Code of Business Conduct and Ethics

Our Code of Business Conduct and Ethics provides guidance in conducting our business activities in accordance with the highest legal, ethical and professional standards.

The Code of Business Conduct and Ethics (the Code) is approved by the Co-CEOs and the Board of Directors. It is made available to all our employees in both English and French and covers a broad range of topics, including compliance, responsible management, conflicts of interest, anti-corruption and anti-bribery, respect at work, human rights, and the environment.

Implementing the Code

Each director, officer, and employee is provided with a copy of the Code and is required to sign an annual acknowledgement of compliance. In 2015, all our people acknowledged compliance with the Code.

The implementation of the Code is the responsibility of the Vice-President and General Counsel, who provides an annual report to the Audit Committee of the Board.

Furthermore, as part of our Code of Business Conduct and Ethics training sessions, we educate our employees on the application of our policies and procedures. 

Reporting Mechanisms

Mechanisms for seeking advice and reporting concerns can be directed to the appropriate supervisor, to the Vice-President and General Counsel, and to the Audit Committee of our Board. Confidentiality of reports made in good faith regarding alleged violations is maintained.

2015 Achievements

  • All our employees acknowledged compliance with the Code.
  • No breaches of the Code were reported.
  • Developed a Third Party Code of Conduct. 
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