CODE OF CONDUCT
The very essence of the services Garda provides demands that we consistently maintain the highest possible standards of honest and ethical behavior. In keeping with this objective, Garda has five Guiding Principles that express these high standards and they form the foundation for our behavior.
These principles are closely related to our way of doing business and govern our relations with our partners. They help us achieve our goals and motivate us to excel in the way we render our services.
Stephan Cretier
President and Chief Executive Officer
Jurisdiction
Every employee, without exception, of Garda and of its subsidiaries for which they work and regardless of the legal jurisdiction of that company, are governed by the underlying rules of the five Guiding Principles formulated by Garda.
It extends to every employee in every location worldwide. References to specific regulatory bodies should be interpreted to mean the relevant entity or organization in the appropriate jurisdiction.
1. UPHOLDING THE LAW
Garda employees and of its subsidiaries will, at all times, abide by the law and respect its intent in the best interests of our clients, employees and shareholders.
Laws, Rules and Regulations
Garda employees and of its subsidiaries must respect the laws and regulations of all countries where they carry out their activities.
Our employees must not do anything contrary with a law or a regulation in force. They are urged to request a legal opinion if needed.
2. CONFIDENTIALITY
Garda and its subsidiaries have undertaken to implement procedures to conform with protection of personal information laws in the territories where they carry out their activities.
Internal Information
All employees, whatever their role, level, department or area, are to scrupulously avoid using, sharing or disclosing non-public information about Garda, its subsidiaries, affiliates or clients (both current and prospective), except in the legitimate course of doing business.
Certain information concerning the plans, methods, practices and activities of Garda and of its subsidiaries is proprietary and classified as either Restricted, Confidential or Garda Internal.
Client lists and information (i.e. computer/electronic files, paper records, etc.) are the property of Garda and of its subsidiaries.
Employees of Garda and of its subsidiaries recognize that all the information which they obtained during the course of their work is the sole property of Garda and of its subsidiaries and that they are not to remove any proprietary information from the corporation's premises without permission. When they leave the service of Garda and of its subsidiaries, they are obliged to continue safeguarding the privacy of both clients and employees, and to protect the confidentiality of the corporation.
External Information
Our Employees are to share Restricted, Confidential or Garda Internal information only with third parties who have undertaken in writing to keep the information confidential in accordance with Garda requirements and then they may share only that information which is needed to satisfy the conditions of a contract and only with those who need to know.
Web Site :
Garda and its subsidiaries offer the security and protection of all confidential information recorded in its systems and those of the Internet.
Garda and its subsidiaries ensure that the information obtained is submitted to internal measures of confidentiality, are protected from any disclosure except with those which have the right to have access or when required by law.
Investigation Services
Garda has one of the most experienced teams in the field of investigation services in Canada. Its services are distributed according to two principal points: external investigations which deal mainly with thefts, frauds and abusive behaviors and internal investigations, which include background checks.
External Investigations
The employees of Garda and of its subsidiaries working in the field of the external investigations carry out checks and gather information on a daily basis. Our employees understand the need for protecting personal information and for ensuring its confidentiality.
The employees of Garda and of its subsidiaries working in the field of investigations conform to the laws in force in all the territories where they carry out their activities and recognize the importance of high standards in order to protect personal information and any electronic documents collected.
Internal Investigations
Employees of Garda and of its subsidiaries working in the field of the internal investigations gather information on a daily basis. Our employees process the data collected according to laws in force in the territories where they carry on their activities. The personal information must remain confidential and is to be used only for purposes for which they were obtained. They can be revealed only to those which have the right to have access or when required by law.
3. INTEGRITY
Our employees' primary business loyalty must be to Garda and to its subsidiaries. They are to avoid any situation that could result in a conflict of interest or in the perception of one.
Any decision made by employees in the course of their work is to be made in an objective manner based solely on the best interests of Garda and of its subsidiaries and unaffected by any consideration of personal gain for themselves or for anyone personally associated with them including friends and relatives
Employees are not to approve a product, a service request or a transaction for themselves or for any client with whom they are personally associated, including friends and relatives. Our employees who find themselves in a work situation with a person to which they are personally associated with must declare it in order to avoid any situation of conflict of interests.
Payments, Gifts, Entertainment
Employees are encouraged to consider the motive behind business gifts and entertainment and are to ensure that the practice is done only in the spirit of business courtesy and relationship management and in no way creates an environment where one party feels a sense of obligation to the other party.
Employees are not to be involved in any act that could be interpreted as seeking, receiving or dispensing a bribe, kickback or questionable payment. It is unethical and illegal.
Insider Trading
By law, Garda must quickly communicate to the public any important information which relates to it including the information which, if it were known to the public, would have an influence on the price of its shares. This information is published in either a press release or in a filing with the proper regulatory authorities and organizations.
The employees of Garda and of its subsidiaries know that it is illegal for them, or for the members of their immediate family, to benefit from this information by selling or by trading shares of Garda. They know that it is illegal to transmit this information to other people so that they can benefit from it. Our employees also know that they must show discretion when they discuss the activities of Garda and of its subsidiaries in public places or on a cellular telephone.
4. FAIRNESS
Garda and its subsidiaries strive to treat people fairly, carefully weighing our responsibilities to all stakeholders. Business relationships, whether cooperative or competitive, will be pursued freely, fairly and openly.
Equal Opportunity
Garda is committed to promoting equal opportunity in all dealings with employees, clients, suppliers and others that they deal with in the normal course of business. Garda abides by the non-discrimination or human rights legislation in the various jurisdictions where it operates. These laws often prohibit discrimination on various grounds, with some examples being race, color, religion/creed, age, gender, marital status, sexual orientation and disability.
It can happen that distinctions are added or prohibited in a certain territory and it is the responsibility of the people in charge to know these distinctions. Where laws do not prohibit discrimination, or where they allow for differential treatment, Garda and its subsidiaries are still committed to non-discrimination principles and will ensure that they do not operate in a way that simply continues stereotypes or establishes barriers.
Workplace Safety
Safety and health in the workplace are a joint responsibility of Garda, its subsidiaries and employees. They must be aware of any potential work hazards in certain workplaces and are responsible for taking all reasonable and necessary precautions to ensure their own safety as well as that of their colleagues.
Free Competition
Garda and its subsidiaries are committed to free competition and do not support any agreements, actions or concerted practices that restrict or impede fair competition.
Garda and its subsidiaries use only fair and honest sales and negotiating methods. Garda prohibits any sales practices that could be misconstrued as an attempt to impose undue pressure on or coerce a client into obtaining a product or service
5. LOYALTY
The employees of Garda and of its subsidiaries are responsible for the honesty and for the integrity which prevails in their work environment and consequently, they must protect not only the rights and the assets of the clients, but also the reputation of their employer.
The employees of Garda and of its subsidiaries are protected from adverse repercussions which they could be exposed to by reporting irregularities if they denounce an employee who acts in a dishonest way, which is carrying out illegal activities, which carries out operations or maintains a relationship that could give rise to a conflict of interests, which is falsifying records, breaches any of the Guiding Principles of the present document, or commits any other serious infraction that has occurred either inside or outside the corporation.
Our Employees are to promptly report any facts to their manager, to senior management or to any designated persons, each of whom is then required to report the issue through a process established by Garda.
Misappropriation
The employees of Garda and of its subsidiaries recognize that the funds and the property which are entrusted to them by the clients must be treated with the greatest care. Our employees understand their responsibility to protect any and all property. An unsuitable or negligent attitude in the way of protecting funds and property constitutes a violation of this Guiding Principle.
At all times, Garda and its subsidiaries must protect their clients assets and of their companies. They must prevent, by any means, any form of unsuitable use of these assets. An unsuitable use can include theft, fraud and misappropriations.
Information Technology Use/Information Security
The employees of Garda and of its subsidiaries are required to follow the policies, procedures and standards relating to Information Technology, Information Security and Privacy. Any observed or suspected Information Technology, Information Security or Privacy incidents or lapses are to be reported as expediently as possible to the responsible person of the department.
Our employees are prohibited to participate in any online forum, or send or display any material in a manner that can tarnish the image and reputation of Garda and of its subsidiaries.
Our employees are not to violate copyright, trademark or patent laws, or any other legal right.
Obedience of instructions
The employees of Garda and of its subsidiaries must carry out the tasks which are assigned to them, according to the directives and powers which are conferred to them, while respecting the policies, the methods and the standards in force.
They must carry out their work while respecting the limits of the powers which are conferred to them whether it is for a signature, a delegation of powers or other requirements stipulated in the policies. They must avoid being placed in a conflict of interests, falsifying writings or reports or breaching the Guiding Principles stated in this document. They must prevent being responsible of a breach or of any other infraction whether inside or outside the corporation.
Our employees who witness an unusual situation in the course of business of a client, a situation that is likely to have negative repercussions, must report it without delay to their manager or with senior management.