Whistleblowing policy

1. Purpose

This whistleblowing policy explains how anyone connected with Corpshore Canada, the Canadian operation of Corpshore Solutions Corporation, can raise a concern about suspected wrongdoing, and how we handle those concerns. We want people to feel able to speak up, and we are committed to protecting those who do. This policy supports our code of ethics.

2. Who can use this policy

This policy is available to our employees, candidates, contractors, suppliers, clients and any other person who has a genuine concern about our conduct or that of someone acting on our behalf. You can raise a concern whether or not you are certain it is well founded, as long as you raise it honestly and in good faith. You do not have to be directly affected by the conduct to raise a concern about it, and you can raise a concern even if it relates to something that has not yet happened but that you reasonably believe is likely to.

3. What to report

You should report any conduct you reasonably believe is unlawful, unethical or a breach of our policies. This includes, for example: fraud, theft or financial misconduct; bribery or corruption; breaches of privacy or misuse of personal information; discrimination, harassment or a threat to health and safety; anti-competitive conduct; forced labour, child labour or other human-rights abuse in our operations or supply chain; and any attempt to conceal such conduct. This policy is for reporting wrongdoing. Personal grievances about your own employment are usually better raised through the relevant human-resources or employment process, although we will help you find the right route.

4. How to raise a concern

You can raise a concern by email to privacy@corpshore.ca, which reaches a responsible person who handles reports, or by writing to us, marked confidential, at The Exchange Tower, 130 King Street West, Suite 1900, Toronto, Ontario M5X 2A2, Canada. Please give as much detail as you can, including what happened, who was involved, when and where, and any evidence you have, so that we can look into it properly. You may raise a concern openly or, if you prefer, anonymously, although anonymity may limit our ability to investigate or to keep you informed.

5. Confidentiality

We treat reports confidentially. We share the identity of a person who raises a concern only where it is necessary to investigate properly, where the person agrees, or where the law requires it, and we tell the person where that is likely. We handle any personal information involved in a report in accordance with our privacy policy.

6. How we handle a report

When we receive a concern, we acknowledge it, assess it, and decide how to look into it. We may investigate ourselves or appoint someone independent, and we act proportionately to the nature and seriousness of the concern. We gather the relevant facts objectively, give anyone who is the subject of a report a fair opportunity to respond where that is appropriate, and reach a conclusion based on the evidence. Where a concern is substantiated, we take corrective action, which may include changes to our practices, disciplinary action, or a report to an authority where the law requires it. We handle every report fairly, including for anyone who is the subject of a report, who is treated as innocent unless and until the concern is substantiated. We keep the person who raised the concern informed of the outcome as far as we properly can, recognising that we may not be able to share every detail for reasons of confidentiality or law.

7. No retaliation

We do not tolerate retaliation against anyone who raises a concern in good faith or who assists an investigation. Retaliation includes dismissal, discipline, demotion, harassment or any other detriment. Anyone who retaliates against a person for raising a concern in good faith is themselves subject to disciplinary or other action. If you believe you have suffered retaliation for raising a concern, tell us immediately using the routes above.

8. Good faith and false reports

You are protected under this policy if you raise a concern honestly and reasonably, even if it turns out to be mistaken. Knowingly making a false or malicious report, however, is a breach of this policy and may itself lead to action.

8a. How to raise a concern effectively

You do not need to prove your concern before you raise it, and you do not need to investigate it yourself. It helps us if you raise a concern early, describe what you have seen or been told as specifically as you can, and let us know if you have any worry about your own position so we can address it. If you are unsure whether something falls within this policy, raise it anyway and we will help you find the right route. Raising a concern honestly is always the right thing to do, even if it turns out there was an innocent explanation.

9. External reporting

This policy does not prevent you from reporting a concern to a regulator, a law-enforcement authority or another body where you have the right to do so. We would welcome the chance to address your concern first, but nothing in this policy limits any right you have to report externally or any legal protection you have as a whistleblower under applicable law.

9a. Records

We keep a confidential record of the concerns raised under this policy, how we handled them, and their outcomes. We use these records to meet our legal obligations, to identify patterns, and to improve our practices, and we handle any personal information in them in accordance with our privacy policy. Access to these records is limited to those who need it.

10. Review

We review this policy from time to time and update it as our business and the law evolve, and we promote it so that the people who may need it know it exists and how to use it. The date at the top of this page shows when it was last revised. Questions about this policy can be sent to privacy@corpshore.ca.