USE & PROTECTION OF ACCEDE ASSETS / CONFIDENTIALITY

​

Every Access Valve employee has a responsibility to protect the assets of the company. This responsibility extends to physical assets, intellectual assets, and trademarks and brands.

​

Physical assets include funds, products, facilities, equipment, and electronic information systems. These assets are to be used for Access Valve business. Each employee must follow applicable security and use procedures to protect the company’s physical assets from theft, loss, damage, or misuse. Any theft, loss, damage, or misuse should be reported immediately to the nearest Access Valve office.

​

Intellectual assets include process and product information, internal communication, digital information stored on any electronic device, documents, and verbal discussions that have been identified as proprietary or Business Confidential. If an employee becomes aware of any misuse of the company’s intellectual assets, he/she should report it to their manager immediately. Among Access Valve’s most valuable assets are its trademarks and brands. To protect the value and recognition of Access Valve’s trademarks, the company has guidelines that specify how and when they may be used. These guidelines must be followed whenever the company’s trademarks and/or brands are used, whether in internal or external communications or in materials prepared by third parties, such as marketing agencies, distributors, and Original Equipment Manufacturers (OEMs).

​

A. Proprietary and Confidential Information

​

Each director, officer, and employee will safeguard all proprietary and confidential information by marking such information accordingly, keeping it secure, and limiting access to those who have a need-to-know in order to do their jobs. This includes:

• Information that is not generally known to the public,

• Information that could be helpful to competitors,

• Information that suppliers or customers have entrusted to the company.

In the event that Access Valve elects to publicly disclose material, non-public information, such disclosure must be made only through a designated Access Valve spokesperson.

Please address any question about whether or not information you acquire in the course of doing your job is proprietary or confidential to your manager.
 

​

B. Records Management/Data Protection

Access Valve has a comprehensive records management policy that all employees are expected to follow. Company records must be maintained or destroyed only in accordance with the established records retention schedule. No employee is allowed to alter, conceal, or destroy documents or records that are subject to an investigation or that may be used in an official proceeding. This includes paper documents and electronic documents such as e-mail.

​

Violations of the Policy

The rights and obligations of employees as described in this policy are a condition of employment for all employees of Access Valve. Failure to comply with this policy may result in disciplinary action up to and including termination.

 

FRAUD

Within Access Valve, “fraud” is defined as the use by an employee of his or her position for personal enrichment through the misuse or misapplication of Access Valve resources or assets.

​

In this context, actions constituting fraudulent behavior include, but are not limited to:

• Removal, misuse or destruction of Access Valve assets.

• The offering or taking of inducements, gifts or favors which may influence the action of any person.

• False accounting – dishonestly destroying, defacing, concealing or falsifying any account, record or document required for any accounting purpose; or furnishing information which may be misleading, false or deceptive.

• Unauthorized disclosure or manipulation of sensitive information.

• Forgery or alteration of any document belonging to the Company.

• Profiteering as a result of insider knowledge of company and customer activities; for the purpose of personal gain, gain for another or with intent to cause loss to another.

• Areas of Access Valve business where risks may be particularly high include:
   

• • letting or managing of external contracts,

  • handling cash, invoices, receipts or accounts,

  • expense claims,

  • payroll including the reporting of flexible hours,

  • handling sensitive information,

  • over seeing high-volume, high-value or high-risk assets.
     

If fraud occurs, Access Valve is obliged to carry out a vigorous and prompt investigation, taking appropriate legal and/or disciplinary action in all cases where that would be justified, and to ensure that any necessary changes to systems and procedures take place immediately to prevent similar frauds from happening again.

​

​

ALCOHOL & DRUG

​

Access Valve is committed to being the industry leader in providing outstanding value to its customers, a safe and stimulating work environment for its employees, and superior returns for its shareholders. Recognizing the potential negative effects of alcohol and drugs on the organization, in particular the hazards that those individuals who abuse alcohol and/or drugs pose to themselves, their co-workers, and the general public, Access Valve has implemented a drug and alcohol policy. Drug and alcohol abuse is not acceptable in the workplace. Access Valve acknowledges its obligation to take all reasonable steps to ensure the health and safety of its workers. This policy provides for the testing of employees for drug/alcohol abuse, assisting employees who voluntarily seek help for problems relating to alcohol and/or drugs, and educating employees on the dangers of drug and alcohol abuse. The Drug and Alcohol policy applies to all employees of Access Valve. This policy may also be extended to subcontractors. For the purposes of this policy, the following are prohibited:

• Being impaired by alcohol/drugs while at work.

• The possession or use of illicit drugs on Access Valve premises, at Access Valve work sites, or in Access Valve vehicles.

• The presence in the body of illicit drugs (or their metabolites) while at work.

• Refusal to submit to drug/alcohol testing, failure to report to an Access Valve-designated facility for a drug/alcohol test, or tampering or attempting to tamper with a test sample.

​

 

HARASSMENT & VIOLENCE PREVENTION

​

Anyone who infringes a right protected by the Alberta Human Rights Act or otherwise engages in acts of discrimination, harassment or violence shall be subject to complaint procedures; remedies and sanctions as outlined in district regulations. The manager shall ensure that new employees receive a copy of this regulation and ensure that it will be profiled at orientations for new Access Valve employees.

​

Definitions

​

“Discrimination” and “Harassment” mean any unwelcome verbal or physical behavior, conduct or communication, directed at an individual that is offensive to that individual and is based on any of the rights identified in the Alberta Human Rights Act, including, but not limited to, gender, marital status, sexual orientation, race, color, religious beliefs, place of origin, ancestry, age, physical disability, mental disability, source of income or family status of that person or class of persons.

​

“Violence” means the attempted, threatened or actual conduct of an individual that causes or is likely to cause injury, and includes any threatening or intimidating statement or behavior that gives an individual reasonable cause to believe that they are at risk of injury. Violence is different than discrimination and harassment and goes beyond being merely “offensive” to aggressive behavior involving physical contact or statements involving threats of physical harm to the individual.

​

Some examples of discrimination, harassment or violence which Access Valve will not tolerate are: verbal or physical abuse, assaults, threats, innuendos or taunting of any individual on the grounds listed above. Further examples include the display of pornographic, racist or offensive signs or images; offensive practical jokes that result in awkwardness or embarrassment; inappropriate invitations or requests, whether indirect or explicit. Sexual advances, request for sexual favors, and other verbal or physical conduct of a sexual nature constitute "Sexual Harassment" when:
 

• Submission to such conduct is made explicitly or implicitly a term or condition of an individual's employment;

• Submission to or rejection of such conduct is used as the basis for decisions affecting an individual's employment, promotion, or movement within Access Valve;

• Such conduct has the purpose or effect of humiliating an individual or substantially interfering with an individual's work performance or creating an intimidating, hostile or offensive work environment.

• Sexual harassment can include, but is not limited to, the following:
   

• • An implied or expressed threat of reprisal for refusal to comply with a sexually oriented request;

  • Inappropriate physical contact (touching, patting, or pinching with an underlying sexual connotation);

  • Unwelcome remarks, jokes, innuendos, or taunting of a sexual nature about an individual's body, attire, age or marital status;

  • Displaying of pornographic or sexist materials;

  • Sexual assault or attempted sexual assault.

​​

No employee or other individual shall commit an act of violence, discriminate against, harass and/or sexually harass another employee or prospective employee or member of the public on Access Valve premises or during Access Valve sponsored activities.

​

Procedure

​

1. Say "NO". No one should ignore an act of discrimination, harassment or violence. Inform the offending individual that his/her behavior is inappropriate, unwelcome and must stop immediately.

2. Stay safe. Employees and other individuals should take all reasonable steps to protect themselves from violence or to prevent themselves from being vulnerable to violence. A physical response to violence is only acceptable for immediate defense of person and shall not extend beyond protection and disengagement.

3. Seek Guidance. Employees should discuss incidents of discrimination, harassment or violence with their manager.

4. File Formal Complaint. Employees or other individuals may file a written complaint with executive management about any act of discrimination, harassment or violence. This process is separate from any legal complaint the individual may make with the police or other authority.

​​

Timelines

​

All written complaints must be received with six (6) months from the date of the alleged discrimination, harassment or violent behavior or from the date on which the most recent (last) discrimination, harassment or violent behavior is alleged to have occurred. A written complaint outside of this time frame may be considered by consulting executive management.

 

INFORMATION SYSTEMS USAGE

​

The hardware and licensed software available at Access Valve are intended for use by Access Valve employees. Use of these resources by anyone outside Access Valve requires approval. Users shall not disclose confidential passwords, access codes, account numbers or other authorization assigned to them.

​

• Users of information technology are expected to use the systems in a manner that preserves the privacy of others. Users shall not attempt to gain access to the files or directories of another user without clear authorization from the other user. Users shall not attempt to intercept any network communications, such as electronic mail or user-to-user dialogue.

• Users must not attempt unauthorized access or otherwise interfere with computing and communication installations external to Access Valve. Activities engaged in by users with the intention of interfering with or altering the integrity of computing or communication systems at Access Valve are unacceptable. Such activities include unauthorized use of accounts, impersonating other individuals in communications, attempts to capture or decode passwords or encryption, and destruction or alteration of data or programs belonging to other users. The willful introduction of computer viruses into the Access Valve Energy computing environment or other environments via the Access Valve network is unacceptable. The intention to restrict or deny access by legitimate users to the system is unacceptable.

• Damage, destruction or theft of hardware, software, data or related equipment is unacceptable.

• Users must not attempt to access or copy the programs and information belonging to or licensed to Access Valve or to other users unless they have proper authorization to do so. Programs and data may not be moved from one computing system to another without permission. The terms and conditions in software licenses vary considerably. The onus is on users/owners to familiarize themselves with their responsibilities and abide by limitations under each agreement.

• Users must use computing and communication facilities and services only for the purposes for which they were authorized. Specifically, instructional, research, and administrative accounts must not be used for private consulting or sold to other individuals; use of any part of the computing facility for direct personal financial gain (except for appropriate contract and external accounts) or to provide free resources for unauthorized purposes is not allowed. When outside professional activities of users would involve the use of the Access Valve's computing and communication facilities, approval shall be obtained from executive.

• Users must be sensitive to the public nature of shared facilities and must not print or display on screens in such locations images, sounds or messages which are likely to create an atmosphere of discomfort or harassment for others.

• Users must not use computing and communication facilities to send, print or display obscene or harassing messages. Every user bears the primary responsibility for the material he or she chooses to access, send, or display. The facilities may not be used in any manner to create, send or display material which contravenes relevant policies or statutes. Users are directed to the provisions of the Alberta Human Rights Code and the Criminal Code of Canada for assistance in determining whether any images, sounds or messages may be considered harassing or obscene.

• Users of e-mail and other electronic communications tools are required to use these resources in a responsible manner consistent with other business communications such as written correspondence and the phone.​​

• Responsible use of e-mail includes:

  • Not 'rebroadcasting', i.e. forwarding e-mail that is deemed confidential by the sender to third parties

  • Not posting materials that contain virus hoaxes or spam

  • Not sending e-mail in such a way that disrupts normal e-mail service

  • Not sending materials that are fraudulent, defamatory, harassing or of a threatening nature

  • Not unlawfully soliciting or exchanging copies of copy-righted material by e-mail

  • Users should clearly identify themselves through an e-mail signature that specifies their name, position, and contact information; this can also include an affiliation with another institution or agency connected with their official work, if any. Any action that defrauds another or misrepresents or fails to accurately identify the sender is considered to be an inappropriate use of e-mail.

​

POLITICAL CONTRIBUTIONS

Access Valve does not make contributions or payments or otherwise give any endorsement of support which would be considered a contribution to political parties or candidates. Furthermore, Access Valve does not use corporate funds to make contributions to political candidates, political parties, political committees, or other such political entities.

 

PUBLIC DISCLOSURE OF INFORMATION

In the event that the company elects to publicly disclose material, non-public information, such disclosure must be made only through a designated company spokesperson, such as, President, Vice President, or any other authorized person.

 

LOBBYING ACTIVITIES

​

Principles to be observed in lobbying activities:

• Professionalism-Lobbying activities always have to be conducted in a fair and professional manner, based on the highest ethical and moral standards. Any impression of inappropriate behavior is to be avoided.

• Compliance with legal provisions-Any lobbying activity conducted must be in compliance with the applicable legal provisions.

• Candour-Obtaining information in the course of lobbying activities in a dishonest manner or any attempt to do so is forbidden. Any inappropriate behavior or pressure on officials is to be abstained from.

• Prohibition of corruption-Granting, offering and promising inadmissible advantages to officials is forbidden. Participation in any activities that may appear to be corrupt or illegal is to be abstained from.

• Honesty-Corporate lobbyists provide open, comprehensive and truthful information on their lobbying activities, their employer and the specific causes pursued by the latter. In the conduct of lobbying, lobbyists are to provide officials and other stakeholders with up-to-date and correct information at any time.

• Integrity / Confidentiality-The highest level of integrity is to be observed in the conduct of lobbying. Any information received as confidential in the course of lobbying activities is to be protected from disclosure to individuals from outside the company. Unless required by law or by the public authorities, such information must neither be disseminated nor used for purposes other than those intended in its disclosure.

• Conflicts of interest-Any action that would expose officials to a conflict of interest is to be avoided. This applies, in particular, if there are grounds to assume that officials would be influenced in the unbiased exercise of their office through such action. Persons conducting lobbying activities have to gather prior information on any restrictions and incompatibility rules which the official is subject to, provided such rules have been publicly communicated, and consider such information in their lobbying activities.

 

REPORTING OF BUSINESS EXPENSES

Access Valve’s financial, accounting and other reports and records will accurately and fairly reflect the transactions and financial condition of the Access Valve in reasonable detail, and in accordance with generally accepted accounting principles, practices, procedures and legal requirements. No one will authorize payment knowing that any part of the payment will be used for any purpose other than what is described in documents supporting the payment. Everyone will exercise integrity, prudence and sound judgement when they incur and approve business expenses. They must be reasonable and necessary for business reasons. Expenses incurred in the performance of Access Valve business will be reimbursed in accordance with Access Valve policy, through the filing of expense reports, which must be documented accurately and completely.

 

CODE OF CONDUCT VIOLATIONS

Employees of Access Valve have a duty to report violations of this Code. Access Valve engages in business activities that are rooted in public trust. Access Valve’s continued success depends on maintaining its ethical reputation. Reasons such as, "everyone does it," or "it's not illegal," are unacceptable as excuses for violating the Code. The Code of Conduct will be enforced at all organizational levels. Violations of the Code will be taken extremely seriously and will result in prompt disciplinary action, which may include termination of employment. If any breach of the Code violates the law, civil or criminal legal proceedings may also result. As appropriate, an impartial investigation will be conducted. Access Valve will strive to protect the anonymity of anyone who in good faith reports suspected Code infractions. All concerns, questions and complaints will be taken seriously and handled promptly, confidentially and professionally. No retaliation will be taken against any employee for raising any concern, question or complaint in good faith. Access Valve wishes to encourage an open culture where all concerns expressed in good faith will be investigated and, if appropriate, acted upon.