This Code of Business Ethics (the “Code”) applies to all employees, officers and directors (collectively, “employees”) of BluMetric Environmental Incorporated (the “Company”).
The provisions of this Code are mandatory, and full compliance is expected under all circumstances. The Code affirms the commitment of the Company to uphold high ethical standards and to specify the basic norms of behaviour for those who are involved in representing the Company.
Employees should use this Code as a tool to provide direction and assistance in their business conduct in representing the Company. Where an employee has any doubts or questions concerning any of the principles set forth in this Code, he or she should seek advice as indicated below.
When considering their own conduct, employees should also be guided by some basic questions they can ask themselves, such as:
This Code does not, nor could it, address all forms of business conduct or employee activity. The matters expressly dealt with are indicative of the Company’s commitment to the maintenance of high standards of conduct and are to be considered prescriptive of the type of behaviour expected from employees in all circumstances. Employees are therefore expected to comply with the spirit and intent of this Code and to make themselves aware of, and comply with, relevant laws, Company policies and other standards governing their conduct.
All contractors engaged on behalf of the Company shall undertake, as a condition of their engagement, to adhere to principles and standards of business conduct consistent with those set forth in this Code.
No Right to Employment
While the provisions of this Code are part of the terms and conditions of employment of all employees, the Code does not constitute a contract of employment or any assurance of continued employment.
Failure to comply with the Code can have severe consequences for both the employee and the Company. Appropriate discipline, up to and including dismissal, will be imposed by the Company for violations of the Code. Furthermore, conduct that violates the Code may also violate federal or provincial law and can subject both the Company and the employee to prosecution or other legal actions. The principles set forth in this Code are conditions of each employee’s engagement with the Company. Employees continue to be bound by these conditions, as revised from time to time to reflect changes in business or organization. Any employee who does not comply with these conditions will be subject to the consequences set out above. The Company’s senior officers and other managers are responsible for monitoring compliance with the Code within their respective areas of responsibility.
Approval and Reporting to the Board of Directors and the Corporate Governance and Nominating Committee
The Code has been approved by the Board of Directors (the “Board”). The Office of the Corporate Secretary shall report periodically to the Board on the distribution and communication of this Code. Management shall also report periodically on issues relating to compliance with the Code to the Corporate Governance and Nominating Committee and, as necessary, to the Board.
Assistance and Reporting of Violations
Any employee needing help or information concerning the Code may contact his or her manager or the Human Resources Department.
In addition, employees must keep in mind that there are many different kinds of competition and business practices issues that can arise in the Company’s business activities. Where an employee believes that such issues may exits, he or she should seek advice from legal counsel before proceeding.
In addition, all employees shall endeavour to deal fairly with the Company’s customers, suppliers, competitors and other employees, and should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.
For the Company to effectively implement this policy, it is critical that all employees respond to and report any concerns about retaliatory behaviour (threatened or actual). If an employee believes that he or she has been subject to retaliation or threatened retaliation because he or she has taken any of the actions referred to above, the employee should report such conduct to his or her manager or the “Appropriate Authority” as defined in the Company’s whistleblower policy (Ombudsman for HR matters, Board Chair or Corporate Counsel for financial/legal matters). The Company will investigate promptly any complaint of retaliatory or other improper behaviour. Complaints and investigations will be handled in a confidential manner, consistent with any corrective action that is taken by the Company.
Employees should be aware that they personally may be subject to criminal liability if they retaliate against an individual because that individual provided truthful information to a law enforcement official regarding the commission or possible commission of a federal offence.