Ethics and Conduct Policies
All employees are bound by either (i) the Code of Ethics and Conduct or (ii) the Financial Management Code of Ethics and Conduct.
Every employee must acknowledge that they agree to abide by the Code. In addition, all senior management and staff involved in financial reporting and disclosures sign-off on a separate Financial Management Code of Ethics and Conduct.
The Code shall be discussed with employees and shall be placed in prominent places as follows:
- Employee handbooks and new employee orientations;
- Company websites and intranets;
- Periodic employee performance reviews.
Code Of Ethics and Conduct
The most important asset of FirstService Corporation and its subsidiaries ("FirstService" or the "Company") is our employees and their relationship and reputation with our customers. Our reputation is a valuable asset that reflects personally on every employee. Therefore, each employee, officer and director of FirstService has an obligation to protect our reputation and must abide by the highest standards of honesty and integrity. In conducting our daily business and striving to meet our goals we must ensure that we abide by the following principles.
- Act with honesty and integrity in all matters.
- Act in a manner that will not discredit the Company.
- In representing the Company and carrying out the Company's business, conduct yourself with the highest ethical standards. Never conduct or condone business in a corrupt manner.
- Comply at all times with government laws and regulations in the conduct of business either at home or in a foreign country.
- Ensure that all of your activities are free from any conflict of interest between you and the Company or a customer or supplier.
- Not accept anything of value that could be described as an inducement or which could impair your judgment in making a decision which is in the best interest of the Company.
- Maintain all Company, client and supplier information in the strictest of confidence.
- Protect the Company's, confidential or proprietary information and never use this information for personal gain or to the detriment of the Company's competitive position.
- Before communicating with the press, ensure that such communication complies with the Company's guidelines and is approved by the Company's CEO.
- For those employees having financial reporting responsibilities, ensure full, fair, accurate, timely, and understandable disclosure of information in reports and documents that are filed with FirstService or any of its subsidiaries and with all regulatory bodies.
It is the responsibility of every employee to report any deviation from this Code of Conduct and Ethics to your supervisor or Company's senior financial officer. If in doubt, ask.
Financial Management Code of Ethics and Conduct Policy
Policy statement covering ethical and disclosure obligations for all officers, senior management and financial or accounting personnel with financial reporting or disclosure responsibilities.
FirstService Corporation ("FirstService" or the "Company") is committed to maintaining high ethical standards related to our financial reporting processes and internal controls. As a public company, it is of critical importance that all filings by FirstService with all applicable securities regulators and any other public communications be accurate, complete and timely. As a result, FirstService expects all employees involved in the financial reporting and disclosure processes to take this responsibility very seriously and this commitment must be supported by the highest level of ethical standards. This Financial Management Code of Ethics and Conduct (the "Code") embodies these principles.
All officers, senior management and financial or accounting personnel with financial reporting or disclosure responsibilities within FirstService and its subsidiary companies have a special role both in meeting these responsibilities and also in promoting a culture throughout the Company that ensures the accurate, complete, fair and timely reporting of FirstService's operating results and financial condition.
Employees bound by this Code include:
- Chief Executive Officers and Presidents
- Chief Financial Officers, Vice Presidents of Finance, Controllers
- Business Unit Presidents
- Other senior financial and accounting personnel with financial reporting or disclosure responsibilities as may be designated by the CEO or CFO of FirstService Corporation
Each such person receiving this document agrees that he or she will:
- Act with honesty and integrity, avoiding any actual or apparent conflicts of interest. Proactively promote the highest principles of honesty and integrity and be an example of ethical behavior as a responsible employee within FirstService.
- Provide full, fair, accurate, timely and understandable financial information and disclosures in all reports and documents that the Company files with, or submits to, government and regulatory agencies, self-regulatory bodies and stock exchanges and in all other public communications.
- Comply with all rules and regulations of federal, state, provincial and local governments and applicable public and private regulatory agencies or bodies and act as appropriate based upon one's position with FirstService to assure that the Company complies with all such rules and regulations.
- Act in good faith, responsibly, with due care, competence and diligence, without misrepresenting any material facts relating to FirstService or allowing one's independent judgment to be subordinated or compromised.
- Respect the confidentiality of information acquired in the course of one's work duties and responsibilities with the Company, except when authorized or otherwise legally obligated to disclose such information. Confidential information acquired in the course of one's work duties and responsibilities will not be used for personal advantage.
- Share knowledge and maintain professional skills important and relevant to the needs of one's work duties and responsibilities and to fellow employees.
- Protect the Company's assets and resources and help ensure that they are used only for the Company's legitimate business purposes.
- Promptly report any fraudulent, other improper activity or non-compliance with this Code committed by any person employed by FirstService or any of its subsidiary companies, including, but not limited to, one's immediate manager, any member of senior management, or anyone who has any significant responsibility over internal financial reporting controls of FirstService or its subsidiary companies.