Canadian Tire

Business Ethics

Our Commitment

We are committed to maintaining our place as one of Canada’s most trusted companies by embracing clear ethical conduct standards across our operations and ensuring that our culture prioritizes operating with integrity.

Our efforts to foster emotional connection, brand recognition and customer loyalty have allowed Canadian Tire to become one of Canada’s Most Trusted Brands1. We are not only proud of this achievement, but also consider it to be a significant competitive advantage. Our current and future success is partly due to the diligence we have demonstrated over the decades to earn and preserve the trust Canadians have in us.

To maintain trust, we have adopted high standards of business conduct. Conducting business in accordance with these standards builds and protects our reputation with employees, customers, suppliers and our other stakeholders.

We believe it is vital that everyone on our team has a shared understanding of what it means to act with honesty, integrity and respect. We achieve this through our Triangle Ethics Office (TEO), codes of conduct and compliance programs. These resources are supported by our leadership commitment to our Code of Conduct (the Code) and CTC’s Core Values, which drive a culture of integrity in our operations that fosters a positive and productive working environment and helps us manage risk. Our standards of conduct apply to all employees, directors and independent contractors, from the CEO to corporate-operated store employees across the country and employees that source products globally.

We Are Here to Make Life in Canada Better by maintaining the trust that Canadians have in our brand.

Our Approach

1

We foster a culture of integrity across our operations

The TEO was established in 2005. It is run by a team of employees dedicated to updating, communicating and overseeing compliance with the codes of conduct for CTC and our Canadian subsidiaries, with executive oversight and reporting obligations to the Board’s Audit Committee.

Our approach to supporting an ethical business culture is periodically put through a review process. In 2021, the TEO reviewed the Code and related protocols to confirm our processes were operating effectively and efficiently. Employees are encouraged to seek guidance from the TEO, or their human resources representative, with any Code-related questions. In the event that a situation arises that the employee feels is in breach of the Code, they also have numerous channels (including anonymously) to bring the complaint or concern forward to the TEO. The TEO will review the concerns raised, conduct or facilitate an investigation as necessary, and ensure an appropriate resolution is found. On a quarterly basis, the TEO 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 (new or changed laws and regulations) that occurred during the reporting period that could impact our standards.

TEO Expansion in 2022

TEO Expansion in 2022

In light of industry concerns about credit card sales practices and our focus on building trust, the TEO is expanding the capabilities of our business conduct hotline and web reporting service to enable the acceptance of complaints about sales practices and will oversee their resolution.

Our employee onboarding approach requires new employees, including directors and independent contractors, to review and sign-off on the Code. All current employees are expected to review and acknowledge updates to the Code. The annual Code sign-off process undertaken in 2022 also required employees to complete a training module that covered information on the Code, scenarios that reflected the four Commitments described below, and an assessment requiring an 80% grade to pass.

Employees are encouraged to seek guidance from the TEO, or their human resources representative, with any Code-related questions. In the event that a situation arises that the Employee feels is in breach of the Code, they also have numerous channels (including anonymously) to bring the complaint or concern forward to the TEO. The TEO will review the concerns raised, conduct or facilitate an investigation as necessary, and ensure an appropriate resolution is found.

Our values in action: we take personal responsibility

Our Canadian Tire 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.

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.

Did you know?

The TEO, with assistance from the Human Resources team, supports CT REIT with their employees’ training and annual sign-off of their code of conduct. Any incidents or breaches of the CT REIT code of conduct are also overseen by the TEO and reported to management of CT REIT on a quarterly basis.

Canadian Tire Store
2

We engage in fair competition

We have an uncompromising commitment to comply fully with all laws that are applicable to our business. One of the most significant of these is competition law. 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, how to address those situations and when to seek legal advice.

3

We set ethical standards for our business relationships

It is important to us that our values are 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, we know we must be aware of and in compliance with the various – and changing – laws and regulations of the countries in which we operate. In alignment with our values, we strive to go above and beyond in meeting compliance requirements and will continue to do so wherever possible.

All of our suppliers are required to demonstrate, and attest to their understanding and compliance with the standards set out in our Supplier Code of Business Conduct. Learn more about our responsible sourcing practices here.

1 University of Victoria, Gustavson School of Business. 2022. “Gustavson Brand Trust Index”. Retrieved: https://www.uvic.ca/gustavson/brandtrust/assets/docs/final--gbti-2022-main-report.pdf

Unless otherwise indicated, information in this ESG Report is provided for the 2021 fiscal year. For further information on our approach to ESG reporting, including our Glossary, which sets out definitions of capitalized terms and acronyms that are not otherwise defined in this page, and our forward-looking information disclaimer, please click here.