Code of Business Conduct - Leighton Asia

Code of Business ConductThree Fundamental ConceptsThe LAIO business conduct framework involves three basic concepts:PreventionThe most effective solution to ethics and compliance issues is to prevent thembefore they occur. This is achieved through a strong culture of ethical leadershipand equipping LAIO Employees with information, training and tools so theyunderstand what the potential risks are and what is acceptable behaviour. ThisCode is a cornerstone of our prevention efforts.Monitoring & DetectionLAIO has a monitoring and detection process to identify breaches of this Code, todetermine the causes of such breaches and to implement timely and appropriatecorrective action. This process includes a culture that encourages the reporting ofsuspected breaches of this Code. LAIO provides various channels to permit suchreporting, implements periodic risk assessments and compliance reviews, and has aquarterly reporting process.ResponseIf a suspected breach of this Code is reported, it will be investigated promptly and, ifsubstantiated, timely and appropriate action will be taken to address the particularissue and to prevent recurrences.Decision Making FrameworkThis Code provides a decision making framework by establishing the principles andvalues that guide actions and decisions. The aim is to promote an organisationalculture that enables LAIO Employees to respond appropriately to situations and beaccountable for their decisions.This Code cannot describe every situation, law or Leighton Rule that may apply toyou. This Code provides a framework but you are still required to exercise goodjudgement.Ethical Decision Making ModelStep 1 – Define the Issue• What is concerning about the situation?• Who else is involved and what is their perspective?• What effect does your behaviour have on the issue?Step 2 – Identify the underlying policies, principles and values• How do the policies of LAIO require you to behave?• If there is no relevant policy how does this Code require you to behave?• If this Code does not deal with the issue how do our values require you tobehave?Leighton Asia, India and Offshore Revision 430 November 2014 Page 6 of 46