Our behaviours and decisions on the right track

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1 VIA Rail s Code of Ethics Our behaviours and decisions on the right track This is a shortened version of the Code, the full version is available on ivia.

2 VIA Rail s Code of Ethics Our behaviours and decisions on the right track OUR VALUES diligence The human way to accomplish our mission integrity The human way to behave Avoid real, apparent or potential conflicts of interest Refuse to accept gifts or benefits that may affect our objectivity Protect company assets Avoid taking part into professional activities that may conflict with our job Participate in political or public life activities in a responsible personal matter Respect all laws, rules and policies that apply to VIA Rail Respect internal policies, conventions and directives Protect the confidentiality of personal information entrusted to us as part of our job Avoid inappropriate hierarchical relationships (family relationship or personal relationship) Know-how The human way to work Be present in our jobs and respect our work schedules Be preventative and demonstrate diligence when we put our security procedures into practice Protect the safety of everyone, including our customers, our colleagues, the public and our own Prevent all violence in our workplaces Participate in social media in a respectful and loyal way whether for official or personnal use Be alert and ready, avoid becoming overcome by the consumption of alcohol, medication or illegal drugs while accomplishing our work Respect human dignity and recognize the value of each and every person Promote based on skills and by treating everyone fairly and respectfully Create and promote a workplace that is conducive to using both official languages Reduce our environmental footprint Contribute to the sustainable development of our company

3 TO WHOM DOES THE CODE APPLY? The Code of Ethics applies to all VIA Rail employees, including full-time, part-time, and contractual employees. OUR RESPONSIBILITIES as employees as managers Encourage business practices and behaviours that respect VIA Rail s values, including integrity, diligence and know-how Prevent or resolve ethically problematic situations Demonstrate openness to dialogue and collaboration during situations requiring our participation to resolve a non-ethical situation Report all possible violations, breaches, or wrongdoings with regard to the Code of Ethics and related policies when they come to our attention Adopt appropriate and exemplary behaviour Educate, encourage and inspire our employees and colleagues to follow suit Cultivate a sense of responsibility by making ourselves accountable for our actions Prevent and promptly address ethically problematic situations Promote, create, and maintain honest business practices

4 Process for reporting an ethical issue 1A Immediately contact your supervisor OR VIA Rail s Ombudsman. 1B Contact the Ombudsman if there is a situation that directly involves your supervisor, their superiors, or if you are concerned about the confidentiality of your reporting. 2 If following a dialogue with our supervisor OR with the Ombudsman / Compliance Officer, we come to the conclusion that this is an ethical issue that requires a disclosure in good and due form, fill in the form provided for that purpose in the appendix of the Code of Ethics and send it to the Ombudsman. 3 For any situation for which ambiguity is such that a preliminary investigation is needed to determine the best decision, the immediate superior OR Ombudsman appeal to the Ethics Committee for determination.? 4 In any situation, if the impact on the reputation of the organization is or may be major, the superior OR the Ombudsman appeal to the Ethics Committee. 5 Once a decision is made in step 2, 3 or 4, if the nature of the information allows it, the Ombudsman or the Ethics Committee shall communicate the decision to the discloser. reputation? NOTE All employees can contact their Human Resources advisors to obtain support about using the available resources and to understand the reporting process at Ethique_Ethics@viarail.ca

5 Guide to ethical Discussions We may be confronted with ethical questions, including situations in which making a decision is not just a formality, but instead requires discussion and, sometimes, support. When you are uncertain or hesitant about making a decision or taking action, please use this procedure to guide your discussions and choices. step 1: Define the problematic situation What is making me uncomfortable? Who are the parties involved? If I take such an action or make such a decision, what would be the impact on me and on the parties involved? step 2: Determine whether VIA Rail s Code of Ethics or its policies can guide me in the right direction Does VIA Rail s Code of Ethics address this problematic situation? If so, what is the expected behaviour under the circumstances? Is there a VIA Rail policy that indicates what behaviour to adopt under the circumstances? If so, what is it? step 3: Determine the values involved Which VIA Rail value is involved? How would the decision I am about to make or the action I am about to take affect this value? Given the expected behaviour and values of VIA Rail, what would be the best decision to make or the best action to take under the circumstances? step 4: Validate my decision Would I like if someone did this to me? Does my decision place the interests of VIA Rail before my personal interests? Would I be capable of justifying my decision to colleagues, to my immediate supervisor and to Canadian citizens? step 5: Ask for help Should I seek advice before acting? (If so, see the section How the Code of Ethics is applied.) Prevention mechanisms Since it is everyone s responsibility to adopt exemplary behaviour, VIA Rail promotes a constructive approach that hinges on communication and encourages dialogue. When an employee is personally involved in a situation or witnesses a situation that constitutes or could constitute a violation of the law or the Code of Ethics, VIA Rail strongly encourages reporting the situation and getting help.

6 Did you know Our professional obligation continues even after we have left employment with VIA Rail. Subcontractors, entrepreneurs, suppliers and any third party bound by a contract with VIA Rail must comply with the organization s values and ethical standards, as indicated in their contract. WHEN SHOULD THE CODE OF ETHICS BE USED? OUR RESPONSIBILITIES For conflicts of interest submit the appropriate form (available on ivia or upon request to your manager) In case of uncertainty about our ethical responsibilities consult the complete version of the Code of Ethics and its Ethical guide (available on ivia or upon request to your manager) To make a report, if we are involved in or witness report it to our immediate supervisor or to the Ombudsman/Compliance Officer Reporting in bad faith corrective or disciplinary measures may be taken Confidentiality the information you provide to the Ombudsman/ Compliance officer will be treated as strictly confidential INDIVIDUAL COMMITMENT AND RESPECT OF THE CODE Commitment to respect the Code of Ethics is a condition of employment All new full-time, part-time and contractual employees joining VIA Rail must commit to respecting the principles stated in the Code of Ethics Management staff members must renew their commitment to the values and exemplary behaviours by signing the commitment form Employees who refuse to commit to respect the Code of Ethics or who do not exhibit the exemplary behaviours described in the code may be subject to corrective or disciplinary action, including dismissal and civil or criminal prosecution ReFLEctION One of your colleagues informs you that he has observed that invoice approvals were often granted without anybody knowing for which services these bills were paid. What do you do? A proponent informs you that the company she works for is participating in a Request for Proposal to obtain a contract with VIA Rail and invites you to accompany her to a hockey game. What do you do? Following a discussion with his manager, a colleague writes disrespectful comments about him on social media. What do you do? See the Guide to Ethical Reflection in the Code s full version. RESOURCES the complete version of the Code of Ethics (available on ivia) your immediate supervisor Ombudsman / Compliance Officer: Louis Haeck ombudsman@viarail.ca 1637 de l Église Street Saint-Laurent (Quebec) H4L 2J2 Phone: (direct line) Fax: general Inquiries: ethique_ethics@viarail.ca

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