Compliance with law and business ethics

The Company’s policy is to conduct its affairs in compliance with all applicable laws and regulations, while observing the highest standards of business ethics. Integrity, honesty, forthrightness and fairness are of primary importance throughout the Company’s business and community relationships. Transcom expects each employee to deal fairly with the Company’s customers, suppliers and competitors, and to perform his or her duties in such a manner as to preserve the Company’s good name and reputation.

Equal opportunity employment

The Company maintains a strong policy of equal opportunity employment for all employees and applicants for employment. The Company hires, trains, promotes and compensates each employee based upon job-related factors such as the individual’s ability, work quality, attitude, competence and potential, as well as the Company’s operational needs, without regard for race, colour, religion, gender, sexual orientation, national origin, citizenship, age, marital status, or disability, as well as all other classifications protected by applicable laws. It is the Company’s policy to promote a fair and collegial working environment for all its employees.

Safe workplace

The Company requires each employee to perform his or her work in a safe manner so as not to cause harm to himself or to others. The Company similarly insists that work conducted under its leadership or supervision be performed safely. Work performed individually or under Company leadership must also comply with applicable environmental standards and regulations.

Competition

Employees of the Company must be aware that there are laws protecting and promoting proper competition, including laws protecting competitors’ proprietary and/or sensitive information. Company employees and consultants, especially any persons having direct contact with competitors, have a responsibility to know and obey these laws.

Bribes

No employee of the Company shall directly or indirectly offer, give, solicit, or accept any money, privilege, or special benefit, gift, or other item of value for the purpose of obtaining, retaining or directing business, or bestowing or receiving any kind of special or favoured treatment for the Company. The Company does not permit or condone the use of receipt of bribes, or any other illegal or improper payments or transfers in the transaction of its business. The use of any outside consultant, attorney, accountant, or agent in any manner for any purpose that would be contrary to this prohibition will not be permitted.

Political Contributions

No corporate funds or services shall be paid to any political party or any candidate for, or incumbent in, any public office except as permitted by law and as approved by the Board of Directors.