P3 — Ethical Behaviour and Code of Conduct Procedures

1. Purpose

1.1

These Procedures are intended to provide guidance to employees about the implementation of Policy P3 – Ethical Behaviour and Code of Conduct.

2. Definitions

2.1

The words used in these Procedures shall have the same meaning as set out in Policy P3 – Ethical Behaviour and Code of Conduct.

3. Guiding Questions

3.1

Employees need to make a sincere and honest evaluation before acting in the course of their employment. The following questions assist employees who are evaluating an ethical position:

1. Is this action legal?
2. Does this action reflect RRC Polytech’s values as set out in this Policy, the Conflict of Interest Policy and the Strategic Plan?
3. Is this the right thing to do?
4. Is this the appropriate thing to do considering all of the circumstances?
5. Would it appear to a reasonable observer that it is the right thing to do?
6. Would I want others to know about my actions in this matter?
7. What would the public response be if this action attracted media attention?
8. Did I talk to the right people before acting?
9. Is this consistent with standards of conduct, or code of ethics of my professional designation?

4. Dealing with Vendors and Stakeholders

4.1

RRC Polytech is a valuable customer for many suppliers of goods, services and facilities. People who want to do business, or to continue to do business, with RRC Polytech must understand that all purchases by RRC Polytech will be made exclusively in accordance with our Procurement policies, practices and needs.

4.2

Illicit payments and Rebates: Purchases of goods and services by RRC Polytech must not lead to employees, or their families, receiving any type of personal payment provided as compensation for preferential treatment or any other type of improper services received. Such compensation may be referred to as a kickback, bribe, rebate, or other term and may be money, a gift, credit, or anything of value. Receiving such an illicit payment is a corrupt practice that interferes with an employee’s ability to make unbiased decisions. Employees, or their families, must not accept any form of “under-the-table” payment.

5. Receipt of Gifts and Entertainment

5.1

Gifts and entertainment can be misunderstood. They can appear to be attempts to wrongfully influence employees into directing RRC’s business to a particular vendor or to favour a particular stakeholder. To avoid both the reality and the appearance of improper relations with suppliers or potential suppliers, RRC Polytech employees will comply with Policy P1-Conflict of Interest and the specific guidance provided in P1 Procedures related to the receipt of gifts and entertainment.

6. Reporting Ethical Violations

6.1

Employees must immediately report any violations of this Code. Failure to do so can have serious consequences for the employees, and RRC Polytech. RRC Polytech has a Public Interest Disclosure Policy, Policy P2, that describes the mechanism to disclose wrongdoing. If an Ethical violation does not fall within scope of Policy P2, ethical violations should be reported and reviewed as follows:

1. Reports of violations should be made by employees to their immediate supervisor.
2. After a violation is investigated, appropriate action will be taken. Management has the right to determine the appropriate disciplinary action for a violation of the Policy up to and including termination of employment.
3. Employees should be aware that in addition to any disciplinary action taken by RRC Polytech, violations of the Ethical Behaviour and Code of Conduct Policy, and associated Procedures may require restitution and may lead to civil or criminal action against individual employees.
4. Supervisors have the responsibility of taking remedial steps to correct any operating procedures that may contribute to violations of this Code.
5. Retaliation in any form against an individual who reports a violation of this Code in good faith or who assists in the investigation of a good faith reported violation, is itself a serious violation of this policy. Acts of retaliation should be reported immediately to their supervisor and the Director of Human Resources Services. RRC Polytech reserves the right to consider consequences, up to and including dismissal, for reports made in bad faith of violation of this Code.