Dear Colleagues:

As we continue to grow our business and expand into new markets, operating with integrity and in full compliance with the law is critical. To that end, I am pleased to announce the latest version of our Code of Conduct, The Right Turn 2.0 for Colas USA and its subsidiaries (collectively “Colas” or the “Company”).  As with the previous version, this document will apply to all employees and supplements the Bouygues Group Compliance Program and Colas SA Compliance Procedures[1] . In that regard, it will address areas of law and compliance that may be unique to our operations in the United States. I urge you to review the new Code and our compliance documents from time to time to keep that information fresh in your mind.

Most of the time the right thing to do in a given situation is obvious. Sometimes, however, the answer is not always clear. That question can often be answered by applying the “Four C’s” to guide your decision-making:

• Compliance:  Is your behavior/proposed action legal? Does it comply with the law and Company policies?
• Consistent: Is your behavior/proposed action consistent with our core values? Is this what we stand for?
• Community:  Is your behavior/proposed action something you would like to see published in the newspaper?
• Conscience:  Is your behavior/proposed action something you could comfortably explain to your children?

This Code of Conduct surely helps us in doing things the right way. That said, it cannot replace thinking for yourself or leading by example. We do that by helping each other make the right decisions, operating according to our values, and encouraging one another to speak up. I cannot stress enough the importance of that last part – speaking up. An ethical breach remains one of our biggest risks. It takes thousands of people and decades to build a solid reputation for integrity and only one person and a few seconds to tear it down. When we see unethical behavior at Colas, we must speak up – no exceptions.

I know you will do your part to protect our reputation and to act with the highest levels of integrity, not just because it is part of your job, but more simply because it is the right thing to do. Thank you for taking the time to review the new Code and I wish you the best on your journey with Colas.

Thank you,

Download your copy of the Right Turn Code of Conduct!

[1] Colas Inc. and its subsidiaries are part of the Colas SA and Bouygues group of companies.  Bouygues’ Group Code of Ethics can be found at:  https://www.colasusa.com/wp-content/uploads/2023/02/2021-Code-of-Ethics.pdf. This Code of Conduct is intended to supplement the Bouygues’ Code and its corresponding Colas SA Compliance Program Documents.  In any areas in which this Code and the Bouygues Code conflict, this Code should govern an Employee’s actions.  The Bouygues Compliance Program Documents, the Colas SA Compliance Procedures and The Right Turn 2.0 are collectively referred to here as the “Code”.