Ethics Policy

Purpose

The purpose of this Business Ethics Policy is to articulate Boulart Inc.’s commitment to the highest standards of ethical conduct and professional integrity. This policy is designed to guide employees and representatives in making decisions that are consistent with the company’s values, support a culture of honesty and accountability, and help ensure that business is conducted legally, fairly, and transparently.

Scope

This Policy applies to:

• applies at every level of Boulart Inc., and extends to all partners, and employees (including full-time, part-time, temporary, probationary, casual and contract staff)
• applies to the physical offices of Boulart Inc.
• extends outside of the offices of Boulart Inc. (such as off-site client meetings, business travel, firm-sanctioned social events and to electronic communications)

Compliance with this policy is a condition of employment and/or continued business relationship. All employees must sign an acknowledgement form confirming they have read, understood, and agree to comply with this policy.

Core ethical Principles

3.1 Integrity and Honesty

Employees are expected to act with honesty and uphold strong moral principles in all business dealings. This includes:

• Being truthful in communications with colleagues, clients, and partners.
• Avoiding deception, manipulation, and any form of fraud.
• Representing the company accurately and never falsifying records or reports.

3.2 Compliance with Laws and Regulations

We are committed to full compliance with all applicable local, national, and international laws, including:

• Employment and labor laws
• Tax and financial regulations
• Anti-corruption and bribery laws
• Environmental and health & safety standards

3.3 Confidentiality and Privacy

All employees must protect sensitive information and respect privacy rights, including:

• Personal data of clients, employees, and business partners
• Trade secrets and proprietary information
• Financial, strategic, and operational data

Unauthorized sharing or misuse of confidential information is strictly prohibited and may be grounds for termination or legal action.

3.4 Fair Dealing

Employees should treat all clients, vendors, competitors, and coworkers fairly and ethically by:

• Avoiding manipulation, coercion, or unfair practices
• Honoring contractual obligations
• Competing fairly and respecting the marketplace

3.5 Anti-Bribery and Anti-Corruption

No employee may offer, accept, solicit, or authorize any form of bribe, kickback, or illicit payment. This includes:

• Gifts or entertainment intended to influence business decisions
• Donations or sponsorships tied to a business favor
• Facilitating payments to expedite routine government actions

3.6 Conflicts of Interest

Employees must avoid and disclose any personal interests that may conflict with company interests.

A conflict of interest occurs when personal interests interfere with professional responsibilities. Examples include:

• Working for or owning a stake in a competitor
• Hiring or contracting family members without disclosure
• Accepting gifts or favors from clients or vendors

Use of Company Resources

Employees are entrusted with company assets, including equipment, technology, and intellectual property. These must be:

• Used for legitimate business purposes only
• Maintained with care and not misused, damaged, or wasted
• Returned upon termination of employment or contract

Company-provided resources such as internet, email, and mobile devices should not be used for unlawful or inappropriate purposes.

Workplace Conduct

5.1 Respect, Diversity, and Inclusion

We are committed to a respectful and inclusive workplace. Discrimination, harassment, or any form of unfair treatment is not tolerated.

All employees should contribute to a positive work environment by:

• Treating others with dignity
• Valuing diverse perspectives
• Communicating professionally and respectfully

5.2 Health and Safety

Employees must:

• Follow all health and safety guidelines
• Report unsafe conditions or incidents promptly
• Avoid behaviors that compromise the safety of themselves or others

Reporting and complaint investigating

Boulart Inc. encourages a culture of openness and accountability. Associates, employees and all collaborators are encouraged to raise issues, ask questions and report concerns in good faith and without any fear of retaliation. Boulart Inc. commits to investigating every case or complaint received. Information obtained about an incident or complaint, including identifying information about any individuals involved, will not be disclosed unless disclosure is necessary to protect employees, to investigate the complaint or incident or to take corrective action or otherwise as required by law.

All employees have a right to freedom from reprisals or threat of reprisals for refusing to accept harassment in any form, for making a formal complaint or cooperating in an investigation.

Anyone at Boulart Inc. found to have engaged in conduct constituting a violation of human rights may be subject to disciplinary actions including coaching, formal warnings, suspension, termination, or legal action.

Contact

For any questions or requests for information, we invite you to contact the person below, who will be happy to assist you.

Human Resources Director: Caroline Saillant