We have a responsibility to both our clients and our communities to conduct business with the highest standard of integrity, and that means more to us than just ticking boxes and filing documents. We carry this commitment with us into all aspects of work, large and small, seen and unseen, and our Code of Conduct is designed to guide you to identifying, assessing, and responding to potential compliance risks. Our Code of Conduct applies to any officer, director, employee, or consultant, and as a part of the P&J family you are encouraged and empowered to question and report any complaints without fear of retribution. Maintaining P&J’s integrity is our collective responsibility.
Our Code of Conduct is maintained and enforced by our Compliance & Ethics Committee, led by PIH’s Corporate Compliance & Ethics Officer. This year, Lee Haniford is assuming this role, which John Lawrence has served for more than 4 years. Lee will be responsible for ensuring that company operations are conducted at the highest level of integrity possible. This includes investigating and reviewing any potential violations of our code of conduct for any of our companies, including P&J, RowCon, and NFS and ensuring that our Compliance & Ethics Committee meets on a regular basis.
You can report an ethics violation anonymously through a 3rd party by contacting P&J’s ethics help line at (844) 286.6021 or by filing a report via pandj.ethicspoint.com.
For any additional questions you may have or to receive a copy of our Code of Conduct, please email ethicsreport@phillipsih.com
| Q. I am working on a bid submission, and in order to gain the contract, I am considering under-estimating the costs, as I know I can charge the customer for overruns on the contract when we have won it. Is this appropriate? |
| A. No. It is never acceptable to deliberately misrepresent costs that we intend to incur and bill to the customer. |
| Q. Another company has asked to discuss what contract terms and pricing we have negotiated with a supplier, as they would like the same kind of deal that we have. Is this ok? |
| A. No. We have an ethical and contractual obligation to respect the confidentiality of the supplier’s pricing. Our actions might also be construed as an attempt to fix prices in the supply market, which could damage the Company's reputation, or result in legal action. |
| Q. Stan heard a subordinate of Harold's say that Harold, a construction manager, had paid $1,000 to a government official who approved the building plans for the project, for a "quicker" approval process. Should Stan report what he heard? |
| A. Yes. While Stan is not sure that Harold engaged in a kickback scheme, he should report what he heard so the Company can investigate the allegation. |
| Q. I was informed that we could hire a local company or consultant to help get all the necessary permits from a foreign government. An advance payment has been requested to “help move the process along.” Since we don’t really know where the money is going, do we have to worry about it? |
| A. Yes. We are responsible for the actions of any third party working on our behalf. The request for an advance payment is itself a red flag, the comment, even more so. Consult with the Corporate Compliance & Ethics Officer before proceeding. |