A gift, meal, or invitation to an event cannot be intended to influence a business decision in favor of any Colas company. In addition to possible conflicts of interest, offering or receiving such items from someone exercising decision-making power over a matter involving the Company is prohibited For a more detailed discussion of gifts and hospitality, please see Chapter III, Section 1 of the Bouygues Anticorruption Compliance Program and Section 4 of the Colas SA Compliance Procedures.

Giving or receiving gifts of material value, other than promotional items with a company logo (such as pens, safety vests, hats, etc.) is generally not permitted unless specifically approved by your supervisor and your local Ethics Manager. Likewise, business meals with 3rd parties are subject to the thresholds set forth in the Colas SA Compliance Procedures. For tickets or invitations to sporting or cultural events received from or offered to 3rd parties, please see Section 4 of the Colas SA Compliance Procedures.

One important note – a gift, invitation to an event, or a business meal that is requested by a 3rd party is not acceptable as it is expected by the 3rd party and no longer considered common hospitality. If someone asks you for something like that, notify your Ethics Manager immediately.

Finally, employees who work in procurement, business development, estimating, and project management must take care to avoid any gifts or lavish meals/events so as to avoid even the appearance of impropriety.

The special rules for dealing with Government personnel and Government contracts are described below. It is critical that all employees understand and adhere to these rules. The consequences of a violation can be severe to the Company and to the individual who commits the violation.

As a general rule, when it comes to a public official, do not give anything of value without the explicit approval of the Company’s Chief Ethics & Compliance Officer or General Counsel.

The term “public official” includes any and all employees of federal, state, local, or foreign governmental agencies, elected or appointed officials at any level of federal, state or local government (whether salaried or unsalaried), and consultants retained by federal, state or local governmental agencies. The term “public official” shall also include family members of a public official.

If in doubt about any of these obligations, contact your local Ethics Manager for further guidance.

ETHICS LEADERSHIP MOMENT: You are invited by one of our vendors to a local college football game. The cost of the ticket is $150. How do you handle this?