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CODE OF CONDUCT WSP
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TABLE OF,CONTENTS CODE OF CONDUCT 3, Introductory remarks 3. Scope and applicability 4, Compliance with the Code 4. Interpretation of the Code 4, Business standards 5. Business integrity 5, Financial conduct 8, Conflicts of interest 11. Fair dealings 12, Employment policies 15, Use of Corporation assets 17.
Confidential information 20, Document retention 21. Where to turn for help 21, Reporting suspected violations 22. Appendix A Glossary 24, Appendix B Business Conduct Hotline Numbers 26. wsp com page 2, CODE OF CONDUCT, APPROVED BY THE BOARD OF DIRECTORS ON MARCH 17 2015. REVISED IN FEBRUARY 2017 MARCH 2018 AND MARCH 2019. INTRODUCTORY REMARKS, As a professional services firm we seek to adopt best practices that contribute to preserving the reputation we.
have built over the years This reputation along with the excellence of our professional services enables us to. maintain the relationships of trust we have with our clients shareholders employees and other stakeholders . We are proud of our success which rests not only on the excellence of our services and leadership but also on the. loyalty of our clients This is the result of our disciplined and thorough approach to the work we do and the. motivation we feel to give the best of ourselves , Our employees are all ambassadors for WSP Global Inc and its subsidiaries collectively the Corporation and. their actions whether on a business professional or personal level reflect on our organization The integrity of. our business depends on the integrity of each and every one of our employees . In order to continue to earn the trust of our clients and stakeholders and to preserve our reputation we must set. high standards of conduct for ourselves In that regard our Code of Conduct the Code reflects our. commitment to abide by ethical principles in our business dealings with clients shareholders employees and. suppliers It aims among other things to provide guidance and a framework for our actions and behaviours with. respect to our corporate obligations as well as our business activities This Code applies to all our employees . officers and members of the board of directors , Integrity is everyone s business All employees must read our Code adopt it and as a matter of obligation comply. with it Each of us has a role to play in upholding the very highest standards of integrity . Alexandre L Heureux,President and Chief Executive Officer. wsp com page 3, SCOPE AND APPLICABILITY, The Code of Conduct the Code concerns WSP Global Inc and its subsidiaries collectively the Corporation . and applies to all employees without exception This includes the President and Chief Executive Officer officers . vice presidents directors managers employees independent contractors and other persons subject to an. employment type relationship with the Corporation its subsidiaries and affiliated companies and members of the. board of directors of the Corporation collectively the Employees The Code sets forth general principles to. guide Employees in making ethical decisions It takes into account applicable legal and regulatory requirements . and is designed to provide overarching guidance In adhering to the Code Employees will be in compliance with. increasingly complex international and national laws and regulations For ease of reference a list of defined. terms is included in the glossary at the end of the Code . The Code is to be read together with its underlying policies such as the Anti Corruption Policy and regional. supplements as applicable , As a professional services firm whose staff includes Employees from many different backgrounds the Corporation.
is also governed by and required to comply with the codes of ethics of various professional orders and. organizations It should also be noted that this Code does not replace or amend any legislative or regulatory. provisions ,COMPLIANCE WITH THE CODE, All Employees have a responsibility to understand and comply with the Code Employees must act in. accordance with WSP s guiding principles and perform their duties with honesty and integrity in all areas . including those not specifically addressed by the Code . Subject to applicable laws regulations collective agreements and procedures suspected violations of the Code. and underlying policies will be investigated and disciplinary measures up to and including dismissal may be. taken against any Employee who , violates the Code or does not adopt the conduct advocated therein . encourages other Employees to violate the Code , deliberately breaches the obligation to report a Code violation or fails to do so promptly or withholds. relevant information concerning a violation , refuses to cooperate during an investigation related to a suspected or known violation . confronts another Employee who reports a potential violation . There is nothing in the Code that would prevent the Corporation from taking disciplinary action on matters. involving Employee misconduct whether expressly covered by the Code or not . INTERPRETATION OF THE CODE, The Governance Ethics and Compensation Committee of the Corporation s board of directors the Governance.
and Compensation Committee comprised of three independent directors and the Chief Ethics and. Compliance Officer are responsible for overseeing the interpretation of the Code . The Governance and Compensation Committee may review modify or amend the Code at any time to reflect the. complexity of the changing business environment in which the Corporation operates This Committee is. wsp com page 4, responsible for developing best in class governance standards for the Corporation and for reviewing related. procedures to ensure compliance with applicable laws and regulations . The Corporation s Internal Audit department is also tasked with ensuring that these governance standards are. respected The Internal Audit department reports to the Audit Committee of the Corporation s board of directors. the Audit Committee ,BUSINESS STANDARDS,The Corporation s key business standards include . The commitment to adopt a zero tolerance policy to any form of corruption . The commitment to act ethically with integrity fairness and excellence in dealings with all business. partners and the expectation of the same commitment in return . The expectation that Employees will avoid personal activities and financial transactions that conflict or. appear to conflict with those of the Corporation . The commitment to take appropriate measures to deter fraud . The commitment to keep accurate books and records throughout the Corporation s operations . The commitment to protect trade secrets and confidential information of the Corporation and the. expectation of the same commitment by business partners . EACH EMPLOYEE HAS AN ESSENTIAL CONTRIBUTION TO MAKE . The Corporation is in the professional services industry and each Employee must act accordingly Each Employee. is an ambassador of the Corporation s guiding principles and must play a key role in complying with the Code and. its underlying policies , Furthermore because of their leadership role management and senior executives of the Corporation are. expected to set an example by conducting themselves in an exemplary manner at all times and in all situations . ACTING WITH HONESTY AND INTEGRITY IS , The Corporation expects that its Employees will never get involved in theft fraud bribery bid rigging or any sort. of breach of trust situation in the performance of their duties . BUSINESS INTEGRITY,GENERAL, The Corporation carries out its business activities with honesty and integrity at all times The future of the.
Corporation s success depends upon the trust of clients and other stakeholders as well as on the Corporation s. reputation for technical expertise and reliable ethical conduct . In all the Corporation s business activities it complies with both the letter and the spirit of national and. international laws Regardless of the country Employees find themselves in they must diligently protect the. Corporation s integrity at all times and must comply with the legal and regulatory requirements of the countries. in which the Corporation operates ,wsp com page 5, The Corporation is subject to strict anti corruption laws including the Canadian Corruption of Foreign Public Officials. Act CFPOA the United States Foreign Corrupt Practices Act FCPA and the United Kingdom Bribery Act UKBA They. can apply to Employees and subsidiaries everywhere in the world regardless of nationality or location The. penalties for infringement of these laws can include fines and prison sentences for individuals and heavy fines for. companies ,ZERO TOLERANCE TO ANY FORM OF CORRUPTION. The Corporation has a zero tolerance approach to all forms of corruption In particular the following practices. are expressly prohibited by the Code as well as under international anti corruption legislation bribery kickbacks. and facilitation payments ,BRIBERY, Bribery includes payments to secure a business advantage to which the Corporation is not entitled A bribe may. take the form of a financial inducement a gift in kind or some other favour such as an offer of employment to a. relative of the person being bribed None of these are acceptable . KICKBACKS, Kickbacks are a form of bribery that arise when suppliers of service providers pay part of their fees to the. individuals who awarded the contract or provide some other form of business advantage . FACILITATION PAYMENTS, Facilitation payments are small payments to officials with a view to speeding up routine governmental.
transactions to which the payer is already entitled Examples include payments to speed up customs clearances . and extra fees to officials to secure electricity connections In the case that a demand for facilitation payment. includes a threat of violence or personal harm Employees will use their best judgment to abide by the. Corporation s business standards while ensuring that any risk to life or liberty is minimized . Employees who encounter any form of corruption including bribery kickbacks or facilitation payments must. report the situation directly to the regional Compliance and Ethics representative the Chief Ethics and. Compliance Officer or through the Corporation s Business Conduct Hotline Once reported the situation will be. recorded and the necessity of further action will be assessed . For more information on the Corporation s approach to anti corruption please refer to the Anti Corruption Policy . which is available on the Corporation s web and intranet sites . GIFTS ENTERTAINMENT AND HOSPITALITY, Employees may not solicit give or receive either directly or indirectly gifts gratuities special allowances . favours or benefits in relation to an individual or corporation with which they do business if the benefit could. unduly influence the judgment of the recipient by creating a disproportionate obligation to return the favour or. by creating an appearance of impropriety , Employees must be vigilant when exchanging business courtesies If there is any appearance that either party is. under a business obligation as a result of the gift entertainment or offer of hospitality then it is not acceptable . wsp com page 6, By maintaining independence the Corporation and its Employees avoid real apparent or potential conflicts of. interest Employees must therefore decline or return an invitation or a gift that is offered repeatedly or whose. significance makes them uncomfortable and notify their immediate supervisor . REGISTERING A BUSINESS COURTESY EXCHANGE, The specific monetary value of acceptable modest gifts entertainment or hospitality applicable in each region in. which the Corporation operates is available through regional guidelines which can be requested from any local. senior manager or the regional Compliance and Ethics representative The regional guidelines will establish when. a business courtesy exchanged with a third party must be approved and registered Where registration is. required the business courtesy exchange must be recorded in the Corporation s gift entertainment and. hospitality registry accessible through the Corporation s intranet . For more information and guidance on the exchanges of gifts entertainment and hospitality please refer to the. Gifts Entertainment and Hospitality Policy which is available on the Corporation s web and intranet sites . WORKING WITH THIRD PARTIES, The Corporation does not engage in any form of corruption or bribery either directly or indirectly This zero .
tolerance approach applies to all Employees and external third parties with whom the Corporation carries out. business including business partners joint venture or equity partners acquisition targets service providers . suppliers vendors consultants sub consultants contractors or any other persons acting on its behalf such as. agents representatives or sponsors and their employees or other persons working on their behalf This. commitment is made on ethical grounds and because Employees personally and the Corporation could be held. legally accountable if business partners are involved in any malpractice or corruption when acting on its behalf . For more information on how to identify and manage bribery and corruption risk relating to third parties please. refer to the Working with Third Parties Policy which is available on the Corporation s web and intranet sites . SPECIAL CONSIDERATIONS FOR GOVERNMENT AND PUBLIC OFFICIALS. Most national and international anti corruption legislation focuses on government officials also referred to as. public officials or foreign officials though the UKBA also covers bribes between private individuals Anti . corruption legislation often uses a wide definition of government and public officials to include persons who are. not simply traditional representatives of governments at the federal state or municipal levels appointed or. elected Enforcement proceedings particularly in the US have made it clear that the definition of government. and public officials may also encompass a wide range of civil servants as well as employees of state owned or. state controlled entities , Employees must therefore take particular care when involved in any business relationship or discussion with a. government or public official ,POLITICAL CONTRIBUTIONS AND INVOLVEMENT. Political contributions and donations can involve cash and non cash items such as the use of corporate facilities . services or materials or Employee time Typically they are to support a governmental entity or a political. organization party or candidate As a general rule the Corporation does not make any political donations or. contributions ,wsp com page 7, This being said Employees have the right to participate in political activities in their personal capacity and to pay. political contributions out of their own pocket so long as this does not lead them into a real apparent or. potential conflict of interest situation Furthermore Employees will not be reimbursed in time money or in any. other form of compensation by the Corporation for their activities . Exceptionally in the US the Corporation s operating companies may make political contributions or donations as. they are permitted by law and are an accepted part of local custom and practice with respect to government and. industry engagement In the US the Corporation s operating companies making political contributions or. donations must comply with applicable policies and processes For more information on the unique requirements. applicable in the US please refer to the US Supplement to the Code of Conduct . RESPECTING COMMUNITIES, The Corporation contributes positively to communities in which it carries out business activities through the. services provided and the lasting infrastructure that is left for the public such as schools hospitals other social. infrastructure and transport systems The Corporation and its Employees always respect the traditions cultures. and laws of the countries in which operations are carried out and take into account the concerns of the wider. community including both national and local interests . The Corporation is never complacent about the way it operates in a local area or the impact operations can have. on local people and their environment Communities affected by the Corporation s projects will be regularly. updated and informed of their progress Additionally the Corporation will seek to employ qualified local people. on its projects wherever possible , The Corporation believes that profitable markets healthy communities and environmental limits are not.
competing interests they are shared outcomes that closely align with one another The Corporation through its. Employees will listen to the concerns of local communities and wherever it can will act to mitigate them to the. very best of its capabilities ,FINANCIAL CONDUCT,FRAUDULENT OR DISHONEST ACTIVITIES. Employees are strictly prohibited from carrying out fraudulent or dishonest activities All statements and reports . including expense reports invoices pay slips and Employee records must be prepared carefully and honestly . For example Employees must not engage in the following activities which are deemed fraudulent and dishonest . Falsification of supplier invoices or receipts , Fictitious payroll transactions . Deliberate false statements made orally or in writing about the Corporation other Employees supervisors . oneself or work related situations , Approval or receipt of payment for goods not received or services not performed . Misappropriation of funds securities supplies or any other assets . Creating or altering hardcopy or electronic documents with the intent to defraud the Corporation or its. clients ,wsp com page 8, Falsification of financial or accounting data related to cash transactions . Improper use or falsification of the Corporation s letterhead for non business related purposes . BOOKS ACCOUNTING RECORDS AND INTERNAL CONTROLS, The Corporation is required under various national and international securities tax and other laws and.
regulations as well as the International Financial Reporting Standards IFRS to keep books records and accounts. that accurately reflect overall operations and to establish for this purpose an appropriate accounting and internal. control system All transactions assets and liabilities of the Corporation recorded in its books must accurately. reflect its overall operations The Corporation s books records and accounts must therefore be valid complete . accurate and based on verifiable supporting documentation Under no circumstances should parallel accounts be. kept , The Corporation adopted internal controls and procedures to meet its accounting requirements and comply with. legislation and regulations Employees are required to comply with and implement such controls and procedures. in order to ensure that all financial transactions are recorded completely and accurately Employees must notably. adhere to the following rules , Employees must not make improper or inaccurate time sheet entries . Employees must not improperly accelerate or defer the recording of revenues or expenses so as to give the. impression that financial targets or results have been attained . Employees must not keep assets or funds in reserve by not officially recording them in the books . Employees must not establish or maintain accounts and financial records in an inadequate incomplete . fraudulent or misleading manner , Employees must not issue payments for reasons other than those stated in the supporting documents . Employees must not submit or approve an expense report where they suspect that some expenses were not. actually incurred are not accurate do not clearly or accurately describe the expense or its purpose or do not. comply with the expense policies , Employees must not sign any documents that they know or suspect to be inaccurate or untruthful . Employees must not interfere with the process of auditing the Corporation s accounts by internal or external. auditors nor seek to improperly influence the auditing process either directly or indirectly . Employees in supervisory roles must implement internal controls relating to the activities for which they are. responsible with a view to safeguarding the assets of the Corporation and ensuring the accuracy of its. financial reports and accounts , No transactions may be concealed from management or from the Corporation s auditors .
Any Employee who does not comply with these rules can be considered as engaging in fraudulent or dishonest. activities Furthermore the Corporation may take all appropriate measures to recover wrongfully obtained. assets , Any Employee with knowledge of irregularities concerning the accounting of a transaction involving the. resources of the Corporation must promptly report the situation to their immediate supervisor the Vice. President of Internal Audit and or the Chief Ethics and Compliance Officer Irregularities can also be reported in a. confidential manner in accordance with relevant internal procedures notably through the Corporation s Business. Conduct Hotline ,wsp com page 9, STOCK MARKET TRANSACTIONS AND INSIDER TRADING. Securities legislation imposes restrictions on the purchase sale or other dealings of securities by anyone. possessing privileged information that is not yet public knowledge and that could impact the share price of the. securities of a given corporation , Employees are therefore not authorized to sell or purchase securities of the Corporation or third party. companies with which it has business dealings when they have knowledge of material non public information. obtained in the course of employment nor are they authorized to pass on such tips to anyone else In addition . Employees must take care not to inadvertently disclose confidential information to their spouse family members. or anyone else living in their household or to business partners friends or acquaintances because this could be. considered insider trading ,DEFINITION OF MATERIAL NON PUBLIC INFORMATION . Information should be regarded as material and non public if it has not been previously disclosed and is not. otherwise available to the general public and if there is a reasonable likelihood that it would be considered. important to an investor in making an investment decision regarding the purchase or sale of the Corporation s. securities Such material non public information could therefore spur investors to buy sell or trade the. Corporation s securities as well as the securities of third party companies with which it has business dealings . Examples of information considered to be material until disclosed publicly include . Acquisition related information , Quarterly and annual financial statements .
Strategic plans , Business results , Operating statistics and. Major changes in senior management ,DEFINITION OF AN INSIDER . An insider is an individual who possesses material non public information on the Corporation An individual who. conducts transactions on the securities of the Corporation before that information becomes known to the public. is engaging in insider trading , For example insider trading occurs where an Employee who knows that the Corporation is about to conduct an. important transaction to finalize an acquisition that could have an impact on the share value buys or gets. another person to buy shares on the stock exchange before that information is made available to the general. public , For more information on insider trading please refer to the Insider Trading Policy which is available on the. Corporation s web and intranet sites ,wsp com page 10.
CONFLICTS OF INTEREST,GENERAL, To maintain the trust of clients and the public Employees are required to behave in a loyal manner at all times so. as to protect the interests of the Corporation , Employees must therefore avoid behaviours that might be prejudicial to the Corporation its image and its. reputation This is notably achieved by avoiding conflicts of interest and by respecting the confidentiality of the. Corporation s information ,PERSONAL CONFLICTS OF INTEREST. Employees must avoid putting themselves in a real apparent or potential conflict of interest situation As an. example a conflict of interest exists if a given Employee allows or appears to allow their personal or private. interests or the interests of their family other relatives or associates a company they own or in which they have. an interest a business partner etc to affect their ability to perform their work objectively impartially and. effectively , Employees must avoid real apparent or potential conflicts of interest whereby personal interest may be to the. detriment of the Corporation s interests If there is a conflict the interests of the Corporation must take priority . Employees must also adhere to regional conflicts of interest guidelines where applicable . SERVICE EXCLUSIVITY, Employees are required to work exclusively for the Corporation while being employed by it This requirement.
may vary in certain regions and is subject to local laws and collective agreements Employees should check with. the local Human Resources department , Employees may not carry out business activities or accept mandates on behalf of third parties either directly or. indirectly for compensation or otherwise which compete with the regular activities of the Corporation unless. they have obtained prior consent from their supervisor and the regional Compliance and Ethics representative . In the event that a member of management is asked to become a board member of a company or other. organization he she may not accept such an appointment without prior approval from the Regional President. and CEO ,EXAMPLES OF CONFLICTS OF INTEREST, To determine the existence of a real apparent or potential conflict of interest Employees should consider. whether i their behaviour is in line with the Corporation s guiding principles ii they are performing their. duties in an objective and impartial manner iii their actions or decisions result in or give the appearance of. resulting in a financial or other benefit for themselves someone with whom they have a personal relationship or. a company or other entity in which they hold an ownership interest and iv they would be embarrassed to. discuss the situation with their supervisor or colleagues . The following are examples of real apparent or potential conflict situations and the action to be taken . Doing or carrying out business with family and friends must be disclosed and the Employee must not be. involved in any selection process involving such persons . wsp com page 11, Information on corporate business opportunities contemplated by the Corporation should never be discussed. with third parties in which an Employee may have a direct or indirect interest . Direct supervision of anyone with whom an Employee has a family relationship must be avoided as it could. give rise to an appearance of favouritism , Disposal of any Corporation assets in favour of an Employee his her family relative or associate for a. consideration lower than fair market value must be authorized by the Compliance and Ethics Office or Legal. department ,REPORTING AND REGISTERING A CONFLICT OF INTEREST.
If an Employee believes that there is a real apparent or potential conflict of interest the situation must be. promptly reported in writing to the Employee s immediate supervisor Furthermore any real apparent or. potential conflict of interest must be recorded in the Corporation s conflict of interest registry accessible through. the Corporation s intranet , BENEFITS OR FAVOURS RELATING TO CORPORATION ACTIVITIES. Employees must not seek to take advantage of benefits or favours that could arise or be discovered by them as a. result of their employment at the Corporation They must not use the Corporation s property or information. obtained through employment with the Corporation to their own benefit . Employees must not seek to take advantage of a business opportunity that could become available to them. outside the workplace if the business opportunity is related to the Corporation s existing or proposed business. activities Moreover Employees may not use property or information belonging to the Corporation for personal. advantage nor may they compete with the Corporation in any business endeavour . Furthermore subject to business relationships that the Corporation may already have negotiated or entered into. with certain business partners Employees may not use the Corporation s name to obtain discounts or any other. preferential treatment without written authorization . FAIR DEALINGS,GENERAL, Any business transacted on behalf of the Corporation must be conducted in an honest and straightforward. manner so as to protect the integrity and reputation of the Corporation It is the Corporation s policy to avoid. misrepresentation manipulation concealment or any misuse of confidential information and to not engage in. negative discourse against competitors or any unfair practices with shareholders clients suppliers competitors. and Employees ,SELLING CORPORATE SERVICES, The Corporation develops innovative solutions manages efficiently and delivers the best projects for its clients . The Corporation further provides a constructive experience based on professionalism and a proactive approach. to client needs ,wsp com page 12, Clients expect that the Corporation will offer them quality services They further expect accurate descriptions of. the benefits that may be derived from such offerings To maintain the trust of its clients the Corporation. undertakes the following commitments , To only offer services that it is authorized to provide alone under contract through an alliance or through.
an agent , To only offer services that clients desire . To promote its services in a straightforward and honest manner . To allow business partners to ask questions about their competitive choices . To deal with clients in a courteous professional and constructive manner . FAIR COMPETITION, The Corporation values fair and open competition It will not enter into any business arrangement that eliminates. or discourages competition or that confers an inappropriate competitive advantage as such arrangements. interfere with commerce and free trade Activities of this type include price fixing agreements boycotting of. suppliers or clients bid rigging cartel conduct exclusive dealing misuse of market power controlling the output. or limiting the supply of goods and services unconscionable conduct concerted practices price signalling price. fixing to eliminate a competitor entering into an agreement or arrangement with competitors to divide a market . etc Employees must comply with international and national competition and anti trust laws such as Canada s. Competition Act ,INFORMATION ABOUT COMPETITORS, Employees are entitled to stay informed about the markets in which the Corporation operates and this includes. obtaining information about competitors their products services technologies pricing marketing campaigns . etc However such information must be collected through legal and ethical means failing which the Corporation. would be acting illegally and could expose itself to legal proceedings . DISCLOSURE OBLIGATIONS, The Corporation is required by virtue of various securities legislation to inform the public on a regular basis. concerning the state of its business and financial situation This is done primarily through the Corporation s. quarterly and annual reports as well as through material published in connection with the annual shareholders . meeting The Corporation provides additional disclosures through information produced for specific occasions . such as communications with financial analysts and quarterly press releases All Employees who are involved in. preparing and disseminating such information or who themselves offer such information have an obligation to. ensure that the disclosure is full fair accurate timely and understandable . The Corporation has adopted control methods and procedures designed to meet the above disclosure. requirements An Employee with knowledge that information made public is not accurate complete or timely or. with knowledge that a given development or fact may require disclosure must report the matter immediately to. the Compliance and Ethics Office , To ensure maximum consistency in the information disclosed to the public only a limited number of individuals.
are authorized to communicate with the financial community on behalf of the Corporation These individuals are . wsp com page 13, The Chairman of the Board , The Chief Executive Officer . The Chief Financial Officer , The Communications Investor Relations Officer . Other persons authorized by the Chief Financial Officer . For more information on disclosure obligations please refer to the Corporation s Public Disclosure Policy available. on the Corporation s web and intranet sites ,MEDIA RELATIONS. The Corporation encourages all of its regional operating entities to be timely responsive and open with local. media as well as to create opportunities that enhance the firm s image and safeguard its reputation All media. relations activities including through social media such as but not limited to Twitter Facebook LinkedIn or. YouTube with the exception of the restrictions above are coordinated by the Regional Head of. Communications Marketing , Given the large size and international structure of the Corporation it makes many routine announcements or. otherwise discloses information to the public that would not meet the definition of prohibited disclosure set out. in the Public Disclosure Policy Many of these routine communications relate to i specific projects ii clients iii . work in progress iv awards or v views expressed by experts working for the Corporation Please note that. when making a disclosure about a specific project prior client consent must always be obtained . When an information request involves disclosure of information the disclosure of which is or may be restricted . the Regional Head of Communications Marketing will contact the Investor Relations Officer for guidance. regarding the request prior to providing a response The Investor Relations Officer may require that the Regional. Head of Communications Marketing respectfully decline the request as containing confidential or proprietary. information or may allow the Regional Head to proceed with a response . Staff members who are not authorized to serve as spokespersons at the corporate or regional level will not. respond on behalf of the Corporation to any enquiry from or initiate communication with the media The. Regional Head of Communications Marketing has a duty to speak truthfully and openly to the best of his her. knowledge regarding the Corporation subject to the disclosure restrictions detailed in the aforementioned Public. Disclosure Policy and other internal policies ,wsp com page 14.
EMPLOYMENT POLICIES,GENERAL, The Corporation is committed to providing a work environment that is characterized by respect and dignity . Employees are expected to conduct themselves with honesty and integrity and to treat others with fairness . dignity and respect Each individual Employee is entitled to work in a businesslike environment that is free of. discriminatory practices and that promotes equal employment opportunities Relations between individuals in. the workplace are expected to be at all times professional in nature and free from any form of unlawful. discrimination or harassment , It is Corporation policy to comply with applicable employment and labour legislation as well as any other. legislation governing employer employee relations and the workplace and existing collective agreements No. Employee may interfere with or retaliate against another Employee who seeks to assert his her rights under. legislation governing labour or employee relations Any questions regarding labour and employee relations or. related Corporation policies should be directed to the regional Human Resources department . DEVELOPING PEOPLE, The Corporation s decisions about recruitment hiring compensation development and promotion are made. solely on the basis of a person s ability skills experience behaviour performance and potential for the job . The Corporation firmly believes that if it employs the best people and gives them an environment in which to. grow and develop it will achieve its business goals and retain its top talent Developing its Employees is the best. way to develop the organization as a whole As such the Corporation undertakes the following commitments . To employ people who will uphold high standards of ethical conduct . To provide Employees with a clear understanding of corporate goals objectives performance standards and. behaviour expected of them , To provide Employees with a fair evaluation of their performance . To create a working environment in which all Employees feel valued . To provide constructive comments and feedback to develop Employees skill sets and improve business. practices , To encourage and support all Employees so they can achieve their best potential .
To identify and satisfy training and development needs so Employees can perform and develop their skill. sets , To uphold a fair system of recognition reward and promotion across the Corporation . To never deny a promotion or opportunity on the basis of any form of discrimination . ALCOHOL DRUGS AND OTHER SUBSTANCES, The Corporation is committed to providing a drug free and alcohol free workplace The consumption of alcoholic. beverages by Employees while on duty or on Corporation premises is strictly prohibited Employees are. prohibited from reporting for work under the influence of alcohol an illegal drug or a controlled substance . Possessing using selling or offering illegal drugs and other controlled substances is prohibited in all.


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Dear Colleagues, Roche is recognised as a leader in creating, producing, and marketing innovative healthcare solutions of high quality for unmet medical needs.

Code of Conduct on the Safety and Security of Radioactive ...

Code of Conduct on the Safety and Security of Radioactive

FOREWORD This Code of Conduct on the Safety and Security of Radioactive Sources was approved by the Board of Governors of the International Atomic Energy Agency

REVI SED OCTOBER 2017 - Delta Sigma Theta

REVI SED OCTOBER 2017 Delta Sigma Theta

Members of Delta Sigma Theta Sorority Re garding Membership Intake Prohibitions (No Hazing Contract), and the Notice to Applicant/Candidate/Pyramid Regarding Privilege and Responsibilities. Revisions to this Code of Conduct, including the sanctions and fines to be assessed under this Code, shall be made by

NEC3 Term Service Contract (TSC3) Transnet Limited

NEC3 Term Service Contract TSC3 Transnet Limited

Transnet will not participate in corrupt pr actices. Therefore, it expects its suppliers to act in a similar manner. >> Transnet and its employees will follow the laws of this country and keep accurate business records that re?ect actual transactions with, and payments to, our suppliers. Suppliers Code of Conduct PREVIEW COPY ONLY

CODE OF CONDUCT

CODE OF CONDUCT

employee is obligated to act with the highest degree of integrity and in full compliance with the law. Our Code of Conduct helps us understand the ethical and legal guidelines that direct our business activities, and it is periodically updated to re main timely and relevant. It is not a substitute for good judgment, nor does it

PUBLIC SERVICE IN NIGERIA- AN OVERVIEW OF FUNCTIONS AND ...

PUBLIC SERVICE IN NIGERIA AN OVERVIEW OF FUNCTIONS AND

PUBLIC SERVICE IN NIGERIA- AN OVERVIEW OF FUNCTIONS AND CODE OF CONDUCT Junaidu Bello Marshall, Esq. Lecturer, Faculty of Law, Usmanu Danfodiyo University, Sokoto- Nigeria Aminu M. Murtala Esq. Lecturer, Faculty of Law, Usmanu Danfodiyo, Sokoto- Nigeria ABSTRACT: This paper examines the functions of public service and the code of conduct for public servants in Nigeria with a view to ...

Code of Student Conduct and Discipline

Code of Student Conduct and Discipline

Richmond County School System Acknowledgement of Receipt of the Code of Student Conduct and Discipline 2018-2019 School Year The undersigned parent or guardian and student acknowledge receipt of a copy of the Code of

CODE OF CONDUCT FOR TEACHERS - Toolkit on teacher codes of ...

CODE OF CONDUCT FOR TEACHERS Toolkit on teacher codes of

CODE OF CONDUCT FOR TEACHERS . PART 1: INTRODUCTION . 1. The education of the children of this country has been largely entrusted into the hands of the members of the Ghana Education Service. This places members of the Service, whatever their role, in a special position of responsibility, which requires exceptionally high

Code of Conduct - EICC, Electronic Industry Citizenship ...

Code of Conduct EICC Electronic Industry Citizenship

Electronic Industry Citizenship Coalition Code of Conduct v5.1 2 A. LABOR Participants are committed to uphold the human rights of workers, and to treat them with

VALIDATION DATE APPROVED SIGNATURE CODE OF CONDUCT

VALIDATION DATE APPROVED SIGNATURE CODE OF CONDUCT

CODE OF CONDUCT APPROVED SIGNATURE Signature on file PURPOSE Public service requires public trust built on the transparency of state government programs and the integrity of employees. This policy has been developed to provide guidance on proper business and ethical conduct for Oregon Department of Transportation (Department) employees. The Department expects employees to meet these ...

Code of Conduct and Ethics - TD Bank

Code of Conduct and Ethics TD Bank

D. Failure to Comply ... The Code of Conduct and Ethics (Code) establishes the standards that govern the ... Bank (TD Bank) together with its ...

Unlocking Infrastructure Delivery and Restoring the ...

Unlocking Infrastructure Delivery and Restoring the

Culture Charter and Code of Ethics Sustainability Framework How does Transnet integrate ethical conduct in infrastructure delivery Sustainable Development criteria of the Project Life Cycle Process Strategic projects in KZN: Applying an ethical balance to delivery of projects - example