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ETHICS AND COMPLIANCE

In support of its commitment to conduct business responsibly, ethically and legally, Pulice Construction maintains an Ethics and Compliance Program with its Code of Business Ethics and Code of Conduct serving as the foundation. The Code of Business Ethics and Code of Conduct assists the Company in upholding its commitment to fulfilling Pulice Construction’s core business values and ethical principles by providing guidance on issues which may arise in day-to-day operations including areas such as personal and business integrity, business activities and relationships, and Company information and property. Pulice Construction promotes every employee, and all those it does business with, to be accountable and responsible for upholding its commitment to operating with integrity in all aspects of its business.

Pulice Construction’s Ethics and Compliance Program reflects the Company’s commitment to comply with applicable governing laws and regulations. Pulice Construction’s program seeks to prevent, detect, and resolve potential violations of law or company policy. Its compliance program is dynamic, involving multiple policies, procedures and its Code of Business Ethics and Code of Conduct.

Code of Business Ethics and Code of Conduct

Anti-Corruption Policy

Policy On Operation of the Ethical Channel

Ethics Channel

Dragados Code of Conduct for Business Partners

Antitrust Compliance Policy