Gill is committed to conducting our business ethically, legally and in a manner that is environmentally and socially responsible. We believe that demonstrating our commitment to corporate responsibility is integral to creating long-term employee, customer and shareholder value. Operating responsibly is both a core value and a common goal of Gill’s leadership and staff.

This Policy articulates Gill’s commitment to responsible development where our employees, contractors and directors are empowered and expected to comply with the requirements of this Policy. This Policy encompasses the areas of governance, people, the environment, safety and engagement.

Gill will:
• Maintain high standards of integrity with employees at all levels of the organization.
• Comply with and where possible, exceed legal requirements and industry standards applicable to our activities
• Conduct business in an open, honest and ethical manner
• Integrate corporate responsibility in our business planning and decision-making processes

Gill will conduct our business in a manner that is environmentally responsible as outlined in our Environment Policy.

Gill will provide a safe and healthy workplace as described in our Health and Safety Policy.

Gill will:
• Engage and work with stakeholders in a timely, respectful and meaningful manner in our planning and operations. We value the input of our stakeholders and, where appropriate, incorporate their feedback in our ongoing operations.
• Provide ample opportunity for face-to-face feedback at all levels of the organization per our open-door policy

A whistleblower as defined by this policy is an employee of Gill who reports an activity that he or she considers to be illegal or dishonest to one or more of the parties specified in this policy. The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures. Appropriate management officials are charged with these responsibilities.

Examples of illegal or dishonest activities are violations of federal, state or local laws; billing for services not performed or for goods not delivered; and other fraudulent financial reporting.
If an employee has knowledge of or a concern of illegal or dishonest fraudulent activity, the employee must contact his or her immediate supervisor or the Director of Human Resources. The employee must exercise sound judgment to avoid baseless allegations. An employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination.

Whistleblower protections are provided in two important areas – confidentiality and against retaliation.
• To the extent possible, the confidentiality of the whistleblower will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defense.
• Gill will not retaliate against a whistleblower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments and threats of physical harm. Any whistleblower who believes he/she is being retaliated against must contact the Director of Human Resources immediately. The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.
All reports of illegal and dishonest activities will be promptly submitted to the Vice President of Administration who is responsible for investigating and coordinating corrective action. Employees with any questions regarding this policy should contact the Director of Human Resources.

It is our policy to conduct our business in an honest and ethical manner. Gill takes a zero-tolerance approach to Bribery and Corruption and is committed to acting professionally, fairly and with integrity in all our business activities.

This policy does not prohibit normal and appropriate hospitality (given and received) to or from Third Parties.

An employee is prohibited from accepting a gift or giving a gift to a third party in the following situations:
• It is made with the intention of influencing a Third Party to obtain or retain business, to gain a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favors or benefits
• It is given in your name and not in the name of the Company
• It includes cash
• It is of an inappropriate type and value and given at an inappropriate time (e.g. during a tender process)
• It is given secretly and not openly.
Gill appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable, justifiable and is proportionate. The intention behind the gift should always be considered.

It is not acceptable for an employee (or someone on your behalf) to:
• Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
• Give, promise to give, or offer, a payment, gift or hospitality to a Public Official or Third Party to ‘facilitate’ or expedite a routine procedure;
• Accept payment from a Third Party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;
• Accept a gift or hospitality from a Third Party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
• Threaten or retaliate against another Employee who has refused to commit a bribery offence or who has raised concerns under this policy; or
• Engage in any activity that might lead to a breach of this policy or perceived breach of this policy.
It is the employee’s responsibility to:
• Ensure that all accounts, invoices, memoranda and other documents and records relating to dealings with Third Parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept ‘off-book’.
• Declare and keep a written record of all Gifts, Invitations & Hospitality according to Company practice accepted or offered, which will be subject to managerial review.