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E&C Corporate

Code of Ethics Policy

Ethical Standards for all Elephant & Castle Employees:

  1. Obey the law – we will conduct our business in accordance with all applicable laws and regulations.
  2. Promote a positive work environment – for all employees to feel respected and treated with dignity.
  3. Make accurate public disclosures – all disclosures made in all periodic reports and documents filed with the SEC, and other public communications are full, fair accurate and timely.
  4. Record costs properly – employees and their supervisors are responsible for ensuring that labour and material costs are accurately recorded and charged on the companies' records.
  5. Adhere to all anti trust laws that protect the free enterprise system and promote open and fair competition.
  6. Carefully bid, negotiate and perform contracts following all laws and regultions that pertain to the acquisition of goods and services.
  7. Avoid illegal and questionable gifts or favors .   Elephant & Castle employees are prohibited from offering or giving tangible gifts (including tickets to sporting, recreational, or other events) having a market value of $250.00 or more,   to a person or entity with which the company does or seeks to do business, unless specifically approved by his or her supervisor, and/or the Corporate Office.
  8. Conflict of Interest – Employees will avoid any relationship, influence or activity that might impair, or even appear to impair, an employee's ability to make objective and fair decisions when performing their job.   Some examples of conflict could include: Employment by a competitor; Acceptance of gifts, payment, or service from those seeking to do business with Elephant & Castle; Ownership of, or substantial interest in a company that is a competitor or a supplier, having a personal interest or potential gain in any company transaction.
  9. Keep proprietary and private information documents protected and secured.
  10. Employees will not engage in Speculative or Insider Trading.

What To Do If You Have Concerns:

At Elephant & Castle, our goal is to foster and maintain an ethical work environment. At times, we may be faced with ethical dilemmas, or a potential breach of our ethical standards.   If you are in doubt about an ethical situation, ask yourself, “Are my actions legal?”, “Am I being fair and honest ?”, “How will it look in the newspaper?”.

If you are faced with an ethical dilemma, or you suspect that improper conduct is taking place, it is best to bring it to someone's attention.   Usually, your General Manager is the best source of information or guidance; however there are many other channels of communication available to you:

  1. One of the Managers on the Management Team.
  2. Your Director of Operations: John Luvison, D.O., Eastern Region or Steven Meeker, D.O., Western Region
  3. Human Resources – Doris Montgomery
  4. Chief Operating Officer – Peter Laurie
  5. President and Chief Executive Officer – Rick Bryant

If you need more information, talk to your manager, or you can talk to one of the people listed above by contacting the Home Office: 12th Floor, 1190 Hornby Street, Vancouver, B.C., V6Z 2K5, Phone 604-684-6451.

All Enquiries will be treated with dignity, respect and confidentiality.  

We are all responsible for adhering to the standards of our Climate Goals and Code of Ethics and for raising questions if we are concerned that these standards are not being met.   Violations of the Code are cause for corrective action, which may result in disciplinary action up to and including discharge.   For information about how investigations into breach of Code of Ethics please see our Whistleblower Policy.

We are proud of our employees and our company.   Thank you for doing your part to create and maintain an ethical work environment!

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Elephant & Castle Group, Inc.
12th Floor 1190 Hornby Street
Vancouver, B.C. V6Z 2K5
Canada
Tel: 604-684-6451
Fax: 604-684-8595

 


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