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About Canway
Applying the highest standards of excellence to the relocation and storage of the customers belongings
COMPLIANCE WITH LAWS AND REGULATIONS
Canway is committed to full compliance with the laws, rules and regulations of the cities and states in which it operates. You must comply with all applicable laws, rules and regulations in performing your duties. Where you think a conflict exists between these Standards and an applicable law, rule or regulation, or if you have a question concerning the legality of your or other staff’s conduct, you should consult with your manager or another party.
Members of the Board of Directors and corporate officers have fiduciary duties and other legal obligations. To the extent that these Standards conflict with those fiduciary duties and other legal obligations, Directors and corporate officers must act in accordance with those duties and obligations, unless these Standards impose higher standards of conduct, in which case Directors and corporate officers should follow these Standards. All other staff, too, should follow these Standards when they impose a standard that is higher than the applicable law.
CONFLICTS OF INTEREST
We all must avoid conflicts of interest. A conflict of interest exists when a personal interest or activity interferes or appears to interfere with the duties that you perform at or owe to Canway. A conflict of interest may unconsciously influence even the most honest person and the mere appearance of a conflict may cause staff members acts to be questioned. We all must avoid situations that affect or appear to affect our ability to act in the best interests of Canway.
You should carefully review your own situation for any conflicts of interest. You must disclose any conflicts or potential conflicts to your manager. In consultation with the Corporate Compliance Program and the Law, your manager will determine whether a conflict or potential conflict exists and whether any corrective action should be taken.
Members of Canway Board of Directors and Canway corporate officers have a special responsibility to avoid conflicts of interest because of their high visibility in the business community and in the community generally. Many Directors and corporate officers have substantial business and personal interests outside of Canway. Members of the Board of Directors should disclose any actual, potential or apparent conflicts to the Chair of the Audit and Compliance Committee of the Board of Directors. Officers and all other partners should disclose actual, potential or apparent conflicts to the Chief Compliance Officer. All staff members, including Directors and officers, with actual, potential or apparent conflicts should recue themselves from the decision-making process with respect to any matter involving the conflict.
Some situations in which conflicts of interest may arise, and therefore should be avoided, are:
Being employed by or operating a firm (including consulting) which does or desires to do business with Canway or which competes with Canway (for example, working in a competitor’s company)
Making a substantial direct investment in such a firm (by you or a member of your immediate family)
Engaging a family member to perform services for Canway
Acting on behalf of anyone besides Canway in any transaction with Canway (for example, helping someone sell products and/ or services to Canway)
and
Engaging personally in real estate or other transactions in which Canway has an interest
These examples do not cover all conflicts of interest. If you have any questions about this policy or any situation you may have, please contact your manager or the staff Resources department, or call the Helpline. Your department or business unit may have more detailed guidelines on these issues.
GIFTS AND ENTERTAINMENT
Canway desires to treat fairly all persons and companies with whom it does business, such as its customers and suppliers. Giving or accepting valuable gifts or entertainment might be construed as an improper attempt to influence the relationship.
You may not give or receive a gift with a market value of more than $75 per year to or from someone who does or would like to do business with Canway. A gift of money should never be given or accepted (except that our on site staff may accept customary tips for packing, moving and/or unpacking services well done). A gift of nominal value may be given or accepted if it is a common business courtesy. A gift or favor should not be accepted or given if it might create a sense of obligation, compromise your professional judgment or create the appearance that it might. In deciding whether a gift is appropriate, you should consider whether public disclosure of the gift would embarrass you or Canway.
You may not encourage or solicit meals or entertainment from anyone with whom Canway does business or from anyone who desires to do business with Canway. Staff may offer or accept meals and entertainment if it is reasonable and customary, occurs infrequently and is not expensive.
Canway prohibits offering, giving, soliciting or receiving any form of bribe or kickback.
There are serious penalties, including criminal sanctions, for engaging in this conduct. Any staff member who engages in such conduct will be disciplined, which may include immediate dismissal.
If you have any questions about this policy, please talk to your manager, contact the staff Resources department, or call the Helpline.
SALES PRACTICES AND ADVERTISING
In all sales and advertising, Canway competes on the merits of our products and services. Our communications with our customers or potential customers must be truthful and accurate. When we say something about our products and services, we must be able to substantiate it. We sell the quality of what we do; we do not disparage or take shots at our competitors.
If you are involved in advertising, be sure that the Law and Corporate Affairs department reviews any advertising material before it is used.
OUT OF TOWN BUSINESS
Canway will observe the highest ethical standards in all business transactions. Canway should not conduct business in any city in a way that would be illegal or improper in Canada. In addition, all staff must follow applicable laws when conducting Canway business.
All our staff must comply with all Canadian laws regarding customs and trade. Canway will be accurate and truthful in representing national business transactions to government agencies. All information that our staff members furnish to any Customs official or to any agent which Canway may have hired must be accurate and truthful. If you conduct business nationally on behalf of Canway, please make sure you have a thorough understanding of these laws.
ANTITRUST AND FAIR COMPETITION
The laws of Canada are intended to promote vigorous competition in a free market. It is in Canway’s best interest to promote free and open competition. Canway must make its own business decisions, free from understandings or agreements with competitors that restrict competition. While it is beyond the scope of this policy to explain the laws in detail, Canway considers compliance with these laws of vital importance. The following principles must be observed by each staff member conducting business on behalf of Canway.
Agreements or understandings with competitors, whether written or not, on such matters as prices, terms or conditions of sale, limits on production, division of territories or customers, and boycotting of third parties not only are bad business practices, but are often criminal violations. As a result, they cannot be defended or justified no matter how well intended. Agreements or understandings with customers regarding resale prices are also unlawful.
Price discrimination is unlawful. Price discrimination occurs when two or more purchasers who compete with each other pay different prices or receive different terms or conditions of sale for the same service, and the difference in price, terms or conditions of sale is not justified.
Although it is usually a seller who commits unlawful price discrimination, a buyer will violate the law if it induces the seller to give the discriminatory price and the buyer has reason to know the price difference cannot be justified. Justifications include meeting a competitive price offer, equal availability, changed conditions and savings in the actual cost of manufacture, transportation or sale. Rebates, commissions and other forms of support, if not available to all customers, may be unlawful.
When in doubt about compliance with the antitrust laws, staff must seek the advice of Canway’s Law associates. In conducting Canway business, each staff member must:
Compete vigorously and ethically
Treat all suppliers objectively, honestly and fairly
Not discuss pricing, production or markets with competitors or customers
Not set resale prices with customers or suppliers
Avoid any practice that could be characterized as unfair or deceptive and always present Canway services and products in an honest manner
Not induce a third party to breach an existing agreement
Never make a claim about a product without factual support
Never criticize a competitor’s product without specific proof that the statements are true (we focus on the positive aspects of Canway)
Never act in a manner which could be interpreted to exclude present or potential competitors or to control market prices
and
Make clear to all suppliers and potential suppliers that Canway expects them to compete fairly and vigorously for Canway business and Canway will select its suppliers using high business and ethical standards
The following types of arrangements with suppliers or customers may be unlawful and should not be entered into without the approval of Canway’s Law associates:
Exclusive dealing (the agreement of a supplier not to sell to a competitor or the agreement of a customer not to buy from a competitor)
Tie-in sales (requiring a customer to buy an unwanted product as a condition of purchasing a desired product)
Staff members who address pricing, determine who will serve what markets or interact with competitors should consult with a Law associate.
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