A message from Leadership

Keltbray has a reputation for delivering operational excellence, safely and with integrity. These are critical qualities if a company wants to grow and create value for all its stakeholders. This reputation is founded on our Purpose and Values, which define who we are and underpin everything we do.

These values come to life through the standards of behaviour set out in this Code of conduct. They define how we manage the social, environmental and economic issues faced in our daily activities, and guide us in our commitment to our stakeholders to deliver safe and sustainable infrastructure and built environment engineering solutions that meet the needs of modern society.

The behaviour of every single one of us has a direct bearing on how well we perform and how the outside world views Keltbray. The Code of Conduct will guide and unite our behaviour and actions in this regard to ensure we create a future success that we can all be proud to be a part of – acting as 'one Keltbray'.

By working according to our values and complying with, and where possible, exceeding the minimum standards set out in this Code, I am confident we will build a resilient and sustainable business that becomes a beacon in our industry for the ethical and effective relationships it builds, and the valuable contributions it delivers to the communities where we work.

Brendan Kerr

Executive Chairman

Contents

– A message from Leadership – What is The Code of Conduct? – Our core purpose and values – How does The Code guide how we do business? – Who does The Code apply to? – How does The Code work? – How to report a Code breach – The Code

Section 1: Social and environmental responsibilities – Health and safety – Environmental sustainability and ethical sourcing – Respecting communities – Charitable and not-for-profit organisations

Section 2: Corporate integrity – Laws and regulations – Bribery and corruption – Fraud, deception and dishonesty – Money laundering – Conflicts of interest – Gifts, gratuities and hospitality

Section 3: Working relationships – Equality, diversity and inclusion – Harassment and bullying – Human rights and modern slavery – Drugs and alcohol – Relationships with employees – Relationships with customers – Relationships with suppliers and other third parties

Section 4: Company assets and information – Handling confidential information – Protecting company assets and intellectual property – Protecting personal data – Using company IT and communications systems – Communicating externally 2 4 5 6 8 9 10 12

14 16 17 18 19

20 22 23 24 25 26 27

28 30 31 32 33 34 36 37

38 40 41 42 43 44