CEERS

Claims Expedition and Enhanced Recovery Specialists

Code of Conduct

MANDATORY CODE OF BUSINESS CONDUCT AND ETHICS

CEERS ASSOCIATION

TO ALL DIRECTORS, OFFICERS, EMPLOYEES, MEMBERS, AGENTS AND CONTRACTORS OF CEERS:

1.0 OVERVIEW


As a socially responsible Society, CEERS (Claims Expedition and Enhanced Recovery Specialists) (herein ‘CEERS’) is committed to maintaining the highest possible standards in respect of Societal and personal integrity. To be involved with CEERS is to conduct one’s self in the highest ethical standards and to contribute positively to the communities in which we live.
It is the policy of CEERS to conduct its affairs in accordance with all applicable laws and regulations and to conduct all activities with the highest ethical standards. This Code of Business Conduct and Ethics (the “Code”) applies to the Society’s Directors, Officers, Employees, Members, agents, and contractors (collectively herein ‘All’).

This Code establishes the minimum moral and ethical standards and expectations for conduct required by all. You must not engage in any on-duty conduct that would impair your job performance, cause damage to CEERS or public property, jeopardize your safety or the safety of others, or negatively affect CEERS’s reputation or image. If you are wearing clothing with a CEERS logo, be mindful that the public sees you as representing CEERS and your conduct affects the Society’s reputation and image. If you have supervisory or lead responsibilities, you have additional responsibility to take these actions:

  • Educate your charges on this Code and the requirements applicable to their work activities
  • Promote compliance with this Code and other relevant policies, standards, and procedures.
  • Report suspicions or allegations of misconduct in accordance with Society procedures.

This Code of Conduct is not intended to supersede any other applicable legal or regulatory requirements or any other federal, provincial, or local governmental entity.

In the event that any employee or contractor is uncertain of any behavior relative to the Society’s Code or any other ethical standard, they are responsible for discussing potential situations with senior
management of CEERS to determine the appropriateness of an action beforehand.

Violations of this Code are not permitted and will be dealt with accordingly. Wilful disregard of criminal statutes underlying this Code may require the Society to refer such violation for possible criminal
prosecution.

CEERS is committed to complying with all applicable laws that protect against unlawful discrimination. See section 2.0.

All are required to promptly report to CEERS’s senior management any observed or perceived violations of this Code.

The Code will be reviewed and approved annually by CEERS’s Board.

2.0 WORK ENVIRONMENT


2.1 Discrimination and Harassment Free Environment
CEERS will not tolerate workplace discrimination, bullying and/or harassment. All must ensure that CEERS has a safe and respectful work environment, free of discrimination, bullying and harassment. We place high value on equity, fairness and dignity. Harassment on the basis of race, gender, sexual orientation, color, national or ethnic origin, religion, marital status, family status, citizenship status, veteran status, age or disability is prohibited. Harassment generally means offensive verbal or physical conduct that singles out a person to the detriment or objection of that person. Harassment covers a wide range of conduct, from repeated direct requests of a sexual nature to insults, offensive jokes or slurs, which results in an inhospitable work environment. Harassment may occur in a variety of ways and may, in some rare circumstances, be unintentional. Regardless of intent, such conduct is not acceptable and may also constitute a violation of human rights legislation.


No one may harass another employee, contractor, customer, vendor, supplier, visitor or any other person on CEERS’s premises or while doing its business regardless of location.


2.2 Safe Working Conditions
We are committed to ensuring the health and safety of All.
We all have the right to work in an environment that is safe and healthy. In this regard, we must:

  1. Comply strictly with the letter and spirit of applicable occupational, health and safety laws and the
    public policies they represent;
  2. Follow work instructions or procedures on health and safety laws;
  3. Not consume or be under the influence of drugs or alcohol during working hours. In order to protect the safety of all employees, employees must report to work free from the influence of any substance that could prevent them from conducting work activities safely and effectively;
  4. Not engage in illegal or dangerous behavior; or
  5. Not possess or use weapons or firearms or any type of combustible materials while representing CEERS or conducting activities on behalf of CEERS.

CEERS will not tolerate acts or threats of violence or acts of intimidation or hostility towards another person or group of persons.

3. BUSINESS ETHICS AND PRACTICES


3.1 Protecting the Society’s Assets and Resources:
CEERS’s assets are to be used only for the purposes of fulfilling your corporate responsibilities. CEERS’s assets are meant for business use and not for personal use.  All have a responsibility to protect and safeguard CEERS’s assets from loss, theft, misuse, carelessness and waste. 

CEERS’s property should never be used for personal gain, and you should not allow CEERS’s property to be used for illegal activities.  If you become aware of theft, misuse or waste of our assets or funds or have any questions about your proper use of them, you should speak with senior management. 

CEERS’s assets include, in addition to any physical asset, all memos, notes, lists, records, software and other documents (and copies of each of these) that you make or compile relating to CEERS’s business.  All of these are to be delivered to CEERS promptly after your employment or engagement ceases, or at any time that CEERS requests.

Misappropriation of CEERS’s assets including Confidential Information is a breach of your duty to CEERS  and may be an act of fraud against CEERS. Carelessness or waste of CEERS ‘s assets may also be a breach of your duty to CEERS  and could result in dismissal. 

3.2 Policy Regarding E-mail, Internet, Telephones and other forms of Communication 

Use the Society’s various forms of communication properly and appropriately. 

We provide some of our employees with access to e-mail, the internet, telephones and other forms of communication for business purposes, and while we understand the need for limited and occasional use of these tools for personal purposes, this use should not be excessive or cause detriment to CEERS.  Internet use must be conducted in a professional manner.   For example, sending e-mails that are derogatory or harassing to another person or group of people or chain e-mails, is prohibited.  In addition, employees must be vigilant to ensure that the network security is maintained. 

3.3 Confidential Information 

Protect the confidentiality of CEERS’s “non-public information”. 

“Non-public information” is information that is not generally available to the public through a press release, or widely reported media coverage.  The circulation of rumors, or “talk on the street”, even if accurate, is not considered public disclosure.  The most common example of “material non-public information” is information about earnings or financial performance that has not yet been publicly disclosed.

Except where it is authorized or legally required, all employees must keep confidential all information concerning CEERS or its business that is not generally available to the public. 

Information is considered to be public if it has been disclosed in an annual report, annual information form, management information circular, press release or interim report. The obligation to keep certain information confidential applies both during appointment or employment with CEERS and after termination of appointment, or employment for a maximum period permissible by law or as otherwise defined in your consulting agreement. 

Protect the confidentiality of “non-public information” about customers and others. 

We also respect confidentiality of information regarding other companies.  If you learn of confidential information about another Society in the course of your position, you should protect it the same way that you would protect confidential information about CEERS.  Data protection and privacy laws that affect the collection, use and transfer of personal customer information are rapidly changing areas of law, and you should consult with senior management if you have any questions regarding appropriate uses of customer information. 

Disclosure of Confidential Information can be harmful to CEERS and could be the basis for legal action against CEERS and/or the employee, officer or director responsible for the disclosure. 

Protect the confidentiality of “non-public information” about customers and others. 

We also respect confidentiality of information regarding other companies.  If you learn of confidential information about another Society in the course of your position, you should protect it the same way that you would protect confidential information about CEERS.  Data protection and privacy laws that affect the collection, use and transfer of personal customer information are rapidly changing areas of law, and you should consult with senior management if you have any questions regarding appropriate uses of customer information. 

Disclosure of confidential information can be harmful to CEERS and could be the basis for legal action against CEERS and/or the employee and/or the contractor. 

3.4 Media, Public and Governmental Inquiries 

Do not speak on behalf of the Society unless you are authorized to do so. 

When members of the media, financial analysts or government authorities contact CEERS to request information, the response can have far-reaching implications, including effects on CEERS’s public image and its ability to compete.  When we provide information on CEERS’s operational strategies or financial results, we must ensure both that the information is accurate and that it is an appropriate time to “go public” with that information. 

If you receive a request for information from outside CEERS, you must forward it to Brian Hunt (president) if you are not authorized to speak on behalf of CEERS . 

3.5 Conflicts Of Interest 

Avoid situations in which your personal interests conflict, might conflict or might appear to conflict with the interests of CEERS . 

We expect that you will act honestly and ethically and in the best interests of CEERS by avoiding conflicts of interest in your personal and professional relationships.  While we respect your right to manage your personal affairs and investments and we do not wish to intrude on your personal life, CEERS’s employees should place CEERS’s interest in any business transaction ahead of any personal interest or gain. 

You may have a conflict of interest if you are involved in any activity that prevents you from performing your duties to CEERS properly, or that may create a situation that would affect your judgment or ability to act in the best interests of CEERS. For example, no employee should have a significant interest in a business that supplies goods or services to, or secures goods or services from, CEERS, without receiving approval of his or her supervisor.

To avoid conflicts of interest, you should identify potential conflicts when they arise and notify senior management if you are unsure whether a relationship or transaction poses a conflict or appears to pose a conflict. Senior management will be able to clear or resolve certain conflicts, or will be able to contact someone else who can. Directors should consult with the Chairman of the Board.

3.6 Compliance with Laws, Rules and Regulations 

Know and comply with all laws, rules and regulations applicable to your position. 

As with all companies, CEERS’s activities are subject to complex and changing laws, rules and regulations.  Ignorance of the law is not, in general, a defense to an action for contravention.  We expect you to make every reasonable effort to become familiar with laws that affect your job and your performance and to exert due diligence in complying with these laws, rules and regulations and, to ensure that those individuals reporting to them are also aware of these laws, rules and regulations.  Our objective is to restrict willful or negligent violations of these laws, rules and regulations. 

If you have any doubts as to the applicability of any law, you should refer the matter to senior management who may obtain advice from the Society’s legal counsel. 

CEERS’s policy is to meet or exceed all applicable governmental requirements regarding its activities.  As an employee or contractor, you must be aware of the applicable governmental requirements and report any violations thereof to senior managements or in accordance with the Reports and Complaints section of this Code.  Similarly, no one may enter into any arrangement contrary to applicable requirements or laws.  

3.7 Membership on Boards of other Organizations 

If you are an officer or employee of CEERS, you must obtain formal written permission before you join the board of directors of another Society or government organization if there is any possible linkage of CEERS to that outside firm. 

Serving as a director of another Society, even one in which CEERS has an interest, may create a conflict of interest. Being a director or serving on a standing committee of some organizations, including government agencies, may also create a conflict. 

Before accepting an appointment to the board or a committee of any organization whose interests may conflict with CEERS’s interests, employees must receive written approval from the CEO.

Employees are permitted, however, to serve on boards of charities or non-profit organizations or in private family businesses that have no relation to the Society and its businesses.  Prior approval is not required for these types of situations.  If you hold a position with a charity or non-profit organization and if you speak publicly for the entity, you should ensure that you are seen as speaking on behalf of the entity or as an individual, and not on behalf of CEERS. 

3.8 Personal Opportunities 

Do not take personal opportunities that are discovered through the use of property or information of CEERS or in your role with CEERS . 

You are prohibited from taking opportunities for yourself that you discover through the use of CEERS’s information or position; from using CEERS’s property, information or position for personal gain; or from competing with CEERS.  You owe a duty to CEERS to advance its legitimate interests when the opportunity arises. 

3.9 Fair Dealing 

Deal fairly with CEERS ’s members, sponsors, customers and suppliers. 

You must endeavor to deal fairly with security holders, CEERS’s customers, suppliers, competitors and employees, and should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice. 

3.10 Giving Gifts 

Use your best judgment in giving gifts. 

You should not offer expensive gifts or other benefits to persons, including public officials and political parties that might influence or be perceived as influencing a business decision. 

Employees, whose duties permit them to do so, such as employees in marketing, may offer modest gifts, entertainment or other benefits to persons who have a business relationship with CEERS.  The benefits must be given in accordance with generally accepted ethical business practices.  For example, it is acceptable to take a person who has a business relationship with CEERS or entity that transacts business with CEERS  or competes with CEERS  to dinner; however, it is not acceptable to give a customer cash. 

Any donation or benefit to a public official or political party must be in accordance with this Code.  We encourage you to become involved in political activity acting on your own behalf, but not as a representative of CEERS. 


3.11 Receiving Gifts 

You must not accept expensive or inappropriate gifts or other benefits from persons doing or seeking to do business with CEERS. 

You cannot solicit, encourage or receive bribes or other payments, contributions, gifts or favors that could influence your or another person’s decisions.  It is acceptable to accept modest gifts, entertainment or other benefits from persons doing or seeking to do business with the Society, provided the benefits are given in accordance with generally accepted ethical business practices.  For example, a pair of tickets to a baseball game may be accepted from a supplier. However, it is not appropriate to accept a trip from a supplier, unless there is a specific business purpose and the trip has been approved by senior management. 

3.12 Accuracy of Books and Records 

Ensure that the books and records of the Society are complete and accurate. 

The books and records of CEERS must reflect in reasonable detail all its transactions in a timely and accurate manner in order to, among other things, permit the preparation of accurate financial statements in accordance with generally accepted accounting principles.  All assets and liabilities of CEERS must be recorded as necessary to maintain accountability for them. 

All business transactions must be properly authorized.  All transactions must be supported by accurate documentation in reasonable detail and recorded properly.  The recorded value for assets must be compared to the existing assets at reasonable intervals and appropriate action taken with respect to any differences. 

No information may be concealed from the auditors, the internal audit function, the Audit Committee or the Board.

In addition, it is unlawful to fraudulently influence, coerce, manipulate or mislead any independent public or certified accountant who is auditing our financial statements. 

3.13 Accounting, Auditing or Disclosure Concerns 

Provide accurate and fair public disclosure. 

We are required to provide full, fair, accurate, timely and understandable disclosure public communications made by the Society.  All employees who are responsible for the preparation of CEERS’s public disclosures, or who provide information as part of the process, have a responsibility to ensure that disclosures and information are made honestly, accurately and in compliance with CEERS’s disclosure controls and procedures. 

We all have a responsibility to submit good faith questions and concerns regarding accounting, auditing or disclosure matters. Complaints and concerns related to such matters include, among others, actions involving: 

  • Fraud or deliberate errors in the preparation, maintenance, evaluation, review or audit of any financial statement or financial record;
  • Deficiencies in or non-compliance with internal accounting controls;
  • Misrepresentation or false statements to or by a senior officer or accountant regarding a matter contained in the financial records, financial reports or audit reports; or
  • Deviations from full and fair reporting of CEERS ‘s financial condition. 

4. COMPLIANCE WITH THE CODE 

4.1 General

This Code is made available to every employee and contractor via a posting on our website.  Each employee and contractor is responsible for reading and understanding this Code.  Each employee and contractor may be required to sign an acknowledgement in the form of the Statement of Compliance acknowledging their understanding and commitment to adherence to this Code. 

The Code is intended to serve as a guide for your own actions and decisions and for those of your co-workers. 

4.2 Reports and Complaints 

Each of us is obligated to report any violation of the Code, any law or any regulations to the appropriate representative of the Society.

As an employee or contractor, if you believe that a violation of the Code or any law, rule or regulation has been or is likely to be committed by you or someone else who is a representative of CEERS, you have an obligation to promptly report the relevant information to senior management.  Senior management will generally be in the best position to resolve the issue.  However, if you feel uncomfortable approaching senior management with your concern, or if you have any specific or general questions, you may contact the President of CEERS. 

Employees and contractors can raise concerns either orally or in writing although reports to the President may only be made in writing. 

The most important thing you should remember when dealing with these types of questions or concerns is that when in doubt, ask. 

4.3 Treatment of Reports and Complaints 

Confidentiality of reported violations will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review and subject to law.  You may make a report anonymously.  You should write a letter and include as many specific details as possible, including back-up documentation where feasible, in order to permit adequate investigation of the concern or conduct reported.  Vague, non-specific or unsupported allegations are inherently more difficult to pursue. 

4.4 Penalties for Violating the Code 

We will not discharge, demote or suspend you if you, in good faith, report concerns about actual or potential violations of laws, rules or regulations, or this Code. 

Retaliation is prohibited; however, the Society reserves the right to discipline you if you make an accusation without a reasonable, good faith belief in the truth and accuracy of the information or if you knowingly provide false information or make false accusations.  “Good faith” does not mean that you have to be right, but it does mean that you must believe you are providing information that is true. 

If you believe that you have been unfairly or unlawfully retaliated against, you may file a complaint with senior management or the CEERS’s President. 

Contact Information: 

Phone: 604-644-4814

E-mail: brian.hunt@ceers.ca

4.5 Waivers 

Waivers of the Code for employees may be granted only in writing by the Brian Hunt, president. 

5. LEGAL NOTICE 

This Code serves as a reference to you.  CEERS reserves the right to modify, suspend or revoke this Code and any and all policies, procedures, and programs in whole or in part, at any time. CEERS also reserves the right to interpret and amend this Code and these policies in its sole discretion as it deems appropriate. Any amendments to the Code will be disclosed and reported as required by law. 

Neither this Code, these policies nor any statements made by any employee of CEERS , whether oral or written, confer any rights, privileges or benefits on any employee or contractor, create an entitlement to continued employment at CEERS , establish conditions of employment, or create an express or implied employment contract of any kind between employees and CEERS .  In addition, all employees and contractors should understand that this Code does not modify their employment relationship, whether at will or governed by a written contract. 

The most recent version of this Code that appears online at www.ceers.ca and may be more current and up to date and supersedes any paper copies should there be any discrepancy between paper copies and what is posted online. 

6.CONCLUSION


In the final analysis you are the guardian of CEERS’s ethical standards.  While there are no universal rules, when in doubt you should ask yourself:

  • Will my actions be ethical in every respect and fully comply with the law and with CEERS policies? 
  • Will my actions have the appearance of impropriety? 
  • Will my actions be questioned by my Board members, sponsors, membership, associates, clients, family and the general public? 
  • Am I trying to fool anyone, including myself, as to the propriety of my actions?

If you are uncomfortable with your answer to the above, you should not take the contemplated action without first discussing this with senior management.

Any employee or contractor who ignores or violates any of CEERS’s ethical standards, or who penalizes a subordinate for trying to follow those standards, or willfully or knowingly omits to tell the entire truth during any ethics or other CEERS  investigation, or obstructs, defeats or attempts to stop an ethics or other CEERS  investigation, will be subject to corrective action, up to and including immediate dismissal.  However, it is not the threat of discipline that should govern your actions.  We hope you share our belief that a dedicated commitment to ethical behavior is the right thing to do, is good business, and is the surest way for CEERS  to remain a successful and responsible employer.