At The Elephant and Castle Group Inc., all directors, officers and employees are expected to observe high business and personal ethics while conducting their duties.  As representatives of the company, we must fulfill our responsibilities with honesty and integrity and we comply with all applicable laws and regulations.  We have embodied our standards in our Code of Business Conduct and Ethics.

Also, regulators in Canada and the U.S. have established or proposed rules requiring public companies to establish procedures for a confidential, anonymous complaint procedure for employees who have concerns about questionable accounting, internal controls or auditing matters.

Reporting Your Concerns

We expect all directors, officers and employees to comply with the Code of Business Conduct and Ethics and to report any concern of violations of the Code or of this Whistleblower policy.  We are committed to a culture where it is safe and acceptable for all employees, directors or officers to raise concerns about violations of the Code. 

Concern Reporting Process

We encourage employees to share their questions, concerns, suggestions or complaints with someone who can address them properly.  Often, your General Manager may be able to address an area of concern.  If you are not comfortable speaking with your manager, or are not satisfied with your GM’s response, you may speak with your Director of Operations, Human Resources or the Chief Operating Officer.  All Managers of the company are required to report suspected violation concerns to the President and Chief Executive Officer of the Company.

If you are a director or officer, or if the concern relates to corporate accounting practices, internal controls or auditing, you should contact the Chair of the Audit Committee at the contact information below.

If the matter relates to suspected fraud or securities violations, or if you are not comfortable with the above procedures, you may contact our Outside Legal Counsel, who has specific responsibility to investigate all reported violations (contact information below).

No Retaliation

If you raise a concern or report a violation of the code, you will not be retaliated against in any way, even if there is no finding of wrongdoing, so long as you have acted in good faith.  Acting in good faith means acknowledging that violation reporting is a serious matter and to be entered into where legitimate concerns arise.  Conversely, making knowingly false accusations will be treated with equal concern and investigation that could lead to disciplinary action.

Investigation of Complaints

The Corporation’s Outside Legal Counsel is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Code and, at his discretion, shall advise the President and Chief Executive Officer, the Chief Financial Officer and/or the Audit Committee.  He has direct access to the Audit Committee of the Board of Directors and is required to report to the Committee at least annually on all compliance activity.

Confidentiality

You may report your concerns relating to possible violations of the code on a confidential basis, or you may report them anonymously.  All reports will be kept confidential to the extent possible, while still allowing an adequate investigation.

Handling Complaint Reports

Your complaint will be formally acknowledged in a timely manner (where the report has not been made anonymously).  All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.