We work with honesty and integrity. We stand behind our word. We treat each other and our neighbours with respect. We openly report on our performance.

• We investigate all ethical complaints thoroughly and promptly.
• We will not allow or pursue retaliation of any kind against an employee who reports a violation or ethical concern.
• Every employee is required to certify upon hiring and biennially after that he or she has received, read, understands, and will comply with our Ethics Policy.
• All employees received web-based training on the Ethics Policy in late 2013.
• All new employees are required to sign the policy.
• Managers are accountable for ensuring their employees are aware of, understand, and adhere to our Ethics policy.
• We conduct an annual fraud risk assessment across the entire organization. It considers all areas of the business and includes potential fraud scenarios. If gaps are identified in control structures, remedial action plans are developed.

Employees are encouraged to raise potential violations of our ethics policies, laws or regulations.

To report a concern, employees can:

• Speak with their manager or any member of senior management.
• Anonymously report a concern by contacting the company’s Integrity Hotline, which operates 24 hours, seven days a week and is staffed by an independent third party under strict confidentiality obligations.

We ACT on our word

In 2013, we reviewed nine complaints on topics such as conflicts of interest, respectful workplace and inappropriate behavior, and seven complaints pertaining to vandalism, fraud, and misuse of company resources. These investigations and actions resulted in:

• coaching provided to employees
• three permanent- and five temporary-employee terminations