Last Revised July 2009
The AccessPrivacy Code of Business Conduct describes our values and collective commitment to ethical business practices and regulatory compliance. All Members of our Team1 are responsible for understanding and complying with the Code of Business Conduct and any other applicable laws, regulatory requirements and policies, at all times. The Code of Business Conduct is supplemental to any rules of professional conduct or similar requirements applicable to lawyers in each province.2
Our reputation is the foundation of our business, and we will do all we can to protect it to achieve our goal of being Canada’s leading provider of privacy, compliance and information governance services.
Our core values The following values guide our behaviours: Integrity We exhibit integrity by always interacting with our clients and each other ethically and honourably. Respect We exhibit respect by fully considering the diverse needs of our clients and others and always striving to be open, honest and transparent. Entrepreneurial spirit We use our entrepreneurial spirit and high levels of knowledge and experience to bring creative solutions to our clients. Accountability We exhibit accountability by always striving to meet the expectations of our clients for high-quality and exceptional products and services.
1. Integrity
We recognize that ethical behaviour is best for AccessPrivacyHB, even if that means putting aside short-term interests. We are committed to acting with honesty and integrity and in compliance with applicable laws and regulatory requirements. Professionalism We are committed to discharging all of our assignments with diligence and skill. Business development We will not adopt any method of obtaining or maintaining business that detracts from the professional reputation of AccessPrivacyHB or its employees. Gifts and entertainment Employees are expected to use good judgment and discretion when giving or accepting gifts or entertainment in business settings. In general, the giving and accepting of gifts and entertainment are appropriate if the gift does not, or does not appear to, affect the recipient’s objectivity. All employees are responsible for understanding and complying with Heenan Blaikie LLP policies that address issues relating to gifts and other benefits.
2. Respect We manage our business responsibly in order to maintain the respect and confidence of our clients, the public and each other. We strive to be open, honest and respectful in sharing our ideas and thoughts, and receiving input. Harassment and Discrimination We are committed to a harassment-free work environment in which our employees, clients and others are treated with respect and dignity. This includes creating a work environment that enables us to attract and retain a diverse workforce. All employees are responsible for understanding and complying with Heenan Blaikie LLP policies and applicable laws and regulatory requirements on harassment and discrimination. Complaints of harassment or discrimination are treated seriously, confidentially and with sensitivity. Conflicts of interest Employees are expected to act in the best interest of AccessPrivacyHB and to exercise sound judgment unclouded by personal interests or divided loyalties. Both in the performance of our duties for AccessPrivacyHB and our outside activities, we seek to avoid the appearance of a conflict of interest, as well as an actual conflict of interest. All employees are responsible for understanding and complying with Heenan Blaikie LLP policies and applicable laws and regulatory requirements on conflicts issues. Securities trading In the course of doing business for AccessPrivacyHB, we may become aware of confidential information about publicly traded companies. Some confidential information is sensitive enough that, if other people knew it, they would consider it important in deciding whether to buy or sell that company’s securities, or it could be reasonable to expect that the price of the securities would be significantly affected. This kind of information is commonly called inside information. We discuss this information on a limited basis, and do not pass on (or “tip”) inside information to anyone except those persons who need to know that specific information in the necessary course of business. All employees are responsible for understanding and complying with Heenan Blaikie LLP policies and applicable laws and regulatory requirements that address issues relating to insider trading and tipping.
3. Entrepreneurial spirit We encourage collaboration, take pride in each others’ accomplishments and build and nurture long-standing, mutually gratifying client and other relationships. We believe our spirit and entrepreneurial energy enriches our work environment and serves to advance the interests of our clients.
4. Accountability
We strive to meet the expectations of our clients for high-quality and exceptional service, and we continually seek new ways to improve our products, service and responsiveness. Product and service value We are committed to providing timely, cost-effective service by working closely with our clients to achieve their objectives in the most practical and efficient manner. Confidentiality Protecting the confidentiality of client dealings with us is essential to safeguarding our reputation. All client information is presumed to be confidential information unless the contrary is clear. All employees are responsible for the safeguarding and appropriate handling of any confidential information entrusted to them in compliance with Heenan Blaikie LLP policies and applicable laws and regulatory requirements. Document retention We create, retain and dispose of our business records, both written and electronic, as part of our normal course of business in compliance with Heenan Blaikie LLP policies and applicable laws and regulatory requirements.
Any employee who believes they may have breached the AccessPrivacyHB Code of Business Conduct has an obligation to report it to the Managing Director & Head immediately. Employees also have an obligation to promptly report actual or perceived breaches of the Code of Business Conduct by another employee or contractor, and AccessPrivacyHB will protect from retaliation any employee who reports such breaches in good faith.
Consequences of failing to comply with the Code of Business Conduct Adherence to the AccessPrivacyHB Code of Business Conduct is a condition of employment. Any breach will be treated as a serious matter, and may result in discipline up to and including termination.
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1"Members of our Team" means any full-time, part-time, temporary or contract lawyer, employee or contractor of Heenan Blaikie LLP and HB Global Advisors Corp. that provides legal, consulting or information services under the AccessPrivacyHB name. 2 These rules of professional conduct, codes of ethics or similar requirements also apply to non-lawyer employees of Heenan Blaikie LLP and HB Global Advisors Corp. To download our Code of Business Conduct please click here.