DOC

COMPLAINT AND CONCERNS PROCEDURES FOR ACCOUNTING, INTERNAL

By Carl Lawson,2014-05-15 19:30
5 views 0
COMPLAINT AND CONCERNS PROCEDURES FOR ACCOUNTING, INTERNAL

    EXPERTECH NETWORK INSTALLATION INC.

    COMPLAINTS AND CONCERNS PROCEDURES FOR ACCOUNTING, INTERNAL ACCOUNTING

    CONTROLS, AUDITING AND OTHER MATTERS

    OBJECTIVE AND SCOPE

In keeping with the commitment of the Corporation and its subsidiary to maintain high ethical

    standards in their business practices, the Corporation’s Financial Reporting Committee has established these procedures for:

    ? The receipt, retention and treatment of complaints and/or concerns received by the

    Corporation or its subsidiary from any person, regarding accounting, internal accounting

    controls or auditing matters of the Companies; and

    ? The confidential submission by employees, of concerns regarding questionable

    accounting or auditing matters.

POLICY OVERSIGHT

The Expertech Financial Reporting Committee has the ultimate responsibility for the stewardship

    of this Policy. Under the direction of the Expertech Financial Reporting Committee, the

    Corporation’s Vice President, Human Resources shall administer these Procedures and ensure compliance by the Corporation and its subsidiary.

COMMUNICATION

All employees and all directors and officers of the Corporation and its subsidiary shall have

    access to a copy of these procedures. These procedures shall also be posted on Expertech’s

    website and all intranet websites of the Corporation and its subsidiary.

REPORTABLE ACTIVITIES

The following activities shall be reported promptly to the appropriate channel of communication:

    ? Any concerns or complaints with respect to the Corporation’s or its subsidiary’s

    accounting, internal accounting controls, or auditing matters; or

    ? Evidence of an activity by an employee, director or officer of the Corporation or its

    subsidiary that may constitute:

    o Corporate fraud;

    o Violation of federal or provincial laws; or

    o Misappropriation of any property of the Corporation or its subsidiary.

REPORTING A REPORTABLE ACTIVITY

A report should, to the extent possible, provide sufficient, precise and relevant information

    (pertaining to dates, places, persons involved, witnesses, and amounts involved) with respect to

    the reportable activity.

A. IN PERSON OR IN WRITING

A reportable activity could generally be reported, either in person or in writing, to the employee’s

    immediate manager. However, if such reporting is either inappropriate in the circumstances,

     54861872.DOC 1

    EXPERTECH NETWORK INSTALLATION INC.

    COMPLAINTS AND CONCERNS PROCEDURES FOR ACCOUNTING, INTERNAL ACCOUNTING

    CONTROLS, AUDITING AND OTHER MATTERS

    does not, in the employee’s opinion, provide the necessary level of confidentiality, or as the employee otherwise prefers, the reportable activity should be reported to the Vice President,

    Human Resources of the Corporation.

B. BY TELEPHONE

To report a reportable activity by telephone, any employee of the Corporation or a member of the

    public can call the Corporations toll-free reporting line at 1-866-484-3199. There will be no caller

    identification and no call-return on this line. If a reporter is unwilling to leave a message

    regarding the substance of the report but is willing to forfeit anonymity, he/she should leave

    his/her name and details as to where he/she can be reached.

    PROTECTION OF REPORTERS AND CONFIDENTIALITY

The Corporation and its subsidiary are committed to:

    ? Maintaining procedures that permit confidential reporting of a reportable activity; and

    ? Providing a work environment based on trust and respect and enabling all employees to

    work without fear of intimidation, discrimination or violence. No reporting by a reporter

    acting in good faith of a reportable activity or of information relating to the investigation of

    a reportable activity shall result in any retaliation against the reporter.

Any retaliation against a reporter shall be treated as a serious violation of these procedures.

    Corrective measures of varying degrees of severity, including but not limited to discharge without

    notice, can be taken against any person who is determined to have engaged in any retaliation

    against a reporter.

Information regarding the identity of a reporter shall remain confidential at all times, except as

    otherwise expressly permitted by the reporter or as required by applicable law. Confidential

    information relating to a report and any questions regarding these procedures, a reportable

    activity or a report shall only be disclosed to those persons who have a need to know and only to

    the extent to which they need to know such information to properly carry out an investigation of

    the reportable activity, in accordance with these procedures.

No record of a report will be placed in the personnel file of any reporter who is an employee.

    Instead, any such record shall be kept in a separate and confidential file, for a period of no less

    than three (3) years.

PROCEDURES FOR HANDLING THE REPORTING OF A REPORTABLE ACTIVITY

Any employee of the Corporation or its subsidiary who receives a submission from any person

    regarding a reportable activity shall immediately report such submission to the Vice President,

    Human Resources of the Corporation (if the reportable activity does not involve her) or notify the

    President and Chief Executive Officer of the Corporation (if the reportable activity does involve

    the Corporation’s Vice President, Human Resources), regardless of the materiality of the

    allegation.

The Vice President, Human Resources, upon receipt of a submission from any person regarding

    a reportable activity, shall:

     54861872.DOC 2

    EXPERTECH NETWORK INSTALLATION INC.

    COMPLAINTS AND CONCERNS PROCEDURES FOR ACCOUNTING, INTERNAL ACCOUNTING

    CONTROLS, AUDITING AND OTHER MATTERS

    ? Notify the Corporation’s President and Chief Executive Officer of the report (if the

    reportable activity does not involve him) or notify the Corporation’s Chairman of the

    Board (if the reportable activity does involve the Corporation’s President and Chief

    Executive Officer); and

    ? Review and assess the seriousness of the reportable activity and investigate such

    reportable activity as appropriate.

Investigations of a reportable activity will be conducted as quickly as reasonably possible, taking

    into account the nature and complexity of the reportable activity and the issues raised in the

    report. The Vice President, Human Resources shall, as appropriate and whenever possible,

    report back to the reporter on the status of the investigation.

The Vice President, Human Resources shall prepare a report to the Corporation’s Financial

    Reporting Committee on a timely basis for each meeting of the Financial Reporting Committee, or

    upon their request, showing the number and nature of all reports received since the last meeting

    or request for such information, describing how such reports were handled, the results of any

    investigation, and any corrective action taken.

CONTACT PERSONS

Any questions with respect to the general application of this policy, to any report, or any

    reportable activity, should be directed to the Corporation’s:

Vice President, Human Resources

    Ms. Karen Hunt

    Tel (705) 721-3075

    E-mail: khunt@expertech.net

Vice President, Finance & Administration

    Mr. Nicolas Siou

    Tel (514) 255-6665 x3235

    E-mail: nsiou@expertech.net

President and Chief Executive Officer

    Ms. Lynn Loewen

    Tel (514) 255-6665 x2254

    E-mail: lloewen@expertech.net

Expertech Financial Reporting Committee Chairman

    Mr. Bernard le Duc

    Tel (514) 870-8276

    E-mail bernard.leduc@bell.ca

Updated : February 20, 2009

     54861872.DOC 3

Report this document

For any questions or suggestions please email
cust-service@docsford.com