We hereby declare that, the code as set out below, is to take effect from December 30th, 2005.
For POLY MEDICURE LIMITED
POLY MEDICURE LIMITED
CODE OF ETHICS FOR DESIGNATED PERSONS
This Code of Ethics for Designated Persons (the “Code”) helps maintain the standards of business conduct for POLY MEDICURE LIMITED (the “Company”), and ensures compliance with legal requirements, specifically as per New Clause–49 of the Listing Agreement. The Code is to deter wrongdoing and promote ethical conduct. The matters covered in this Code are of the utmost importance to the Company, its shareholders and business partners. Further, these are essential so that the Company can conduct its business in accordance with its stated values.
The Code is applicable to the following persons, referred to as Designated Persons:
Ethical business conduct is critical to Company’s business. Accordingly, Designated Persons are expected to read and understand this Code, uphold these standards in day-to-day activities, and comply with all applicable laws; rules and regulations; and all applicable policies and procedures adopted by the Company that govern the conduct of its employees.Because the principles described in this Code are general in nature, Designated Persons should also review the Company’s other applicable policies and procedures for more specific instruction. They may contact firstname.lastname@example.org of corporate department if they have any questions.
Nothing in this Code, in any Company policies and procedures, or in other related communications (verbal or written), creates or implies and employment contract or term of employment.
Designated Persons should sign the acknowledgement form at the end of this Code and return the form to the Legal/Secretarial department indicating that they have received, read and understood, and agree to comply with the Code. The signed acknowledgement form will be located in each Officer’s personnel files. Each year, as part of their annual review, Designated Persons will be asked to sign an acknowledgement indicating their continued understanding of the Code.
All Designated Persons are expected to act in accordance with the highest standards of personal and professional integrity”, honesty and ethical conduct, while working on the company’s premises, at offsite locations where the Company’s business is being conducted, at Company sponsored business and social events, or at any other place where Designated Persons are representing the Company.
The Company considers honest conduct by Designated Persons. The Company considers ethical conduct to be conduct conforming to the accepted professional standards. Ethical conduct includes the ethical handling of actual or apparent conflicts of interest between personal and professional relationships. This is discussed in more detail in Section III below.
In all cases, if any Designated Person is unsure about the appropriateness of an event or action, please seek assistance in interpreting the requirements of these practices by contacting Jkoswal@polymedicure.com of Corporate Department.
A Designated Person’s duty to the Company demands that he or she avoids actual and apparent conflicts of interest and discloses actual and apparent conflicts of interest. A conflict of interest exists where the interests or benefits of one person or entity conflict with the interests or benefits of the Company. Examples include:
The Company’s policy is to provide full, fair, accurate, timely, and understandable disclosure in reports and documents to file with, or submit to the Stock Exchange(s) and other public communications. Accordingly, Designated Persons must ensure that they and others in the Company comply with disclosure controls and procedures, and internal controls for financial reporting.
Designated Persons must comply with all applicable government laws, rules and regulations. Designated Persons must acquire appropriate knowledge of the legal requirements relating to their duties sufficient to enable them to recognize potential dangers, and to know when to seek advice from the Legal/Secretarial department. Violation of applicable governmental laws, rules and regulations made, subject Designated Persons to criminal or civil liability, as well as to disciplinary action by the Company Such violations may also subject the Company to civil or criminal liability or the loss of business.
Part of a Designated Persons job and of his or her ethical responsibility is to help enforce this Code. Designated Persons should be alert to possible violations and report this to the Legal/Secretarial department and the Designated Persons must cooperate in any internal or external investigations of possible violations. Reprisal, threat, retribution or retaliation against any person who has, in good faith, reported a violation or a suspected violation of law, this Code or other Company policies, or against any person who is assisting in any investigation or process with respect to such a violation, is prohibited.
Actual violations of law, this Code, or other Company policies or procedures, should be promptly reported to the Legal/Secretarial department.
The Company will take appropriate action against any Designated Persons whose actions are found to violate the Code or any other policy of the Company’s sole discretion. Where the Company has suffered a loss, it may pursue its remedies against the individuals or entities responsible. Where laws have been violated, the Company will cooperate fully with the appropriate authorities.
The Company is committed to continuously reviewing and updating our policies and procedures. Therefore, this Code is subject to modification. Any amendment or waiver of any provision of this Code must be approved in writing by the Company’s board of directors and promptly disclosed on the Company’s website and in applicable regulatory filings pursuant to applicable laws and regulations, together with details about the nature of the amendment or waiver.
I have received and read the Company’s Code of Ethics for Designated Persons (the “Code”). I understand the standards and policies contained in the Code and understand that there may be additional policies or laws specific to my job. I agree to comply with the Code.
If I have questions concerning the meaning or application of the Code, any Company policies, or the legal and regulatory requirements applicable to my job, I know I can consult the Legal/Secretarial department, and that my questions or reports to these sources will be maintained in confidence.
Designated Persons Name
Signature _ _ _ _
Date _ _ _ _
Please sign and return this form to the Corporate Department.