Compliance with Laws, Rules and Regulations
Compliance with both the letter and the spirit of all laws, rules and regulations applicable to our business is critical to our reputation and continued success. All employees must respect and obey the laws of all jurisdictions in which we operate. Failure to comply with this Code will result in disciplinary action which may include termination of employment with the Company.

Compliance With Antitrust Laws
The company believes in fair and open competition, and strictly adheres to the requirements of antitrust laws. These laws generally prohibit collusion between firms and other unfair business conduct that would lessen competition.

Compliance with Environmental Laws
The company takes its responsibility to conduct its business in a safe and reliable manner with respect for the environment very seriously. The Company will strictly comply with all environmental legislation in all aspects of our work. The Company will monitor its environmental performance and will look for ways to reduce and prevent waste, emissions, spills and other releases from our operations so as to minimize, wherever possible, our impact on the environment.

Gifts and Entertainment
The exchange of gifts and entertainment is a common practice in most business communities and is designed to develop and foster goodwill among business partners. Accepting gifts and entertainment can cause problems when they compromise – or appear to compromise – our ability to make fair and objective business decisions. No gift or entertainment should be accepted, or offered, if it will unfairly influence a business relationship.

There are many factors that influence whether a gift or entertainment is normal and customary. Gifts or entertainment should be moderate, reasonable and in good taste, be of a style or value commonly accepted for business occasions and should not be unusual for the recipient’s job or community. The exchange must create no obligation or sense of obligation and should occur infrequently.

Business entertainment can present situations where discretion is required since some commonly accepted business invitations can include recreational opportunities or event tickets that are of significant value. In these cases the recipient should ensure that there is a valid business development reason for attending and that there will be representation from other business executives at the event. If the invitation is for an event where the value being received may be significant, officer approval is required, or in the case of the President, approval by the Chair of the Policy and Board Governance Committee. As transportation costs for events can also be significant, payment of these costs by another party is not acceptable and will be covered by the Company if there is a valid business reason to accept the invitation.

Use of Company Computers
The Company provides computers and internet access to assist employees in their work. Incidental and occasional personal use is permitted, but never for personal gain or any improper purpose. The Company has a formal policy with regards to the use of Company computers and information technology equipment that all employees have signed and are expected to be aware of and comply with. Violation of these policies may result in disciplinary actions up to and including termination of employment with the Company.

Political Activities and Contributions
We respect and support the right of our employees to participate in political activities of their choice provided that their involvement is kept separate from their role as an employee. Employees must take care to represent their views as their own and not the Company’s. These activities should not be conducted on Company time or involve the use of any company resources such as telephones, computers or supplies unless specifically approved by an officer of the Company.

There are laws and regulations pertaining to political contributions made both in dollars and in “kind”. Where the Company deems appropriate, it may occasionally choose to make such contributions but only when authorized by the Chief Executive Officer, and only when the contribution is legal and appropriate for corporations such as the Company.

Payments to Domestic and Foreign Officials
We will not make payments of any sort to government officials to obtain a favourable decision or to attract or retain business. We will comply with the U.S. Foreign Corrupt Practices Act (FCPA) and all other laws prohibiting improper payments to domestic and foreign officials. While the FCPA does permit “facilitating” payments, the Company’s policy is to avoid such payments. Violation of this policy may result in disciplinary actions up to and including termination of employment.

Reporting of Illegal or Unethical Behaviour or Accounting Related Complaints
Employees are encouraged to talk to supervisors, managers or other appropriate personnel when in doubt about the best course of action in a particular situation and to report any concerns they have about violations of laws, rules, regulations or this Code or in relation to any questionable accounting, auditing or financial reporting. Reference is made to our Whistleblower Policy as to an available procedure for the submission of matters through a confidential anonymous process. The Company will not allow any retaliatory action against any employee who, in good faith, reports a possible violation or concerns.

Compliance Procedures
This Code is not intended to address all of the situations you may encounter. There will be occasions where you are confronted by circumstances not covered by this policy or procedure and where you must make a judgment as to the appropriate course of action. In those circumstances you are encouraged to use your common sense and to contact your supervisor, manager or other appropriate person for guidance. Reference is made to our Whistleblower Policy as to an available procedure for the submission of matters through a confidential anonymous process.

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