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Welcome Core Values 1. Colas Compliance Program and Code of Conduct 1.1 Ethics Managers 1.2 Employee Responsibilities 1.3 Non-Retaliation 1.4 Consequences for Violations 2. Incident & Injury Prevention 3. Fraud, Deception & Dishonesty 4. Investigations & Audits 5. Protecting Company Assets 6. Public Affairs: Political & Charitable Contributions 7. Antitrust Laws & Competing Fairly 8. Gifts & Hospitality 9. Conflicts of Interest 10. Equal Employment Opportunity (EEO) & Other Employment Laws 11. Safeguarding Intellectual Property & Secure Communications 12. Social Media Usage 13. Privacy, Trade Secrets & Company Information 13.1 Privacy 13.2 Trade Secrets 13.3 Company Information 14. Government Contracting 14.1 Doing Business with the Government 14.2 Procurement Integrity 14.3 False Claims 14.4 Socioeconomic Programs 14.5 Truth in Negotiations Act 14.6 Compliance with Contract Requirements 14.7 Accurate Representations & Certifications 14.8 Proper Invoicing & Cost Charging 14.9 Bribes, Gifts Kickbacks & Gratitudes 14.10 Former Government Personnel 14.11 Foreign Corrupt Practices Act (FCPA) 14.12 Buy American Act & Trade Agreements Act Compliance 14.13 Mandatory Disclosures Procedures Colas Ethics Hotline Colas | Right Turn We Open The Way English Español The Right Turn 2.0 Our Code of Conduct Letter from Our President & CEO Dear Colleagues: As we continue to grow our business and expand into new markets, operating with integrity and in full compliance with the law is critical. To that end, I am pleased to announce the latest version of our Code of Conduct, The Right Turn 2.0 for Colas USA and its subsidiaries (collectively Colas” or the Company”). As with the previous version, this document will apply to all employees and supplements the Bouygues Group Compliance Program and Colas SA Compliance Procedures [1] . In that regard, it will address areas of law and compliance that may be unique to our operations in the United States. I urge you to review the new Code and our compliance documents from time to time to keep that information fresh in your mind. Most of the time the right thing to do in a given situation is obvious. Sometimes, however, the answer is not always clear. That question can often be answered by applying theFour C’s ” to guide your decision-making: Compliance : Is your behavior/proposed action legal? Does it comply with the law and Company policies? Consistent: Is your behavior/proposed action consistent with our core values? Is this what we stand for? Community : Is your behavior/proposed action something you would like to see published in the newspaper? Conscience : Is your behavior/proposed action something you could comfortably explain to your children? This Code of Conduct surely helps us in doing things the right way. That said, it cannot replace thinking for yourself or leading by example. We do that by helping each other make the right decisions, operating according to our values, and encouraging one another to speak up. I cannot stress enough the importance of that last part – speaking up . An ethical breach remains one of our biggest risks. It takes thousands of people and decades to build a solid reputation for integrity and only one person and a few seconds to tear it down. When we see unethical behavior at Colas, we must speak up – no exceptions. I know you will do your part to protect our reputation and to act with the highest levels of integrity, not just because it is part of your job, but more simply because it is the right thing to do. Thank you for taking the time to review the new Code and I wish you the best on your journey with Colas. Thank you, Download your copy of the Right Turn Code of Conduct! [1] Colas Inc. and its subsidiaries are part of the Colas SA and Bouygues group of companies. Bouygues’ Group Code of Ethics can be found at: https://www.colasusa.com/wp-content/uploads/2023/02/2021-Code-of-Ethics.pdf . This Code of Conduct is intended to supplement the Bouygues’ Code and its corresponding Colas SA Compliance Program Documents. In any areas in which this Code and the Bouygues Code conflict, this Code should govern an Employee’s actions. The Bouygues Compliance Program Documents, the Colas SA Compliance Procedures and The Right Turn 2.0 are collectively referred to here as the Code”. Copyright Colas Inc. 2019 Welcome Core Values 1. Colas Compliance Program and Code of Conduct 1.1 Ethics Managers 1.2 Employee Responsibilities 1.3 Non-Retaliation 1.4 Consequences for Violations 2. Incident & Injury Prevention 3. Fraud, Deception & Dishonesty 4. Investigations & Audits 5. Protecting Company Assets 6. Public Affairs: Political & Charitable Contributions 7. Antitrust Laws & Competing Fairly 8. Gifts & Hospitality 9. Conflicts of Interest 10. Equal Employment Opportunity (EEO) & Other Employment Laws 11. Safeguarding Intellectual Property & Secure Communications 12. Social Media Usage 13. Privacy, Trade Secrets & Company Information 13.1 Privacy 13.2 Trade Secrets 13.3 Company Information 14. Government Contracting 14.1 Doing Business with the Government 14.2 Procurement Integrity 14.3 False Claims 14.4 Socioeconomic Programs 14.5 Truth in Negotiations Act 14.6 Compliance with Contract Requirements 14.7 Accurate Representations & Certifications 14.8 Proper Invoicing & Cost Charging 14.9 Bribes, Gifts Kickbacks & Gratitudes 14.10 Former Government Personnel 14.11 Foreign Corrupt Practices Act (FCPA) 14.12 Buy American Act & Trade Agreements Act Compliance 14.13 Mandatory Disclosures Procedures Colas Ethics Hotline Start Typing English...
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