Fraud Policy FEBRUARY 2014

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1 Fraud Policy FEBRUARY 2014

2 TABLE OF CONTENTS 1. Application of Policy Purpose of Policy Fraud Policy Definition of Fraud Duties and Responsibilities of an Employee or Contractor... 3 The following are the duties and responsibilities of an Employee or contractor under this Policy:... 3 (a) Duties of Employees in Managerial Positions... 3 (b) Employee and Contractor Duties:... 3 (c) Suspicion of Fraud: Reporting Suspected Fraud Conducting Investigations... 4 The following process will be applied to conduct investigations:... 4 (a) Responsibility to Investigate... 4 (b) Access to Records: Inquiries About Investigations Actions to be Taken Following an Investigation Questions and Advice Related to the Policy... 5 FRAUD POLICY PAGE 1 FEBRUARY 2014

3 1. Application of Policy This Application of Policy applies to employees, directors, officers, agents and contractors of Manitoba Telecom Services Inc. and its subsidiaries (collectively referred to as the Company ). References herein to specific job titles or roles shall apply to any future individuals with different job titles or roles but who carry on substantially the same employment role or function. 2. Purpose of Policy This Policy has been established to promote consistent organizational behavior and to facilitate the development of procedures and controls to safeguard the proper use of the Company s finances and resources and provide guidelines for the conduct of investigations. The Company has a commitment to high legal, ethical and moral standards. Employees, directors, officers and agents (collectively Employees or individually Employee ) and contractors are expected to share this commitment. The Company has procedures in place that reduce the likelihood of fraud occurring including procedures and systems of internal control and risk assessment. In addition the Company seeks to ensure that a risk awareness culture exists throughout the organization. 3. Fraud Policy Fraud, in any form, will not be tolerated. This includes acts of fraud committed against the Company as well as acts committed against outside parties intended to benefit the Company. Any Employee who knowingly observes or suspects dishonest or fraudulent activity must report it immediately in accordance with section 6 of this Policy. All reasonable steps will be taken to protect the confidentiality of a person who in good faith advises of or reports possible misconduct and the employment status of such person will not be affected by so advising or reporting. The Company is committed to investigating all cases of suspected fraud and taking the appropriate action following such investigation. Any investigative activity required will be conducted without regard to the suspected wrongdoer's length of service, position/title, or relationship to the Company. Employees and contractors who commit an act of fraud are subject to disciplinary action, including termination with cause, criminal prosecution, or both. The Company will pursue full recovery of all losses resulting from an act of fraud. 4. Definition of Fraud For the purposes of this Policy, fraud is defined as dishonest, irregular or illegal acts, characterized by a deliberate intent at concealment or false representation, resulting in the diversion of Company resources, whether or not for personal gain. FRAUD POLICY PAGE 2 FEBRUARY 2014

4 Examples of acts considered fraudulent: forgery or alteration of any document or account belonging to the Company (for example, a cheque, bank draft, or contract); financial reporting schemes such as manipulating earnings through improper revenue recognition, and overstatement of assets or understatement of liabilities; misappropriation of funds, securities, supplies, or other assets; impropriety in the handling or reporting of money or financial transactions; profiteering as a result of insider knowledge of Company activities; knowingly disclosing confidential and proprietary information to unauthorized parties; accepting or seeking anything of material value from contractors, vendors, or persons providing services/materials to the Company; destruction or removal of records; unauthorized removal or inappropriate use of furniture, fixtures, and equipment; and/or any similar or related inappropriate conduct. 5. Duties and Responsibilities of an Employee or Contractor The following are the duties and responsibilities of an Employee or contractor under this Policy: (a) (b) (c) Duties of Employees in Managerial Positions: All managers have a duty to familiarize themselves with the types of improprieties that could occur within their areas of responsibility and to be alert for any indications of irregularity. This includes identifying the risks to which systems and procedures are exposed, developing and maintaining effective controls to prevent and detect fraud, and ensuring that controls are being complied with. Employee and Contractor Duties: Employees and contractors at all levels are accountable for setting the appropriate tone of intolerance for fraud by complying with all laws, rules, regulations, professional codes of conduct and policies. Employees and contractors must act with propriety in the use of official resources and in the handling and use of corporate funds whether they are involved with cash or payments systems, receipts or dealing with suppliers. Suspicion of Fraud: Employees and contractors who suspect fraud must report it as outlined in section 6 of this Policy. Failure to report suspected fraud may be subject to appropriate discipline. Individuals who knowingly make false allegations of fraud will be subject to appropriate discipline. When fraud is suspected, under no circumstances should an Employee or contractor attempt to: (i) (ii) personally conduct investigations or interviews/interrogations related to any suspected fraudulent act; or contact the suspected individual in an effort to determine facts or demand restitution. FRAUD POLICY PAGE 3 FEBRUARY 2014

5 6. Reporting Suspected Fraud Any Employee or contractor who knowingly observes or suspects dishonest or fraudulent activity must report it immediately to the Director, Corporate Security, the Director, Internal Audit or the Chief Corporate and Strategy Officer & Corporate Secretary. If you are not comfortable reporting to one of the above, you may also submit a written report to the Chair of the Audit Committee. This written report should fully describe the suspected fraud. The Company will ensure any necessary investigation is conducted in accordance with section 7 of this Policy. The Director of Corporate Security may, in the course of an investigation, interact with individuals from other departments within the Company as considered necessary, such as Human Resources and/or the Law Department. All reasonable steps will be taken to protect the confidentiality of a person who in good faith advises of or reports possible misconduct and the employment status of such person will not be affected by so advising or reporting. The company has also established a confidential and anonymous reporting mechanism with an independent company which can be accessed via a web-based tool at or by calling Conducting Investigations The following process will be applied to conduct investigations: (a) Responsibility to Investigate: The Corporate Security department has the primary responsibility for coordinating the investigation of all allegations of fraud where there is sufficient cause. No one other than the Corporate Security department should attempt to personally conduct investigations or interviews related to any allegation of fraud. Great care must be taken in the investigation of suspected improprieties or wrongdoings so as to avoid mistaken accusations or alerting suspected individuals that an investigation is under way. (b) Access to Records: The Corporate Security department, in the course of conducting any investigation, will have free and unrestricted access to all Company records and premises and the authority to examine, copy, and/or remove all or any portion of the contents of files, desks, cabinets, and other storage facilities on the premises without prior knowledge or consent of any individual who may use or have custody of any such items or facilities when it is within the scope of their investigation. This access is only permitted in relation to an investigation and must be in accordance with applicable privacy legislation and in accordance with employment contracts or collective agreements. 8. Inquiries About Investigations All inquiries concerning the activity under investigation from the suspected individual, his or her attorney or representative, or any other inquirer should be directed to the Director, Corporate Security or the Director, Internal Audit. No information concerning the status of an investigation should be provided by any other person without the written consent of the Chief FRAUD POLICY PAGE 4 FEBRUARY 2014

6 Corporate and Strategy Officer & Corporate Secretary. The proper response to any inquiry is: I am not at liberty to discuss this matter. Under no circumstances should any reference be made to the allegation, the crime, the fraud, the forgery, the misappropriation, or any other specific reference. 9. Actions to be Taken Following an Investigation The results of the investigation will be included in a written report prepared by the Corporate Security department and presented by the Director Internal Audit to the Audit Committee and through it to the Board. Based on the results of the investigation, management will determine an action plan for discipline, any referral to the applicable law enforcement agency and/or changes to processes or controls. All actions taken in response to an established act of fraud must be approved by the Chief Corporate and Strategy Officer & Corporate Secretary of Manitoba Telecom Services Inc. The Company will pursue every reasonable effort to obtain recovery of any losses incurred as a result of fraud. Decisions to prosecute by way of civil proceedings or refer the investigation results to the appropriate law enforcement and/or regulatory agencies for independent investigation will be made in conjunction with the Chief Corporate and Strategy Officer & Corporate Secretary and senior management, as will final decisions on disposition of the matter. 10. Questions and Advice Related to the Policy Your manager is normally the first person you would contact if you have questions about anything in this Policy. In some cases, you may feel more comfortable discussing the matter with someone other than your manager. In those cases, please refer to section 6 of the Guide for Business Conduct & Ethics. If there is any question as to whether an action constitutes fraud, you should contact the Corporate Security department for guidance. * * * FRAUD POLICY PAGE 5 FEBRUARY 2014

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