Ethics Hotline Policy
All employees are required to receive and review information regarding FirstLine, FirstService Corporation's ethics hotline.
This information is to be re-communicated to employees annually and is to be displayed throughout the organization, such as on intranet sites, posters in common areas and communications in company newsletters.
Every employee, officer and director of FirstService Corporation ("FirstService" or the "Company") has an ongoing responsibility to report any activity or suspected activity of which he or she may have knowledge relating to the integrity of the Company's financial reporting or which otherwise might be considered sensitive in preserving the Company's reputation.
For further clarity, the following items are examples of fraudulent or other issues that should be reported
- Any violation of the Code of Ethics and Conduct or our Financial Management Code of Ethics and Conduct;
- Any complaint regarding accounting, internal controls, disclosure controls or auditing matters;
- Any good faith concerns regarding questionable accounting or auditing practices;
- Disclosure of proprietary or confidential information; and
- Violations of federal, provincial/state or local laws or regulations.
Should an employee, officer or director witness or suspect fraudulent behaviour, they should contact FirstLine.
Reporting and Investigation Procedures
FirstLine is available to employees of all FirstService companies to report concerns. It is operated by a third party, NAVEX Global, a company that specializes in ethics and compliance reporting. Access to a live interview specialist is available around the clock, and calls may be made from any location at any time. Callers can choose to give their name or remain anonymous if they wish.
All calls to FirstLine are documented and reported back to FirstService and the Chair of the Audit Committee. Management will then initiate an investigation into the matter and ensure proper resolution to the matter.
FirstService's Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns with the comfort that they will not suffer any adverse consequence and that the concern will be appropriately received, considered and investigated. No employee of the Company who in good faith reports an accounting irregularity or wrongdoing will suffer harassment, retaliation, discipline or adverse employment consequence.