Stormtech Canada Associate Handbook

• Business is dynamic and as circumstances change, existing disclosures may no longer be accurate or complete. When this happens, associates must freshly disclose any new or emerging forms of conflict of interest. Disclosure provides transparency to actual, potential, or perceived conflict of interest risks to Stormtech. It is a necessary part of mitigating these risks, but disclosure alone is not sufficient. This policy also requires addressing a conflict of interest. Addressing a conflict of interest is the responsibility of the Manager. Stormtech expects the Manager to: • Disclose, manage, and treat the information disclosed by the associate with appropriate confidentiality and without bias. • Report the conflict of interest to People & Culture and the respective Department leader, to seek guidance and determine a resolution. • Fairly evaluate the conflict-of-interest situation disclosed by the associate, including the risks to the business interests and reputation of Stormtech, in conjunction with People & Culture and the Department Leader. • Make a pragmatic decision to address the conflict of interest so that risks to Stormtech are minimized and the interests of the associate and the Company are protected as far as possible. • Communicate the decision and its reasoning to the associate and follow up to ensure the associate understands and complies. Many conflicts of interest situations can be addressed in a simple and mutually acceptable manner; pro-active, open dialogue between Managers and associates is essential to supporting this outcome. 5. RESPONSIBILITIES Managers are responsible for • Adhering to this Policy within his or her area of responsibility, to lead by example, and to provide guidance to those associates reporting to him or her. Associates are responsible for • Disclosing when they have, potentially have, or could be perceived as having, a conflict of interest. • Consulting their manager or People & Culture if in doubt about what circumstances might create a conflict of interest. People & Culture is responsible for • Supporting the resolution of conflict of interests within the organization and ensuring conflicts of interest are disclosed by new hires during the hiring process.

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