1. Colas Compliance Program and Code of Conduct

The Right Turn 2.0

Our Code of Conduct

COLAS USA ETHICS & COMPLIANCE PROGRAM OVERVIEW

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.

1.1 ETHICS MANAGERS
To provide support at the local level, each of Colas’ operating companies has designated an “Ethics Manager.” For the name and number of the Ethics Manager for your company, please check with your company’s Human Resources department.

1.2 EMPLOYEE RESPONSIBILITIES
One person’s actions (or inaction) can devastate Colas or any of its affiliated companies. That is why it is required to report known or suspected violations of our Code of Conduct or the law to one or more of the following: your immediate supervisor, your local Ethics Manager, the Chief Ethics & Compliance Officer (ethics@colasinc.com), General Counsel, or if anonymity is desired, the company’s Ethics Hotline. The Ethics Hotline is available 24 hours per day, 7 days per week. It is operated by Convercent, which forwards your questions or concerns to the appropriate person within the group. If you have any concerns, you can anonymously contact the Colas USA Ethics & Compliance Hotline at 1-800-461-9330 or visit www.colasusaethics.com. You can also text any concerns you may have to 862-259-6307. For more information on this, please consult Colas USA’s Ethics Hotline Policy.

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.

1.3 NON-RETALIATION
Colas USA does not tolerate any form of retaliation against any employee who, in good faith, reports possible misconduct. “Good faith” means that you honestly believe everything you have reported is true and that you have reported everything you know.

Any Colas USA employee who engages in any form of retaliation against another employee will be subject to disciplinary action up to, and including, termination of employment.

1.4 CONSEQUENCES FOR VIOLATIONS
Violations of the law, or of the policies set forth in this Code of Conduct may subject an employee to disciplinary action, up to and including termination. Such discipline will also apply to any supervisor who directs such actions or learns of them and does nothing to correct them.