Privacy Policy

Deschênes Group Inc. and its subsidiaries (“Deschênes”) recognizes that the proper management of personal information is very important. Accordingly, in line with Deschênes Privacy Protection Policy, all personal information will be handled in the following manner:

1. Acquisition of Personal Information

Deschênes will acquire in a fair and lawful manner, only such personal information as is necessary, and will ensure that the use of such information is restricted.

2. Personal Information Use

Personal information acquired by Deschênes may be used in the following ways:

To provide products or services requested by the customer, including product sales, repair and inspection, after-sales service, and catalogue distribution (personal information includes all information necessary to understand the requirements of a customer, such as customer purchase history and customer delivery status);
To enable response to customer requests, including customer inquiry history (and the collection of customer inquiries for the purpose of improving Deschênes responsiveness);
As a reference to determine customer requirements for products, planning, development, advertisement, sales and service activities of Deschênes (this personal information will include answers to questionnaires given at the time of purchase, customer satisfaction survey, and customer inquiry history)
To send information about Deschênes as well as its products and services, or other items such as catalogs, brochures, information on new products, books, or any other information that Deschênes considers to be of interest to the customer.
To notify a prize winner or send a prize, or for the purpose of other pertinent communication with the person in question;
To verify participant presence in exhibitions and seminars, as well as correspond with them after the event;
To develop and maintain smooth relations with business partners and related entities;
As a reference in the recruitment of an individual where the personal information is provided by an inquirer or an applicant to Deschênes.
As defined by the Personal Data Protection Law and other applicable laws and regulations.
The acquired personal information may be processed and used as statistical data, provided that particular individuals cannot be identified.

3. Personal Information Use

Provision of Personal Information to Third Parties

Acquired personal information shall not be disclosed to third parties except as listed below:

With prior consent;
Where authorized by the Personal Data Protection Law or any other relevant laws and regulations
If Deschênes is ordered or allowed to disclose such information pursuant to a ruling or order of a Court, a tribunal, an arbitrator or any judicial or administrative authority having jurisdiction.

Provision of Personal Information to Sub-contractors

Acquired personal information may be disclosed and offered to sub-contractors within the limited scope necessary to achieve the purpose for which the information is being used; e.g. when Deschênes sends products to a distributor or assigns the role of organizing a campaign to a data processing company. In such event, a confidentiality agreement shall be signed by the third party and Deschênes shall strictly monitor and supervise the handling of the personal information by the third party.

Personal Information Sharing

Acquired personal information may be shared and used within Deschênes and its subsidiaries in order to attain the usage purposes described in Section 2, "Personal Information Use". Personal information that may be shared within the group means: names, addresses, telephone numbers, email addresses, purchase histories, repair histories, inquiry histories and contents, and request contents. Deschênes is responsible for protecting the personal information that is shared and used by the Group. Deschênes will observe the Personal information Protection Policy and strictly control the security of personal information.

4. Proper Management of Personal Information

Deschenes will deploy all necessary and appropriate security measures to prevent the acquired personal information from being leaked or lost. All personal information are gathered and held to secure the safety of the personal information in accordance with Deschênes Privacy Protection Policy related to information management. Deschênes will also offer all training necessary to ensure the proper handling of information to its directors, employees, and other related personnel.Although every effort is taken to ensure no one else will see or obtain your personal information, complete confidentiality and security is not yet possible on the Internet. Any unencrypted e-mail communication on the Internet is, as with communications via any other medium such as cellular phones, not secured or confidential, and is subject to possible interception, loss and/or alteration. You acknowledge and agree that Deschênes, its affiliated companies, agents or their respective employees, directors or officers, will not be liable to you or any third party, in any manner whatsoever, for any damage as a result of information transmitted by email to Deschênes. You assume all risks related to such communications.

5. Inquiries & Changes

Inquiries from customers regarding their own personal information, including verification of the purpose of the usage of the personal information, and the giving of opinions or making of complaints with regard to personal information handling, shall be forwarded to the division to which the customer initially provided his/her personal information. If you do not know the corresponding division, or if you wish to have your information deleted or modified in any way, please contact our person responsible for the protection of personal information:

M. Éric Filiatrault
Responsable à la protection des renseignements personnels

gouvernance@groupedeschenes.com

3901 Jarry Est, Bureau 250, Montréal, QC, H1Z 2G1

6. Improvement

Deschênes will comply with privacy protection-related Canadian laws and regulations, and will review and improve the contents of this document to strive constantly towards better privacy protection. Although our commitment to privacy will not change, Deschênes may modify, alter or otherwise update this Policy from time to time without notice. Personal information refers to information with which a particular individual can be identified, including any information that can be matched with other information to identify a particular individual.

Supplier code of conduct

At Deschênes, we are committed to a standard of excellence in every aspect of our business, to ethical and responsible conduct in all of our operations, to the respect of the rights of all individuals, and to respect for the environment. We expect the suppliers (as well as permitted subcontractors) who do business with the Company to share these same commitments. The Company strongly encourages each Supplier to meet the following standards in all activities that relate directly or indirectly to the Company.

We will evaluate a Supplier's compliance with these standards in determining whether to grant or continue approved status for such Supplier. Suppliers that do not conform to these standards may be disqualified from approved status and/or have their business relationship with the Company terminated.

Compensation

Supplier must comply with all applicable wage and hour laws and regulations, including those relating to minimum wages, overtime, and other elements of compensation, and will provide all legally mandated benefits.

Hours of Labor

Supplier will maintain work hours in compliance with all applicable wage and hour laws and regulations. Supplier will not require employees to work more than any limits on regular and overtime hours allowed by any applicable local law.

Coercion and Harassment

Supplier will treat each employee with dignity and respect, and will not engage in or permit corporal punishment, threats of violence, or other forms of harassment whether based on race, colour, gender, sexual orientation, national origin, religion, disability, age, or any other legally protected characteristic.

Discrimination

Supplier will not discriminate in hiring practices or any other condition of work on the basis of race, sex, sexual orientation, colour, age, gender, national origin, physical or mental disability, religion, status as a disabled veteran, or other legally protected characteristics.

Workplace Safety & Emergency Planning

Supplier will provide a safe and healthy workplace for employees by endeavoring to meet or exceed international safety standards. Supplier must have procedures in place for handling emergencies such as fire, spills, and natural disasters.

Freedom of Association and Collective Bargaining

Employees who wish to join or not join trade unions and to bargain collectively shall not be interfered with, penalized or retaliated against.

Environmental Protection

Supplier will comply fully with all applicable environmental laws, and seek ways to conserve natural resources and energy, reduce waste and the use of hazardous substances, and minimize any adverse impacts on the environment.

Compliance with Applicable Laws

Supplier will comply with all laws and regulations applicable to their business, as well as the standards of its industry, including those pertaining to the manufacture, pricing, sale, distribution, labeling, import, and export of merchandise. Without limiting this requirement, Supplier will not violate, misappropriate or infringe upon the intellectual property rights of the Company or any third party or engage in any activities which would violate any applicable laws and regulations relating to (a) human rights, (b) bribery or illegal payments, (c) laws against unfair competition, (d) unfair and deceptive trade practices, (e) the environment, (f) health and safety, (g) international trade, including exports and imports, (h) data privacy, (i) money laundering, (j) employment, (k) contracting with governmental entities, or (l) medical devices, if applicable.

No Forced or Child Labor

All work must be voluntary. Suppliers will not use or in any other way benefit from any form of prison, trafficked, bonded (including debt bondage), indentured, coerced or compulsory labor or other forms of forced labor, or any forms of slavery. Supplier will not purchase materials or services from companies engaging in such practices.

The unlawful use of child labor by Supplier is strictly forbidden. If the jurisdiction in which the Supplier is doing business does not define “child” for purposes of minimum age of employment, the minimum age shall be 15 years of age. Supplier must observe all legal requirements regulating hours and working conditions for minors.

Commercial Bribery

Supplier will not bribe in any way any officer, director, manager, employee, representative or agent of the Company, including without limitation, by offering or giving kickbacks or by offering or giving gifts of more than nominal value.

Accounting Records

Supplier's accounting records must (1) be kept and presented according to the laws of each applicable jurisdiction, (2) in reasonable detail, accurately and fairly reflect transactions, assets, liabilities, revenues and expenses, and (3) not contain any false or misleading entries.

Conflicts of Interest

Supplier must immediately report to the Company any "conflict of interest" of which they become aware. A “conflict of interest” is any circumstance, transaction or relationship directly or indirectly involving the Supplier in which the private interest of any employee of the Company improperly interferes, or even appears to improperly interfere, with the interests of the Company.

Subcontracting

In addition to any restrictions on the use of subcontractors that are otherwise agreed to between the Supplier and the Company, Supplier will make reasonable efforts to communicate this policy to any subcontractors in connection with any Company business, and ensure they operate according to this policy.

Suppliers of Materials incorporated into Products Sold to the Company

For any materials incorporated into products sold to the Company, the Supplier will make reasonable efforts to communicate this policy to any suppliers of materials in connection with any Company business, and ensure they operate according to this policy.

Monitoring and Compliance

Supplier understands that the Company, or our designated agents (including third parties) may engage in monitoring activities to assess compliance with this Code of Conduct including on-site inspection of facilities and review of books and records. Neither the Company nor any of its authorized agents assumes any duty to monitor or ensure compliance with this Code of Conduct, and Supplier understands that Supplier is solely responsible for full compliance with this Code of Conduct by its officers, directors, managers, employees, mandataries, representatives and agents.

Management System and Communication

Supplier must establish and maintain processes that are reasonably designed to ensure compliance with, mitigate the risks identified in, and facilitate continuous improvement with respect to, this Code of Conduct.

Supplier must ensure that this Code of Conduct is adequately communicated to all employees. Supplier should immediately notify the Vice-President Procurement of Deschenes Group Inc., Mr. Patrick Lanthier, at planthier@groupedeschenes.com upon learning of any known or suspected improper behavior by Supplier, its own suppliers or subcontractors, or by employees of the Company.