GETTING HELP

• All employees assigned to take training on this Code or any other internal policy must complete that training when assigned.
• All directors, officers, and employees have a responsibility to read, understand, and follow our Code of Conduct. Remember, this is only the starting point. Our Code does not attempt to address every situation you might encounter in your job. So where do you turn for help?
  • Most of the procedures and policies noted in the Code can be found in your employee handbook or manual or on the Company’s intranet sites.
  • Your first resource is your immediate supervisor. He or she is willing to answer your questions or to contact a Company resource who can. But, if you feel your situation would make it impossible or uncomfortable to approach your immediate supervisor, you should go to your next level of management or your local Ethics Manager/Human Resources Department. You can also contact the Chief Ethics & Compliance Officer or the Legal Department.
  • At any time you can anonymously contact the Colas Ethics Hotline at 800-461-9330, via SMS text at 862-259-6307 or visit www.colasusaethics.com to report concerns or suspected violations. All matters will be handled in a manner consistent with the Colas USA Ethics Hotline Policy.
  • The Colas Ethics Hotline is answered twenty-four hours a day, seven days a week by an outside service. When you call, you will be asked for the general nature of your concern so your call can be appropriately handled. You may call anonymously.
  • Regardless of how you choose to speak up, you are required to do so. Hoping the issue will just resolve itself is not an option.

ETHICS LEADERSHIP MOMENT: You are attending a trade association meeting and your counterpart from one of our competitors is seated next to you at a dinner. He asks you about whether we plan to bid on an upcoming project for the state DOT. What do you say?

DISCIPLINE

• All employees are expected to read, understand, and comply with all Company policies, including but not limited to, our Code of Conduct.
• Violations of law, this Code, and other Company policies and procedures can lead to disciplinary action up to and including termination. Supervisors, managers, and officers can also be subject to discipline if they condone, permit or have knowledge of illegal, unethical, or other improper conduct and do not take appropriate action.
• The Company will not tolerate retaliation or any form of an adverse personnel action against anyone who, in good faith, uses the Colas Ethics Hotline or otherwise reports or raises questions regarding potentially illegal, unethical, or improper conduct.