Ethics & Compliance

Together, we are building a company where people want to work, grow and succeed – and that is something we can all be proud of.

Our Business Code of Conduct applies to everyone across the Groupe Dynamite Inc. (“GDI”) network, employees, executive officers, members of our Board of Directors, consultants, intermediaries, lobbyists and anyone working on our behalf.

The Business Code of Conduct contains rules and guidelines for personal conduct and ethical behavior at GDI. We have based it on our values, and the laws, regulations and rules, both local and national, that apply to our business.

GDI With Respect

Respect is at the heart of all that we do – how we interact with our customers, each other and the world around us. No matter where we are in the world and which logo we wear, this is part of what defines us, and what has helped us welcome so many people into the GDI family as we have grown over more than 40 years.

Whistleblower Policy

Adopted by our Board of Directors, the purpose of the Whistleblower Policy is to ensure that all directors, officers, employees and suppliers have the means to report complaints or concerns regarding material financial matters, compliance with legal and regulatory requirements and violations of the Corporation’s Business Code of Conduct and Company policies, while at the same time providing protection against retaliation for reports made in good faith. Reports can be filed anonymously through the Navex portal available by using the following link: https://secure.ethicspoint.com/domain/media/en/gui/96547/index.html.

The procedures set forth in this Policy set forth how and where to submit a complaint or concern, who deals with a complaint and how that complaint will be handled, processed and documented. This Policy also describes the standards and principles that will govern the processing of all complaints and concerns whether they are received from people within the Company or external parties.

GDI Hotline

Your voice matters in protecting and nurturing our culture of respect. It is important to speak up about unethical or inappropriate behavior that could harm our people or our business. Reports can be made anonymously by contacting our GDI Hotline using a local toll-free number or via the web. If you share your identity and contact information, this information will be kept confidential to the extent it is possible to do so, consistent with applicable federal and/or local law and the need to conduct a thorough investigation. The information you provide will be relayed to the proper GDI resource for follow-up.

Compliance

Our Human Resources and Corporate Governance Committees are responsible for monitoring compliance with our Business Code of Conduct. All management level and above employees undergo an annual certification process, and all new employees are required to read and sign the Business Code of Conduct as part of their onboarding process.

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