CODE OF CONDUCT

(the “CODE”)

I.               PURPOSE AND SCOPE

Accurate Screen Ltd. and its directors, officers and employees (collectively, “Accurate”, or “our”, “us”, “we”) are committed to maintaining the highest standards of ethical conduct, transparency, and accountability in all our business relationships. Operating under these core business principles builds trust, inspires confidence, leads to strong and lasting business relationships, and improves our Service Pledge to provide high quality product and customer service.

The Code sets out the measures that Accurate undertakes to ensure we can continue to meet our legal obligations, including under the following legislation:

  • the Fighting Against Forced and Child Labour in Supply Chains Act; and
  • employment and labour legislation (which includes regulations and published guidance made pursuant to such laws).

II.             APPLICATION OF THE CODE

Accurate is committed to take commercially reasonable measures, including carrying out appropriate risk management and due diligence, to ensure the respect of the Code across our entire business and within our supply chains. Accurate is responsible for ensuring that our suppliers, vendors and service providers meet the requirements hereunder.

We undertake to:

  • perform our work duties and conduct our business relationships with integrity and in a dynamic, straightforward, honest and fair manner;
  • comply with laws that apply to us;
  • avoid conflicts of interest;
  • foster a work environment based on mutual trust and respect and that encourages open communication;
  • maintain a safe, healthy and secure work place;
  • protect the environment and use energy and other resources efficiently;
  • support a culture in which ethical conduct is recognized, valued and exemplified; and
  • promptly report issues relating to the Code and potential violations, non-compliance with applicable laws, regulations or company policies or procedures and any other emergencies.

III.           OBLIGATIONS OF SUPPLIERS

1.     Complying with laws and applicable standards

In all Accurate’s activities, we shall operate in a manner that complies with the laws, rules, and regulations in the jurisdictions in which we operate and are applicable to us. This includes adherence to environmental, health and safety standards, labour laws, and any other legal requirements relevant to our business activities. Where the provisions of law and the Code address the same issue, the provision that is most stringent will apply.

2.     General Application of Human Rights & Employment Standards

Accurate must maintain a workplace characterized by professionalism, and respect for the dignity of every individual whom we employ, including respect for differences between individuals. Accurate shall promote and provide inclusive, respectful, healthy, and safe workplaces that are free from harassment, discrimination, workplace violence, retaliation, and other disrespectful and inappropriate behaviour.

Accurate shall not unlawfully discriminate in recruitment and employment practices. All employees shall have equal access to employment, including hiring, salary, benefits, advancement, training, allocation of work, or retirement, and are not subject to discrimination in discipline or termination, regardless of their race, sex, gender identity, religion, nationality, marital status, ethnic origin, caste, sexual orientation, disability, illness, pregnancy, age, language, social origin, membership with worker organizations including unions, belief, any other personal characteristics, social group, protected status, or any other status.

Accurate shall take commercially reasonable measures to ensure we:

  • provides a workplace in which all workers are treated with respect and dignity;
  • provides workers with clear and understandable employment documentation in a language understood by the worker;
  • complies with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits;
  • where no wage law exists, workers are paid at least the minimum local industry standard;
  • manages operations in a manner so that overtime does not exceed levels that create inhumane working conditions;
  • allows our workers the right to leave work and freely terminate their employment within legal notice period requirements;
  • has zero tolerance for unlawful discrimination, harassment, and workplace violence;
  • has in place all policies, procedures, trainings, registrations and requirements required under applicable laws;
  • complies with all applicable regulations to prevent illegal, clandestine, and undeclared employment;
  • recognizes and respects the rights of employees to freely associate, organize and bargain collectively, in accordance with local laws and the fundamental conventions of the International Labor Organization; and
  • respects any applicable collective bargaining agreements regarding work hours, overtime, rest period requirements, and paid vacation.

3.     Prevention and Elimination of Forced Labour and Child Labour

Accurate stands by our commitment to prevent and eliminate the exploitation of persons by means of threat, force, coercion, or deception, including any work or services performed involuntarily and under the premise of any penalty. Accurate must and will not engage in or contribute to the use of Forced Labour or Child Labour (each as defined below).

  • Forced labour (“Forced Labour”) means labour or service provided or offered to be provided by a person under circumstances that:
    • could reasonably be expected to cause the person to believe their safety or the safety of a person known to them would be threatened if they failed to provide or offer to provide the labour or service; or
    • constitute forced labour or compulsory labour as defined in article 2 of the Forced Labour Convention, 1930, adopted in Geneva on June 28, 1930.

Forced Labour includes work or services not voluntarily performed that is exacted or coerced from a person under threat, force, or penalty, or threatened abuse of law or legal process.

  • Child labour (“Child Labour”) means labour or services provided or offered to be provided by persons under the age of 18 years and that:
    • Are provided or offered to be provided in Canada under circumstances that are contrary to the laws applicable in Canada;
    • Are provided or offered to be provided under circumstances that are mentally, physically, socially or morally dangerous to them;
    • Interfere with their schooling by depriving them of the opportunity to attend school, obliging them to leave school prematurely or requiring them to attempt to combine school attendance with excessively long and heavy work; or
    • Constitute the worst forms of child labour as defined in article 3 of the Worst Forms of Child Labour Convention, 1999, adopted at Geneva on June 17, 1999.

Accurate is strictly prohibited from:

  • using any form of slave, forced bonded, indentured, or prison labour;
  • threatening workers with or subjecting them to harsh or inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental coercion, physical coercion, verbal abuse, or unreasonable restrictions on entering or exiting company-provided facilities;
  • engaging in or benefitting from any form of human trafficking;
  • requiring, as a condition of employment, a worker to deposit or surrender an original of any government-issued identification, passport, work permit, or any other documents necessary for free movement and termination of employment; and
  • requiring workers to pay employers’ or their agents’ recruitment fees or other similar fees to obtain their employment.

In addition, a employees must meet the legal minimum age as established by applicable laws and regulations. All work must be voluntary, and workers shall be free to leave work or terminate their employment with reasonable notice.

Accurate is encouraged to take commercially reasonable steps, including risk management and due diligence, to ensure that it is not directly, or indirectly, causing or contributing to Forced Labour or Child Labour in any aspects of our operations, and that our suppliers and subcontractors are doing the same. Accurate is encouraged to identify and focus on vulnerable workers and at-risk regions, where there is heightened risk for Forced Labour or Child Labour.

If Accurate discovers a suspected case of Forced Labour or Child Labour, it shall deal with it immediately. Corrective action should provide for the full protection of the worker, in line with principles articulated in the International Labour Organization’s Combatting Forced Labour: A handbook for Employers & Business.

4.     Operational-Level Grievance Mechanism

Accurate is encouraged to develop and maintain an operational-level grievance mechanism to effectively identify, address, remedy and prevent any Forced Labour or Child Labour, or other adverse human rights impacts, that may occur in connection with our business relationship.

Accurate shall ensure that any grievance mechanism implemented is accessible, predictable, equitable, and transparent, and based on engagement with affected stakeholders. Accurate shall maintain open channels of communication with those individuals or groups of stakeholders that are likely to be adversely impacted by potential or actual human rights violations so that the occurrence or likelihood of adverse impacts may be reported without fear of retaliation. Accurate shall ensure that workers have an effective mechanism to report grievances and that facilitates open communication between management and workers. Accurate shall not retaliate or commit any act of reprisal against any person for good faith reporting of breaches of the Code.

5.     Health and Safety

Accurate is committed to provide a work environment that is safe and healthy, and that meets or exceeds the standards of all applicable occupational health and safety legislation. Accurate seeks suppliers that share Accurate’s commitment to continuous improvement in safety performance. To that end, Accurate is committed to regularly review and update our health and safety programs and practices in a manner that ensures ongoing compliance with law and industry standards.

In addition to complying with all national laws, regulations and procedures concerning health and safety, Accurate shall ensure that actual and potential risks to worker health and safety at the workplace are identified, assessed, and eliminated or mitigated and shall conduct regular risk reviews. Accurate shall at all times be in possession of all legally required and valid permits and certificates related to health, safety, and environmental issues such as including but not limited to, fire safety inspections, machinery inspections, waste disposal, environmental licenses, sanitation permits, vehicle inspection permits. Accurate shall ensure that no worker shall suffer any negative consequences for refusing to work with machinery, equipment, tools or in conditions that are reasonably considered unsafe. Where appropriate, Accurate shall ensure that workers are provided with adequate personal protective equipment at no cost, training on the safe use of tools and equipment and shall supervise employees’ adherence to safe working practices.

6.     Due Diligence and Risk Management

In line with the UN Guiding Principles on Business and Human Rights, Accurate is committed to maintain appropriate risk management and/or due diligence processes to identify, prevent, address, mitigate, and account for the Forced Labour, Child Labour, human rights, and ethical risks associated with our business practices.

Accurate shall develop and track performance objectives, targets, and implementation plans, adopt self-evaluation mechanisms, and drive continuous improvement. Accurate shall self-evaluate and make improvements to meet or exceed our expectations and those of our customers as reflected in our Standards. Accurate is committed to continuously assess our risks specific to women and vulnerable groups, including children, indigenous peoples, and temporary or migrant workers. We encourage our suppliers to do the same.

Accurate must establish a due diligence process to manage the risks of a violation of the standards set out in the Code in our supply chains. Management must develop appropriate processes to identify, monitor, and understand applicable laws and regulations to control identified risks and maintain compliance. Accurate must continuously monitor and enforce the standards set out in the Code in our operations and supply chain, including with subcontractors.

 

 

IV.           COMPLIANCE

Reporting

Accurate is required to take reasonable steps to ensure that the Code is made available to our Representatives and throughout our supply chains. We encourage asking questions and raising issues regarding the Code.

Anyone with reason to believe that Accurate or one of our Representative is not in compliance with the Code, or Accurate has engaged in illegal, unethical, or otherwise improper conduct, is encouraged to report such conduct to Accurate by using the following avenue:

Accurate Screen Ltd.

#105 5440 72 Avenue SE

Calgary, Alberta

T2C 4X5  Canada

Attention: Ashley Moisey

587.319.2546

Ashley.moisey@accuratescreen.ca

Any submission made by an employee regarding a violation of the Code will be treated on a confidential and anonymous bases, unless specifically permitted to be disclosed by the employee or unless required by law. Submission will only be disclosed to those persons who have a need to know in order to properly carry out an investigation of the potential violation of the Code.

Any employee who in good faith reports a violation of the Code will be protected from threats of retaliation, discharge or other types of sanctions that are directly related to the disclosure of such violation.

No employee will be penalized for inquiring, in good faith, about a violation of the Code or for obtaining guidance on how to handle suspected illegal acts or policy violations. Further, Accurate will not allow retaliation for reports made in good faith.

Violation or Non-Compliance

Disciplinary action up to and including dismissal will be taken should a director, officer or employee:

  • violate the Code, disregard proper procedures or ask others to violate the Code;
  • deliberately fail to promptly report a violation or withhold relevant information concerning a violation;
  • fail to cooperate in the investigation of a known or suspected violation; or
  • take action against an employee who reports a violation or breach of the Code or other policy.

Annual Review and Sign Off

To demonstrate our commitment to the shared values and standards described in the Code, all directors, officers, and employees, must certify annually that they have reviewed and followed the Code.