Truman Employee Code of Business Conduct And Ethics

1) Introduction
2) Compliance with the Law is Required
3) Accountability for Adherence to this Code
4) Conflicts of Interest
5) A Safe and Healthy Work Environment Must Be Maintained
6) Reporting Procedures & Compliance with this Code
7) Corporate Opportunities Belong to the Company
8) Non Disclosure & Confidentiality Must Be Maintained
9) Competitors and Others Must Be Dealt with Fairly
10) Company Assets and Property Must Be Protected and Used Properly
11) Discrimination and Harassment Are Not Permitted

Introduction

Truman is committed to maintaining high standards for honest and ethical conduct in all of its business dealings. This Code of Business Conduct and Ethics (referred to as this “Code”) covers a wide range of business practices and procedures. It does not cover every issue that may arise, but rather is intended to set out basic principles with which we expect you to comply as an employee of our company. This Code applies to all of the employees, officers and directors of Truman, or any of our subsidiaries, which is referred to collectively in this Code as the “Company.” Each of employee is expected to conduct yourself in accordance with the policies set forth in this Code and seek to avoid even the appearance of improper behaviour. Our human resources and ownership are also expected to adhere to and promote our “open door” policy. This also means that they are available to any of you who may have ethical concerns, questions or complaints.

Truman Code has been adopted for use company wide effective: February 1st 2000. File Updated: Nov 1st 2008.

Compliance with the Law is Required

Obeying the law, both in letter and in spirit, is the foundation on which this Company’s ethical standards are built. You should respect and obey the laws, rules and regulations of Canada, provinces, cities, and other jurisdictions in which we operate. Although not all of you are expected to know the details of these laws, it is important that you know enough to determine when to seek advice from your supervisors, managers or others. The Company’s general counsel is available to all employees who have any questions about the details of laws and regulations applicable to them. If a law conflicts with a policy in this Code, the law takes precedence over this Code; however, if a local custom or policy conflicts with this Code, this Code takes precedence over it.

Accountability for Adherence to this Code

As a condition of your employment with the Company, you accept the responsibility of complying with the policies set forth in this Code. If you violate any of these policies, you will be subject to disciplinary action, including suspension or termination of employment for cause, or other legal action if appropriate under the circumstances. This Code does create a contract of employment between you and the Company, but does not guarantee that your employment with the Company will continue as long as you comply with its policies. Acknowledgement, acceptance and understanding of this contract by you is wholly agreed by you way of receiving and accepting payment for the Company.

Conflicts of Interest

A “conflict of interest” occurs when your individual private interests interfere or conflict with the interests of the Company or even when they only appear to interfere or conflict. If you have a conflict of interest it may be difficult for you to perform or work objectively and effectively, or to exercise sound business judgment on behalf of the Company. Conflicts of interest should be avoided.

It may not always be clear whether a situation presents a conflict of interest or potential conflict of interest. For example, a conflict of interest can arise involving your family members or even your close friends. Examples of some potential conflicts of interest are:

Obtaining a loan, guarantee of obligations or other similar financial accommodation from the Company or from a third party, such as a competitor, customer or supplier.
Receipt of an improper personal benefit as a result of your position with the Company, whether that benefit is received from the Company or a third party, such as a competitor, customer or supplier
Serving as an officer, employee or consultant, or otherwise having a material financial interest in a competitor, customer or supplier of the Company.
If a situation arises which you believe could involve a conflict of interest, or even the appearance of a conflict of interest, on your part, you should report the matter to your supervisor or department manager. If you are an executive officer of the Company, any actual or potential conflict of interest must be reported to Truman ownership immediately.

A Safe and Healthy Work Environment must be maintained

The Company strives to provide each employee with a safe and healthful work environment. We have developed an extensive Safety program that must be adhered too. You must assist in maintaining a safe and healthy workplace for all employees by following safety and health rules and practices and reporting accidents, injuries and unsafe equipment, practices or conditions. Misconduct, Violence and threatening behaviour are never permitted. All employees should report to work in condition to perform their duties, free from the influence of alcohol or illegal drugs and in professional attire. The use of illegal drugs in the workplace will not be tolerated.

Reporting Procedures & Compliance with this Code

You are urged to promptly report illegal, unethical or improper behavior, including financial misconduct and other violations of this Code or laws. If you wish, your concerns or complaints will be kept confidential and your identity will be kept anonymous, though we may be required by law to reveal this information in some circumstances. We will not allow retaliation against you if you report misconduct by others in good faith.

The following are some guidelines you may follow in reporting violations of this Code or other misconduct, or if you are unsure about how to handle a situation:

You are encouraged as a first step to speak openly and freely to your supervisor, human resources or the owner directly. If for any reason you are not comfortable approaching any of the above and you are not satisfied that your complaint has been handled fairly or appropriately, then you can contact the following:

General Counsel, Dunkley Law Office – Michael Dunkley or Khalil Haji (khalil@khlawgroup.com) 2. Brenda Thibault (403) 240-3246 or (brenda.thibault@trumanhomes.com)

Corporate Opportunities belong to The Company

Employees, officers and directors have a duty to advance the Company’s legitimate interests when the opportunity to do so arises. You are prohibited from taking for yourself personally opportunities that properly belong to the Company or which you discover through the use of corporate property, information or position. You are also prohibited from using corporate property, information or position for personal gain or competing with the Company.

Safeguarding Personal Information

Truman is committed to protecting the security of your personal information. We endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Access to Your Personal Information

You may ask to see the personal information we have about you. A request to review your personal information must be made in writing to Truman’s Privacy Officer. Truman will endeavour to provide the information requested within a reasonable time from the date of the written request, or within the time otherwise required by law.

If you make a request to review your personal information, we may request specific information from you to enable us to confirm your identity and right to access such information. We may also require information that would assist us in locating your personal information. We may charge a fee to access your personal information; if so, we will notify you of that fee at the time you make your request or within a short time thereafter.

Truman reserves the right to decline to provide access to personal information in certain circumstances. These include, but are not limited to, circumstances where the information requested:

Would disclose personal information, including opinions, about another individual
Would disclose Truman’s trade secrets or other confidential business information
Is subject to lawyer-client privilege
Is not readily retrievable and the burden or cost of providing it would be disproportionate to the value of the information
Does not exist or cannot be found
Could result in serious harm to the individual requesting it, serious harm to the life, safety or health of another person, or serious emotional harm or embarrassment to another individual
May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions
May be or is required to be withheld by other legislation

Where information requested will not or cannot be disclosed, Truman will provide the reasons for non-disclosure.

Non Disclosure & Confidentiality Must Be Maintained

You must maintain the confidentiality of confidential information entrusted to you by the Company or our suppliers, customers and others with whom we conduct business. Furthermore, you may not use any such information for your own (or any third party’s) profit or advantage. You may disclose confidential information when disclosure is authorized by the Truman ownership or required by laws, regulations. Confidential information generally includes any and all non-public information; that might be useful to competitors or others, or harmful in any way to the owner or Truman if such information were ever disclosed. Your obligation to preserve confidential information continues even after your employment ends. You should consult the Truman general counsel if you believe you may have a legal obligation to disclose confidential information.

Competitors and Others must be dealt with fairly

We seek to outperform our competition fairly and honestly. We seek competitive advantages through superior performance, never through unethical or illegal business practices. We do not permit or condone improper taking or use of proprietary information of others, possessing trade secret information that was obtained without the owner’s consent, or inducing such disclosures by past or present employees of other companies. You should endeavour to deal fairly with our customers, suppliers, competitors and employees and not attempt to take unfair advantage of anyone through manipulation, concealment, abuse of privileged or confidential information, misrepresentation or any other intentional unfair-dealing practice.

Company Assets and Property must be protected and used properly

You should endeavour to protect the assets and property of the Company and ensure their efficient use. Theft, carelessness and waste have a direct impact on profitability. You should immediately report any suspected incident of fraud or theft affecting the Company. You should not use Company assets for non-Company business, though incidental personal use is permitted. You may never use Company funds or property in furtherance of any unlawful purpose.

Your obligation to protect the assets and property of the Company includes our proprietary information, including intellectual property, such as trade secrets, patents, trademarks and copyrights, and business, marketing and strategic plans, designs, databases, records, salary information and any unpublished financial data and reports. You may not use or distribute this information without proper authorization.

Discrimination and Harassment are not permitted

The Company does not tolerate any form of discrimination or sexual harassment in the workplace. The Company is an equal opportunity employer. It is our policy to provide equal opportunities for all applicants and employees and to recruit, hire, transfer, promote, train and administer all personnel policies without regard to race, color, religion, national origin, gender, age, marital status, disability or veteran status.

If you feel that you are being subjected to discriminatory treatment or sexual harassment you should immediately consult the procedures described in the section labeled “Reporting Procedures; Compliance with this Code.” The Company will not take or permit retaliatory actions against an employee who, in good faith, reports or provides information about misconduct.

Should you require a hard copy of this file visit human resources or reference the employment care package received upon the start of employment.