PUBLIC AFFAIRS: POLITICAL & CHARITABLE CONTRIBUTIONS
The Company encourages all employees to participate in lawful political and charitable activity. Employees should conduct such activities on their own time. In no event may any employee be reimbursed for personal political activities. Under no circumstances may an employee engage in lobbying activities on behalf of any Colas USA company without the express written consent of the Colas USA CEO, General Counsel, and its Chief Ethics & Compliance Officer. No Company asset shall be used for political activities or lobbying of any kind. The Colas Group has expressly stated that it intends to maintain a neutral stance on political activities at all times. In that regard, employees must avoid involving the Colas Group in such activities, and they must also refrain from disclosing their relationship with any Colas company.
All charitable activities conducted on behalf of the Company must comply with the Colas SA Compliance Procedures. That means that all forms and approvals set forth in the Colas Compliance Procedures must be properly filled out and submitted.
There will be no pressure placed on employees, officers, or directors to contribute to any charitable or political activity personally.
For further information, contact the Chief Ethics & Compliance Officer or the Legal Department. To report concerns or possible violations of this policy, contact the Colas Ethics Hotline.
ETHICS LEADERSHIP MOMENT: Your supervisor calls a team meeting to tell you that she wants each of you to donate to and vote for her friend who is running for congress in your congressional district. She explains that she would really appreciate your help and it would be reflected on your annual performance review. No big deal, right?
Answer: Wrong! It is expressly against Company policy for any employee to pressure another to donate money or to vote in any
particular way as part of their employment with Colas.