General Standards Of Conduct

We expect all employees to adhere to general standards of business conduct while performing their job duties.

We believe our values are the foundation for the Code and that the Code guides our behavior. This section of the Code defines the general standards of conduct expected of all employees. The standards described below provide the minimum behavioral expectations for all employees. Further details covering specific aspects of acceptable or prohibited behaviors and business practices are covered in other sections of the Code and in the Company’s policies and applicable procedures.

In situations where an employee is unsure of what to do or internal guidance is unclear, they should contact their manager or the Human Resources, Legal or Compliance Departments for additional guidance. Similarly, all employees must promptly report any identified or potential violations of the Code or these general standards of conduct to their manager or the Human Resources, Legal or Compliance Departments.

Harassment and discrimination

We value a positive, constructive, and ethical work environment free from harassment. Workplace harassment of any kind is prohibited. Harassment includes any action that creates an intimidating, hostile or offensive work environment, whether physical, verbal or other.

We welcome diversity and are an equal opportunity employer. The Company prohibits any form of discrimination or harassment and provides fair treatment to all employees regardless of race, colour, origin, citizenship, religion, gender, sexual orientation, gender identity, marital status, pregnancy, age, medical condition or disability.

Additionally, we must always respect the privacy of others.

Drugs, alcohol, substances, and violence

We are committed to securing a safe and healthy workplace for our employees free from drugs, alcohol, substances and violence.

Employees must comply with Company policies regarding the use of alcohol and the possession, sale or use of illegal substances. Unless otherwise offered by the Company as part of a Company-sponsored travel, event or activity, alcohol may not be consumed during working hours. The Company reserves the right to test employees for drug, substances and alcohol during working hours, business travel and during any event sponsored by the Company.

Equally important, we do not tolerate violence or any threats of violence and prohibit the possession of weapons of any kind on Company property or while off-site conducting Company business.