«R E S O U R C E S R E S U L T S R E L AT I O N S H I P S R E P U T A T I O N Table of Contents Message from Doug Wonnacott 2 Doing the Right Thing 3 ...»
Code of Conduct
R E S U L T S R E L AT I O N S H I P S
Table of Contents
Message from Doug Wonnacott 2
Doing the Right Thing 3
Our Code, Our Conduct, Our Values 5
Employees 7 Employment Practices 7 Safeguards on Canexus’ Employee Personal Information 8 Diversity 8 Prohibition on Workplace Discrimination, Harassment and Violence 9 Drugs and Alcohol 9 Appropriate Use of Company Resources 10 Appropriate Use of Canexus’ Proprietary and Confidential Information 11 Illegal Conduct – Fraud, Embezzlement and Criminal Conduct 12 Our Relationships Conflicts of Interest 15 Gifts and Entertainment 16 Confidentiality of Third-Party Information 17 Our Reputation Accuracy of Canexus Business Records and Public Filings 19 Cooperating with Audits and Investigations 20 Insider Trading and Tipping 20 Competition and Antitrust Laws 21 Anti-Corruption Practices 22 Responsible Care® 23 Quality 23 Our Results Driving Results 25 Making the Right Decision 25 Message from Doug Wonnacott Dear Colleagues In 2012 Canexus adopted a Code of Conduct which was intended to serve as a guide to each of us in carrying on our business, whether it be with our colleagues, our customers, our suppliers or our shareholders. With the passage of time, as we have grown as an organization, we haveundertaken some revisions to the Code of Conduct to ensure that it remains in step with our current business operations and philosophy.
With the dawn of a new year upon us, I want to take this opportunity to both introduce our revised Code of Conduct and to remind each of you of the core values that we expect will
guide everything that we do at Canexus; namely:
● Resources – Our resources drive success. People excellence is achieved by embracing continuous learning, empowerment, teamwork, recognition and diversity.
● Relationships – We value long-term, mutually beneficial relationships with our stakeholders founded upon respect, trust and open communication.
● Reputation – Our reputation is based upon our unwavering commitment to integrity, Responsible Care® and quality.
● Results – We all take responsibility for our results through innovation, continuous improvement, prudent risk-taking and fact-based decision-making.
Each of us at Canexus is responsible for conducting ourselves with these core values in mind.
In every business decision we make, we must be guided by these core values and following the principles set forth in this Code of Conduct.
Our goal is to maintain a culture at Canexus where every member of the organization not only understands his or her role in the success of our company but in performing that role, does so in an ethical manner in keeping with our core values.
Sincerely, Doug Wonnacott President and Chief Executive Officer Doing the Right Thing Everyone at Canexus is expected to use good judgment and common sense to do the right thing and to comply with laws and regulations. To determine whether a course of action is right, employees should consider how management, other employees and external stakeholders could interpret the contemplated course of action.
Compliance with Laws, Rules and Regulations Canexus is committed to operating within the framework of the laws, rules and regulations applicable to its business. All employees are expected to understand and adhere to the laws affecting their work and must not encourage other employees or persons with whom Canexus does business to breach the law.
In addition to this Code, Canexus has adopted a number of formal policies that address various aspects of its business and affairs that are subject to specific legal requirements or restrictions. All employees should familiarize themselves with the content of, and comply with, all such policies.
Chances are that you will find yourself faced with an ethical dilemma, especially if you manage a team. You know t h a t perceptions matter. You know that everyone has their own way of doing things. But you also know that, as a part of the same organization, we are all accountable to each other and to the company. To maintain your personal commitment to
doing the right thing you should:
• demonstrate by action what it means to act with integrity;
• work in an honest manner;
• consider the best interests of your co-workers, Canexus and its exter nal stakeholders;
• ensure that you understand and comply with the Code, values and policies;
• make sure to ask for help and to help when asked; and
• report instances of noncompliance with the law, Canexus policies or the Code.
In situations where there is some uncertainty, employees are expected to seek guidance through their supervisors, our Director of Human Resources or our General Counsel.
Duties of Those who Supervise Others
If you supervise others, you have additional responsibilities under the Code to:
• lead and demonstrate ethical business practices by example;
• make sure your staff is aware of the Code’s requirements;
• enforce the Code consistently; and
• support employees who, in good faith, raise ethical questions or concerns.
Asking Questions and Raising Concerns Canexus’ integrity and values can only be maintained if we, as representatives of the company, ask questions and raise concerns in the appropriate situations. In addition to knowing and following your legal and ethical responsibilities, you should report ethical violations. Reportable instances include a perceived or actual violation of the law, of Canexus policies, of an endangerment to an employee or the public’s safety, health or security, accounting or auditing irregularities or other business conduct t h a t i s contrary to Canexus’ values.
In most cases, integrity concerns can be raised directly with a supervisor. In addition to your
supervisor, you may also speak with:
• your supervisor’s supervisor;
• the head of your department;
• our Director of Human Resources;
• our General Counsel; or
• our Manager of Internal Audit.
Canexus also maintains an Integrity Helpline which is operated by an independent third-party company. The Integrity Helpline is available 24/7, 365 days a year and facilitates confidential
and anonymous reporting. You may submit a report online through the EthicsPoint website:
www.ethicspoint.com. Or you may call the Integrity Helpline via one of the following numbers:
North America – 1-888-205-1295 Brazil – 0800-891167
Question: What happens when I call the Integrity Helpline?
Answer: Your phone call will be answered by a live operator at EthicsPoint. You will be asked a series of questions about the incident you are reporting. P l e a s e e nsure that your answers are honest and straightforward and that you provide sufficient and detailed information to allow Canexus to investigate the situation thoroughly and in a timely and professional manner. You may elect to remain anonymous, h o w e v e r i f y o u d o Canexus will only be able to contact you through EthicsPoint. After you complete y o u r report, you will be assigned a unique report key code which you can use in the future to check for feedback or to answer any questions with respect to the investigation. You are encouraged to check back as the investigator may need more information to complete the inquiry.
Our Commitment to Non-Retaliation Canexus understands the importance of employee reporting and undertakes not to retaliate against an employee or other person who, in good faith, raises concerns or questions about Canexus business practices. Anyone responsible for retaliating against those who make reports in good faith will be subject to disciplinary action up to and including dismissal.
Acting in good faith means that you have provided all the information you are aware of and believe is true. If it turns out you are wrong, that’s okay. The most important thing is that you ask the question or raise the concern where appropriate.
Canexus understands the importance of employee reporting; it is part of the foundation of our ethical culture as it helps preserve and promote our values and commitment to ethical conduct.
Canexus will ensure that employees who, in good faith, raise concerns or questions about Canexus business practices are not subjected to retaliation of any kind or in any form. Acting in good faith means that you have provided all of the information that you are aware of and that you believe that information to be true. If it turns out you are wrong, that’s okay. The most important this is that you ask the question or raise the concern where appropriate. Anyone responsible for retaliating against an employee who makes a report in good faith will be subject to disciplinary action up to and including dismissal.
Our Code, Our Conduct, Our Values The Code of Conduct is the standard by which Canexus employees, officers, and Board members, as well as those doing business with Canexus, are expected to follow. As
representatives of Canexus, our actions should be guided by our four core values:
Resources, Relationships, Reputation and Results. By reminding oneself of our four core values, representatives of Canexus will be assisted in making ethical business decisions and complying with the Code of Conduct and Canexus’ policies.
Our Values at Work
Resources are the foundation for success. Without Resources, we cannot have Relationships, Reputation or Results. People excellence is achieved by embracing learning, empowerment, teamwork, recognition and diversity. We strive to respect and treat everyone in a fair and ethical manner. Canexus’ employees are empowered to make changes to save time and money and create opportunities for the organization.
Relationships produce long-term growth, achievements and opportunities. Ethical business practices build the trust that is a crucial component of sustainable, effective working relationships. Strong Resources are key building blocks for fostering Relationships.
Reputation is key to the success of Canexus. Not only must we follow Canexus values, but we must complete our tasks with an unwavering commitment to integrity, the principles of Responsible Care® and quality. Strong Resources and Relationships underlie Reputation.
We are committed to equal opportunity employment where each of us, regardless of culture, gender, race, colour, ethnicity, age, nationality, sexual orientation or disability has the opportunity to reach our full potential.
As part of the employment process, Canexus routinely conducts background checks on candidates. Background checks may be required by law for certain positions. Background checks also allow Canexus to affirm a candidate’s information. These checks allow Canexus to be sure that it is hiring employees who are best qualified for the position.
Canexus also values the referrals of current employees. We believe that current employees are able to identify others who share Canexus’ values and high work standards.
In handling your personal information, Canexus is accountable for its use and disclosure, will inform you of why it is required and what it will be used for, will ask for your permission prior to its use and disclosure and will keep the information secure.
Question: I received a call from someone asking for a Canexus employee’s start date, title and salary. She told me she was contracted by the Canexus Human Resources department and that it was an urgent project. What should I do?
Answer: Information about our employees is confidential and disclosure is limited to those who are authorized to have access to it. Do not provide this information unless you are certain that disclosure is authorized. In this case, it is best to take her name and number and call back once you have confirmed the legitimacy of the request.
Diversity A diverse group of people and ideas in the workplace is essential to our business success.
We all benefit from a work environment of diversity which offers a wide range of perspectives and promotes fairness and equity. All employees are expected to respect and value the contributions that people of different characteristics, experiences and backgrounds offer.
Question: I am interviewing potential candidates for a job but I feel that the traveling requirements require too much travel time from a single parent.
I agreed to interview a single parent for the job, but only out of courtesy.
Answer: Assuming that the travel time required of the job is too much for a single parent is a violation of this Code and Canexus policies. Such an assumption may also be illegal. Every employee and interviewee should be given a genuine opportunity, without bias or discrimination, to demonstrate that they can meet the job requirements.
Prohibition on Workplace Discrimination, Harassment and Violence Canexus is committed to maintaining a positive work environment in which all of our employees are treated with respect and dignity.
Conduct that discriminates against an employee or group of employees due to their race, religious beliefs, colour, gender, disability, age, ancestry, family status, source of income or sexual orientation is prohibited.
Harassment is also prohibited. Harassment is any kind of conduct or comment that is known or could reasonably be known to be unwelcomed or inappropriate. Harassment can take many forms including offensive remarks, unwelcomed advances, a sexual joke or ethnic, racist or sexual slurs.
We should all be aware that a joke that may be funny to one person may be offensive to another. If your conduct could possibly cause insecurity, discomfort, offence or humiliation to another person or group, then it is not appropriate behaviour.