4. Investigations & Audits

The Right Turn 2.0

Our Code of Conduct


Government Inquiries: From time to time, our employees, officers, and directors may come into contact with government officials. Dealing honestly with government officials is always the rule – no exceptions. Any information provided that relates to your duties at Colas must be completely honest and truthful. Upon receiving a request for information, subpoena, or other legal documents from a government agency, you should notify our General Counsel immediately upon receipt. You should also immediately preserve any related document, electronically stored information, or other evidence. You should never under any circumstances, destroy, discard, or alter any Company documents (whether electronic or paper) that are potentially relevant to any actual or anticipated governmental investigation or inquiry or to any anticipated or pending lawsuit or other proceeding, even if Company policy would otherwise permit you to destroy, discard, or alter such documents.

Company Investigations: You must fully and transparently cooperate in any Company investigations of possible or alleged violations of the Code. This includes any internal investigator or third party retained by the Company. This involves providing truthful and complete answers, preserving any relevant evidence, and not discussing the investigation with anyone unless you are expressly instructed to do so. Failure or refusal to cooperate with any internal investigations could lead to disciplinary action, up to and including termination of employment. If you have any questions about this process, please contact your local Ethics Manager.

Audits: Audits can be performed by management, customers, governmental agencies, our parent company auditors, and external financial auditors. You have an obligation to cooperate with them and to provide them with truthful and accurate information.

ETHICS LEADERSHIP MOMENT: You are being interviewed as part of a company internal investigation. You think you may have some relevant information but you are worried about disclosing information that could affect others within the Company. What should you do?

Answer: As an employee of the Company, you are required to disclose any and all relevant information as part of an investigation. Any issues regarding confidentiality will be addressed by the investigators in consultation with counsel.