*Under review by current board.*

Director and Employee Code of Conduct

Introduction

Within Heiltsuk Economic Development Corporation (HEDC) and all of its operating subsidiaries, we believe in upholding the highest standards of legal and ethical conduct in the operations of our business. This means that as Directors and Employees we will conduct ourselves in a manner consistent with our core values of honesty, transparency, efficiency, integrity, fairness, respect, and responsibility. We share these values with our owners, the Heiltsuk People. We will also comply with all legislation applying to our business.

The purpose of the Director and Employee Code of Conduct is to ensure that all HEDC Directors and Employees understand their specific legal and ethical responsibilities, to provide help in recognizing and dealing with those responsibilities, and to explain how to report inappropriate conduct related to those responsibilities.

In support of our commitment to uphold our core values and corporate expectations, we ask all Directors and Employees to read and to comply with our Code of Conduct.

1.0 Complying with Legislation

HEDC’s Directors and Employees will comply with the letter and the spirit of the law. Our business is subject to a significant number of types of regulation, and the following areas are especially important to individual Directors and Employees:

  • Health and Safety – Workplace safety is the uncompromised right and responsibility of all Directors and Employees. Compliance with all safety legislation and safe operating procedures is mandatory.
  • Environment – Environmental protection is a fundamental HEDC value; every Director and Employee has a role in ensuring HEDC’s operations comply with environmental legislation and regulatory standards.
  • Human Rights – Every person has the right to equal treatment without discrimination with respect to employment. As part of our hiring practices, we will give preference to Haida people who are equally qualified for job openings.
  • Competition – HEDC and its Directors and Employees must make their own decisions on the basis of the Company’s best interests and must do so independent of competitors.

2.0 Avoidance of Conflict of Interest

Generally, a conflict of interest exists when a Director’s or Employee’s personal conduct, interests, or financial dealings may influence their judgment in the performance of their HEDC duties, and in some instances, continues after the employment relationship has ended.

All Directors and Employees have an obligation to be free of conflicting interests when they represent HEDC in business dealings or when they are making recommendations that could affect HEDC decisions. Directors or Employees who find themselves in an actual or apparent conflict of interest must disclose the conflict and abstain from voting or taking other actions that impact the outcome of the activity or business transaction. Full disclosure enables Directors and Employees to resolve unclear situations and gives an opportunity to dispose of or appropriately address conflicting interests before any difficulty can arise. More generally, such Directors and Employees should excuse themselves from discussions and communication with management and staff where the issues could raise an actual or apparent conflict.

Directors and Employees must never engage in conduct which is harmful to HEDC or its reputation.

Examples of conflicts of interest include, but are not limited only to the following:

  • Financial Interests – A conflict exists when a Director or Employee who is able to influence business with HEDC owns (or a member of their immediate family owns), an interest in a competitor of HEDC, or any enterprise which has current or prospective business with the Company as a supplier or contractor.
  • Third Parties – A conflict exists when a Director or Employee has a role with a competitor of HEDC or with a supplier to the Company. A conflict also exists when a Director or Employee performs work or services for another business or organization to such an extent that they do not devote the necessary time and effort to their HEDC responsibilities.
  • Relationships with Customers or Suppliers – A conflict arises when a Director or Employee accepts any gift or favour of greater than nominal value from any person or organization who is a competitor of HEDC or who does business with HEDC as a supplier or contractor.
  • Relationship with a new Employer – a conflict may also occur after employment ceases if a former employee shares confidential HEDC information with their new employers, or in any way entices customers or employees away from HEDC or its businesses.

3.0 Customer First Approach

HEDC has a customer first approach in its businesses many of which are consumer oriented such as tourism and retail products. Our customers ultimately provide the income to maintain and expand HEDC.

Customer service is a series of activities designed to enhance the level of customer satisfaction – that is, the feeling that our products or services have met the customer expectations. Employees are expected to strive for a high degree of customer service and act in a professional manner with all customers at all times.

4.0 Confidentiality and Protection of Personal Information

A Director or Employee must at all times maintain the confidentiality of all confidential information and all records of HEDC and must not make use of or reveal such information or records except in the course of performance of their duties or unless the documents or information become a matter of general public knowledge.

Similarly, Directors or Employees may not use confidential information obtained through their association or employment with HEDC to further their private interests or the private interests of their friends or relatives or future employers who are competitors of HEDC or its subsidiaries.

A Director or Employee is responsible for the security of information and materials entrusted to them.

5.0 Fair Dealings

Every Director and Employee will deal fairly with HEDC’s directors, employees, customers, suppliers, and contractors. HEDC is committed to encouraging a work environment in which everyone is treated with respect and dignity. All Directors and Employees are to conduct themselves in a businesslike manner that promotes equal opportunity and prohibits discrimination or harassment of any kind.

6.0 Outside Employment

HEDC Employees may hold outside jobs or engage in modest self-employment activities on their own time, using their own resources, and in a manner not adversely affecting their performance or objectivity for HEDC.

However, no HEDC Employee may accept work with a competitor, or with any entity that could lead to a conflict of interest or situation prejudicial to HEDC’s interests.

7.0 Misuse of Alcohol and Drugs

Employees must not enter the workplace under the influence of alcohol or illegal drugs, or prescription drugs that impair safety and performance. Any person who does so will be immediately removed from the workplace and put under suspension while disciplinary action is determined. Alcohol and illegal drug use on the job is strictly prohibited.

8.0 Integrity of Records and Sound Accounting Practices

HEDC takes very seriously the accuracy of its financial records and statements. Accuracy and reliability in the preparation of business records is critically important to our decision making and to the proper discharge of financial, legal, and reporting obligations. All business records, expense accounts, invoices, bills, payroll, and employee records are to be prepared with care and honesty. False or misleading entries are not permitted.

9.0 Expense Accounts

Many Employees use expense accounts, commonly referred to as travel and entertainment expenses. Such expenses must be documented and recorded accurately. If you are not sure if a potential expense is allowable, ask your supervisor who must also review and approve your expense claims. If employees attend a group function, the most senior HEDC person present pays the charge and files an expense claim listing those present.

10.0 Use of HEDC Resources

Directors and Employees are required to safeguard all HEDC resources and to use them for legitimate business purposes. Safeguarding includes protection against unauthorized or inappropriate use, access, or destruction—as well as protection from theft.

Reasonable incidental use of HEDC’s telephones, computers, electronic mail systems, or Internet is allowed.

Some additional points:

  • Copyright ­- Anything you develop, create, or author in your capacity as a HEDC Director or Employee becomes the sole and exclusive property of HEDC.
  • Right to Search – HEDC reserves the right to search its property to protect that property, information, or other assets and to maintain a safe work environment. This means that the Company may review and monitor electronic communications, telephone records, and the contents of computers, file cabinets, desks, lockers, and offices.
  • Use of Technology – Technology is provided to enable us to do our jobs. Directors and Employees are responsible for the efficient use of HEDC’s technology and are required to avoid situations that may drain the productivity of these resources or result in increased costs. This would include unreasonable use of social media or technology for games etc. during working hours.

11.0 Reporting

If you see something that may be a violation of the Code of Conduct contact your supervisor or a member of senior management. This can be done without fear of action being taken against you when a report is made in good faith.

Reports will be investigated promptly, confidentially, and impartially.

12.0 Impact of Non-Conformance to Code of Conduct

Any breach of the Director and Employee Code will be dealt with fairly after an impartial investigation. Appropriate action, which could include removal from office or termination of employment or services, will be taken with any Director, Employee or anyone we do business with if the person’s action is found to violate the Code. In the event a former employee discloses confidential information, or is found to be enticing HEDC customers or employees to their new place of employment, action will be taken up to and including legal action.