Our Approach
1
Maintaining a culture of integrity
The Triangle Ethics Office is run by a team of employees dedicated to updating, communicating
and overseeing compliance with the codes of conduct for CTC and its subsidiaries (apart from
Helly Hansen), with executive oversight and reporting obligations to the Board’s Audit
Committee.
Our onboarding process requires new employees, directors and independent contractors to
review and sign off on their respective codes of conduct. All current employees and directors
are also expected to review and acknowledge any updates to their respective codes of conduct.
Ongoing education and awareness of our ethics program is facilitated through the annual Code
sign-off process, which is also paired with an employee training module every other year that
covers the employee’s code of conduct, scenarios that reflect the four commitments described
below and an assessment requiring an 80% grade to pass. In 2022, 97% of our employees4
completed the annual sign-off of their respective code of conduct. All CTC, Canadian Tire Bank
and CT REIT directors also completed their respective code of conduct annual sign-off in 2022.
The onboarding process also requires all new employees to complete training on harassment
and discrimination, prevention of workplace violence, and occupational health and safety. It is
the responsibility of all employees to ensure that the Company continues its long tradition of
maintaining a respectful and safe workplace. Employees are informed of their responsibilities
and obligations and given tools to manage and reduce the risk of harassment, discrimination,
violence, and workplace hazards.
Our values in action: We take personal
responsibility
The commitments outlined in our Code of Conduct reflect our values and form the
foundation for how we go about business and interact with internal and external
stakeholders.
Commitment 1
We treat others as we would like to be treated.
Commitment 2
We safeguard our Company assets, information and reputation.
Commitment 3
We conduct our business honestly and with integrity.
Commitment 4
We contribute to the communities in which we operate.
Our approach to supporting an ethical business culture is periodically put through a review
process. In early 2023, the Triangle Ethics Office completed its annual review of the CTC and
CT REIT codes of conduct and related protocols that were leveraged in 2022 to confirm our
processes were operating effectively and efficiently throughout that year.
Employees are encouraged to seek guidance from the Triangle Ethics Office with any questions
on our codes of conduct. In the event that a situation arises that the employee feels is in breach
of a code, they also have numerous channels (including anonymous submission) to bring the
complaint or concern forward to the Triangle Ethics Office, which will review the concerns raised, conduct or facilitate an investigation as necessary and ensure an appropriate resolution
is found. On a quarterly basis, the Triangle Ethics Office issues a report to the Audit Committee
of the Board that consists of a statistical summary of reported incidents and their resolutions,
incident trends, granted waivers of compliance with the Code (if any) and significant
developments that occurred during the reporting period that could impact our standards,
including regulatory developments.
Investigating complaints by third parties
The Triangle Ethics Office oversees the resolution of all matters related to the ethical
conduct of our operations, including complaints made by individuals outside of the
enterprise, such as our customers and suppliers. Whatever channel an individual uses,
the matter will be directed to the Triangle Ethics Office to ensure that the conduct in
question is investigated in a manner consistent with the standards we strive to uphold at
the Company.
2
Engaging in fair competition
The fundamental objective of competition law is to maintain and encourage free and fair
competition in the marketplace. These laws reflect the belief that in a marketplace characterized
by honest and vigorous competition, the most innovative and efficient companies will thrive, and
consumers will have the best products and services available at fair prices.
Our reputation and long-term success are based not only on how effectively we serve our
customers and how successful we are at increasing shareholder value, but also on the way we
conduct our business and our competitive practices in the marketplace. As such, we have an established competition law compliance governance structure, which includes a Competition
Law Corporate Operating Directive and Compliance Manual that sets out operational
expectations that must be complied with across the Company. We also conduct ongoing training
to assist employees in identifying situations where competition law issues may arise and
knowing how to address those situations and when to seek legal advice.
3
Setting ethical standards for our vendors and other business relationships
It is important to us that our values be shared among those with whom we do business. We
believe we can achieve the best outcomes by agreeing that specified ethical standards will
apply across our value chain and will govern our business relationships before we start doing
business with a new supplier or other third party. As a Company with global relationships, this
can result in going above and beyond local compliance requirements to ensure that we are
consistently embodying our values of honesty, integrity and respect across our value chain.
All our vendors are required to demonstrate and attest to their understanding and compliance
with the standards set out in our Supplier Code of Business Conduct, which is reviewed
regularly. We also have programs in place to audit our vendors against our standards. Learn
more about our responsible sourcing practices here.