Code of Conduct

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Purpose

The success of Alpa Construction (our “Company” or “Alpa”) depends on the expertise and experience of

our team, along with our reputation for doing business in an ethical and fair way. Conducting our business

with a strong sense of ethics, honesty, and integrity is critical to maintaining trust and credibility with

customers, contractors, suppliers, Associates, and business partners. Our values and our Code of Business

Conduct and Ethics (our “Code”) guide our day-to-day actions and, at Alpa, we hold ourselves and each

other accountable for maintaining these standards.

Our Code should help guide your conduct in the course of our business. Many of the principles described

in our Code are, however, general in nature, and the Code does not cover every situation that may arise.

Use common sense and good judgment. Our Code is not the exclusive source of guidance and information

regarding the conduct of our business. You should consult applicable policies and procedures in specific

areas as they apply, and you may always contact Paul Adamczyk or any member of senior management

for guidance on complying with our Code and applicable laws and regulations.

Finally, it is crucial to the administration of this Code that if you ever become aware of an actual or potential

ethical problem or illegal behavior, you should promptly report it to Paul Adamczyk. There will be no

retaliation for reporting such matters in good faith. It is every Associate’s responsibility to live up to this high

ethical standard and act accordingly.

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Scope

Our Code applies to all managers, officers, and Associates of Alpa Construction (for simplicity, collectively

referred to as “employees”). Agents and contractors of the Company are also expected to read, understand,

and abide by this Code. Employees are expected to comply with all applicable government laws, rules, and

regulations. We expect that our business partners will maintain, at a minimum, the standards of conduct outlined in this

Code.

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Employee Responsibilities

Employees are expected to comply with both the letter and the spirit of our Code. This means you must

understand all of our policies, procedures, and the laws and regulations that apply to your job and comply

with them, even if you feel pressured to do otherwise. If you have any questions about applying the Code,

it is your responsibility to seek guidance. Our Code also requires you to cooperate fully and candidly in any

investigation of suspected violations of the Code, our policies and procedures, or applicable laws and

regulations.

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Asking Questions and Reporting Concerns

If you have a question about the Code or if you are aware of or suspect an activity is illegal or in violation

of the Code, you must discuss your question or report your concern to Paul Adamczyk where you can report

confidentially or anonymously. This allows the Company to deal with the issue promptly and responsibly.

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Additional Responsibilities for Managers

All Alpa leaders must promote an environment where compliance is expected and ethical behavior is the

norm. No one should ask Alpa employees to break the law or to act in a manner inconsistent with the

Company’s values, policies, or procedures. Managers receiving reports of or otherwise becoming aware of

any violation or suspected violation of the Code, the law, or any other Company policy or procedure must

take appropriate action, which includes promptly reporting it to Paul Adamczyk.

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Commitment to Non-Retaliation

1We believe it is essential to create an environment in which individuals feel able to raise any matters of

genuine concern internally without fear of adverse action being taken against them. Your concerns will be

taken seriously, will be investigated appropriately, and—to the extent practicable—will be kept confidential.

Alpa prohibits retaliation, in any form, against anyone who, in good faith, reports violations or suspected

violations of this Code, Company policies and procedures, or applicable law, or who assists in the

investigation of a reported violation. Acts of retaliation should be reported immediately to your manager or

to a member of senior management.

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Consequences for Violations of Our Code

Anyone who violates our Code will be disciplined appropriately, up to and including termination of

employment.

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Alpa’s Commitments

Antitrust and Fair Competition

We believe in free and open competition. Strict laws are in force prohibiting collusive or unfair business

behavior that restricts free competition. United States antitrust laws and other countries’ competition laws

are quite complicated, and failure to adhere to these laws could result in significant penalties imposed on

both Alpa and the employees who violated the law.

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Honest Advertising and Marketing

It is our responsibility to accurately represent Alpa and our products in our marketing, advertising, and sales

materials. Deliberately misleading messages, omissions of important facts, or false claims about our

products, individuals, competitors or their products, services, or employees are inconsistent with our values.

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Protecting Customer/Third Party Information Privacy

We take the protection of privacy for our customers and other third parties that have entrusted us with

information very seriously. We follow all applicable laws and regulations directed toward privacy and

information security. We must safeguard all confidential information our customers and other third parties

share with us by ensuring that their information is only used for the reasons for which the information was

gathered. If you do not have a business reason to access this information, you should not do so. If you do,

you must also take steps to protect the information against unauthorized use or release.

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Anti-Corruption/Anti-Bribery

Alpa conducts business in an honest and fair manner at all times. No Alpa employee or anyone acting on

behalf of Alpa may offer, provide, or receive bribes, kickbacks, or other improper benefits to obtain business

or an unfair advantage. A bribe is defined as directly or indirectly offering anything of value (e.g., gifts,

money, or promises) to influence or induce action or to secure an improper advantage. Kickbacks are

agreements to return a sum of money to another party in exchange for making or arranging a business

transaction. You must avoid participating in bribery and kickbacks, or even the appearance of it, in all

business dealings.

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Gifts, Favors and Entertainment

Alpa maintains a detailed policy limiting the use of gifts, favors and entertainment. Associates are required

to review and adhere to that policy. Modest gifts, favors, and entertainment are often used to strengthen

business relationships. However, no gift, favor, or entertainment should be accepted or given if it obligates,

or appears to obligate, the recipient, or if it might be perceived as an attempt to influence fair judgment.

This includes, for example, expensive entertainment or event tickets (e.g., sporting events, concerts, etc.),

particularly when and Alpa employee is not attending the event. Gifts, favors, or entertainment must not

be offered or given to any government official.

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Avoiding Conflicts of Interest

2We have an obligation to make sound business decisions in the best interests of Alpa without the influence

of personal interests or gain. Our Company requires you to avoid any conflict, or even the appearance of a

conflict, between your personal interests and the interests of our Company. A conflict exists when your

interests, duties, obligations, or activities, or those of a family member, are or may be in conflict or

incompatible with the interests of Alpa. Conflicts of interest expose our personal judgment and that of our

Company to increased scrutiny and criticism and can undermine our credibility and the trust that others

place in us. Should any business or personal conflict of interest arise, or even appear to arise, you should

disclose it immediately to your manager for review. In some instances, disclosure may not be sufficient and

we may require that the conduct be stopped or that actions taken be reversed where possible. As it is

impossible to describe every potential conflict, we rely on you to exercise sound judgment, to seek advice

when appropriate, and to adhere to the highest standards of integrity.

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No Discrimination or Harassment

We strive to foster a safe, welcoming and positive workplace environment where we treat our employees,

customers and business partners with dignity, fairness and respect. We are committed to providing a work

and business environment and business that is free of discrimination and unlawful harassment. We prohibit

discrimination and harassment, including sexual harassment, based on individual's race, color, religion,

sex, sexual orientation, gender identity, national origin, age, marital status, genetic information, disability or

protected veteran status, or any other category protected by law. We expect our business partners to

demonstrate the same commitment.

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Workplace Safety and Violence Prevention

We strive to provide a safe and healthy workplace for employees, customers, and visitors to our premises.

All employees have responsibility for ensuring proper safety and health conditions. Alpa is committed to

maintaining industry standards in all areas of employee safety and health. To support this commitment,

employees are responsible for observing all safety and health rules, practices, and laws that apply to their

jobs, and for taking precautions necessary to protect themselves, their co-workers, customers, and visitors.

Employees are also responsible for immediately reporting accidents, injuries, occupational illnesses, and

unsafe practices or conditions to their manager. Threats, acts of violence, and physical intimidation are

strictly prohibited. Possession of weapons on the job or on Alpa premises is prohibited. No talk of violence

or joking about violence will be tolerated.

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Compliance with Laws and Regulations

All employees must conduct business in strict compliance with all applicable federal, state, and local laws

and regulations and we expect our business partners to do the same. Alpa is also committed to complying

with the industry-specific policies of our business partners that extend to the conduct of our Company and

our employees. We may refuse to continue doing business with any business partner who engages in

conduct that violates this Code or otherwise engages in illegal or unethical business conduct.

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If you have any questions regarding any of the topics addressed above, contact Paul Adamczyk.

 

​NOTE: This Code is not a contract of employment and does not create any contractual rights between

the Company and any Associate or third party. The Code sets standards of conduct and ethics that are

required when an employee is at work or acts on the Company’s behalf.

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