A Message from Our MD

Dear Team,

Our success begins and ends with you – our dedicated and caring team members. Every day, you provide
valuable services and solutions to our customers, communities and environment. For me personally, I am
driven to make ECC Ltd, a great place to work for all employees. I want our company to be a place where
you can spend your entire career feeling accepted, challenged and valued.

Every day, we must foster a People First culture where employees are empowered to Do the Right Thing. The
Right Way. This idea sets the standard for our fundamental commitments and core values and guides our
daily actions and decisions. Our dynamic and distinct culture allows us to operate by the same standard –
one that unites us and defines who we are as a company.

Our Code of Conduct provides guidance and insight into how to act in accordance with this standard.
We must always act with integrity and comply with all internal policies and external laws. Our
reputation and success depend on it.

While the Code cannot address every situation you may face, it is a good place to get a better
understanding of the rules that apply to your job. We want you to feel comfortable Speaking Up if you
have a question, issue or concern. A good place to start is generally your supervisor or People Business
Partner. You can also contact the appropriate ECC Ltd department, any member of management or the
Integrity Helpline. Rest assured that when you SPEAK UP, it’s our job to listen and respond. We will not
tolerate any type of retaliation for an issue or concern that is raised in good faith.

I greatly appreciate all you do and want to personally thank you for committing to and adhering to the
Code of Conduct – and our promise to always work for a sustainable tomorrow.

Sincerely,

…………………………………………..
Samwel Lema
Managing Director – ECC Limited

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Table of Contents
A Message from Our CEO...................................................1

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 DO THE RIGHT THINGS AT RIGHT WAY

Our Commitments and

Values

As Construction Company, and in

the simplest terms, our values come
down to this: Do the Right Thing.
The Right Way. This idea sets the
standard for our Fundamental
Commitments and Core Values and
guides our daily actions and
decisions.

Our Fundamental Commitments:

Our People First
The proud, caring and resilient members of the ECC
family are the foundation for our success. We commit to
taking care of each other,
our customers, our communities and the environment.

Success with Integrity

Our success is based not only on the results we achieve, but
how we achieve them. We commit to being accountable, honest,
trustworthy, ethical and compliant in all we do.

Our Core Values

Inclusive and Diversity
We embrace and cultivate respect, trust, open communications and diversity
of thought and people

Clients
We place our customers at the center of what we do and
aspire to delight them every day.

Safety
We have zero tolerance for unsafe actions and conditions and make
safety a core value without compromise.

Environment
We are responsible stewards of the environment and
champions for sustainability.

Our Code's Purpose

Do the Right Thing. The Right Way. is a roadmap for how we align
our daily actions with our Fundamental Commitments and Core
Values. Our Code of Conduct outlines how we treat each other and
how we conduct our business. Our reputation rests upon our daily
actions and the decisions we make every day.

While this Code doesn’t cover every situation, it can be used for
guidance on how to handle different situations. It also provides
additional resources, such as links to more specific policies and
Rightdepartments
procedures, as well as references to different Thing you can
contact.
To help you use the Code, we have organized the
Table of Contents around our Fundamental
ECC Limited operates in highly regulatedCommitments.
industries. We must
If you have comply
any questions regarding
with all federal, state, provincial and local laws and regulationscontact
the Code of Conduct, please that the Legal and
Compliance Officer …………… email…….
apply to our business. Every employee is responsible for complying
with this Code, ECC Limited, policies and all applicable laws and
regulations. You must also act in a manner consistent with our
Fundamental Commitments and Core Values. Failure to fully comply
may result in disciplinary action, up to and including termination.
6
Code Applications

This Code refers to Elerai Construction Company Limited. and its

subsidiaries as or the “Company.” The Code applies to every ECC
employee and our Board of Directors. We also expect our consultants,
contractors, subcontractors’ vendors and other third parties to act in a manner
consistent with our Code when conducting business on our behalf. If you
are represented by a union and your collective bargaining agreement
conflicts with any part of the Code, your collective bargaining agreement
takes precedence

Understanding Our Code

You should be generally
familiar with the entire
Code, even though some
sections may not directly
apply to your daily
activities. In certain
sections of the Code, you
will see additional
information to help guide
your daily actions.
This includes:
• Right Thing boxes that call out key points.
• Right Way boxes
that will provide you
 with answers to
potential questions
you may have.
• Resources sections with links to ECC policies.

Expectations and Guidance

The following summarizes some of the key expectations for complying with
the Code and our Commitments and Values. They include expectations that
apply to all of our employees and additional expectations for our leaders.

Expectations for Our Employees

 Promote and display our commitments and values through your daily
words and actions.
 Engage and take ownership of compliance and ethics.
 Know and proactively comply with the Code and Company policies.
 Take responsibility for protecting and strengthening the Company’s
culture and reputation.
Expectations for Our Leaders

 Foster a SPEAK UP environment based on trust and free of a fear of

retaliation.

 Help your employees understand their compliance responsibilities.

 Set an example by holding yourself and your employees accountable

to Do the Right Thing. The Right Way.

 Evaluate your employees not only on their results, but also how they
achieve them.

SPEAK UP | LISTEN UP | FOLLOW UP

• Everyone is expected to SPEAK UP

immediately when they have a question,
issue or concern.
• When you SPEAK UP, a good
place to start is generally your
supervisor or People Department
 Representative. You can also
contact the appropriate Company
department, any member of
management or the Integrity
Helpline.
• When you SPEAK UP, the Company
will LISTEN UP and FOLLOW UP.
The Company strictly prohibits any form of retaliation when someone
SPEAKS UP in good faith and believe.

Guidance on How to Do the Right Thing. The Right Way.

1. Is it Legal?
2. Is it in compliance with our Code, policies and procedures?
3. Does it reflect our Fundamental Commitments and Core Values?
4. Would your team members, your supervisor and the cCompany
approve?
5. Would you be proud if your action was on the front page of the local

SPEAK UP | LISTEN UP | FOLLOW UP

Our culture fosters an environment of open and honest communication.
Every employee should feel comfortable seeking guidance and raising
issues or concerns. If you see or suspect any misconduct, SPEAK UP – even
when it’s difficult. When you SPEAK UP, you won’t be ignored.

SPEAK UP
ECC cares and expects you to SPEAK UP when you have any type of
compliance or ethics question, issue or concern. This includes complaints
or concerns about harassment, discrimination, fraud, safety, the environment,
accounting irregularities or theft.

We need you to SPEAK UP immediately if you are aware of any possible

violation of our Code of Conduct, Employee Handbook, Company policy
or external law, rule or regulation to prevent future misconduct. Our
Company policies do not restrict you from reporting any potential
violation of laws or regulations to relevant government authorities.
When reporting an issue or concern, it is important to provide all of the
relevant details so that it can be fully investigated. Reports should be made
in good faith. We look into all reported concerns. Anyone who knowingly
makes a false complaint, threatens others or maliciously damages another
person’s reputation will be subject to disciplinary action, up to and
including termination.

LISTEN UP | FOLLOW UP
ECC is committed to a SPEAK UP environment where you SPEAK UP and
we will LISTEN UP and FOLLOW UP. No matter how an issue or concern
is reported, it will be reviewed and appropriately investigated based on the
information provided. It will be treated confidentially to the extent possible
in light of the Company’s need to follow up and investigate your concern.

We respond immediately to reports of illegal activities, security issues,

accounting or auditing irregularities, Company policy violations or health
and safety concerns by working with the appropriate investigative teams. If
we find violations of laws, regulations, policies or our Code of Conduct, we
will act promptly. We will make changes so that similar problems don’t
happen again.

You may be asked to participate in an internal investigation into potential

issues or concerns or investigations conducted by an external third party.
If asked, you must fully cooperate. This includes:
• Disclosing any relevant information in a complete and honest
manner.
• Not discussing investigation details with anyone outside of the
investigation.
• Not interfering with the investigation or providing misleading
information.
Failure to fully cooperate may result in disciplinary action, up to and
including termination.

Right Thing
When you speak up, a good place to start
When you SPEAK UP, a good place to start is generally your
supervisor or People Department representative. You can also contact:
 • An employee in another department such as Compliance
and Ethics, Legal, Corporate Security, Safety, Internal
Audit, Government Affairs or Environmental Protection
• Any member of management
• The Integrity Helpline

INTERGITY HELPLINE

If you do not feel comfortable

reporting an issue or concern to a ECC
employee, or if you previously raised
an issue and did not get a satisfactory
response, please contact the Integrity
Helpline at ………………………… or
[email protected]. It is maintained by a
third party to which reports can be
made anonymously 24 hours a day, 7
days a week.

We keep reports about compliance and

ethics concerns in confidence. We advise
only those people who need to know of a
reported incident to ensure that
immediate and appropriate action is
taken. Every effort will be made to
protect the confidentiality of individuals
who report violations of the law,
Company policies or perceived unethical
conduct.

ZERO TOLERANCE

ECC strictly prohibits any form of retaliation against anyone who

SPEAKS UP in good faith. Anyone who retaliates against someone who
SPEAKS UP will be subject to disciplinary actions, up to and including
termination.
We know it takes courage to share your concerns. We will not retaliate or
permit retaliation against anyone for:
• Raising questions, issues or concerns in good faith.
• Making a report of possible
misconduct or legal violations to us
or a government authority.
• Assisting in an investigation of alleged misconduct.

We take claims of retaliation seriously. Allegations of retaliation will

be investigated, and appropriate action will be taken.

TAKING CARE OF EACH OTHER

The Company’s success is based on the actions of its proud, engaged and
resilient team members. It all starts with us taking care of each other by
creating an environment of trust, respect and mutual civility. We must:
• Work cooperatively as a team.
• Respect the dignity of each individual.
• Listen openly to concerns and suggestions.
• Comply with all policies, laws and rules that apply to our work.
• SPEAK UP immediately when we have any questions, issues or
concerns.
Employment Equality

ECC never make employment decisions or engage in harassment based on:

• Race
• Color
• Sex
• Pregnancy
• Sexual orientation
• Gender identity expression
• Religion
• Marital status
• Age
• National or ethnic origin
• Disability
• Genetic information
 • Veteran status
• Citizenship status
• Support for or against a Union
• Any other characteristic protected by applicable laws, regional
regulations, or local laws, and regulations

INCLUSIONS AND DIVERSITY

ECC are committed to fostering a diverse and inclusive work environment.

We embrace and
cultivate respect, trust, open communications and diversity of thought and
people. We strive to attract, develop and retain a workforce that is as diverse
as the markets we serve. This ensures an inclusive work environment that
embraces the strength of our differences and allows employees to maximize
their potential.

Your caring attitude plays an important role in creating a workplace where

everyone treats each other with honesty, dignity and courtesy. This fosters
an atmosphere of trust, openness, candor and belonging.

ANTI-HARASSMENT

ECC policy prohibits harassment and sexual harassment. You must not harass
others while at work or at work-related functions. When representing the
Company, you’re expected to be courteous, polite, respectful and
professional to everyone. This same conduct applies to how you treat our
customers, partners, vendors and suppliers.

We will not tolerate abusive, threatening, offensive or intimidating verbal or

physical conduct whether at work or outside of work hours that harms a
person’s ability to do his or her work or otherwise affects the terms and
conditions of his or her employment.

Any employee who feels threatened, harassed or discriminated against, or

who witnesses such conduct, should SPEAK UP immediately.
Workplace Violence

ECC have a zero-tolerance policy for acts of violence and behavior that
could lead to or cause workplace violence. You are prohibited from
engaging in any act that could cause another individual to feel threatened
or unsafe. This includes:
• Verbal assaults
• Threats of violence or intimidation
• Aggression
• Hazing
• Causing physical harm to someone
• Intentionally damaging property
• Sabotage

Alcohol and Drugs

ECC take care of each other. We follow our safety procedures and promote a
culture of safety. To ensure the safety of our employees, customers and the
communities in which we operate, WM takes a zero- tolerance approach to
drugs and alcohol in the workplace. No person may use, transfer, sell,
possess, make, consume, handle, inhale, purchase, transport or otherwise be
involved with alcohol or unlawful drugs while on Company property,
customer property or while operating our vehicles. We prohibit employees
from performing any work while under the influence of alcohol,
cannabis/marijuana
or unlawful drugs. Under limited circumstances, alcohol use may be
allowed for some Company- sponsored events. Such events must be
approved by management and cannot be scheduled before or during an
employee’s work day.
Over-the-counter drugs and medication prescribed to you by a doctor can
also affect your ability to do your job. You should not work if any
prescribed or over-the-counter drug causes safety or performance
concerns. If a prescription drug interferes with or in any way impacts
your ability to perform your job, you must notify your supervisor or
People Department.
 Safety

Our "Mission to Zero" Culture

We have zero tolerance for unsafe actions and conditions and make
safety a core value without compromise. We are committed to safety
at our facilities, on the roadways and in our communities. No matter
what you do, where you work or what line of business you are in, you
are expected to put safety first.

We take care of each other by following our health and safety rules
and procedures, as well as all applicable laws and regulations. Our
Mission to Zero (M2Z) culture guides our daily actions and decisions.
Nothing justifies ignoring these safety standards.

Stop Work Authority is your right. No matter what your position is,
you are empowered to. take immediate action to ensure the safety of
yourself and those around you.

You should always SPEAK UP if you:

• Are asked to do a job or task you consider unsafe.
• Are asked to be non-compliant with a rule, regulation or law.
• Are asked to do a job you think you are not properly
trained to perform.
• See someone performing a task that you think is unsafe or
that the person is not properly trained to do.
• Suspect that a vehicle, truck or piece of equipment is not
operating properly and may be unsafe.
• Observe or are made aware of an unsafe condition or
potential danger to others or yourself.

Taking Care of Our Business

Confidential Information and Privacy

You must protect the confidential information of our Company, our

employees, customers and other third parties. As part of your job, you
may acquire certain information about
ECC, its customers or other third parties that is confidential, non-public
and/or proprietary. You should assume this information is confidential and
non-public unless the Company has publicly released the information
through authorized and approved processes. This information can also be
referred to as “highly restricted.” Confidential information includes:
• Employee and applicant data
• Personal information
• Pricing and cost data
• Mergers, acquisitions and divestiture info
• Proprietary business processes and procedures
• Financial data
• Trade secrets
• Computer software
• Marketing and sales programs
• Customer or third-party information

Always take reasonable and necessary precautions to protect any

confidential information. You must only share confidential information on a
need-to- know basis, even with people inside the Company.

You should not use or disclose any confidential information to anyone

outside of ECC, even
to members of your own family, unless the disclosure is
properly authorized and approved

Use of Company Information’s and Assets

ECC property is intended to be used for business purposes. We must protect

these assets and use them wisely. This property includes, but is not limited
to:
• E-mail and voicemail
• Computers and mobile devices
• Confidential and proprietary information
• Vehicles and equipment
• Lockers and supplies
• Facilities and other workplaces
• Company documents and data
• Computer networks and software
• Access to and use of the Internet
 • Other technology resources

Personal use of Company computers, networks, printers, mobile devices, e-

mail and the Internet should be kept to a minimum and cannot have a
negative impact on productivity. The usage also cannot negatively affect the
functioning of these systems. Under no circumstances can you use
Company property for illegal or inappropriate purposes. Employees cannot
use Company digital devices and systems to send, knowingly receive, store
or forward messages that contain information that is:
Employees must make sure Company mobile devices or personal devices
that are being used for Company business are always physically protected,
and that updates and patches are installed to mobile devices as scheduled.
You should be aware of cyber security risks and contact the information
security team at [email protected] immediately if you have any questions,
issues or concerns.

Employees must not duplicate, install or use software in violation of its

copyright or applicable license terms. Employees must not install software
on a WM-issued computer without approval from both their manager and
the IT Department, and the software must have been purchased or
authorized by WM. Employees
may not make copies of electronic data, unless permission has been
obtained from the copyright owner.

Other types of personal use of Company property are not permitted unless
approved by your supervisor or People Department representative.
Additionally, scavenging or taking materials that are intended for disposal or
recycling is prohibited.

When we grant you access to our systems and networks, we assign you an
individual login account with a confidential password. You are responsible
for your use of this assigned.
You must also not knowingly access websites that contain this type of
information. ECC computers, digital devices and systems must be used in
accordance with applicable laws and software agreements.

Environment
We are responsible stewards of the environment and champions for
sustainability. There are a variety of federal, state, provincial and local laws
and regulations that apply to our business. We have developed processes
and tools to achieve a high standard of environmental performance and
compliance. These processes and tools have been pulled into one Company-
wide program that we call ECC’s Environmental Management System
(EMS). The focus of the EMS is integrating environmental functions into
the core of our business. It enables us to reduce our environmental impacts
and increase our operating efficiency. Every employee should be aware of
our EMS.

Our daily actions and decisions must reflect our commitment to advance
environmental stewardship. We do this by aligning our environmental
priorities with those of our customers, communities and regulators. This
can be seen in our efforts to:
• Reduce our use of natural resources.
• Eliminate potentially harmful environmental impacts.
• Foster a culture that considers the environment in every
business decision.
• Implement proactive environmental practices that differentiate us
from our competitors.

Openly discussing the importance of protecting the environment supports

this commitment and promotes a strong culture of compliance.

Our Sustainability Report captures this commitment. It focuses on educating

our employees, customers and communities on our efforts to be safe,
resilient and sustainable.

As a company, we prepare for emergencies by maintaining an

Emergency Situations and Evacuation Plan Policy. This policy states
management objectives for addressing emergency situations. We also
maintain a Crisis Management Plan that identifies the unique risks our
sites may encounter. This plan includes reporting and response
requirements for specific emergency situations at each of our Company
locations.

We expect employees to help us meet our environmental goals and

expectations by:
• Following Company policies and procedures.
• Complying with laws and regulations.
• Operating our assets in an environmentally sound and safe manner.
• Identifying, communicating and mitigating risks to people and the
environment.

For more information on our sustainability efforts, please contact the

Sustainability team at [email protected]

Social Media

There are many ways to

communicate and exchange ideas
and opinions through social media.
Social media can include:
• Networking sites
• Personal web pages
• Blogs
• Videos
• Podcasts
• Live chats
• Internet discussion forums
• Tweets
• Text messages
• Instant messages

Social media activity can include your original posts, comments on someone
else’s post, re- posts, likes and emojis on someone else’s posts, and private
or public messages. ECC respects the legal rights of its employees in all
regions in which we operate. Your online posts may not be anonymous and
may affect the Company’s reputation. When you use social media to post
information, comment and exchange ideas related to the Company or its
business, you are individually responsible for the content. ECC’s social
media guidelines cover using social media to post information, comment or
exchange ideas related to the Company or its business.
Conflict of Interest
When conducting ECC business, you must always act in the
Company’s best interest and avoid any actual or perceived conflicts of
interest.

A “conflict of interest” can arise when your personal interests or

relationships interfere with your loyalty to ECC. An example of a conflict of
interest is when your own personal interests (or those of a family member)
affect your ability to do what’s best for the Company. A potential conflict
can also exist when interacting with someone with whom you have a close
relationship (e.g., someone that could influence, or appear to influence, your
decisions). Guidance on the definition of “family member” is outlined in our
Conflicts of Interest Policy.

Your obligations related to conflicts of interest can be found in the Code,

the referenced policies and your loyalty agreement, if applicable. You
should:
• Identify situations that create a potential or actual conflict of
interest or even the appearance of one.
• Disclose any potential conflicts of interest immediately to
your supervisor and People Department.

Once your conflict is disclosed, your supervisor and People Department

will comply with the Conflict of Interest Policy’s process for reviewing and
determining:
• Whether an actual conflict of interest exists.
• Whether it can be managed or waived.
• What steps need to be taken to avoid any conflict moving forward.

Conflicts can often be easily avoided or addressed if they are promptly

disclosed. For more information on conflicts of interest, see the Conflicts of
Interest Policy.

While it is not possible to identify every potential situation that could

present a conflict, the following are some of the more common
conflicts of interest situations. If you are presented with one of these
situations or something similar, you should immediately contact your
supervisor and People Department for guidance on how to proceed.
Personal Relationships in the Workplace
You cannot have a family member or a person with whom you are
romantically involved or dating directly report to you.
It’s also potentially a conflict of interest if you have a family member or a
person with whom you are romantically involved in your line of
management, reporting chain or department. These types of relationships
may create the existence or perception of managerial bias with respect to
decisions such as work assignments, performance evaluations,
compensation,
recognition points, expense approval or hiring and employment decisions.

You must also avoid putting yourself in a position where you could
influence employment matters – including hiring, promotion, performance
evaluation, termination, work assignment or the general work environment
– involving a family member or a person with whom you have a close
relationship.

Gifts and Business Entertainment

When used appropriately, the exchange of certain gifts and business

entertainment can help build and strengthen business relationships. Gifts
and business entertainment must never be used to influence, or appear to
influence, a business decision. They also should never create, or give the
appearance of, a conflict of interest. ECC competes solely on the merits of
its products and services.

A gift is considered anything of value accepted from or given to a third

party. Business entertainment is considered entertainment that has a specific
business purpose and is viewed as a normal part of doing business. This
includes such things as an occasional meal with a customer and attending an
event with a vendor.

Gifts and business entertainment cannot be, or appear to be, a bribe, payoff,
kickback, influence or improper payment. The gift and/or business
entertainment must:
• Be permitted by law.
• Have a legitimate business purpose.
• Comply with any applicable Company policies and procedures.
• Be reasonable in value and appropriate under the circumstances.
• Be offered to you, not solicited by you.
• Be infrequent and in good taste.
• Be properly recorded on WM's books and records, if applicable.

Most government officials and employees have significant restrictions on

accepting anything of value. This includes gifts and business entertainment.
If you are providing something of value to a government or foreign official,
it is your responsibility to understand and comply with all local laws, rules
and regulations. You must also comply with the Gifts and Business
Entertainment Policy.

Accuracy of Records and Fraud

Our business and financial records must be accurate and complete. Many
people inside and outside our Company rely on the accuracy of our records.
This includes our statements to investors, government agencies, customers,
vendors and the public. We each have a responsibility to create records that
properly document our business transactions. We must ensure that Company
information is complete, accurate, reliable and protected.

Our financial records and accounts must be maintained in reasonable detail.

They must accurately, timely and fairly reflect all our assets, liabilities,
revenues, expenses and other financial transactions. We must ensure that all
transactions are properly authorized and accurately recorded in accordance
with Generally Accepted Accounting Principles. All transactions must also
comply with our record keeping policies. We have internal controls to
provide reasonable assurance of our compliance with policies, procedures,
laws and regulations.

Falsifying Company information or coercing or asking others to submit

false information or documentation is prohibited. This includes information
or documentation that is stored in writing or electronically. We never
intentionally delay recording transactions or events that are in violation of
policies, laws or regulations. We also never intentionally record incorrect,
incomplete or misleading information about any transaction or event. No
secret or unrecorded funds or assets may be established or maintained for
any purpose.

Fraud starts with knowingly providing false or misleading information. It

also includes the concealment of important information. In addition to
violating this Code, there may be criminal penalties for fraudulent acts,
especially those intended to influence, impede or obstruct an audit,
investigation, lawsuit or other matter.

We cooperate with all government inspections and external audits. During a

government inquiry, we never:
• Conceal, destroy or alter any Company documents.
• Lie or make misleading statements to a government investigator.
• Obstruct the collection of information, data or records.
• Cause another employee to fail to provide accurate information.

The accuracy of our books and records is extremely important to our

Company. If you have any concerns or issues, you should SPEAK UP
immediately.

A good place to start is generally your supervisor or People Department

representative. You can also contact the appropriate ECC department, any
member of management or the Integrity Helpline.

WAIVER AND DISCLAIMER

This Code of Conduct contains information pertaining to certain policies

and practices applicable to employees of the various direct and indirect
subsidiaries of Elerai Construction Company “ECC” used in this Code of
Conduct refers to any direct or indirect subsidiary of Elerai Construction
Company.

The electronic version of the Code of Conduct located on the Company’s

intranet or ECC Now supersedes all prior versions as well as any and all
other Company policies to the extent inconsistent with this Code of
Conduct. Any amendment or waiver of our Code for executive officers or
directors may only be granted by the Board of Directors, or a committee of
the Board, and will be publicly disclosed, when required by law.
We expect each employee to read this Code of Conduct carefully as it is a
valuable reference for understanding your job responsibilities. If you have
any questions or concerns about this Code of Conduct, please ask your
supervisor, your People Department representative or anyone in the
Compliance and Ethics Department.

None of the Company’s personnel documents or benefit plans, including

this Code of Conduct, constitutes, or is intended to constitute, an express or
implied contract guaranteeing continued employment for any employee or
creating any other contractual right. No supervisor or Company employee
has any authority to enter into a contract of employment, express or
implied, that changes or alters the at-will employment relationship.

This Code of Conduct is the property of ECC and all rights are reserved.