MESSAGE FROM THE PRESIDENT AND CEO
Over our history, employees have developed a culture of honesty, integrity and ethical conduct. This Code of Conduct (“Code”) reflects ACC’s commitment to this culture. The Code applies to directors, officers and employees of ACC. We all have access to the Code and we verify each year that we have complied with the Code.
It is our individual responsibility to understand and follow the Code and to act in accordance with the highest level of personal and professional integrity when fulfilling our duties and representing the Company.
Each employee of ACC represents the Company and is expected to act in a manner that will reflect the Company’s commitment to Integrity, Responsibility, Respect, Leadership and Teamwork. The matters dealt with in this code are to be considered representative of the behaviour expected from employees and are to be regarded as the minimum standards of performance required.
COMPLIANCE WITH LAWS, REGULATIONS AND COMPANY POLICIES
We must comply with all applicable laws and regulations, as well as Company policies and procedures, which apply to the duties we undertake for the Company. Employees should ask for guidance from the Vice President – Human Resources if they are uncertain as to the legal or ethical implications of a particular situation.
Employees who come to realize that they may be engaged in activities which could conflict with the best interests of ACC are required to report the situation in writing to their supervisor as soon as possible.
CONFIDENTIALITY OF INFORMATION
Directors, officers and employees may obtain or have access to non-public information relating to the Company (and its related entities). This information may include, but not be limited to, information that is personal in nature, financial in nature or information contained in databases developed or maintained by the Company or on its behalf. It is expected that this information will be held in strict confidence.
In addition, only information required to carry out the Company’s business, and allowed under applicable laws, will be collected. This information will then be accessed, used or retained only for legitimate business reasons.
CONFLICTS OF INTEREST AND PERSONAL OPPORTUNITIES
Directors, officers and employees must not use their positions with the Company for personal gain. Activities which conflict or appear to conflict between the Company’s interests and personal interests or which would cause the performance of one’s duties to be impaired must be avoided.
Directors, officers and employees are not permitted to accept gifts or favours which could influence their ability to exercise objective and independent business judgement.
Should a conflict or appearance of a conflict arise or if there are concerns about the acceptance of a gift or favour, the circumstances should be discussed with the Vice President – Human Resources.
COMPANY ASSETS
The Company has developed a number of internal controls and security processes to safeguard its physical and financial assets. Officers and employees who have access to Company assets must, at all times, follow procedures for the use and protection of these assets, such as using the assets properly and only for legitimate business purposes. In particular, signing procedures must be followed and access cards and passwords must be kept confidential and secure.
RESPECT IN THE WORKPLACE
All employees have the right to work in a safe environment which fosters respect for each employee and which is free from discrimination or harassment. Any situation where an employee feels he/she has been subjected to discrimination or harassment should be disclosed to the Vice President – Human Resources, in accordance with the Company’s Workplace Harassment policy.
FAIR DEALING
All directors, officers and employees are expected to deal fairly with the Company’s customers, security holders, suppliers, competitors and fellow employees. All directors, officers and employees must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any unfair dealing practice.
REPORTING CONCERNS
Any known or suspected breaches of the Code should be brought to the attention of the Vice President – Human Resources, CFO or CEO of the Company. Reporting of such concerns must be made in good faith with reasonable grounds for believing that reportable conduct has occurred. Confidentiality of any report made in good faith will be strictly respected to the extent possible, consistent with the need to conduct an adequate investigation. Employees who have reported concerns in good faith in accordance with this policy will be protected from termination, demotion or other adverse consequences as a result of their reporting. “Good faith” does not necessarily mean that you have to be right but it does mean that you must believe that you are providing truthful information.
If you are uncomfortable reporting breaches of the Code in person, you may choose to use the Algoma Compliance hotline that has been established as part of the Policy Regarding Complaints on Accounting and Auditing Matters referred to below.
SUPPLEMENTARY POLICIES
The Code is supplemented by policies which address various compliance requirements. These policies include:
- Policy Regarding Employee Complaints on Accounting and Auditing Matters
- Corporate Disclosure Policy
- Insider Trading Policy
- Information Resource Policy
- Safety and Environmental Protection Policy
- Employment Equity Policy
- Employee Privacy Policy
- Workplace Harassment Policy
The Company recognizes that there are professional codes with which certain employees are expected to adhere by virtue of their profession. If there is a conflict between this Code and any such professional code, guidance on how to proceed should be obtained from the Vice President – Human Resources.
CONSEQUENCES OF VIOLATIONS OF THIS CODE
Compliance with the Code is mandatory. Failure to comply with this Code may be grounds for disciplinary action, including termination.
REVIEW OF THE CODE
Management Report to Audit Committee
On at least an annual basis, the Vice President – Human Resources will report to the Audit Committee of the Company on matters relating to compliance with the Code, including:
- the number and nature of inquires made to the Vice President – Human Resources;
- any violations and potential violations of the Code;
- the status of any investigations undertaken pursuant to the Code; and
- any actions taken following a violation of the Code.
In addition, in rare circumstances, it may be appropriate for the Company to waive a provision of the Code and such a waiver may be provided only by the Audit Committee of the Company.
The Code is available online at www.algonet.com and each year directors, officers and employees will be required to acknowledge reading and complying with the Code.
