Revised October 1, 2014
The easyhome Code of Business Conduct (the "Code") has been designed to promote a responsible and ethical work environment for all easyhome affiliated companies and subsidiaries and its employees and directors. The Code contains guidelines on proper behaviour in the workplace and who you should contact if you have specific questions or concerns.
References in the Code to easyhome or the Company are generally intended to mean easyhome Ltd. and all of its affiliated companies (including RTO Asset Management Inc., easyfinancial Services Inc., easymortgages Inc., and easyhome U.S. Ltd.) as a group, where applicable.
In doing your job, you are responsible for abiding by easyhome policies and all municipal, provincial, and federal laws in Canada or other jurisdictions as appropriate. You are responsible for knowing and following the laws and policies that relate to your job, including the policies in the Code and all other Company policies, including but not limited to the Code, Operations Manuals, Management and Policy manuals, Employee Handbook and any other applicable operating standards or procedures. Violating these policies may result in disciplinary actions up to and including termination of employment, recovery of damages and filing of criminal charges. It is your responsibility to ask questions, make appropriate disclosures, and bring potential problems to Management's attention.
All employees, managers and directors throughout the term of their employment shall i) diligently, honestly and faithfully serve the Company and shall use their best efforts to promote and advance the interests and goodwill of the Company; ii) conduct themselves at all times in a manner which is not prejudicial to the Company's interests; and iii) devote 100% of their full time and attention to the business and affairs of the Company generally and specifically to their duties hereunder. All employees must adhere to the Privacy laws of each of the provinces, as well as those established on a federal basis, in Canada or other jurisdictions as appropriate.
Over time, new policies may need to be presented/introduced and existing policies revised. While the Company reserves the right to make these changes with or without notice, the Company will try to let you know about any changes affecting your employment as soon as possible.
The provisions of this Code may only be waived by the Company's Board of Directors for all senior management positions, and the CEO for all other positions (i.e. employees may not relinquish their rights under the Code without approval from the CEO or Board of Directors). Any waiver of this Code for an executive officer or director will be promptly disclosed as required by law or applicable stock exchange regulation.
easyhome maintains a third party Confidential Hotline (MySafeWorkplace.com) that can be used to report suspected violations of the Code or illegal activities. This number is 1-800-461-9330. Any issues brought forward through the Confidential Hotline are reported directly to the internal Human Resources and Legal Departments. Fraud related reports are reported to the Chair of the Audit Committee of the Company. The Chair of the Audit Committee receives a consolidated report of all complaints recorded with the third party Hotline.
If you are an employee in need of assistance due to personal, health or family reasons, please contact our EAP provider. The number is available on the Company's intranet, posted in each location, or by contacting the Human Resources Department at 905.272.2788.
It is important to report all violations or suspected violations of the Code. If you have a question about the policies outlined in the Code, talk to your supervisor. If you are not an employee of the Company, contact the Hotline directly. If you want to report a suspected violation, contact the Confidential Hotline. Reports to the Hotline may be made anonymously. Confidentiality for those who report will be maintained to the extent possible. Neither your supervisor nor the Company will take any action against you for reporting suspected misconduct in good faith. Additionally, reports can be mailed to the attention of the Human Resources and/or Legal Department
It is against Company policy for any supervisor or any employee to take any action against another employee, director, a vendor or any other third party which has lawfully provided information, assisted in an investigation or otherwise disclosed information to a government agency when the person has a reasonable belief that the information is true and reveals a violation of or noncompliance with applicable law and/or Company policy. If you believe that you have been the subject of such retaliation, contact the Confidential Hotline immediately.
If you know that someone is carrying on business in a way that is counterproductive to a safe work environment or involves any illegal activity, it is your responsibility to speak up. Contact the Human Resources department or the Confidential Hotline. All reports are confidential and will be investigated.
easyhome employees and directors are required to comply with all applicable laws in Canada or other jurisdictions as appropriate. Any instance of non-compliance with applicable laws may subject the employee to corrective action up to and including termination of employment, recovery of damages, and filing of criminal charges.
If the Code or the Company requires you to take an action or prohibits you from taking action that you believe is in violation of a law, or if you believe there is a conflict between the applicable laws of two or more jurisdictions, please speak with Human Resources or contact the Confidential Hotline.
The Company acknowledges that there are differences in local laws and practices. In some instances, the Code establishes policies and/or requirements that would not otherwise be required in some jurisdictions. In keeping with the Company's commitment to meet the highest standards of business conduct wherever it does business, all employees and directors must comply with all aspects of the Code, even if local laws do not require it. Conversely, there may be laws in certain jurisdictions that may not specifically apply outside of those jurisdictions, and therefore, are not specifically addressed in the Code. You are responsible for knowing and following all such laws and policies that relate to your job.
Throughout this Code, references to "applicable laws" include any law, rule or regulation applicable to the Company or its employees or directors.
You must always deal fairly and honestly with the Company's customers, suppliers, vendors, competitors and employees. You must not take unfair advantage of anyone through manipulation, concealment, abuse of confidential information, falsification, misrepresentation of material facts or any other intentional unfair dealing practice.
Employees or agents of the Company must never directly or indirectly offer, promise to pay or authorize the payment of money, products, services or anything of value to any government official or agent in any country or jurisdiction in order to influence acts or decisions of government officials, to receive special treatment for the Company or for personal gain. All easyhome employees must abide by local laws. Employees working with government officials should request further guidance from the President & CEO, Chief Financial Officer or General Counsel. For more information, contact the Confidential Hotline.
As an easyhome employee or director, you are not allowed to trade securities or to tip others to trade securities of easyhome or other companies when you are aware of material information that has not been made available to the public. Material information is any information that could be considered important by a person in deciding whether to trade in a company's stock. Examples include but are not limited to the following: information relating to sales, inventory, margins, earnings, significant proposed acquisitions, planned stock splits, proposed changes in dividends and other information that has the potential to affect the stock price of easyhome or another company. As a general rule, if the information makes you think of buying or selling the stock of easyhome or another company, it probably would have the same effect on others and likely is material information.
Once material information has been fully disclosed to the public, employees may trade in the Company's stock. Full public disclosure generally means a widely distributed press release followed by three or more days for distribution and interpretation of the information. If you are unsure whether information is material or has been released to the public, contact the Chief Financial Officer or the President & CEO before trading.
Trading on inside information can have severe consequences. Each provincial Securities and Exchange Commission and/or similar agencies are authorized to bring a civil lawsuit against anyone who trades on inside information (or who provides another person with inside information) and also against the Company. Insider trading is also a crime subject to criminal penalties, including jail terms.
In addition to the restrictions on Insider Trading noted above, all senior Company employees (directors, divisional vice presidents, vice presidents, senior vice presidents and president) and all directors must adhere to the Company's blackout periods without exception. The Company's blackout periods generally begin two weeks prior to the end of a fiscal quarter and end two business days following the release of the financial results for that fiscal quarter. Furthermore, any senior Company employee or director wishing to purchase Company stock must first obtain approval in writing from the President & CEO.
easyhome is committed to minimizing any negative impact of our business activities on the environment. All employees are responsible for complying with applicable environmental laws and Company policies.
All collections activities will be in line with the Company's retention practices and in accordance will local and federal laws.
The Company is an Equal Opportunity Employer. Fair employment practices maintained throughout our operations are designed to prevent discrimination on the basis of any protected status.
The Company will ensure that all hiring, training, transfer and promotion decisions are in accordance with equal employment opportunity principles and legislative requirements.
The Company recognizes that each human being has the right to be treated fairly, without distinction, exclusion or preference.
The Company recognizes that all its personnel have the right to work without sexual or racial harassment and will do everything in its power to enforce this statement. Sexual or racial harassment may be defined as an attitude that translates into words, actions or gestures of sexual or racial connotation that are undesired and generally repetitious, and which have a negative effect on a person's physical or psychological dignity or integrity, or lead to an unfavourable working environment.
easyhome will promptly and thoroughly investigate all complaints filed through the Hotline, Legal or the Human Resources Department. Employees are expected to cooperate fully in any such investigation whether or not the employee is actively at work or on leave of absence. Failure to do so may result in disciplinary action up to and including suspension and termination of employment. Moreover, neither your supervisor nor the Company will take any action against you for making a complaint or for cooperating in any such investigation.
If any employee is determined to have violated this policy, easyhome will take appropriate corrective action up to and including suspension with or without pay or termination of employment with or without cause. The complainant will be informed when remedial measures have been taken.
The Company cannot help resolve a complaint unless it is notified. Therefore, it is every employee's responsibility to bring issues to Management or Human Resources' attention so that the appropriate steps can be taken to resolve the issue. If you feel you have been subject to discrimination, harassment or retaliation, or that you have witnessed it in the workplace, please report it promptly to the Human Resources Department or by way of the Confidential Hotline.
Where an investigation has been launched against any employee, active or inactive, the employee is required to participate and cooperate in the investigation process either by phone or in person, including employees on leave of absence.
easyhome has zero tolerance for workplace violence. Consistent with our internal policies, Bill 168, and other provincial, and federal legislation, acts or threats of physical violence, including intimidation, harassment, which includes bullying, and/or coercion, which involve or affect the Company or its employees or directors, will not be tolerated. Acts or threats of violence include conduct that is sufficiently severe, offensive or intimidating to alter the employment conditions at easyhome or to create a hostile, abusive or intimidating work environment for one or several easyhome employees.
The Company does not permit any type of firearm or weapon on its premises or in any Company vehicle. Employees may not be in the possession of a firearm or weapon while engaged in any Company business activity.
Employees may not use, sell, possess, purchase or transfer alcohol or illegal drugs on Company premises or in Company vehicles during work hours. The only exception is that alcohol may be consumed by people of legal drinking age at Company-sponsored functions, in moderation.
Employees must not be under the influence of illegal drugs or alcohol during work hours, regardless of when the drugs or alcohol were consumed. It is also a violation of this policy to sell, transfer or distribute personal prescription drugs on Company premises or in Company vehicles during work hours.
The Company will take all reasonable and practical steps to safeguard all employees, customers and the communities where it operates, in order to maintain at all times an effective safety program, and has zero tolerance for those that intentionally put others at risk for injury. Accidents that cause suffering, loss of time and income, loss of profits and property damage can be reduced and even eliminated by executing the Company's Health and Safety policy.
In fulfilling this commitment to protect both people and property, the Company will provide training to all employees and maintain a safe and healthy work environment, in accordance with acceptable industry standards, and in compliance with legislative requirements. The Company will strive to be proactive to eliminate any foreseeable hazards which may result in fires, security losses, property damage, accidents and personal injuries. All employees will be equally responsible for minimizing accidents within Company facilities.
Accidental loss can be controlled through good management in combination with active employee involvement. Loss prevention is the direct responsibility of managers and employees functioning as a team. All employees shall comply with the Company's health and safety requirements as they apply to the operation and maintenance of facilities and equipment. All employees will perform their jobs properly in accordance with established procedures. It is in the best interest of all parties to consider health and safety in every activity. All employees are required to review the Emergency Response Plan / Evacuation Procedures contained in their store or office location.
Smoking is not permitted in any of our facilities, vehicles or customer's homes.
The Company maintains an official personnel file and other employment records permanently for each employee.
Employees in the stores are required to log in and out of the designated labour tracking system every day, including lunch breaks in excess of 30 minutes.
All time worked by an employee, whether scheduled or unscheduled, overtime or straight time, authorized or unauthorized - must always be recorded exactly as it occurred. Your supervisor will show you the procedure for recording time worked. Under no circumstances may you allow a fellow worker to login in to the time and labour management system for you, and you must not log in to the system unless you are at your permanent work location (i.e. it is not permissible for you to log in from a remote location). Anyone caught punching in and out from another location or by another employee will be terminated. You must keep record of time worked as required by law or policy in your province. You should also note all time that you don't work but for which you are still paid and have your supervisor verify the time. If for any reason an entry must be changed, your supervisor must make the change, and you must initial it.
All overtime must be authorized by the Regional Manager or Department Manager as appropriate prior to working any additional hours. Hours worked in excess of the schedules must be documented on the schedule that is posted in the stores. Overtime is only paid with DVP, Director, and/or Vice President approval.
If you have any concerns about record keeping or just want more information, contact the Human Resources Department, or the Confidential Hotline.
Every employee receives a written performance appraisal, using the appropriate Company form, at least once per year. Employees on authorized leave will have their review dates postponed by the number of days in excess of 31 that they are away from work. Reviews should also be completed after the initial probationary period for new employees. All employees must receive a written copy of their performance review.
By virtue of your employment with the Company, you will be exposed to or will have access to confidential and proprietary information regarding the Company's business, all of which are the property of the Company. Confidential Information includes, but is not limited to, trade secrets, industrial and/or operational processes, patents, customer lists, customer information including customers' or potential customers' specific needs and requirements, pricing information, product development plans, marketing methods and plans, financial results that have not been publicized, business plans and budgets and all other systems, methods, procedures, compilations of information, records and so forth which are owned and shall continue to be owned solely by the Company ("Confidential Information").
During the term of your employment with the Company, and continuing indefinitely thereafter, you agree that you shall hold in confidence and refrain from disclosing the Company's Confidential Information and shall not, except in connection with the performance of your duties with the Company, directly or indirectly use, convey, disclose or reveal, or attempt to use, convey, disclose or reveal, any Confidential Information, unless approved by the Company in writing and at the sole discretion of the Company or required to do so by an applicable governmental or regulatory body.
Any and all ideas, designs, procedures, formulas, inventions or improvements (whether patented, patentable or not) trade names, logos and writings or other materials written or produced by you (collectively, the "Intellectual Property") which you may conceive or produce during the period of your employment with the Company relating or in any way pertaining to or connected with the scope of your employment, or in which the Company has been or may become interested, shall be the sole and exclusive property of the Company.
You shall promptly and fully disclose such Intellectual Property to the Company and shall not disclose the same to others, except with the Company's express written approval.
When requested by the Company, you shall execute any and all applications, assignments and other instruments which the Company shall deem necessary in order to apply for and obtain patents, copyrights, industrial designs and/or any official documents relating to exclusivity of the invention, design or copyright of Canada or any foreign country for such Intellectual Property and in order to assign and convey to the Company the sole and exclusive right, title and interest in and to such Intellectual Property. In particular, respecting writings or other copyrightable materials, the Company may claim authorship as an employer or work made for hire.
Accurate records are essential to the successful operation of easyhome. Employees are responsible for ensuring the protection and accuracy of all Company records, information, and accounts. For example, claims on an expense report or time record, payments and other transactions must be correctly recorded and accounted for and properly authorized in accordance with Company policies.
easyhome's accounting and financial records must reflect in an accurate, complete and timely manner and in reasonable detail, every business transaction undertaken by the Company, and must conform to applicable legal requirements and easyhome's system of internal controls. All employees and directors who have control over easyhome's assets and transactions are responsible for establishing and/or maintaining a system of internal controls in their area of responsibility designed to (a) prevent unauthorized, unrecorded or inaccurately recorded transactions; and (b) permit the preparation of financial statements according to International Financial Reporting Standards.
Documents that belong to the Company must not be destroyed, unless otherwise stated in the Company's Record Retention Policy. Any communication that leads to a legal claim either civil or criminal must also be retained. Please contact the Legal Department should you have any questions.
If you have any concerns about the Company's financial controls, accounting, financial reporting or auditing please contact the Confidential Hotline or the Company's Audit Committee.
It is strictly prohibited to post, send or forward email or text messages or access internet sites that contain libelous, defamatory, pornographic, offensive, racist or obscene remarks, pictures or any other material that a reasonable person would deem inappropriate. If you receive an e-mail of this nature, you must promptly notify your supervisor, delete the email and notify the sender that you are not permitted to receive email of this nature from them or anyone else.
If there is evidence that you are not adhering to the guidelines set out in this policy, the Company reserves the right to take disciplinary action, including termination of your employment and/or legal action.
easyhome will contact the authorities if illegal activity of this nature is found on any employee's computer, internet or email accounts.
Employees are not permitted to access social networking sites such as Facebook, MSN, MySpace, etc. during business hours, unless it is specifically work related.
Employees that send inappropriate messages or posts defaming the Company or another employee, or make discriminatory comments, may face disciplinary action up to and including termination.
Confidential work related information may not be shared with anyone outside the business particularly through any of these social networking sites. easyhome may take legal action against any employee that violates the privacy of another employee or customer or if it determines that there is a breach of confidentiality with respect to the business, or libelous and defamatory comments made about the Company or its employees.
All employees and directors must take every precaution to protect the Company's assets and ensure their proper and efficient use.
Any employee implicated in the manipulation of assets or accounts, theft, fraud or found to be conducting themselves in a manner that contravenes our policies and procedures will be disciplined, up to and including termination. easyhome has a zero tolerance policy for violations of this nature and expects all employees to adhere to all Company policies and procedures at all times.
To further ensure the security and safety of all our employees and customers, some easyhome stores are equipped with recorded video and audio surveillance which may, if applicable, be used during an internal or legal investigation.
Employees are not permitted to use the Company vehicles for personal use or carry passengers that are not easyhome employees.
Employees that incur fines, tickets or moving violations in a Company vehicle at anytime are wholly responsible for paying the fines and tickets within the time allotted.
Employees that are required to drive Company vehicles must always ensure the vehicles meet all standards imposed by the Ministry of Transportation or they are forbidden to move the vehicle.
Employees may only drive a Company vehicle if they meet the requirements of the Company's driver's standards with respect to years licensed, points or other incidents against their license, restrictions, etc. These must be verified upfront in order to comply with Ministry of Transportation or other regulatory mandates. Employees that have not been cleared to drive a Company vehicle may not drive until they have been cleared to do so.
Smoking is not permitted in any Company vehicle.
All employees are required to abide by the Company's inventory practices at all times. This includes weekly and monthly full inventory counts, proper management of service and loaner units, as well as idle units. Employees are not permitted to hide or attempt to hide missing inventory, or inventory that is to be charged off or hold pick-ups (physically picking up product from a customer's home but not picking it up within the POS system). Strict adherence to these standards is required at all times.
All deposits must be made daily as per standard operating procedures, including use of deposit logs. Cheques returned due to Non-Sufficient Funds ("NSF") must be entered into the system when received. Employees are not permitted to hold deposits or NSF cheques for any reason.
All business decisions should be made solely in the best interests of the Company, not for personal benefit. Therefore, you should avoid any action that creates - or appears to create - a conflict of interest with the Company. Questions about potential conflicts of interest and disclosure of these situations as they arise should be directed to Human Resources, or the Confidential Hotline.
You may not obtain a financial interest in any supplier, vendor, distributor, landlord or competitor of the Company without first getting written approval from the President & CEO. An improper financial interest is one that creates or appears to create a conflict of interest with the Company. In addition, employees may not receive any form of compensation from anyone other than the Company for doing their job, including accepting tips from customers. If you have a question about what constitutes an improper financial interest, contact the Confidential Hotline.
Employees are not permitted to lease merchandise through a store, obtain a loan from a kiosk, or access the account of a family member or close personal friend with whom they have a relationship.
If a conflict of interest exists, and there is no failure of good faith on the part of the employee or director, easyhome's policy generally will be to allow a reasonable amount of time for the employee or director to correct the situation in order to prevent undue hardship or loss. However, all decisions in this regard will be at the discretion of the President & CEO, whose primary concern in exercising such discretion will be the best interests of the Company.
You must obtain the written approval of your Divisional Vice President, for field staff, or the President & CEO, for support centre staff, before doing Company business with parties such as relatives, friends, spouses or life partners, and must always keep the Company's best interests in those interactions. In addition, you may not pressure others into hiring a relative or friend as an employee, supplier, vendor, distributor or landlord of the Company.
While we recognize and respect the rights of employees to freely pursue personal relationships with those they encounter in the work environment, employees must use good judgment in ensuring that those relationships do not negatively impact their job performance, their ability to supervise others or the work environment.
Any workplace conduct arising from a romantic relationship, intimate relationship or friendship between employees may be improper if the conduct creates an uncomfortable work environment for others or there is sharing of confidential and private information. Favouritism, open displays of affection and making business decisions based on emotions or friendships rather than in the best interests of the Company are examples of inappropriate conduct.
Employees who find themselves in an intimate relationship or friendship should use tact, good judgment and common sense. Employees in a reporting relationship with someone that they are consensually dating or romantically involved with must inform the next level of management or Human Resources. The Company will work with both individuals to try to separate their employment responsibilities from their personal relationship in order to protect the interests of both employees and others and to avoid any conflict of interest.
Employees should never accept anything of value from anyone, including a current or prospective supplier, vendor, distributor, landlord or competitor of the Company when doing so might compromise, or appear to compromise, the objectivity of your business decisions. If you have a question about this policy, contact the President & CEO or the Confidential Hotline.
Employee product purchases and loans can only be processed centrally through the corporate office. Employees are not permitted to purchase merchandise through the store lease method or cash sales. This includes immediate family members if they reside in the same household. Employees must adhere to the internal Employee Purchase Policy process to purchase only new merchandise.
Customers hired in to our stores as employees must pay out their accounts in full, return the merchandise or transfer the account to an employee purchase agreement, to be paid through payroll deductions. Likewise, customers hired with existing loans must pay out their account in full, or arrange to have the account repaid through payroll deductions.
Relatives of employees are not permitted to have access to Company store computers, access codes, customer files, employee records, vehicles, security codes, etc. or any other Company material, and are not permitted to be in the store during non-business hours for an unreasonable length of time.
Employees are not permitted to "borrow" product from the store. Any special requests must be submitted to the DVP for review and approval, and must be documented on file.
The Company does not contribute to any political parties. You are, of course, free to participate in personal religious or political activities as you see fit during your own personal time. In doing so, however, you should make it clear that you are acting in your individual capacity and not on behalf of the Company.
Except as described below, employees may not work for or receive compensation for personal services from any supplier, vendor, distributor, landlord or competitor of the Company, or any business entity that does or seeks to do business with the Company.
Employees must obtain approval from the President & CEO before serving on the board of directors of another for-profit company. Employees may serve as a director, trustee or officer of a non-profit organization in their individual capacity and on their own time, but must get prior permission from the President & CEO or the Chief Financial Officer, to do so as a representative of the Company. If you have a question about this policy, contact the President & CEO.
Occasionally, an applicant, customer, or current or former employee may file - or threaten to file - a complaint against the Company with the government. If you are notified about such a complaint, immediately call Human Resources, the Legal Department or the Confidential Hotline. Neither your supervisor nor the Company is permitted to take any action against you for either making or reporting such a complaint.
It is Company policy to cooperate with appropriate government requests or investigations. If you are asked to provide information (either written or verbally) for a government investigation or if a government representative appears at your workplace, including representatives from the Ministry of Labour, call the Human Resources Department before providing any information. All information provided should be truthful and accurate and must not obstruct, influence or impede the request for information. Employees should not alter, falsify, mutilate, cover up, or destroy any documents or records related to a government request or investigation or legal proceeding.
You must not speak to reporters on behalf of the Company. Individuals who talk directly to reporters without going through the proper channels risk providing incorrect information or revealing proprietary strategies. Please direct members of the media with inquiries to the President & CEO or Chief Financial Officer
Any employee that holds a mobile device such as laptop, iPad, Blackberry, etc. must ensure it does not contain personal information about any employee or customer without the appropriate level of security, including passwords and encryption.
Requests for information may be directed to the Privacy Officer or online at www.easyhome.ca.
Fraud is illegal. Any indication of fraud no matter how small, will be rigorously investigated and may lead to termination of employment.
Employees are responsible to act at all times with the highest degree of honesty and integrity. Employees are responsible for complying with easyhome's Code and the Fraud Policy. Any employee of easyhome who knows or has reason to believe that fraudulent activity has occurred is obligated to report it immediately to the Human Resources or Legal Department, or by way of the Confidential Hotline.
Employees are responsible for complying with easyhome's Code of Business Conduct and the Fraud Policy. Sign-off on the Code of Conduct also serves as confirmation that you have read, understood and will comply with the Company's Fraud Policy.
On an annual basis, the Company also requires all support centre and easyfinancial employees to complete Anti-Money Laundering certification.
As part of its system of internal controls, the Company has established an Authorization Policy that specifies dollar value maximums by employment position limiting the extent of goods or services that can be procured by all employees on behalf of the Company. Additionally, this Authorization Policy specifies which employees are able to sign and ratify contracts that commit the Company to current or future activities or obligations on behalf of the Company.
All employees are responsible for complying with easyhome's Authorization Policy and sign-off on the Code of Conduct also serves as confirmation that you have read, understood and will comply with the Company's Authorization Policy.