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ACCoUNTABILITy


                 This Code is more than a set of prescriptive   they may be subject to action according to their
                 guidelines issued solely for the purpose of   employment terms and relevant company policies.
                 formal compliance. It represents our collective   When followed in letter and in spirit, this Code is
                 commitment to our value system and to our core   ‘lived’ by our employees as well as those who work
                 principles.                             with us. It represents our shared responsibility to all
                 Every person employed by us, directly or indirectly,   our stakeholders, and our mutual commitment to
                 should expect to be held accountable for his/her   each other.
                 behaviour. Should such behaviour violate this Code,






















                    SPeAK UP…
                    If you are unsure whether a particular action you are about to take is consistent with the principles
                    set forth in the Code, ask yourself:
                    •   Could it directly or indirectly endanger someone or cause them injury?
                    •   Is it illegal/unlawful or out of line with our policies and procedures?
                    •   Does my conscience reject it? Does it conflict with my personal values?
                    •     Would I feel uncomfortable if the story appeared in the media? Would it shame my company,
                        spouse, partner, parent or child?
                    •   Does it ‘feel’ wrong?
                    If the answer to any of these questions is “Yes”, please stop and consult your reporting manager,
                    the Ethics Counsellor, the Human Resource department, the Legal department or any member of
                    the senior management team, to assist you in making the decision.
                                   When faced with a dilemma: Stop, Think, Act Responsibly



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