WORKPLACE SAFETY AND INSURANCE BOARD Code of Business Ethics and Behaviour June 11, 2014
Contents Statement of Intent...3 Application...3 Key Terms...3 Public Body... 3 Public Servant... 3 Conflict of Interest Commissioner... 3 Integrity Commissioner... 3 Ethics Executive.......................................................... 4 Compliance...4 Privacy/Confidentiality...4 Code Provisions...5 Health, Safety and Wellness... 5 Oaths & Affirmations... 5 Oath of Office... 5 Oath of Allegiance... 6 Wrongdoing... 6 Conflicts of Interest... 6 Political Activity... 7 Use of Information Technology Resources... 8 Intellectual Property & Copyright... 8 Business Expenses & Financial Accountability... 8 Procurement of Goods & Services... 8 Social Networking & Blogging... 10 Sensitivity & Fairness To the Public and To Each Other...11 Workplace Violence, Discrimination and Harassment...11 Workplace Diversity...11 Employment of family members or others persons in which the WSIB employee has a substantial interest... 12 Workplace Culture... 12 Amendments to the Code... 13 Reporting an Ethical Violation... 13 Accountabilities... 13 3545A (06/14) WSIB s Code of Business Ethics and Behaviour 2
Statement of Intent The WSIB places the highest value on the integrity of its employees, of the members of the Board of Directors and of the organization itself. The purpose of the Code is to provide guidance to staff and members of the Board of Directors and to help them recognize and resolve ethical issues they may encounter in conducting the business of the WSIB. Everyone to whom this Code applies must comply with its provisions, both in letter and spirit, and is responsible for being familiar with the contents of this Code. Employees who violate this Code may be subject to discipline up to and including a requirement for restitution or termination of employment. Application This Code applies to all employees, including those under contract and those on early leave and to members of the Board of Directors. Retirees and other former employees and members of the Board of Directors continue to be required to comply with certain provisions of this Code after they leave the WSIB. Key Terms The following terms apply in this Code in accordance with the Public Service of Ontario Act: Public Body Agencies, boards and commissions that are prescribed as public bodies under the Public Service of Ontario Act. The WSIB is a public body. Public Servant A person who is employed by or appointed to a public body. All members of the Board of Directors and all employees of the WSIB are Public Servants. Conflict of Interest Commissioner Appointed by the Lieutenant Governor in Council. This position is responsible for approval and publishing of conflict of interest rules for all public bodies, giving direction on conflict of interest and political activity matters referred by the Ethics Executive and acts as the Ethics Executive for former public servants. Integrity Commissioner Appointed by the Lieutenant Governor in Council, the Integrity Commissioner has responsibilities under various statues. Under the Public Service of Ontario Act, allegations of wrongdoing may be directed by members of the Board of Directors and employees to the Integrity Commissioner. WSIB s Code of Business Ethics and Behaviour 3
Ethics Executive Provides advice and direction to employees and members of the Board of Directors on violations to the Code, as well as the approved Conflict of Interest rules, and is accountable for addressing and responding to those violations. At the WSIB the Ethics Executive: For employees is the President. For Board of Directors members, other than the WSIB President and Chair, is the WSIB Chair. For the WSIB President and Chair is the Conflict of Interest Commissioner. For former WSIB Public Servants is the Conflict of Interest Commissioner For more information go to www.oico.on.ca Compliance Compliance is both a corporate and individual responsibility. Everyone has the personal responsibility to know and understand this Code, the Conflict of Interest Rules made pursuant to the Public Service of Ontario Act, and other policies of the WSIB. Privacy/Confidentiality The WSIB takes privacy seriously. The WSIB is a custodian of sensitive personal information and confidential business information. Protecting the confidentiality of the information, whether it is injured workers claim information, WSIB employee information or sensitive business information, is everyone s responsibility. The WSIB is legally obligated to protect the personal information of injured workers, employers and WSIB employees and provide the right to access their own personal information. At the WSIB, issues of privacy are central to everything we do. Employees must at all times respect the privacy of others whether it is injured workers, employers or fellow employees by: Accessing personal information only when it is necessary for the performance of their job duties Understanding when collection, use and disclosure is permitted and when not and to act appropriately Understanding and applying security and privacy best practices to safeguard personal information that is in their custody or control. The importance of maintaining the security of sensitive information is not just a best practice; it is an obligation that we must be vigilant about. Knowing how to handle information properly protects the rights of employers and workers and ensures that the WSIB meets its duties and obligations. WSIB s Code of Business Ethics and Behaviour 4
Code Provisions Health, Safety and Wellness The WSIB is committed to being the leading workplace compensation board and to promoting health, safety and wellness in the workforce. WSIB management is committed to putting in place appropriate work practices and taking all practical measures to ensure that equipment and premises within its control are in safe condition and reduce risk to health. While WSIB management has the prime responsibility for managing health and safety, everyone must protect their own personal health and safety through the decisions and actions they take. The following principles guide the Health & Safety policies of the WSIB: Everyone is entitled to a safe, healthy workplace. Everyone is responsible for health and safety at the WSIB and as such, everyone will take all possible steps to perform work in a safe manner to prevent personal injury and illness. Everyone will take responsibility for their actions and learn from experiences to prevent further incidents and near misses. The WSIB will ensure everyone receives training or guidance in specific work tasks, according to their role, in order to protect their own and others health and safety. Everyone will work in compliance with applicable legislation and established safe work practices and in doing so, be fit for work. Everyone will take timely corrective action to eliminate hazards at WSIB workplaces, or to report hazards beyond their control to their supervisor. WSIB management is committed to putting in place appropriate work practices and taking all practical measures to ensure that equipment and premises within its control are in safe condition and reduce risk to health. The WSIB and OCEU 1750 are committed to consulting about health and safety issues and taking appropriate action to ensure the safety of employees. Refer to WSIB Health & Safety policies for more specific information and guidelines. Oaths & Affirmations As Public Servants, all members of the Board of Directors and all employees of the WSIB are required to swear or affirm both the Oath of Office and the Oath of Allegiance upon commencement of employment or appointment. This act reinforces the importance of public service, and demonstrates the commitment of all members of the Board of Directors and all employees to the public they serve. Oath of Office This oath establishes the employees duty of loyalty to the employer, the duty to comply with all laws, WSIB s Code of Business Ethics and Behaviour 5
and the obligation to maintain confidentiality, even after leaving the public service. Oath of Allegiance This oath establishes allegiance to the Crown. Wrongdoing The Public Service of Ontario Act establishes procedures and provides protection to employees and members of the Board of Directors who disclose wrongdoing at or by the WSIB. Wrongdoing is defined by the Public Service of Ontario Act to mean: Violation by a Public Servant of either a statute or a regulation; An act or omission by a Public Servant that creates a grave danger to life, health, safety of persons or to the environment where the danger is unreasonable under the circumstances; Gross mismanagement by a public servant (e.g. gross waste of money, abuse of authority, abuse of public assets) Directing or counseling someone to commit one of the above. Only acts of wrongdoing as defined above may be reported directly to the Integrity Commissioner. For more information, refer to the Administrative Procedures, or contact the Office of the Integrity Commissioner: Telephone: 416-314-1581 or 1-866-884-4470 Website: www.oico.on.ca Mail: 2 Bloor St. E, Suite 2101, Toronto, On M4W 1A8 Email: info@oico.on.ca Refer to the Disclosure of Wrongdoing Policy on Connex for more specific information Conflicts of Interest A conflict of interest occurs when a person s activities or interests interfere with work responsibilities. Avoiding and preventing situations that could give rise to a conflict of interest or the appearance or perception of a conflict of interest is one of the primary means by which the WSIB maintains public confidence in the impartiality and objectivity of our business activities. Being aware of these situations protects employees and members of the Board of Directors as individuals, as well as the WSIB as a trusted organization. As Public Servants under the Public Service of Ontario Act, WSIB employees and members of the Board of Directors are bound to comply with Conflict of Interest Rules for Current and Former WSIB Employees and Members of the Board of Directors which have been approved by the Conflict of Interest Commissioner and are published on the Commissioners website: http://www.coicommissioner.gov.on.ca/wp-content/ uploads/2014/04/workplacesafetyandinsuranceboard.pdf In addition to this Code, each member of the Board of Directors shall comply with the conflict of interest rules in the Management Board Secretariat Directive entitled Government Appointees. Refer to the Conflict of Interest Disclosure Statement on Connex for more specific information. WSIB s Code of Business Ethics and Behaviour 6
Political Activity The political activity rules in the Public Service of Ontario Act balance the need to preserve the integrity and neutrality of the public service with an individual s right to engage in political activity. An employee or member of the Board of Directors engages in political activity when he or she: Does anything in support of or in opposition to a federal or provincial political party; Does anything in support of or in opposition to a candidate in a federal, provincial or municipal election; Is or seeks to become a candidate in a federal or provincial or municipal election, or Comments publicly and outside the scope of the duties of his or her position on matters that are directly related to those duties and that are dealt with in the positions or policies of a federal or provincial party or in the positions publicly expressed by a candidate in a federal, provincial or municipal election. Members of the Board of Directors and employees may engage in political activity subject to certain restrictions. They may not: Engage in political activity in the workplace; Use WSIB premises, equipment or supplies when engaging in political activity; Associate his or her position at the WSIB with political activity. The legislation protects members of the Board of Directors and employees who decline to be politically active. Some activities require a leave of absence without pay. These include: Being or seeking to be a candidate in a federal or provincial election during an election period; Raising funds on behalf of a federal or provincial party, or a federal, provincial or municipal candidate if the employee or member of the Board of Directors: Supervises other WSIB employees, or Deals directly with members of the public if those members of the public may perceive him or her as a person able to exercise power over them; Commenting publicly, outside the scope of their duties, on matters directly related to their duties and that are addressed in the policies of a federal or provincial party or a federal, provincial or municipal candidate; Engaging in political activity if it could interfere with the performance of his or her duties as a Public Servant; Engaging in political activity if it could conflict with the interests of the WSIB. Members of the Board of Directors and employees seeking an unpaid leave of absence to pursue political activities as described above apply to their Ethics Executive. Where an employee is elected as an official representative of a union representing WSIB employees, the Employer recognizes that the employee, as union representative, may have an enhanced responsibility to the labour movement including associated political ties. If the employee engages in political activity as a union representative, the Employer acknowledges such activities will not be construed as a conflict of interest. WSIB s Code of Business Ethics and Behaviour 7
Use of Information Technology Resources Every employee and every member of the Board of Directors is personally responsible for the protection of WSIB assets and systems assigned to or made available to them. Refer to the WSIB Acceptable Use of Information Technology Policy for more specific information. Intellectual Property & Copyright The WSIB owns the copyright in all works created by its employees in the course of their employment in the absence of any express written agreement to the contrary. As the owner of copyright in such works, the WSIB has all of the exclusive rights associated with ownership as set out in section 3 of the Copyright Act, including the exclusive right to give or withhold permission to do certain acts in relation to the works. The WSIB logo may only be used in the course of conducting WSIB business, or where expressly authorized by senior management. Business Expenses & Financial Accountability The WSIB s financial, accounting and other reports and records will accurately and fairly reflect the transactions and financial condition of the WSIB in reasonable detail, and in accordance with International Financial Reporting Standards (IFRS), practices, procedures and legal requirements. No one will authorize payment knowing that any part of the payment will be used for any purpose other than what is described in documents supporting the payment. Everyone will exercise integrity, prudence, and judgment when they incur and approve business expenses. They must be reasonable and necessary for business reasons. Expenses incurred in the performance of WSIB business will be reimbursed in accordance with the Travel and Business Expenses policy and the Management Board Secretariat Travel, Meals and Hospitality Expenses Directive, through the filing of expense reports, which must be documented accurately and completely. (Refer to Administrative Policy 04-08-01: Travel and Business Expense Policy.) Procurement of Goods & Services The WSIB will only make purchases based on total cost, service, quality and proficiency of, and commitment to, integrity. Those business units or individuals that are planning to purchase goods or services must involve Procurement Services early in the sourcing process to facilitate the supplier selection and qualification process and to conduct negotiations for the specific purchase. The procurement process methods based on dollar value thresholds are as follows: $0 to $5,000 may use Corporate Credit Card All goods and services excluding consulting and professional services, in accordance with the preferred contracted suppliers list, when possible. Other Services greater than $5,000 and all Consulting Services regardless of value must use Procurement Services WSIB s Code of Business Ethics and Behaviour 8
All consulting services, goods, general services and professional services (in any form, including verbal or written orders, letters of intent or contracts). Mandatory requirements set out in the Procurement Directive, approved by Management Board of Cabinet in 2009, include the following: The use of a competitive procurement process for all consulting services irrespective of value, with limited allowable exceptions for non-competitive procurement. In circumstances where a non-competitive procurement is required for consulting services, approval must be secured from both the Deputy Minister and the Minister of Labour for assignments valued $100,000 but less than $1M and from Treasury Board/Management Board of Cabinet for assignments valued $1M or more. Consultants will not to be reimbursed for hospitality, incidental and/or food expenses. No individual WSIB employee or member of the Board of Directors may: Make a purchasing card commitment or sign a purchase order or contract without having the delegated authority to do so; or Make a verbal or written commitment to a supplier for it to provide goods and/or services to the WSIB without a purchase order and/or contract in place unless by purchasing card in accordance with the purchasing card guidelines. A person who fails to comply with this may be subject to disciplinary action up to and including termination. Procurement Services is responsible for preparing cluster-specific reports of situations of non-compliance to the Procurement Policy and procurement administrative processes. Situations of non-compliance include: Goods and/or Services were rendered prior to a Purchase Order being issued Amounts were subdivided to avoid obtaining appropriate approvals Commitment made to supplier or contract was issued prior to obtaining appropriate approvals (including request to waive the competitive process) Services continued to be provided after contract expiry date or in excess of Purchase Order value All WSIB employees are expected to comply with the policies related to expenditures for goods and/or services and the related procedures and guidelines including the following: Expenditure Authority Policy #02-01-01 Procurement Policy #02-02-01 Signing Authority for Payments #04-08-02 Procurement Services Guidebook and Administrative Processes Manual The WSIB will inform all vendors, suppliers, consultants and business partners of their responsibility to act on behalf of the WSIB consistent with the Code and other relevant WSIB policies. WSIB s Code of Business Ethics and Behaviour 9
Social Networking & Blogging Emerging social media/collaboration platforms (blogs, wikis, on-line social networks/publishing/discussion/ video) are changing the way people communicate and engage with each other. In general, social media activities are not permitted at work unless the activities are part of your job function. However, activities inside and outside work that affect your job performance, the job performance of others or WSIB s business interests and reputation are the appropriate focus of policy. When the WSIB communicates publicly whether to its stakeholders, clients, customers or to the general public it has an accepted process. Only those officially designated by the WSIB have the authorization to speak on its behalf. Social networking and blogging are primarily forms of communication among individuals. As such, these activities must be performed on personal and not WSIB time and not from WSIB equipment or e-mail addresses. If participating in social media activities on your own time, the following guidelines apply: The line between personal and work is often blurred in online social networks. Make it clear that what you say are your own views and opinions. Do not identify or represent WSIB positions, strategies or opinions. Assume that what you have written will be read by others (including work and personal colleagues, clients, customers and stakeholders) and can by acted upon. Do not disclose or use WSIB confidential, proprietary, sensitive, financial or business performance information or that of any other person or company online. Do not use or disclose any material that violates the privacy of others. By mindful that what you write will be public for a long time. Do not post material that is obscene, defamatory, profane, libelous, threatening, harassing, abusive, hateful or embarrassing to another person or entity. This includes, but is not limited to, comments regarding the WSIB, WSIB employees, customers, clients, stakeholders, WSIB s partners and WSIB s competitors. Refer to the WSIB Acceptable Use of Information Technology Policy. The WSIB actively monitors social media for mentions of our organization. This is common practice in most large businesses, government agencies and non-profit organizations. Anyone who writes or speaks about the WSIB online can expect that their comments will be noted by the WSIB. If WSIB management finds that an employee s conduct on or off the job adversely affects his or her performance or that of other employees, or the legitimate business interests of the WSIB, such employees will be subject to disciplinary measures, including dismissal. WSIB s Code of Business Ethics and Behaviour 10
Sensitivity & Fairness To the Public and To Each Other The importance of courteous, prompt, sensitive and professional service to the public and to each other as colleagues cannot be over emphasized. We represent not only ourselves, but also every member of the Board of Directors and all other employees of the WSIB. Sensitivity to the needs of the public and to each other involves being polite, even under difficult conditions, in times of personal stress, and in the face of provocation that does not involve a violation of the law. We must not make abusive, threatening, insulting, offensive or provocative statements or gestures to, or about, another person. The WSIB is committed to leading by example and becoming the most effective public sector organization of its kind. This commitment is based on the following principles: We treat everyone with fairness, dignity and respect We act with honesty and integrity in our dealings with the public and each other We demonstrate knowledge and competence in carrying out our work Our employees have the right skills and training to do their jobs and to respond appropriately to individual needs and interests We respect personal privacy, and protect personal information We provide timely access to personal information and business information We communicate and make decisions in a timely manner We keep the public and each other informed and return phone calls and queries as quickly as possible We demonstrate fairness and equity We are open and transparent We demonstrate responsible stewardship and governance. Workplace Violence, Discrimination and Harassment The WSIB does not tolerate or condone workplace violence, workplace harassment or discrimination towards any of its employees by any other employee, its clients, customers, suppliers, visitors, contractors, or the general public. The WSIB considers these to be serious matters and will take whatever steps are reasonable to protect our employees. The WSIB also recognizes domestic violence as an issue that can impact the workplace, and provides for the necessary support and intervention for employees. Refer to the Workplace Violence, Discrimination & Harassment Policy for more information. Workplace Diversity The WSIB celebrates the varied backgrounds, experiences, perspectives and talents of all of its employees and promotes a culture of inclusion and accessibility where everyone feels valued and respected. We embrace and promote these unique and varied backgrounds as a source of new ideas and creativity. Therefore, the WSIB is committed to creating a workforce that reflects the diverse population of the Ontario workplaces and communities that it serves and will actively pursue the removal of systemic barriers that inhibit or prevent equal opportunity for all. We believe that diversity is a long-term commitment and it is embedded in our WSIB s Code of Business Ethics and Behaviour 11
culture and reflected in our people. We will ensure that our staffing process is conducted in alignment with our values of trust, fairness and integrity through impartial recruitment practices, including removing restrictive physical barriers which may deny access to those with physical limitations. We will provide equal opportunity to all qualified persons without regard to race, ancestry, colour, place of origin, sex, ethnic origin, age, marital or family status, disability, sexual orientation, creed, religion and citizenship. The WSIB will continually evaluate its policies and procedures to ensure we are attracting and retaining top talent and supporting all employees to contribute to their fullest potential. Employment of family members or others persons in which the WSIB employee has a substantial interest We value getting the best candidates for our job vacancies (permanent, temporary, summer student and contract) and we encourage our employees to act as ambassadors by referring great talent to our organization. That means that sometimes we may have personal relationships with people working at or applying to the WSIB (e.g. applying to an internal position where we have a personal relationship with the hiring manager or with someone on the team). A personal relationship is defined as a family member (spouse, child, parent or sibling) or other persons in which the WSIB employee has substantial interest e.g. close friend, close associate, person who was in a prior reporting relationship with you at another company, anyone living in your household and any person who has acted in place of a parent to you. WSIB employees must not: Try to obtain favourable treatment for or enhance the personal careers of themselves or any person with which they have personal relationship. Have a direct reporting relationship (either subordinate or supervisory). Attempt to influence or make decisions over an employee in which they have a personal relationship. This includes making enquiries regarding an applicant s status through the recruitment process, providing input into performance management decisions or other employment decisions (e.g. promotions, terminations, compensation) through the course of employment. WSIB employees who become aware of such employment situations must declare the potential conflict of interest to their Ethics Executive (i.e. President) and where necessary take actions with their management to mitigate and avoid any potential conflict of interest. Refer to the Conflict of Interest Rules for Current and Former WSIB Employees and Members of the Board of Directors for more information. Workplace Culture The WSIB s culture of health, safety, wellness, respect and integrity is reflected not only in our human resource policies and programs, but embodied and projected by every employee. Our dress code is one of business casual, to provide an open and welcoming environment for the diverse community we serve. Our employees are professionals, and present themselves in accordance with the nature of the work they do. To further support our sensitivity to each other and the customers we serve, our employees respect the chemical sensitivities of their clients and co-workers. The WSIB has a strong culture that reflects our mandate as well as our commitment to the principles we stand WSIB s Code of Business Ethics and Behaviour 12
by. Our culture of health, safety and wellness is embedded in all of our practices and programs. Values of fairness, integrity and trust define how we interact with our colleagues and clients. Our employees are professionals and behave with respect, transparency and a collaborative approach to working with others. Amendments to the Code The Code and its terms may be modified by the WSIB at any time and at its sole discretion. All amendments will be communicated to staff and members of the Board of Directors as soon as they are approved and will be binding as soon as they are communicated Reporting an Ethical Violation The WSIB fosters an environment in which issues and concerns may be raised and discussed with management or others without fear of retribution or reprisal. If someone becomes aware of activities that are inconsistent with this Code, they may immediately report them using one of the avenues described in the guidelines. Those who report suspected behaviour or actions that are seen as inappropriate will be protected from any kind of reprisal. Likewise, it is unacceptable to make a complaint or file a report knowing it to be false. The WSIB will not discharge, demote, suspend, threaten, harass or in any other manner discriminate against anyone as a result of providing information or assistance for investigations into corporate conduct. Information pertaining to a complaint and/or investigation will be handled in a manner that protects its confidentiality and the privacy of the individuals involved. However, disclosure may be necessary to aid in an investigation, to resolve a complaint, to take appropriate action or as otherwise required or permitted by law. Accountabilities The Chair is accountable: To act as Ethics Executive for members of the Board of Directors; To notify the Minister of Labour of the nature of a conflict of interest of any members of the Board of Directors, including the Chair; To be aware of and respond to violations of the code as reported by the President. The Board of Directors is accountable: To model behaviour through decisions and actions that is consistent with the provisions of the Code and all applicable laws; To direct, as required, policy and procedural change necessary to respond to systemic issues arising out of reported conflicts of interest. The President is accountable: To act as the Ethics Executive for the WSIB employees; To ensure that the Code is implemented and available to all to whom it applies; To make final decisions following breach investigations that cannot be resolved at the local level; WSIB s Code of Business Ethics and Behaviour 13
To report violations of the Code to the Board of Directors, and to ensure systemic and policy changes necessary to support the Code are implemented as soon as the need for the changes are known; To be aware of and respond to trends or systemic causes of workplace harassment at the WSIB; To direct, as required policy and procedural change necessary to respond to systemic issues arising out of reported conflicts of interest. To declare all conflicts of interest (Actual, Apparent or Potential) in writing to the Ethics Executive (i.e. Chair) as soon as they are known. Office of the Vice-President, Human Resources is accountable: To track and oversee investigations as necessary into calls made to the Ethics Line; To report every breach and other activity associated with the Code and their resolutions to the President Chiefs, are accountable: To lead by example. They are the champions of the Code and must hold their direct reports accountable for compliance within their businesses; To monitor compliance with the Code within their businesses; To investigate and review conflicts of interests and employee conflict of interest disclosures, as required, and make recommendation to the Ethics Executive To submit an annual due diligence report to the President confirming that all of their employees have completed annual training on the Code; all employees have acknowledged the Code through the annual performance development process; and all violations of the Code have been reported to the Vice-President, Human Resources; To declare all conflicts of interest (Actual, Apparent or Potential) in writing to the Ethics Executive (i.e. President) as soon as they are known. Chiefs, Vice-Presidents and Executive Directors are accountable: To lead by example. They are the champions of the Code and must hold their direct reports accountable for compliance within their businesses; To monitor compliance with the Code within their businesses; To submit an annual due diligence report to the President confirming that all of their employees have completed annual training on the Code; all employees have acknowledged the Code through the annual performance development process; and all violations of the Code have been reported to the Vice-President, Human Resources; To declare all conflicts of interest (Actual, Apparent or Potential) in writing to the Ethics Executive (i.e. President) as soon as they are known. Directors and Managers at all levels of the organization are accountable: To ensure that all of their employees, both current and new hires, understand their responsibilities under the Code and are in compliance; To ensure that all of their employees complete annual training on the Code; WSIB s Code of Business Ethics and Behaviour 14
To report violations brought to their attention by their employees to the Ethics Executive (i.e. President) as soon as they are known; To take appropriate action to investigate and address known or suspected violations to the Code; To be a concerned, knowledgeable, and reliable counselor to whom employees can comfortably go for advice on business ethics; To maintain employee confidentiality but if disclosure is unavoidable, to inform the employee of the disclosure, in advance if possible; To create a work environment that expects and supports ethical behaviour; To declare all conflicts of interest (Actual, Apparent or Potential) in writing to the Ethics Executive (i.e. President) as soon as they are known. Employees at all levels of the organization are accountable: To complete annual training on the Code; To understand their responsibilities under the Code and to be compliant with the Code; To carry out their accountabilities ethically and with integrity, and to seek advice when uncertain about the right ethical decision; To declare all conflicts of interest (Actual, Apparent or Potential) in writing to the Ethics Executive (i.e. President) as soon as they are known. To co-operate fully with an investigative process in which they are involved as the complainant or a witness. Effective Date: June 11, 2014 BOD Minute: BOD Minute #4(b), June 11, 2014, Page 7300. WSIB s Code of Business Ethics and Behaviour 15