Code of Ethical Conduct

Effective Date: April 1, 2015
Revised Date: August 17, 2020

Samuel Associates pledges that it will uphold this Code of Conduct and the legal guidelines it represents to provide services to our clients and any other business activities. As professionals and responsible corporate citizens, we are committed to a higher level of communication and an improved understanding between the many diverse groups which make up our clients, communities and society.
Samuel Associates has developed this Code through extensive consultation and by incorporating materials from Canadian legislation, government regulation and international law such as the US Foreign Corrupt Practices Act, the UK Bribery Act and the applicable local anti-bribery laws.

CONFIDENTIALITY
Samuel Associates is committed to maintaining the highest degree of integrity in our dealings with potential, current and past clients regarding standard commercial confidentiality, and the protection of all personal information received in the course of providing business services. We extend the same standards to all our employees, associate consultants and clients.
We pledge that the firm will not use confidential information obtained from clients in the normal course of our activities for personal gain or benefit.

ETHICS
We always conduct our services honestly and expect our clients to do the same. Our strategic advice and guidance take proper account of ethical considerations, both direct and indirect consequences. The protection and enhancement of our clients' moral standing and reputation is of utmost importance.

DUTY OF CARE
Our actions and advice will always uphold and abide by all relevant laws and government guidelines. We believe that all businesses and organizations, including this consultancy, should avoid causing any adverse effect on people's human rights in the organizations we deal with, the local and wider environments, and the well-being of society at large.

CONFLICT OF INTEREST
Due to the sensitive nature of our business activities, we will not provide a service to a direct competitor of an existing client. The firm shall not permit either professional or personal interests to conflict with a client without fully disclosing such interests to everyone involved.
We shall deal fairly and honestly with the media, elected or appointed public office holders, government officials and the general public. We will not improperly influence the media, elected or appointed public office holders and government officials. We define influence as the improper use of gifts, privileges or benefits to influence decision-makers or decisions.

INTELLECTUAL PROPERTY AND MORAL RIGHTS
We retain the moral rights in, and ownership of, all intellectual property that we create unless agreed otherwise in advance with our clients. In return, we respect the moral and intellectual copyright vested in our clients' intellectual property or other individuals and organizations.

QUALITY ASSURANCE
We maintain the quality of what we do through constant reviews with our clients, taking into account their overall business aims, activities and outcomes. We do so to ensure that our services remain highly competitive and cost-effective. We encourage regular review meetings with our clients and provide them with periodic progress reports as required.

PROFESSIONAL CONDUCT
We conduct all of our activities professionally and under the highest principles of honesty, integrity and ethics. We take great care to be objective in our judgement and any recommendations that we provide so that issues are not influenced by anything other than the best and proper interests of our clients.

EQUALITY AND DISCRIMINATION
We always strive to be fair and objective in our advice and actions. We are never influenced in our decisions, actions or recommendations by issues of language, gender, race, creed, colour, age or personal disability.
All employees and associate consultants have the right to refuse work on a project if it conflicts with their personal ethics, beliefs or contractual obligations. Individuals on our team are entitled to their own beliefs. They have the right to decline involvement in a specific project or client file without compromising their current positions or future opportunities.

Every individual legally involved with Samuel Associates must confirm that they understand and pledge to abide by the Code of Ethical Conduct. If required by our clients to comply with specific codes of professional and ethical conduct issued by their organization, we will respect every effort to follow those principals.
If a situation arises that conflicts with our Code of Ethical Conduct, appropriate measures to correct the situation will be recommended to the firm's executive management team and communicated immediately to all staff and associate consultants.
This Code of Ethical Conduct is reviewed and updated by the executive management team twice a year to reflect changing federal and provincial legislation, regulations and other government guidelines as well as international laws such as the US Foreign Corrupt Practices Act, the UK Bribery Act and the applicable local anti-bribery laws.

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