Form 6-K BCE INC For: Mar 31
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM 6-K
REPORT OF FOREIGN PRIVATE ISSUER
Pursuant to Rule 13a-16 or 15d-16 under
the Securities Exchange Act of 1934
For the month of: March 2021 | Commission File Number: 1-8481 |
BCE Inc.
(Translation of Registrants name into English)
1, carrefour Alexander-Graham-Bell, Verdun, Québec, Canada H3E 3B3,
(514) 870-8777
(Address of principal executive offices)
Indicate by check mark whether the registrant files or will file annual reports under cover of Form 20-F or Form 40-F.
Form 20-F [ ] Form 40-F [X]
Indicate by check mark if the registrant is submitting the Form 6-K in paper as permitted by Regulation S-T Rule 101(b)(1): _____
Indicate by check mark if the registrant is submitting the Form 6-K in paper as permitted by Regulation S-T Rule 101(b)(7): _____
Indicate by check mark whether by furnishing the information contained in this Form, the registrant is also thereby furnishing the information to the Commission pursuant to Rule 12g3-2(b) under the Securities Exchange Act of 1934.
Yes [ ] No [X]
If Yes is marked, indicate below the file number assigned to the registrant in connection with Rule 12g3-2(b): 82- _____.
Notwithstanding any reference to BCE Inc.s Web site on the World Wide Web in the documents attached hereto, the information contained in BCE Inc.s site or any other site on the World Wide Web referred to in BCE Inc.s site is not a part of this Form 6-K and, therefore, is not furnished to the Securities and Exchange Commission.
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
BCE Inc. |
(signed) Martin Cossette Martin Cossette Vice-President, Legal and Corporate Secretary |
Date: March 31, 2021 |
EXHIBIT INDEX
99.1 Code of Business Conduct
Table of Contents
Exhibit 99.1
Code of Business Conduct
What we do is who we are
Our Moral Compass
Policy Contact: [email protected]
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A Message from our President and Chief Executive Officer
Mirko Bibic
President and Chief Executive Officer
BCE Inc. and Bell Canada
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1 | INTRODUCTION |
1.1 | Scope: Who Does the Code Apply To? |
The Code applies to everyone at Bell, including all directors, executives and employees of BCE Inc., Bell Canada and their subsidiaries. Throughout the Code, we will refer to these companies as Bell.
1.2 | Objectives |
1.3 | Reporting a Misconduct or Violation of the Code The Business Conduct Help Line |
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An unethical behaviour may be reported to your immediate manager. If this wont meet your needs, is inappropriate, does not provide the necessary level of confidentiality or if you otherwise prefer, you can contact our confidential and anonymous Business Conduct Help Line at clearviewconnects.com on a 24/7 basis or by calling 1-866-298-2942 (toll free). You may also contact the Corporate Secretary or the Chair of the Audit Committee.
You can also consult the Complaint Procedures for Accounting and Auditing Matters on the Corporate Policies & Ethics Program intranet site.
1.4 | Responsibilities of Managers & Executives |
1.5 | Penalties for Violations |
Disciplinary action up to and including dismissal will be taken should an employee, manager or executive:
● | violate the Code or a Bell policy, disregard proper procedures or ask others to violate the Code or a Bell policy |
● | deliberately fail to promptly report a violation or withhold relevant information concerning a violation |
● | fail to cooperate in the investigation of a known or suspected violation or |
● | take action against an employee who reports a violation or breach of the Code or other policy. |
1.6 | Annual Review and Sign Off |
To demonstrate our commitment to the shared values and standards described in the Code, all employees, managers, executives and members of the Board of Directors must certify annually that they have reviewed and follow the Code. A copy of these certifications can be found at Attachments 1A and 2A. All employees must also take the on-line course on the Code at least every two years.
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2.2 | Conflicts of Interest |
As employees, managers and executives, our business loyalty rests in placing Bells interests including those of its customers and shareholders before our personal interests and relationships.
A conflict of interest arises whenever we allow, or appear to allow, personal interests or relationships to impair our judgment and ability to make decisions with integrity and honesty. By thinking of ourselves or our relationships first, we may act in a way that is damaging, or potentially damaging, to Bell. We may also harm our personal reputation.
We must not use our position to influence or bypass Bell procedures, or improperly take advantage of information we have access to by virtue of our positon, for personal gain nor for the benefit of our family, friends, colleagues or anyone else.
How Can I Tell If I Am In a Conflict of Interest?
If you are not sure about a particular situation, obtain the guidance you need. Start by asking yourself the following questions:
● | Am I following proper Bell procedures? |
● | Do I stand to potentially gain personally from my actions? |
● | Can my actions potentially result in a financial or other advantage for myself, a near relative (which would include a spouse, sibling, parent, child, or in-law), friend or other relationship? |
● | Am I uncomfortable discussing this with my manager or fellow employees? |
● | Would I act differently if a friend or near relative or relationship werent involved? |
If you have any doubts about a possible conflict, raise the matter with your manager or contact the Business Conduct Help Line at www.clearviewconnects.com or by calling 1-866-298-2942 (toll free).
If there is an actual or potential conflict of interest, you must disclose it immediately to your leader and as part of the annual online review process.
2.2.1 | Conflicts of Interest Relating to Family and Personal Relationships |
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My partner has just become an executive sales manager for a company that services the computers in my department. Do I need to tell anyone about this?
● | Yes. Someone could claim that Bell is giving your partner business because you are a Bell employee. You should notify your manager and make sure you are not involved in any decisions regarding your partners company. This relationship should be disclosed in your annual online review of the Code. |
2.2.2 | Conflicts of Interest Relating to Supplier-Funded Incentive Programs |
Supplier-funded incentive programs, often offered to sales employees by suppliers seeking to sell their products, may only be arranged through an authorized program administrator who does not work with the eligible employees.
Its up to the program administrator to ensure there is no conflict between Bells marketing strategy and the suppliers incentive program. For further information, please refer to the Incentive & Recognition Programs Guidelines on the Human Resources intranet site.
2.2.3 | Conflicts of Interest Arising from Outside Employment and Similar Activities |
I am a Bell technician who installs circuitry for small and medium-sized business customers. With the growth of the Internet and other communications services, demand for my expertise is booming. Can I take advantage of this opportunity and start up an installation business on my own time?
● | No. You cannot engage in any outside activity that might take business away from Bell or any of its subsidiaries. Furthermore, as an employee, you are expected to contribute your energy and ideas to your job as an installer for Bell. |
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As a customer service representative I happen to respond to my brothers telephone call inquiring about a charge on his account for TV services. Can I respond to this call and make adjustments, if any, to his account?
● | No. Employees are not allowed to access or make changes to the billing accounts of their families and friends, including accessing their own or invoicing themselves. |
2.2.4 | Conflict of Interest Guidelines for Executives and External Directorships |
External Directorships
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2.3 | Loans, Gifts and Entertainment |
2.3.1 | Loans from Bell |
We do not accept, whether directly or indirectly, any loan or guarantee of obligations from Bell that are for our personal benefit.
2.3.2 | Business Gifts & Entertainment |
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Factors which you and your manager should consider when assessing the proper course of action include:
● | Is Bell potentially involved in a major procurement activity with the company offering the gift or entertainment? |
● | Would the gift or entertainment be considered appropriate or customary, taking into account the nature of the function or services you perform for Bell? |
● | Would it be perceived as insulting or damaging to the business relationship to return the gift or decline the hospitality? |
● | Can the gift or hospitality be applied to benefit all team members rather than certain individuals? |
● | Is the public sector involved? If so, consult the Regulatory and Government Affairs Team |
2.4 | Political Activities |
2.4.1 | Political Contributions |
2.4.2 | Lobbying on behalf of Bell |
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2.5 | Improper Influence on the Conduct of Audits |
Employees are prohibited from coercing, manipulating, misleading or fraudulently influencing Bells internal or external auditors at any time and especially when the employee knows or should know that his/her action, if successful, could result in rendering Bells financial statements misleading in any way.
2.6 | Trading in Securities |
2.6.1 | Insider Trading |
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Can I use information I obtain by accident or overheard?
● | No. Even when you obtain undisclosed material information by accident, such as by overhearing a discussion of a planned acquisition, you are prohibited by law from trading in securities of BCE Inc., Bell Canada or the target company. In addition, you cannot suggest to a spouse, near relative or friend that they trade in shares of BCE Inc., Bell Canada or the target company while in possession of such information as this would be considered tantamount to divulging that information to someone outside Bell for personal gain or the gain of someone else. Such securities could only be traded on the second business day after Bell or the company being acquired issues a press release publicly announcing the planned acquisition. |
2.6.2 | Short Sales, Calls and Puts |
2.7 | Public Disclosure of Information |
2.8 | Confidentiality of Customer and Employee Information |
2.8.1 | Customer Privacy |
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Interception of Private Communications
Communications between Bell and a customer may be monitored for quality assurance purposes, with an appropriate advisory to the customer.
The unlawful interception of a private communication is prohibited under the Criminal Code. The content of a customers transmissions (including telephone and email) may not be monitored, nor may the content, nature and existence of telephone calls and data transmissions be released to third parties except as explicitly authorized by law.
Unintentional interceptions of a call may occur when providing service, doing repairs or when conducting quality control checks. In these instances, the employee must advise the persons on the call of the unintended interception and immediately disconnect from that call.
Business Customer or Supplier Information
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I am a customer service representative for the residential market. A caller identifying himself as the spouse of a wireless customer requests billing details for the spouses account, indicating that he looks after bill payments for the family. Should I provide the information?
● | If the caller is not explicitly listed on the account as an authorized co-user, the information should not be provided. Account details, particularly for wireless accounts, can be very sensitive information and is often sought in the context of matrimonial disputes. Advise the caller to have the account holder of record contact Bell to have the spouse added to the account as an authorized co-user. This approach applies equally to all customer accounts, in all business units. |
2.8.2 | Employee Privacy |
2.8.3 | Bell Privacy Policies |
To support our commitment to privacy we have developed policies and a formal privacy code - the Bell Privacy Policy and the Bell Employee Privacy Policy - which spell out the commitments of Bell, its employees and agents and the rights of customers and employees regarding personal information.
The Bell Privacy Ombudsman oversees compliance with these privacy policies and may be contacted at [email protected].
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The Bell Privacy Policy, the Bell Employee Privacy Policy and other privacy-related documents are available by following the privacy link on www.bell.ca or on the Bellnet policies page Corporate Policies & Ethics.
2.9 | Information Management |
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Post Employment Obligations
Your obligation to protect Bells confidential information continues after the employment relationship ends. Upon termination of employment or contract, or reassignment, all employees must:
● | return all copies of confidential information and documents, including electronic records, and all third party information entrusted to Bell |
● | return any equipment entrusted to them including mobile devices, laptops and external storage devices |
● | continue to uphold the confidentiality of Bell confidential information and not use or disseminate any such information. This continuing obligation is particularly important in the case of a departing employee who subsequently works for one of Bells competitors or suppliers. |
Preservation of Records under Legal Hold
How do I tell if a document (paper or electronic) is confidential if it is not marked as such?
● | You must begin by asking the person who issued the document (if known), as the originator is the person who must determine the security classification. If you cant find the source of the information and the nature of the document does not make the classification obvious (such as information that has been made public), the document must be treated as confidential until the proper classification is determined. |
2.10 | Dealing with Customers |
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You are trying to close a sale with a customer. There are conditions applicable to the offer youve described that may make the customer reluctant to subscribe. You know those conditions will be described in the confirmation email the customer will receive and in the contract. Can you leave those details out and let the customer read about them?
● | It is your responsibility to communicate our offers and prices accurately. You must advise the customer of all applicable conditions so that they can make an informed choice prior to purchasing. |
2.11 | Dealing with Suppliers and Competitors |
2.11.1 | Supplier Relations - Reciprocity |
Our department is organizing a meeting at a hotel. Due to the large size of our group, and the fact we dont want to travel far, weve chosen a nearby hotel serviced by a competitor. Is this okay, or should we find a hotel that uses Bell services?
● | It is not Bell policy to prohibit employees on company business from dealing with organizations that do not use Bells services. While we actively encourage everyone at Bell to do business with our customers, we must ensure that this is not done at the expense of price, quality and service. |
● | Although the hotel youve chosen is not a Bell customer, you were right to choose it if, in your judgment, it best meets the price-quality-service criteria you are looking for: the hotel is located close to your office, it can easily accommodate all the members of your department and, as a result, will enable your group to save both time and traveling expenses. |
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2.11.2 | Treating Competitors with Respect |
2.11.3 | Obtaining Information about our Competitors |
Our business unit recently hired someone who was employed with a competing radio station. This person has confidential information which would be very valuable to us. Can we ask him to disclose this confidential information?
● | Absolutely not. The new employee has an obligation to protect his/her former companys confidential or proprietary information, just as you would be obliged to protect Bells confidential or proprietary information if you were to leave Bell. You must respect the employees personal integrity as well as his/her obligation to his/her former employer. |
Inducing an employee to disclose such confidential information is a violation of the Code.
If I become aware that this person is disclosing a competitors confidential information to Bell employees, should I report it?
● | Yes you must report this fact to your immediate supervisor or through the Business Conduct Help Line at clearviewconnects.com or by calling 1-866-298-2942 and you must not use such confidential information. Bells reputation could be significantly harmed by such disclosure and taking immediate steps to contain the confidential information is critical. Failure to report is a violation of the Code. |
2.11.4 | Agreements with Competitors |
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2.11.5 | When a Competitor is a Customer |
When providing competitors with network facilities, broadcasting, access or other services, we cannot use information obtained as a result of that process in any manner which would give us an undue competitive advantage. This includes ensuring that this information is not made available to those within Bell or its affiliates who develop competitive service strategies. It also means that we must not disclose a customers choice of competitive carrier to anyone who does not clearly require the information to provide service to the customer.
2.12 | Safeguarding Bell Assets |
2.12.1 | Visible ID |
All employees, consultants and contractors must wear a visible, valid, designated ID card at all times while on Bell premises. An ID card can only be used by the employee to whom it is issued. It cannot be shared or lent. Visitors must wear a visible, valid, designated visitors card while on Bell premises and must be accompanied by a Bell team member at all times. Employees should question anyone on Bell premises not wearing a visible Bell ID or visitors card.
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2.12.2 | Prevention of Fraud |
What is Fraud?
● | Fraud is defined as an intentional deception, falsification or misrepresentation made for personal gain, or to damage or create loss for the organization, customers or individuals. This can include the misuse or misapplication of the organizations resources or assets to conduct internal fraud. This can also include actions taken towards business partners such as clients and service providers as well as false or inflated insurance claims presented to Manulife or any other insurance provider. |
Successfully preventing fraud requires an ongoing commitment from all of us. This includes actively participating in the prevention, detection, and reporting of suspected fraud, whether committed by an internal or external party. As employees we will not engage, directly or indirectly, in bribery, kick-backs, account falsification, false claims, time fraud or any other fraudulent or corrupt business practices.
Fraudulent actions are not only unethical, but may also be a violation of law, Bell has a zero tolerance stance with regards to all confirmed fraud situations. If you are approached by anyone with an opportunity to engage in fraudulent activities, you must report the incident to your manager and Corporate Security or through the confidential Employee Help Line available at clearviewconnects.com or by calling 1-866-298-2942 (toll free).
2.12.3 | Corporate Credit Cards and Bell Funds |
We are personally responsible for funds, cash, cheques, postage, etc., over which we have control. Corporate credit cards are not to be used for personal cash withdrawals or purchases and other charge cards are to be used only for business purposes. We must also ensure that all expense vouchers, benefit claims and invoices are accurate and properly authorized.
Corporate policy regarding the use of corporate credit cards and corporate travel is detailed on the Travel and Expenses Management intranet site. We should, unless unavailable, use the services of suppliers with whom Bell has negotiated agreements (e.g. travel agents, airlines, carrental agencies, taxi companies, hotels).
2.12.4 | Hiring Consultants or Contractors |
Hiring of contractors, consultants or other external resources must follow the rules as outlined on the Contractors and Consultants Procurement intranet site and hiring of external resources must also comply with the principles and procedures of the Contractor Program Policy and the requirements of the relevant Bell Policies available on the Corporate Policies & Ethics intranet site, including the Personnel Security Policy. In addition, all contractors performing high-risk work must be pre-qualified to ensure all workers are competent, trained and compliant with the health and safety requirements of Bell, prior to conducting any work for Bell, as outlined in the Directive on contractor safety and high-risk services.
2.12.5 | Electronic Procurement and Electronic Processing of Expense Reports |
Bell electronically processes much of its procurement needs including employee expense reports and accounting for corporate credit card payments. All employee expense reports and credit card payments must be approved by a leader one level above the employee submitting the reports.
2.12.6 | Business Books and Records |
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2.12.7 | Standard Contracts and Agreements |
If you are in a position to develop or sign contracts, you must take necessary steps to protect the interests of Bell by ensuring that only Bell standard form template contracts are used and, in the case of purchase agreements, the Procurement Policy is followed. All contracts must be reviewed by appropriate departments such as, Legal, Regulatory and Government Affairs, Procurement, Corporate Security, Corporate Responsibility & Environment, Health, Safety and Workplace, Risk Advisory Services and Insurance. Standard contracts must not be modified without prior approval of the Legal Team.
2.12.8 | Information Security |
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2.12.9 | Intellectual Property |
2.12.10 | Proper Use of Bell-Provided Internet Access and Other IT Resources |
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My daughter has asked me if she can use my company laptop to do some research on the internet for a school project. Should I lend her my laptop?
No. To protect our networks, we cant let anyone, even family members, use Bell equipment.
2.13 | Social Media |
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2.14 | Work Environment |
2.14.1 | Mental Health |
2.14.2 | Respect and Professionalism in the Workplace |
Upholding respect and professionalism in the workplace enables us to build and cultivate more meaningful, richer relationships with fellow team members, customers and the broader public, suppliers and shareholders. For this reason, we expect all our employees to respect their colleagues, team members and leaders.
We are committed to fostering a workplace which encourages respect, collaboration, openness and effective communication and which recognizes the intrinsic dignity and worth of all employees and values the diversity of team members, customers, suppliers and shareholders.
Bell supports prevention by equipping employees and leaders with practical resources (Civility guide, Leaders guide to managing conflict, Guide to managing difficult customer or public interactions) available on the Respectful workplace ethics website.
2.14.3 | Diversity, Inclusion and Employment Equity |
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2.14.4 | Preventing Workplace Violence and Harassment |
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2.14.5 | Health and Safety |
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2.14.6 | Emergency Management |
2.14.7 | Business Continuity |
Bell recognizes the importance of its infrastructure and services for its employees and customers. To that end, all business unit leaders and team members must ensure they have appropriate business continuity plans and disaster recovery plans in order to be ready to react to any type of events that may impair our activities.
2.14.8 | Alcohol, Drugs and Other Substances |
2.14.9 | Involvement in a Legal Matter |
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You are a member of the Bell Media News team and you receive a request from the Bell Residential Services team to profile an item they believe is newsworthy. What should you do?
● | Remember that it is acceptable for Bell employees to suggest story ideas, with respect for the Bell Media News teams full authority to decide on news coverage |
● | If you decide the item is not newsworthy, but they persist or escalate the matter, you should discuss it with your supervisor to confirm your position and obtain support |
● | Ultimately, you can engage the Vice President responsible for CTV News or the Vice President responsible for Noovo News, as applicable, who are the final arbiters in matters relating to independent news reporting and have the authority to take steps to ensure the situation is resolved in an appropriate manner in accordance with the Policy on Journalistic Independence |
● | Should you consider that the matter is not handled in accordance with the policy, you can report your concerns through the Business Conduct Help Line |
The Business Conduct Help Line may be reached 24/7 by calling 1-866-298-2942 or by visiting clearviewconnects.com.
Members of the public should call Bell Canadas Complaint and Concerns Line at 1-866-317-3382 with any concerns about Bell activities.
2.16 | Environmental Leadership |
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3 | ROLES AND RESPONSIBILITIES |
3.1 | Business Unit Responsibility |
Managers are required to ensure that all employees have access to the Code either on-line or in a paper format if required, and that they know, understand and comply with its provisions. To this end, they should ensure that all employees review the Code annually and comply with the annual review process outlined in this Code.
3.2 | Board of Directors, Corporate Governance Committee and Audit Committee |
The Board of Directors, with the recommendation of the Corporate Governance Committee, has the authority to approve this policy. In addition, the Corporate Secretarys Office in conjunction with Internal Audit, report quarterly to the Audit Committee on the number and scope of issues brought via the Business Conduct Help Line.
3.3 | Corporate Secretarys Office |
The Corporate Secretarys Office has the responsibility of administering the Code and managing the Business Conduct Help Line, securing annual certification of all executives and members of the Board of Directors under the Code, addressing conflict of interest issues and ensuring compliance by all Business Units.
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The Code of Business Conduct annual review is included in the annual performance process. These procedures are located in the Career Zone intranet site under Objective Performance.
Attachment 1A |
Certification of Directors and Executives under the Code of Business Conduct | |
Attachment 2A |
Form BC 3684 Employee Annual Record of Review | |
Attachment 2B |
Form BC 3684A Disclosure of Conflict of Interest or Potential Conflict of Interest | |
Attachment 3 |
Additional Resources |
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Attachment 1A
CERTIFICATION OF DIRECTORS AND EXECUTIVES
UNDER THE CODE OF BUSINESS CONDUCT
|
The Boards of Directors of BCE Inc. and Bell Canada (in each case, the Company) and our shareholders, expect all Directors and executives of the Company to follow the highest possible standards of honest and ethical conduct and to encourage and promote a culture in which ethical business conduct is recognized, valued and exemplified.
Certification
I certify that I have reviewed, understand and follow the Bell Canada Code of Business Conduct (the Code).
In addition, I support the setting of standards needed to discourage wrongdoing and to promote:
● | honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships, |
● | full, fair, accurate and timely disclosure in reports and documents that the Company files with, or submits to, securities regulators and in other public communications made by the Company, in accordance with the Disclosure Policy, |
● | compliance with laws, rules and regulations of federal, provincial, state or local governments, and other relevant private and public regulatory agencies in all jurisdictions in which the Company operates, |
● | prompt reporting of all material violations of the Code to the Chair of the Audit Committee of the Board of Directors of the Company. |
To the best of my knowledge and ability, I will act in good faith, responsibly, with due care, competence and diligence, without misrepresenting material facts or allowing my independent judgment to be compromised.
I acknowledge that I am accountable for following the Code and the responsibilities I have under it. I also acknowledge that complying with the Code is a condition of my employment. If I do not comply with it or applicable laws, rules or regulations, I may be subject to disciplinary measures, which could include dismissal from the Company.
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Attachment 2A |
Form BC 3684 |
EMPLOYEE ANNUAL RECORD OF REVIEW
|
Note to immediate manager: If this form is completed in paper format, please file original in employees personnel file.
Policy on conflict of interest
Employees owe their first business allegiance to Bell, and therefore they must remain free of interests or relationships which are harmful or detrimental to Bells best interests. Employees should avoid not only a real conflict of interest, but also the appearance of one which could tarnish their own or Bells image. Even though it is not always possible to avoid relationships that could place you in a position of potential conflict, it is important to inform your manager and avoid actions or decisions that would conflict with Bells interests.
Conflict of interest can lead to disciplinary action, even to dismissal and/or prosecution. If you are in doubt, you should discuss your specific situation with your manager, who will then advise you as to the position of Bell with respect to the matter.
Annual certification
I have reviewed, fully understand and follow Bell Canadas Code of Business Conduct including the section on Conflict of Interest. I have reported immediately to my manager and through the annual review process any relationship or other circumstances that do or could place me in conflict with the interests of Bell. Any new situations will be reported as they occur. I hereby certify that I have no real or potential conflict of interest, except what is disclosed through the annual review process.
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Attachment 2B |
Form BC 3684A |
DISCLOSURE OF CONFLICT OF INTEREST
OR POTENTIAL CONFLICT OF INTEREST
|
Note to immediate manager: If this form is completed in paper format, please file original in employees personnel file. A copy should also be sent to the Corporate Secretarys Office at [email protected].
Employee |
||||||||
Family name |
Given names |
Employee number | ||||||
|
|
|
I am directly or indirectly involved in other business or employment, which may give rise to or is at present in conflict with, or potential conflict with, the best interests of Bell:
I have direct or indirect investment, business involvements or relationships, which may give rise to or is at present in conflict with, or potential conflict with, the best interests of Bell:
I have, in the past 2 years, been employed or otherwise commercially involved in endeavours or companies which are in competition with Bell Canada and its affiliated companies (e.g.: Rogers, Telus, Videotron, Cogeco, etc.):
I am currently or was recently bound by restrictive covenants such as non-competition or non-solicitation restrictions:
Other:
For employees who declare a conflict due to past employment by a competitor: I understand that in my previous employment or commercial involvement with a competitor of Bell Canada and its affiliated companies I may have become aware of or given access to undisclosed confidential or proprietary information of my previous employer. As such, unless this information has been publicly disclosed or otherwise available in the marketplace, I am not to share such information. I also acknowledge that I have returned to my previous employer all property belonging to my previous employer including any confidential or proprietary information and documents provided to me including any third party information that was entrusted to me.
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Code of Business Conduct |
Attachment 3
ADDITIONAL RESOURCES
|
If you have any questions regarding the issues raised in this document or any questions on the Code, speak to your manager or use the Business Conduct Help Line at clearviewconnects.com or by calling 1-866-298-2942 (toll free).
If you wish to report any unethical or illegal behaviour such as corporate fraud, or to raise any concerns regarding Bells accounting, internal accounting controls or auditing matters, you may report the matter to your manager or use the Business Conduct Help Line at clearviewconnects.com or by calling 1-866-298-2942 (toll free).
You may also use the following resources:
● | Human resources intranet site |
● | Corporate Security intranet site: |
● | life-threatening emergencies: call 911 |
● | loss or theft of Bell assets, internal fraud, criminal activity, property damage, unauthorized disclosure of confidential information, known failures in security safeguards, malfunctioning doors and locks, emergency response system (non-life threatening emergencies), emergency conditions and service impacting situations are to be reported to Bells National Incident Centre (NIC) at 1-866-714-0911 or at [email protected] |
● | computer security incidents, virus, worms, spam or phishing using Bells name, any other computer or data network attacks, weaknesses in security systems, and unexplained systems changes are to be reported to 1-888-920-8888 |
● | significant facility or utility interruptions, surveillance, control systems or any service failures that impact our telecommunications networks are to be reported to 1-888-570-1091 |
● | Corporate Responsibility at 1-877-235-5368 or at [email protected]. |
● | Enviro-Line Bell (environmental issues) at 1-877-235-5368 |
● | Branding at [email protected] |
● | Corporate Secretarys Office intranet site or at (514) 786-8424 |
● | Occupational Health, Safety and Workplace at (514) 870-5848 or at [email protected] |
● | Bell Privacy Office for customer related privacy issues at [email protected] or for additional privacy related information, visit bell.ca |
● | Information on privacy in the workplace for employees is available on the Privacy intranet site or at: |
● | English: [email protected] |
● | French: [email protected] |
© Bell Canada 2021. All Rights Reserved. |
P a g e | 34 |
Table of Contents
Code of Business Conduct |
Issuing BU |
Law & Regulatory Department | |
Policy sponsor |
Corporate Secretary | |
Policy owner |
Corporate Secretarys Office | |
Primary contact |
Corporate Secretarys Office | |
Required approvals |
Board of Directors, Corporate Governance Committee, Corporate Secretary | |
First Release |
1995 | |
Review cycle |
Annually |
Required Policy or Practice management elements checklist
Monitoring compliance processes defined |
Yes | |
Communication plan complete |
Yes | |
Communication materials complete |
Yes | |
Training plan complete |
Yes |
Revision history
Date |
Change owner | Changed by | Description | |||
June 2015 |
Mirko Bibic | Mirko Bibic | Update | |||
August 2015 |
Michel Lalande | Michel Lalande | Annual update | |||
August 2016 |
Michel Lalande | Michel Lalande | Annual update | |||
August 2017 |
Michel Lalande | Michel Lalande | Annual Update | |||
August 2018 |
Michel Lalande | Miguel Baz | Annual Update | |||
October 2018 |
Michel Lalande | Miguel Baz | Update | |||
August 2019 |
Michel Lalande | Miguel Baz | Annual Review | |||
January 2020 |
Michel Lalande | Miguel Baz | Update | |||
August 2020 |
Michel Lalande | Miguel Baz | Annual Review | |||
January 2021 |
Martin Cossette | Miguel Baz | Update | |||
March 2021 |
Martin Cossette | Miguel Baz | Update |
© Bell Canada 2021. All Rights Reserved. |
P a g e | 35 |
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