Colas employees must at all times avoid conflicts of interest – actual or apparent. This can happen when an employee – or even a member of an employee’s immediate family – has a personal interest that interferes with (or reasonably appears to interfere with) his or her ability to work objectively on behalf of the Company.

All potential conflicts of interest must be disclosed to your supervisor and local Ethics Manager for consideration and approval.

Certain situations are considered per se conflicts of interest and are prohibited. Those situations include but are not limited to:

• Receipt of cash or any cash equivalent, any gift or offer that would be illegal, or anything which is part of a “quid pro quo” (i.e.: something is given in return); and
• Any work-related entertainment that is unsavory, sexually-oriented, or otherwise violates our commitment to mutual respect.

These situations can arise before someone even realizes what they have gotten themselves into. All managers have the responsibility to ensure their employees understand the requirements of this section, to monitor compliance, and to apply appropriate disciplinary action when necessary. Questions that arise should be referred to your supervisor, your local Ethics Manager or the Colas Ethics Hotline.

For further guidance regarding conflicts of interest, you should review the Bouygues Conflicts of Interest Compliance Program document and Section 10 of the Colas SA Compliance Procedures.

ETHICS LEADERSHIP MOMENT: Your spouse works for one of our potential vendors. He asks you if you can give his company a good reference. Is this ok?