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        Compliance

        Health & Safety Policy

        Safety is Everyone's Responsibility

        Valiant TMS is committed to conducting its operations, managing its facilities, and manufacturing its products in a manner that responsibly protects human health and safety. This commitment extends to all Valiant TMS Team Members, and others in the workplace including customers, suppliers, third party service providers, placements and guests in all of our locations. Valiant TMS will strive to minimize the health and safety risks to all people and communities in which we operate through effective engineering, manufacturing, and management controls, training, and health and safety awareness programs.

        Valiant TMS shall continue to comply with applicable laws, regulations and standards governing workplace health and safety. Valiant TMS will comply with its internal health and safety standards that meet or exceed legislative or regulatory requirements.

        Valiant TMS is committed to continuous improvement with respect to health and safety performance. To that end, the Leadership at each facility, through planning and managing its facilities, operations, products, and services, established a commitment to ‘zero’ work-related injuries. Valiant TMS shall provide appropriate leadership support, training and tools to achieve and to improve upon this objective and requirement.

        Valiant TMS shall ensure all leaders/supervisors are competent in the area of their responsibility and ensure they lead by example by using safe workplace practices. They shall also ensure that the working areas they are responsible for are kept safe and clear of hazards, by regularly completing documented inspections.

        All of those who work for or on behalf of Valiant TMS have a responsibility to maintain a safe and healthy work environment. They shall adhere to, support and actively participate in the Valiant TMS health and safety program and initiatives so as to improve performance and minimize risk.

        A safe and healthy workplace is everyone’s responsibility. It is essential that each person understands the importance of a safe and healthy program that protects human health and safety, continuing to support the Internal Responsibility System within all Valiant TMS facilities and sites.

        Business Ethics Policy

        It has always been and continues to be the intent of Valiant TMS that its employees conduct themselves in accordance with the highest standards of integrity, honesty, respect, trust and fairness. As a company, we continually strive to operate within accepted and relevant laws of every local, national and international jurisdiction in which we conduct our business. Valiant TMS expects all its employees to contribute to a respectful, professional and ethical working environment through their actions on a day-to-day basis.

        Guidelines

        • Valiant TMS will ensure ethical and honest conduct through the regular monitoring of the adherence to all local and national laws, to the Valiant TMS Code of Business Ethics and to the guidelines established in the Code of Conduct and Basic Employee Responsibilities.
        • Valiant TMS will support prompt internal reporting of all violations to this Code.
        • Valiant TMS will support accountability for adherence to this Code.

        Violation of Valiant TMS Policies
        No employee should be misguided by any sense of loyalty to Valiant TMS or a desire for profitability that might cause him or her to disobey any applicable law or Company Policy. Employees of Valiant TMS are responsible for ensuring their conduct, as well as the conduct of any individual reporting to them, fully complies with the policies of Valiant TMS. Violation of our policies may result in discipline, up to and including discharge.

        Conflicts of Interest
        Valiant TMS employees shall not participate in any situation or business activity in which their personal or financial interests may conflict, or appear to conflict, with the goals and objectives of Valiant TMS.

        Confidentiality
        All employees are required to make a commitment to hold information used or obtained in the course of their duties in strict confidence. The responsibility of maintaining confidentiality lies with the individual entrusted with the information. Implicit in this trust is the expectation that the individual will not divulge information, or gain access to information, unless there is necessity based on job requirements. Confidential information includes, but is not limited to, employee information such as personal wage and employment information, employer information such as assets, liabilities, manufacturing processes and business transactions, as well as information pertaining to customers and suppliers.

        Privacy and Protection of Personal Information
        Valiant TMS respects the rights of our employees regarding their personal information. Valiant TMS will collect only the necessary information for the purposes of employment. Valiant TMS will not disclose or use this information without the consent of the employee or when legally required to do so.

        Bribery and Corruption
        Valiant TMS does not condone the use of bribes, kickbacks or other illegal payments in the execution of business activities and expects that no employee shall accept any personal gift, payment or favour, which may be believed to influence business transactions. Valiant TMS employees will not offer or accept any gifts, entertainment or anything else of significant value from a competitor, customer, supplier or anyone else who conducts or seeks to conduct business with Valiant TMS.

        Workplace Harassment Policy

        Valiant TMS is committed to providing a workplace free from harassment including but not limited to workplace sexual harassment.

        Valiant TMS policy, strictly prohibits harassment on the basis of sex, orientation, race, colour, national origin, age, religion, belief, height, weight, marital status, family status, economic status, handicap or other unlawful criteria as defined by statute and practice.

        Unlawful harassment includes unwelcome sexual advances, requests for sexual favours or other verbal or physical conduct relating to an individual’s sex, orientation, race, colour, national origin, age, religion, belief, height, weight, marital status, family status, economic status, handicap or other unlawful criteria as defined by statute and practice.

        Valiant TMS shall take all reasonable steps to prevent harassment from occurring and shall initiate an immediate investigation and in the most confidential manner possible and undertake the appropriate remedial action.

        Racial, ethnic and other forms of prohibited harassment includes, but is not limited to:

        • visual conduct, including displaying of derogatory objects or pictures, cartoons, or posters; and
        • verbal conduct, including making or using derogatory comments, epithets, slurs and jokes.

        Sexual harassment includes, but is not limited to:

        • unwanted sexual advances;
        • offering employment benefits in exchange for sexual favours;
        • making or threatening reprisals after a negative response to sexual advances;
        • visual conduct, including leering, making sexual gestures, displaying of sexually suggestive objects or pictures, cartoons, or posters;
        • verbal conduct, including making or using derogatory comments,
        • epithets, slurs, and jokes;
        • verbal sexual advances or propositions;
        • verbal abuse of a sexual nature, graphic verbal commentaries about an individual’s body, sexually degrading words used to describe an individual, suggestive or obscene letters, notes, or invitations; and
        • physical contact, including touching, assault, impeding or blocking movements.

        All Team Members will refrain from nicknames or terms of endearment with a racial or sexual orientation.

        Any Team Member who believes that he or she has suffered workplace harassment in any form, or has witnessed the same, shall report the incident(s) to his or her manager, a Human Resources representative or any member of the Leadership. If the Harasser is the supervisor, the Team Member is to go to HR to report the issue. The HR department and Leadership shall investigate and deal with all concerns, incidents and complaints of workplace harassment in a fair, timely and confidential manner respecting the privacy of all concerned, providing final details of the investigation only to those as required by law. Information to be obtained about any individual, will not be disclosed unless the disclosure is necessary for the purpose of investigating or taking corrective action with respect to the incident or complaint. The Team Member who has alleged the workplace harassment must also be informed in writing the outcome of the investigation.

        Further, Valiant TMS assures all Team Members who report harassment occurrences that they shall be protected from any further acts of harassment, coercion or intimidation and any other form of retaliation due to their reporting an incident or participating in an investigation or proceeding concerning the alleged harassment.

        Team Members who violate this policy shall be subject to a disciplinary action, up to and including termination of employment.

        A workplace free from any form of workplace harassment, including workplace sexual harassment, is everyone’s responsibility. It is therefore essential that each person understands the importance and benefits of a harassment free workplace.

        Quality Policy

        Valiant TMS is committed to enhancing customer experience by involving all stakeholders in the process of continuously improving effectiveness of the Quality Management System, and further strengthening our global leadership in the industry through Excellence in Quality.

        Social Responsibility Policy

        Social responsibility is a bedrock of our culture. We recognize that we have a responsibility to our employees, suppliers, customers, community and our environment. Our philosophy is based on the tradition of giving and sharing — two things that are primary to the quality of life.

        Valiant TMS will actively support and participate in charitable and volunteer activities that promote social, economic and educational development throughout the communities in which we operate.

        Valiant TMS encourages its employees to be involved in volunteer activities that improve or help our communities.

        Business Ethics
        It has always been and continues to be the intent of Valiant TMS that its employees conduct themselves in accordance with the highest standards of integrity, honesty, respect, trust and fairness. As a company, we continually strive to operate within accepted and relevant laws of every local, national and international jurisdiction in which we conduct our business.

        Valiant TMS expects all its employees to contribute to a respectful, professional and ethical working environment through their actions on a day-to-day basis.

        Health & Safety
        Valiant TMS is totally committed to the health and safety of all employees and other parties working for or visiting any of our facilities. We make a continuing effort to provide a safe and healthy work environment and to prevent accidents, injuries, occupational diseases and other potential hazards inherent in the working environment.

        Human Rights & Basic Working Conditions
        Valiant TMS follows all human rights laws within the jurisdictions in which we operate and in doing so, we support the principle that all people are treated in a fair and equal manner.

        Harassment & Discrimination
        Valiant TMS is committed to maintaining a positive working environment, free from any form of harassment and/or discrimination for all its employees, customers and suppliers. No employee, customer or supplier should be subjected to any type of unwelcome verbally or physically offensive conduct. We maintain a zero tolerance policy in this regard.

        Valiant TMS prohibits discrimination of any employee or candidate for employment on any grounds, including race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, age, record of offences, marital status, same-sex partnership status, family status or disability.

        Valiant TMS will not permit retaliation against anyone who brings forward a complaint of harassment or discrimination and will take appropriate action against anyone who does.

        Equal Opportunity & Pay Equity
        Valiant TMS strives to offer the equality of opportunity to all current and future employees and to refrain from discrimination on all grounds when making employment decisions. Valiant TMS respects the principle of “equal pay for work of equal value.”

        Youth Workers
        Valiant TMS promotes the safety and protection of our children and in doing so, does not employ children, except as part of a government approved youth training or apprenticeship program.

        Forced Labour
        Valiant TMS does not utilize practices involving the use of forced labour and we will not knowingly do business with companies that do. Valiant TMS requires that all employees entering into employment with the company or our suppliers do so at their own free will.

        Hours of Work
        Valiant TMS operates in compliance with the applicable laws, provisions and agreements with industry standards regarding working hours and the treatment of overtime.

        Compensation
        In order to promote the well being of our employees and their families, Valiant TMS will ensure that wages and benefits paid will be competitive.

        Training & Education
        Valiant TMS strongly supports all types of training and career development programs to improve and enhance the performance and skills of our employees. Our employees are encouraged to grow and develop professionally.

        Minority Sourcing
        The Valiant TMS Group of Companies fully embraces the strategic imperative to identify, develop and grow long term minority suppliers as an integral part of its supply base.

        Conflict Materials
        Valiant TMS promotes socially responsible and ethical sourcing by making reasonable efforts to identify and trace the source of any Conflict Minerals contained in Valiant TMS products. Valiant TMS strives to avoid knowingly using Conflict Materials or products containing Conflict Materials from sources in identified conflict regions, such as the Democratic Region of the Congo and surrounding countries that fund or support inhumane treatment, including human trafficking, slavery, forced labor, child labor, torture and war crimes and to facilitate compliance with applicable regulations that mandate the disclosure of Conflict Mineral sources contained in Valiant TMS products.

        Environmental Policy

        Valiant TMS Leadership and Team Members are fully committed to protecting the environment and continually striving to improve its operations, products, and services to minimize impacts on the environment.

        To conserve the environment we shall:

        • Continuously improve our environmental performance by encouraging technical innovations and environmental initiatives
        • Prevent pollution to the environment from our operations, products and services
        • Comply with all relevant environmental legislation, regulations, customer and other requirements
        • Set, implement and maintain environmental objectives and targets through leadership review that meets or exceeds all legal requirements and focuses on environmental impacts that are important to Valiant TMS and its stakeholders, such as energy usage, air emissions, waste, and water usage
        • Ensure that Team Members know, understand and adhere to policies, procedures and work? instructions related to the environment

        Accessibility for Ontarians with Disabilities Act (AODA) Policy

        Valiant TMS is committed to providing quality services accessible to all and to communicating with all persons with disabilities taking into account their disabilities.

        Valiant TMS, in so doing, respects and supports the principle that every person has the right to equitable treatment with respect to employment, services, goods and facility access and accommodation provided in a manner allowing for:

        • Independence – allowing people with disabilities to do things on their own without unnecessary help or interference from others;
        • Dignity – providing services in a way that allows people with disabilities to maintain self-respect and the respect of others;
        • Integration – allowing people with disabilities to benefit from the same services, in the same place, and in the same or similar ways as others; and
        • Equality of opportunity – offering people with disabilities an equal opportunity to benefit from Valiant TMS services and benefits, as applicable.

        We are committed to developing customer service policies that respect and promote the dignity and independence of people with disabilities. Therefore, the Company will consider the impact on people with disabilities prior to making any changes to this policy and shall modify or remove any Valiant TMS policy, procedure, work instruction or practice that does not respect and promote the dignity and independence of people with disabilities.

        Questions about This Policy
        This policy exists to achieve service excellence to people with disabilities. A representative from the Human Resources Team shall provide an explanation to any person not understanding this policy or having a question about the policy.

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