Stormtech Canada Associate Handbook

ANTI-BRIBERY AND CORRUPTION POLICY

1. PURPOSE The purpose of this Anti-Bribery and Corruption Policy is to establish clear guidelines for all employees, partners, and stakeholders of Stormtech Performance Apparel to ensure compliance with anti-bribery and anti-corruption laws, and to promote a culture of integrity and ethical business conduct. 2. SCOPE This policy applies to all employees, directors, officers, agents, contractors, and any third parties working on behalf of Stormtech Performance Apparel. 3. POLICY Stormtech Performance Apparel strictly prohibits all forms of bribery and corruption. Employees and associated persons must not offer, give, solicit, or accept any form of bribe, whether directly or indirectly, to or from any person or organization, including government officials, clients, or suppliers. Definitions • Bribery: The offering, giving, receiving, or soliciting of anything of value as a means to influence the actions of an individual or organization. • Corruption: The abuse of entrusted power for private gain. Employees must not offer, give, or accept bribes, whether monetary or otherwise, including gifts, hospitality, or other incentives that could improperly influence business decisions. Facilitation payments, which are unofficial payments made to expedite or secure the performance of routine government actions, are also prohibited. Stormtech Performance Apparel recognizes that certain business-related activities, such as client dinners, providing product samples, or hosting events, are standard practices aimed at building relationships and promoting our products. These activities are permissible, provided they are reasonable, proportionate, and conducted transparently. They must comply with local laws and regulations and should not be construed as attempts to improperly influence business decisions. All employees are responsible for understanding and adhering to this policy. They must avoid any activities that could lead to or imply a breach of this policy. Managers and supervisors are responsible for ensuring that employees understand and comply with this policy. They must also report any suspected violations. Employees are encouraged to report any concerns or suspicions regarding bribery or corruption to their manager, the People & Culture department, or through the anonymous reporting channels provided by Stormtech Performance Apparel. All reports will be treated confidentially and investigated thoroughly. Violations of this policy may result in disciplinary action, up to and including termination of employment. Additionally, individuals found to be engaging in bribery or corruption may face legal consequences, including fines and imprisonment. This policy is essential for maintaining the trust and integrity of Stormtech Performance Apparel’s business practices. All employees must conduct themselves in a manner that upholds these principles.

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