Workleap Code of Ethics

1. The Purpose of the Code

Our Code of Ethics (the “Code”) details Workleap’s expectations toward fulfilling, as a team, our vision and our commitment all the while making people our approach’s focal point.   

Our Code acts as a guide with respect to the line of conduct which must be adopted as you carry out your tasks at Workleap and its subsidiaries as one of its directors, officers, employees, contract workers, consultants and interns.   

To fulfill our vision, maintain the trust of the public and a healthy work climate, it is essential that the fundamental principles of the Code be respected.  

Who is This Code Meant for?

The Code is meant for everyone, regardless of your status, i.e. whether you’re an intern, contract worker, consultant, employee, officer or director at Workleap.    

The rules outlined in this Code are the same for everyone and apply at all times and in all locations when carrying out your duties, during professional or social activities. These rules apply during trips and business meetings as well as during any event where Workleap is involved either as a participant or an organizer.       

When in doubt, come talk to us! Whether you need further information on some aspect of the Code or you’re looking for some advice as to its application, don’t hesitate to discuss the matter with your manager, the C&O team, the Legal Department or any other contact person referred to in this Code. 

2. Respect for Others

2.1. Our intention. At Workleap, people are the focal point of everything we do. In our work environment, we are all, collectively, responsible for creating an environment where we are mindful of one another and where everyone can flourish and reach their full potential. We want to embrace diversity and open-mindedness and mutual respect. The “harmonious coexistence” philosophy means showing empathy for others and being able to engage in more challenging conversations.   

In addition to being mindful others, we want to help everyone know how to react to situations that are uncomfortable or deemed unacceptable.    

2.2. Scope - Who does it apply to? And where? Each and every one of us is entitled to respect. Workleap does not tolerate or allow any form of discrimination or psychological or sexual harassment within its organization. This applies in the context of your relationship with your colleagues, your managers, upper management, customers, suppliers, visitors and any other person you interact with while carrying out your duties. The notion of respect for others applies both in and outside of Workleap offices, during and after working hours, and even on social media. Essentially, whenever and wherever a situation might impact the work environment.   

2.3. Principles: 

• 2.3.1. Accountability. It is our shared responsibility to maintain a work environment which is conducive of respect for others, free of discrimination, harassment and incivility. Consequently, we all have a role in preventing, but also reacting to, situations we consider inappropriate.   
• 2.3.2. Support and discretion. Anyone can expect to be helped and supported, without fear of embarrassment or reprisal from Workleap, when he or she is faced with an uncomfortable or harassment situation and when working toward resolving this kind of situation.   
  
  Any and all situations will be handled with the utmost discretion and confidentiality so as to protect the privacy of those involved. Each and every one of us must be respectful and avoid indulging in gossip and speculation relating to situations which may occur and require some kind of intervention.   
• 2.3.3. Efficiency and objectivity. Workleap will undertake to address any situation brought to its attention as soon as possible. You can also rest assured and reassured that everyone involved will be treated fairly, objectively and with compassion.   

2.4. Definitions. There is a wide range of situations and behaviours that someone may perceive as problematic, whether in terms of incivility, harassment or even violence. Here is Workleap’s understanding of these terms and their meaning:  

🚩 Incivility covers any behaviour which, although not serious or outrageous, is unpleasant or shows a lack of respect, and has a negative impact on the work environment. Any ill-mannered behaviour, when repeated, may be considered as harassment. 
 
A few examples: using a humiliating or embarrassing emoji, spreading rumours, refusing to help a colleague, failing to acknowledge or thank someone, speaking with an impatient or brusque tone of voice, criticizing someone in front of a group. 

🚩 Psychological harassment manifests itself through repeated behaviours, attitudes, gestures or comments that are hostile or undesired, that undermine an individual’s dignity or psychological or physical integrity, and have an adverse effect on the workplace. 
 
Seemingly innocuous uncivil behaviour, when repeated, may be considered as harassment. The more serious a behaviour is, the fewer repetitions are needed for it to become harassment. In other words, even if it’s not serious at first, it can become serious if repeated. And when it’s considered as outrageous, a single event may constitute harassment.  
 
Some examples: humiliating or mocking someone in front of a group, being aggressive, making racist or sexist comments, alienating a colleague, etc. 

🚩 Sexual harassment includes any repeated or upsetting comment, gesture or contact of a sexual nature, in its broader sense, which is not welcomed by the targeted Workleap employee, and which results in offending, humiliating or undermining the psychological or physical integrity of said employee.  
 
For instance: sending messages of a sexual nature, asking personal questions regarding someone’s sex life, commenting on someone’s body, asking for sexual favours, threatening someone with reprisals should they refuse to consent to sexual advances, subjecting someone to unwanted physical contact, sexual assault, etc. 

🚩 Violence in the workplace relates to someone’s actions, behaviours or threats toward an employee which undermines said employee’s physical security or psychological well-being. 
 
Some examples: threats, physical assault, assault, sexual assault, etc. 

☝🏻 The lack of intent to make the other person uncomfortable is never an excuse. In short, a behaviour may be inappropriate even though the person responsible did not intend to cause harm. 

• 2.4.1. Informal resolution. Workleap encourages the informal resolution of uncomfortable situations when possible. In this respect, should you be faced with an uncomfortable situation resulting from something that happened, words which were spoken or one of the ways things are done within the company, we encourage you to, first and foremost, speak directly to the person involved.   
   
  If you choose to discuss the situation with a colleague, your intention must not be to harm the person who is the instigator of the uncomfortable situation or to spread rumours on the behaviour of someone.   
• 2.4.2. A more formal resolution. Should you be unable to reach an informal resolution to a given situation, whether because it’s impossible or that the actions or words spoken have a certain level of severity or because you are simply uncomfortable, you can speak directly to a manager or a C&O team member. Someone with which you discussed the situation during the informal resolution may also report the situation to a member of the C&O team if he or she feels insufficiently equipped to intervene or believes that the situation is serious enough to merit the intervention of the C&O.   
   
  When a situation is brought to the attention of a C&O member, he or she must always take down the facts as well as the point of view of those involved. Various options are then possible. There could be an intervention with the person identified as the source of the uncomfortable situation to put a stop to the behaviour. Facilitating a dialogue between the individuals involved could also be another option toward resolving the situation. If need be, an investigation could be entrusted to an external actor.   
   
  In all cases, the C&O team will see to following-up any and all situations brought to its attention, both with the person that experienced the uncomfortable situation as well as the individual who caused said situation.   
   
  If the person that caused the uncomfortable situation is a C&O member, you can follow the same procedure, but instead of discussing the matter with the C&O team, the manager you called on will go see a member of the Executive Committee who will handle the situation from that point on.   
   
  You may also report inappropriate behaviour anonymously. Please refer to Section 9.3 of this Code for more information. 

2.5. Consequences. If, once it has collected all the facts and assessed the situation, the C&O team comes to the conclusion that someone’s behaviour did in fact affect the well-being of the team and that a person has committed some form of incivility, harassment or violence, administrative or disciplinary measures up to and including termination of employment may be taken, depending on the severity of the situation.   

If, after analysis, the C&O team comes to the conclusion that a complaint has been made for the sole purpose of harming the other individual, administrative or disciplinary measures may also be taken.  

3. Respect for our Customers

3.1. The foundation of our practices. Respect is the cornerstone of any relationship. Consequently, our customers are treated with the same respect, free of discrimination or harassment, regardless of the situation and individual. Honesty, trust, integrity and loyalty must always guide our actions and behaviour when dealing with our customers. Professionalism, trust, authenticity, transparency and integrity are the foundation of any and all communications with our customers. Our goal is to provide them with accurate and comprehensive information so as to offer the best possible advice. We avoid misleading or deceiving them by using false or erroneous information at all costs.   

As to the tone one must adopt when addressing our customers, we encourage you to refer to the brand books adopted for each of our products.  

3.2. Respect for our clientele also means:    

• 3.2.1. Knowing our clients. To provide a service which reflects the quality standards set out by Workleap, it’s important to be tuned into our customers’ specific needs. Consequently, we’re able to provide them with the information they need and guide them appropriately with regard to the products and services best suited to their needs, regardless of our sales targets. We don’t put pressure on a customer to purchase a product.    
• 3.2.2. Providing advice with integrity. We provide advice and carry out the transactions we are authorized to provide or do and for which we are responsible, and remain mindful, when appropriate, of the limits of our own expertise.  

4. Compliance With the Law

4.1. At Workleap, ignorance of the law is never an excuse. In short, this means that it is our duty to know and comply with the laws that relate to our activities, regardless of the nature of our professional status. At no time should we participate in illegal activities or activities that may be perceived as such. In all our practices, both in Canada and abroad, we abide by all applicable laws and regulations.    

4.2. Anti-corruption laws. Corruption on the global stage deepens inequalities; consequently, Workleap takes all laws fighting against corruption very seriously. Corruption in any form, whether directly or indirectly, through a representative, a consultant expert, a distributor or any other intermediary, will not be tolerated at Workleap. We always proceed with the utmost caution in such matters. All dealings with Canadian or foreign public officials must therefore be conducted in compliance with applicable laws, whether in Canada or other countries. When carrying out our responsibilities with regard to Canadian or international public officials, we do not accept, solicit or offer any kickbacks, secret commissions, bribes or other benefits of a similar nature. Our behaviour and actions must not lead to believe that we could accept or give a benefit of a similar nature under any circumstances.   

Here is a concrete example of expected behaviour:   

We do not offer to pay the restaurant bill of the Human Resources Vice President of the Canadian Space Agency (a Canadian government agency), the City of Montreal or the Department of public health in Australia. These relationships must remain strictly business-related and must never give the appearance of seeking to influence their decision in any inappropriate manner.    

4.3. Reporting illegal activity. If you witness illegal activity, you have a duty to report it. We invite you to inform your manager or a member of the C&O team. If you are not comfortable with sharing what you witnessed with someone within Workleap, you may do so anonymously to a third party. Please refer to Section 9.3 of this Code for more information. 

5. Respect for Workleap

5.1. Conflicts of interest. We trust that you will avoid getting in a situation which could lead to a conflict of interest which would in turn be detrimental to Workleap’s interests. You must make sure that your judgment and ability to take an informed decision are never compromised.  

A conflict of interest could, for instance, arise in the following situations:  

• You use confidential information regarding Workleap, which you are given access to in the course of your walk for Workleap, for personal use or for external activities.  
• You share confidential information regarding Workleap strategies with one of your friends to give said friend a helping hand as he/she is hoping to start a business.  
• While attending an event as a Workleap employee, you seize the opportunity to promote your personal project to participants on hand.  

5.2. Be honest and loyal. Be careful to avoid placing yourself in a position where you are competing with Workleap interests by using business opportunities or information owned by Workleap for personal gain. If you are involved in the development of a project outside of your Workleap -related duties which could, on the one hand, compete with Workleap products or services and, on the other, would require the use of the company’s resources, do not forget that you are subject to the duty of loyalty toward Workleap and to the obligations stated in your employment contract. When in doubt, do not hesitate to reach out the Legal Department.   

5.3. Gifts and favours. It is your responsibility to decline any benefit or favour which would have a direct influence on your judgment and your ability to take an informed decision. To give you an idea of a situation which could entail a conflict of interest, here is a case in point:  

One of your tasks it to choose an external provider to carry out a major project. Among the five candidates, one of them gives you a pair of tickets to a concert for you and your significant other. This happens during the selection process. It is therefore your duty to exercise good judgment and recognize that, in this type of situation, you are being offered this benefit in an effort to influence your decision. Consequently, it would be best to decline this gift.  

You may receive modest value or symbolic gifts from service providers from time to time. You may accept such gifts provided they are not susceptible to influence your ability to make impartial decisions. When in doubt, ask a C&O team member for advice.  

6.Respect for our Community and for the Planet

As a very successful Quebec business, Workleap has a social and environmental responsibility that it takes seriously. We are fortunate enough to live in one of the world’s greatest societies and it is our responsibility to do our part. This is one way of taking our place in Quebec’s landscape and to position ourselves as one of its leading companies. And if we do our job well, we will undoubtedly influence other organizations to get more involved themselves.   

Consequently, we are committed to seek and implement strategies that allow us to have a positive impact on our employees, our community, our clients and our environment. Workleap counts on you to collaborate in taking our social and environmental impact into account when we make business decisions. 

7. Self-Respect

7.1. The health of everyone, one of our priorities. At Workleap, our primary focus is your well-being and mental health. We want to create a healthy and stimulating environment, both in and outside of our offices. For instance, we believe that sports can help improve your mental and physical health. Consequently, Workleap has decided to provide you with tangible tools, including a taxable benefit (allocated only to full-time employees), the health spending account, which allows you to fund self-care activities, including sports activities, relaxing getaways and health and leisure equipment. Also, for Workleap, making people the focal point of its activities also means providing its employees with an Employee and Family assistance program (EFAP) as well as with a telemedicine program. These programs allow you and your family to access the services of health professionals in real time, worry-free. 

To learn more about the services that are provided, please check out the relevant Confluence pages or reach out to a C&O team member.   

7.2. The safety of everyone, one of our priorities. As for work safety, it is your responsibility to decide on a course of action that avoids any risks and safeguards your health and safety as well as those of others at all times. If this were not the case, it is your responsibility to report potential problems when they arise to the individuals that have the required skills, namely members of the Work environment team.   

8. Alcohol and Cannabis

8.1. Alcohol. We trust you will drink alcoholic beverages provided at work or at social gatherings organized by Workleap responsibly. Alcohol abuse leading to inappropriate behaviour will not be tolerated. Workleap will always provide alternatives for people who do not wish to consume alcohol. 

As for your personal consumption, we rely on your good judgment to come in to work in top form, so that you can accomplish your work in a professional manner.    

8.2. Cannabis. Workleap’s position is pretty straightforward: Workleap trusts your judgment. Workleap expects that you will take the necessary decisions to be in the best conditions and have the best possible cognitive abilities when at work.  

9. Reporting

9.1. General reports. As stated above, to fulfill our vision, maintain the trust of the public as well as a healthy workplace climate, it is essential that the underlying principles of the Code be upheld. This is all our collective responsibility.  

Should you witness a behaviour that goes against the rules of the Code or of other Workleap policies, permanent instructions, procedures or norms, we encourage you to discuss the matter directly with the person involved to begin with.   

Alternatively, you can report this behaviour to your manager, your manager’s manager, the Legal Department or the C&O team, depending on which individual seems better suited to step in, in your opinion, in these circumstances. Your identity will remain confidential insofar as confidentiality is possible and appropriate, in accordance with the law. 

Here are a few concrete examples to help you identify problematic issues which should be discussed with the person involved or reported to the Legal Department or C&O team:  

• An employee accepts a gift which might influence his judgment;  
• An employee is witness to another employee in a situation involving fraud, such as creating fake invoices.  
• An employee discloses confidential information about a client of Workleap on a public forum. 
• An employee engages in anticompetitive behaviour, such as price fixing with a competitor. 
• An employee disparages a colleague during a team lunch. 

9.2. No retaliation. Workleap will not exert or tolerate any retaliation against an employee for reporting in good faith any behaviour that goes against the rules of the Code or of other Workleap policies, permanent instructions, procedures or norms, unless the report was done for the sole purpose of harming others. If you feel you are suffering reprisals, you must report this to the Legal Department, C&O team or your manager.   

9.3. Anonymous report for non-compliance with the law or for lack of respect for others. Should you witness a behaviour that goes against Sections 2 (Respect for Others) or 4 (Compliance with the Law) of the Code and that you are not comfortable with communicating with the aforementioned individuals, you may file a completely anonymous report. Workleap has put in place a simple anonymous reporting process in collaboration with Cabinet RH, an external law firm which is well qualified to handle this type of report. Here are the steps you should follow: 

• Write to signalementworkleap@lecabinetrh.com to get in touch with Cabinet RH. This email address is for the exclusive use of Workleap employees and interns who want to submit a report; 
• A member of Cabinet RH authorized to attend to these reports will answer you within five working hours so as to schedule a time to collect your statement; 

Once you’ve made your statement, Cabinet RH will send a report to the Legal Department; there, your situation will be assessed so as to identify the appropriate solution. Rest assured that the report will never disclose your identity when it deals with Section 4 of the Code (Compliance with the Law). Depending upon the circumstances, it may not be possible to preserve the anonymity of a person reporting a breach of this Code, particularly where the report pertains to a breach of respect for others. That being said, a report which is susceptible of revealing the identity of the complainant will be shared with Workleap only with the complainant’s consent. 

10. Implementation and enforcement of the Code

It is your responsibility to understand the Code, to be aware of the changes made to the Code and to respect its rules as a condition to your status as a director, officer, employee, contract worker, consultants or intern. The online version of the Code is the official version, and must be complied with at all times, even though you may have signed a previous version of the Code.