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Governance

CODE OF CONDUCT

Tundra Energy Marketing Limited

(together or individually, "TEML" or the "Company")

CODE OF CONDUCT

"Our goal is to be the kind of business organization in which people can place their trust."

James Richardson, Founder, James Richardson & Sons, Limited, 1857

Tundra Energy Marketing Limited and its ultimate shareholder, James Richardson & Sons, Limited ("JRSL"), have established a track record of success and integrity over six generations of doing business in Canada. Ours is a rare heritage, one that provides an important foundation of values, credibility and ethics upon which JRSL and TEML will continue to grow and prosper for the benefit of all their stakeholders. This Code provides our employees, independent contractors, officers and directors (together, "employees") with the standards of acceptable ethical conduct and behaviour when representing TEML and dealing with our stakeholders, who are our shareholders, directors, officers, employees, customers, suppliers, advisors and the communities in which we operate, which will ensure that our organization fulfills the goal of its Founder, James Richardson, "to be the kind of business organization in which people can place their trust."

OBJECTIVES OF THE CODE

The Code of Conduct has three objectives:

INTERPRETATION OF THIS CODE

The purpose of the Code is to provide employees with direction with respect to issues which may arise from time to time. Except where certain actions are specifically prohibited or required, this Code is intended to serve as a general guideline. The absence of specific reference to some other topic, or failure to restrict or prohibit specific actions or behaviour, should not be interpreted as approval of such action or behaviour. Employees are expected to use common sense and, in appropriate circumstances, seek guidance where any question of the appropriateness of specific actions or behaviour is potentially at issue. Wherever any doubt arises with respect to this Code, inquiries should be directed to the President of the Company or the Vice President and General Counsel of JRSL.

This Code is in addition to any code of conduct to which the employee may be subject as a result of the employee's registration with or membership in a professional or industry regulatory or governing authority or organization.

PROPER CONDUCT

Respect for Others

Employees shall treat other employees and stakeholders with dignity, respect and fairness at all times.

Unlawful discrimination, harassment or violence in the workplace will not be tolerated.

Professionalism

Employees will carry out their job responsibilities to the best of their ability in a professional manner.

Alcohol and Drugs

Management approval is required before alcohol may be served on Company premises.

The operation of a Company vehicle or machinery while under the influence of alcohol or drugs is prohibited.

The use, possession or distribution of illicit drugs, illicit paraphernalia or non­prescribed drugs for which a prescription is legally required while on Company premises is prohibited.

This Code is subject to and supplemented by the TEML Alcohol and Drug Policy.

HEALTH, SAFETY AND ENVIRONMENT

TEML endeavours to provide a safe and healthy work environment for all employees and to conduct its operations in a manner which minimizes the harm to our environment.

Employees have a responsibility to help ensure the Company is complying with health, safety and environmental laws and regulations by reporting accidents, potential hazards and other concerns immediately to their manager or to an officer or director of the Company.

CONFLICTS OF INTEREST

General Principle

Employees shall at all times carry out their duties honestly, in good faith and in the best interests of TEML.

Avoiding Conflicts of Interest

Neither employees, nor members of their immediate families (spouse and children), shall accept any gifts, payments, loans, fees, services, discounts or other valuable consideration, either directly or indirectly, from any person or organization with whom TEML does business or is considering doing business with, if such acceptance would, or could reasonably appear to, influence the objective performance of the employee's duties and responsibilities.

Employees shall not grant or give gifts or favours to any party or employee of a party with whom TEML does business or is considering doing business with, unless such gifts or favours are in accordance with generally accepted business practices and would not be viewed as being illegal or improper.

Employees shall not engage directly or indirectly in any business activity that could be viewed as being in competition with TEML, nor shall employees or their immediate families have a financial interest in or with a customer or supplier of the Company where the employee is in a position to influence the relationship between the Company and that other party. It is considered a conflict of interest if employees (other than external directors) conduct non-Company business activities during their normal work day, or utilize Company equipment or facilities for any non-Company related business activity.

SECURITY

The Company and its employees will endeavour to protect the property and assets of the Company and of its employees.

CONFIDENTIALITY

Third Party Information

Many parties with whom TEML transacts business provide TEML with personal, business and financial information of a confidential nature which must be protected.

JRSL and TEML Information

Confidential information about TEML, JRSL and its shareholders (being members of the Richardson Family) must a/so be protected.

The duty to maintain confidentiality and to not use confidential information other than in the best interests of the Company continues after employees are no longer associated with JRSL or TEML.

INTELLECTUAL PROPERTY

All intellectual property including inventions, trade secrets, customer information, customer lists, business plans and strategies, creative materials, methods, processes, software and moral rights related to such intellectual property which employees create or make in the course of their employment shall be assigned to the Company and employees shall waive any moral or other rights that they may have in such intellectual property.

COMPUTER SYSTEM USE

Company computers and other information technology equipment must be kept secure and used appropriately.

BUSINESS COMMUNICATIONS

The Company's electronic devices and services, including, but not limited to, computers, computer-related equipment, products or services are the Company's property and should be used primarily for business purposes. The Company reserves its rights to monitor employee's electronic activities at any time.

DISCIPLINARY ACTIONS

Failure to comply with Company procedures, policies and this Code may lead to disciplinary action.

Subject to the severity of the incident, disciplinary action could involve one or more of the following:

REPORTING BREACHES OF THIS CODE

Reporting breaches or potential breaches of this Code is encouraged.

Approved by TEML Board of Directors February 22, 2017.