Conflict of Interest and Business Ethics Policy

It is Ovation Workplace Services Inc. (Company) policy that all employees avoid any conflict

between their personal interests and those of the Company. The purpose of this policy is to ensure

that the Company's honesty and integrity, and therefore its reputation, are not compromised. The

fundamental principle guiding this policy is that no employee should have, or appear to have,

personal interests or relationships that actually or potentially conflict with the best interests of the

Company.

It is not possible to give an exhaustive list of situations that might involve violations of this

policy. However, the situations that would constitute a conflict in most cases include but are not

limited to:

1. Holding an interest in or accepting free or discounted goods from any organization that does,

or is seeking to do, business with the Company, by any employee who is in a position to directly

or indirectly influence either the Company's decision to do business, or the terms upon which

business would be done with such organization.

2. Holding any interest in an organization that competes with the Company.

3. Being employed by (including as a consultant) or serving on the board of any organization

which does, or is seeking to do, business with the Company or which competes with the

Company.

4. Profiting personally, e.g., through commissions, loans, expense reimbursements or other

payments, from any organization seeking to do business with the Company.

A conflict of interest would also exist when a member of an employee's immediate family is

involved in situations such as those above. This policy is not intended to prohibit the acceptance

of modest courtesies, openly given and accepted as part of the usual business amenities, for

example, occasional business-related meals or promotional items of nominal or minor value.

It is your responsibility to report any actual or potential conflict that may exist between you (and

your immediate family) and the Company.

Anti-corruption and anti-bribery

We comply with anti-corruption and anti-bribery laws as may be applicable wherever we do

business. The Company’s anti-bribery policy including hospitality, “offset” issues, employment of

relatives, guidance on gifts, political/ charitable contributions and extortion/ blackmail responses

are contained in its Anti-bribery and Anti-corruption Policy. (available on

https://www.ovationwps.com/corporate-governance).

Employee Policies

Equal Opportunity 

Ovationwps is an equal opportunity employer and endeavors to treat all potential candidates and employees equally without regard to their race, religion, sex, color, age, national origin, marital status, pregnancy (including child birth), sexual orientation, medical condition, disability etc. Ovationwps further provides equal opportunities in employment, upgrading, promotion or transfer, recruitment or recruitment advertising, layoff or termination, wages or other compensation, selection for training, including apprenticeship, pre-apprenticeship, and/or on the job training. Ensuring and maintaining a work environment free of harassment and intimidation and coercion at all facilities where Ovationwps employees function, is therefore high on the priority list. Ovationwps will ensure adherence to the laws of the land with regard to employment norms and will not indulge in practices such as employing child labor, bonded labor, etc. 

Recruitment decisions will be based on the candidate’s merits, e.g., education, prior experience and qualifications. This includes the individual’s skills, performance, values, leadership and other job related criteria. All employment-related decisions be taken without regard to a person’s race, sex including pregnancy, color, national or social origin, religion, age, disability, sexual orientation, medical condition, political opinion or any other status protected by applicable law and policy. 

Workplace and sexual harassment 

The Company has a strong, clear and documented stand against any form of harassment at the workplace. Harassment as a result of discrimination or which is sexual in nature and has the effect of creating an intimidating, hostile or offensive work environment is not allowed at Ovationwps. 

Allowing harassment to continue

Managers and/or supervisors who allow workplace harassment to continue or fail to take appropriate corrective action upon becoming aware of the harassment may be considered a party to the offense, even though they may not have engaged in such behavior themselves. Thus, they are also held responsible for such misconduct and subject to disciplinary action as per the code. 

Drugs and weapons 

The Company strictly prohibits any person entering the Company or client premises under the influence of or in possession of any intoxicating substance (including alcohol) or any other drugs. Further, any person in possession of unauthorized weapons, illegal firearms, weapons or explosives will not be permitted to enter the Company or client premises. However, trained security personnel may possess authorized weapons as mandated.

Privacy rights of employees

By using, maintaining and transferring personal data in accordance with Ovationwps’s employment data protection standards and related procedures, you are required to maintain the secrecy of and not to divulge or communicate in any manner, any information regarding your remuneration to any other staff members of the Company except to your immediate superior. 

It is the obligation of the employee to furnish true information for 

• Own profile (e.g. education details, work experience, last drawn salary, etc) 

• Time, expense (amount, purpose, period), compensation related allowances, etc 

• Complaints (including whistleblower issues)