i.GENERAL
The Code of Conduct (Code) applies to employees and officers of the Technostrobe Group of Companies (the Group). The Group’s agents, consultants and contractors are also required to act consistently with the Code when acting with or on behalf of the Group. As employees and representatives of the Group, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
II. REPORTING RESPONSIBILITY
As employees and representatives of the Group, we are responsible for complying with the Code and its supporting corporate policies. It is our right and responsibility to promptly report suspected Code contraventions to our local supervisor or manager or Human Resources, or through the other reporting options stated in this policy, and to cooperate with internal or external investigations of reported breaches, as applicable.
III. NO RETALIATION
No officer, employee or other representative of the Group who in good faith reports a suspected breach of the Code shall suffer harassment, retaliation or adverse employment consequence. There will be no retaliation for speaking up and making a truthful report of actual or suspected misconduct, for cooperating in an investigation, or for exercising our legal rights. Anyone subject to this policy who retaliates against someone who has reported a suspected breach in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the Group rather than seeking resolution outside the Group.
IV. REPORTING SUSPECTED BREACHES
The Code addresses the Group’s open-door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor or manager is in the best position to address an area of concern. However, if you are not comfortable speaking with your supervisor or manager or if you are not satisfied with the response received, you are encouraged to speak with someone in your local Human Resources or Finance Departments or anyone in management you are comfortable approaching. Management is required to report suspected breaches of the Code to the Group’s Compliance Officer, who is responsible for investigating all reported breaches.
Alternately, if you are uncomfortable discussing any concerns or if your concerns remain unresolved, or if your concerns relate to suspected fraud, you can submit an Ethics and Compliance form by accessing it here or call the Ethics and Compliance Hotline at +1-450-763-2097 option 8 or contact the Group’s Compliance Officer.
V. COMPLIANCE OFFICER
The Group’s Compliance Officer is responsible for investigating and resolving all reports alleging breaches of the Code and summarizing all reports received in the quarter and reporting any material claims to the Group’s Independent Advisory Committee.
The Group’s Compliance Officer is a member of the Group’s Independent Advisory Committee, who can be contacted as follows:
Mail: 65 rue Herbert O’Connell, Coteau-du-Lac, QC, J0P 1B0, CANADA
E-mail: [email protected]
VI. ACTING IN GOOD FAITH
Anyone who reports a suspected breach of the Code must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a possible breach of the Code. Those who misuse the reporting process and knowingly file reports that are false or malicious in nature are considered to have breached the Code and may be investigated.
If an investigation confirms that a breach of this Section has occurred, an appropriate course of action will be taken, which may include disciplinary measures up to and including termination of employment.
VII. CONFIDENTIALITY
Anyone may submit a report of a suspected breach on a confidential basis or anonymously. Reports of suspected breaches will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
VIII. HANDLING OF REPORTED BREACHES
Anyone making a report will be notified within five business days that the report has been received. All reports will be investigated promptly and appropriate corrective action will be taken as the Group’s Compliance Officer determines is warranted. Due to confidentiality concerns and in order to protect those involved in investigations, the outcome of investigations is not shared with the reporter, however, the reporter will be notified when the investigation is completed and the case is closed.
The online version of the Group’s Whistleblower Policy can be found on the Group’s website at www.technostrobe.com