsible forcorporate / government affairs if you have any questions regarding your interactionwith Government.ReferencesLeighton GGS – Government Relations GuidelineLeighton Asia, India and Offshore Revision 430 November 2014 Page 42 of 46

Code of Business Conduct6.2. Political contributions and activitiesLAIO does not make direct contributions in cash or in kind to any politicalparty. However, LAIO does engage in the democratic process byparticipating in events with political parties and discloses any financialcontributions for this attendance.Our commitmentLAIO does not make direct contributions to any political party, politician, electedofficial or candidate for public office in any country. Examples of prohibited politicalactivities or contributions include:• Free or discounted use of LAIO premises or equipment as a donation to apolitical party• Paying wages or salaries (including on-costs) of a LAIO Employee working for aparty or candidate during normal working hours (except if the LAIO Employeetakes paid leave to work for the party or candidate)• Paid attendance at fundraising events that are not reported and disclosed toLAIOLAIO retains the flexibility to engage in the democratic process by participating inlunches, dinners, conferences or other events with political parties in a transparentmanner which is consistent with its ethical standards. LAIO representatives maymake a financial contribution to attend these functions and events. Participation islimited to senior executives within LAIO and should be approved by either the LAIOManaging Director or LHL Group Manager, Government & Industry Affairs.The Leighton Group will disclose all relevant contributions as required to theAustralian Electoral Commission and the State Electoral Commissions.LAIO recognises LAIO Employees’ rights to participate as individuals in the politicalprocess. Such participation, including contributions of time and money, must beconducted entirely on your own account and you must ensure that your politicaldonations and opinions are not presented as being representative of LAIO or theLeighton Group. In some Australian jurisdictions, officers of the Leighton Group arespecifically prohibited from making political donations.Your responsibilityYou must:• Not be involved with prohibited political groups or activities or make prohibitedpolitical contributions• Not be involved in political activities that give rise to a conflict of interest with theinterests of LAIO or are prejudicial to LAIO• Not have any involvement with political groups or activities that detract from yourability to carry out your employment duties and responsibilitiesLeighton Asia, India and Offshore Revision 430 November 2014 Page 43 of 46

<strong>Code</strong> <strong>of</strong> <strong>Business</strong> <strong>Conduct</strong>6.2. Political contributions and activitiesLAIO does not make direct contributions in cash or in kind to any politicalparty. However, LAIO does engage in the democratic process byparticipating in events with political parties and discloses any financialcontributions for this attendance.Our commitmentLAIO does not make direct contributions to any political party, politician, elected<strong>of</strong>ficial or candidate for public <strong>of</strong>fice in any country. Examples <strong>of</strong> prohibited politicalactivities or contributions include:• Free or discounted use <strong>of</strong> LAIO premises or equipment as a donation to apolitical party• Paying wages or salaries (including on-costs) <strong>of</strong> a LAIO Employee working for aparty or candidate during normal working hours (except if the LAIO Employeetakes paid leave to work for the party or candidate)• Paid attendance at fundraising events that are not reported and disclosed toLAIOLAIO retains the flexibility to engage in the democratic process by participating inlunches, dinners, conferences or other events with political parties in a transparentmanner which is consistent with its ethical standards. LAIO representatives maymake a financial contribution to attend these functions and events. Participation islimited to senior executives within LAIO and should be approved by either the LAIOManaging Director or LHL Group Manager, Government & Industry Affairs.The <strong>Leighton</strong> Group will disclose all relevant contributions as required to theAustralian Electoral Commission and the State Electoral Commissions.LAIO recognises LAIO Employees’ rights to participate as individuals in the politicalprocess. Such participation, including contributions <strong>of</strong> time and money, must beconducted entirely on your own account and you must ensure that your politicaldonations and opinions are not presented as being representative <strong>of</strong> LAIO or the<strong>Leighton</strong> Group. In some Australian jurisdictions, <strong>of</strong>ficers <strong>of</strong> the <strong>Leighton</strong> Group arespecifically prohibited from making political donations.Your responsibilityYou must:• Not be involved with prohibited political groups or activities or make prohibitedpolitical contributions• Not be involved in political activities that give rise to a conflict <strong>of</strong> interest with theinterests <strong>of</strong> LAIO or are prejudicial to LAIO• Not have any involvement with political groups or activities that detract from yourability to carry out your employment duties and responsibilities<strong>Leighton</strong> <strong>Asia</strong>, India and Offshore Revision 430 November 2014 Page 43 <strong>of</strong> 46

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