Our company’s reputation for integrity is perhaps one of our most valuable assets. To maintain and enhance that asset, Colas is committed to developing and maintaining a strong and effective ethics and compliance program. Although the company has appointed a Chief Ethics & Compliance Officer who is tasked with overall responsibility for this program, each of us has a duty to ensure that Colas acts ethically and complies with the law. Rules and regulations have their limits, so the following guidelines require you to think for yourself – to follow the spirit of our Code, but also to apply our principles and our values in doing what is right. This Code applies to everyone. That means all U.S. employees (full or part time) of Colas Inc. and its affiliates. We are also committed to working with third parties whose ethical standards match ours – including vendors, subcontractors, and joint-venturers.

For regular business issues or matters not requiring anonymity, please contact your immediate supervisor or local Ethics Manager for more guidance. Such reports will be treated confidentially, consistent with Colas’ need to conduct thorough investigations, to comply with the law and to cooperate with governmental authorities. All issues raised with your supervisor, the Ethics Manager, or through the Colas Ethics Hotline will be treated seriously. We will follow up on them quickly, discreetly, and without bias. If possible, we will report back to you. Managers must also ensure that their functional departments and direct reports are operating in accordance with the Code. This requires providing an open environment in which employees feel empowered to raise any issues they have without concern for possible retaliation.