Reporting Code of Business Conduct Violations

Reporting Code of Business Conduct Violations

We want to promote an open culture, where people ask questions if they are unsure and raise concerns if they believe our Code of Business Conduct has been violated.

Seeking guidance

Throughout the Code we have tried to include useful guidance to help you apply the principles to situations you may face in conducting your job. However, the right way to act may not always be clear, even after a review of relevant Code provisions. Ask questions before undertaking any action that may violate any applicable law, rule, regulation, Company policy or other provision of the Code. If you have questions, you can seek guidance from your Manager.

Reporting concerns

If you become aware of or suspect any conduct that you believe violates any applicable law, rule, regulation, Company policy or other provision of the Code, you are required to report such improper conduct as promptly as possible. Typically, this would involve reporting the matter directly to your manager. However, if you are uncomfortable reporting the matter to your Compliance Officer, you may always report it to your immediate supervisor.

We encourage open and honest communication. If, however, you feel the need to communicate your concerns anonymously you may do so. You should be aware, however, that it is often more difficult to investigate properly matters communicated anonymously.

Reports of ethical violations will be kept confidential to the extent possible, consistent with our Company’s need to investigate and take action regarding the matter. Employees are also expected to keep information regarding such matters confidential and understand that they are expected to fully cooperate with any such investigation.


No retaliation

We will not permit retaliation against any employee who, in good faith, seeks advice concerning, or who reports or complains of violations of, the Code or other illegal or unethical conduct. If, however, an employee makes a false report of a violation or of questionable behaviour for the purpose of harming another person, the reporting employee will be subject to disciplinary action.



If any provision of the Code is held to be illegal, void or unenforceable because of any law or public policy, the remaining provisions will continue in full force and effect.