Message from the CEO

Doing things right is one of our most important values at Weavik Inc.. We work hard every day to provide

products that enhance the lives of people in our community, our country, and all over the world.

We are clear about what we mean when we talk about doing things right. Not only does it mean that we

provide products that are well made, fairly priced and of exceptional quality, but it also means that every

step we take in making those products is taken with ethics and integrity in mind. We source material only

from suppliers who have impeccable human rights records, ensure our supply chain is of high integrity and

monitor our entire operation for compliance with our code of conduct.

Doing things right is not an option at Weavik Inc.. Working here means making a commitment to uphold

our company values and following the code of conduct outlined in this document. Thank you for upholding

our values and helping us to be the best product supplier we can be.

​

Ben Bittrolff

Chief Executive Officer

Introduction

The code of conduct applies to all Weavik Inc. team members:

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• Full time employees

• Contract workers

Ethical Principles and Core Values

At Weavik Inc. we expect all team members to hold these core values and consider them in their daily

routines:

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• Honesty

• Integrity

• Trustworthiness

• Courage

• Respect for others

• Responsibility

• Accountability

• Obedience to the law

• Empathy

• Teamwork

• Commitment to the code

Decision Making and the Code of Conduct

When making a decision, ask yourself the following:

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• Is it legal?

• Does it comply with the code?

• Does it reflect our company values and ethics?

• Does it respect the rights of others?

• If you are unsure about any of the answers, ask.

Reporting/Speaking Up

The company encourages all employees to ask questions and raise issues without fear of retaliation and is

committed to treating reports seriously and investigating them thoroughly.

Employees must report suspected unethical, illegal, or suspicious behavior immediately. The company does

not tolerate retaliation against anyone who makes a good faith report of suspected misconduct or

otherwise assists with an investigation or audit.

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To report a concern:

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• Talk to your manager

• Contact Human Resources at (519) 404-8772

• Contact the Chief Executive Officer directly at (519) 404-8771

• Make a confidential and/or anonymous report online at ben@weavik.com

No Retaliation

Employees who report a concern in good faith cannot be subjected to any adverse employment action

including:

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• Unfair dismissal, demotion, or suspension

• Unfair denial of a promotion, transfer, or another employment benefit

• Bullying and harassment, either in person or online

• Exclusionary behavior

• Any other behavior that singles out the person unfairly

Equal Opportunity

The company will not tolerate discrimination based on race, color, religion, gender, age, national origin,

sexual orientation, marital status, disability or any other protected class.

Harassment

Treat all fellow employees, customers, business partners, and other stakeholders with dignity and respect

at all times.

Any type of harassment, including physical, sexual, verbal, or other, is prohibited and can result in

disciplinary action up to, and including, termination.

Harassment can include actions, language, written words, or objects that create an intimidating or hostile

work environment, such as:

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• Yelling at or humiliating someone

• Physical violence or intimidation

• Unwanted sexual advances, invitations or comments

• Visual displays such as derogatory or sexually-oriented pictures or gestures

• Physical conduct including assault or unwanted touching

• Threats or demands to submit to sexual requests as a condition of employment or to avoid negative consequences

Bullying

We are committed to ensuring that our employees, our contractors, and our customers work in safe and

respectful environment that is free of bullying. Bullying can include:

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• Spreading malicious rumor or gossip

• Excluding or isolating someone socially

• Establishing impossible deliverables

• Withholding necessary information or purposefully giving the wrong information

• Intimidating someone

• Impeding someone’s work

• Unfairly denying training, leave, or promotion

• Constantly changing work guidelines

• Sending offensive jokes or emails

• Criticizing or belittling someone constantly

• Tampering with a person's personal belongings or work equipment

Conflicts of Interest

A conflict of interest can occur when an employee’s personal activities, investments, or associations

compromise their judgment or ability to act in the company’s best interests. Employees should avoid the

types of situations that can give rise to conflicts of interest.

It’s important for employees to disclose any relationships, associations, or activities that could create

actual, potential, or even perceived, conflict of interest to their manager or the Human Resources

Department.

External Communication on Behalf of the Company

Only the Chief Executive Officer, Chief Technology Officer, and Chief Operations are authorized to represent

the company to media and/or legal authorities. Employees should refer all requests for information or

interviews to the Communications Department

Confidentiality

The company and its employees maintain the confidentiality of all proprietary information. Proprietary

information includes all non-public information that might be harmful to the company and its customers

and business partners if disclosed.

Confidential information can include:

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• Customer lists

• Supplier lists

• Pricing information

• Terms of contracts

• Company policies and procedures

• Financial statements

• Marketing plans and strategies

• Trade secrets

• Any other information that could damage the company or its customers or suppliers if it was

• disclosed

Privacy

The company complies with the requirements of the country’s and international privacy laws. All

employees sign an agreement that contains provisions for information confidentiality and non-disclosure.

The company and its employees do not disclose any private, personal information of:

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• Employees

• Customers

• Suppliers

• Competitors

• Third parties

​

Employees store all personal information securely, mark it as confidential and store it only for as long as it

is needed for the purpose for which it was collected.

When providing personal information, employees limit access to only those with a clear business need for

the information.

Employees are required to report any breaches of privacy, including the loss, theft of, or unauthorized

access to personal information, to their manager.

Competition, Fair Dealings and Antitrust

While the company competes aggressively for new business, relationships with business partners are built

upon trust and mutual benefits and compliant with competition/antitrust laws.

Employees are required to:

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• Communicate the company’s products and services in a manner that is fair and accurate, and

• that discloses all relevant information

• Familiarize themselves with the company’s fair competition policies and remain aware of the

• consequences of any violation of policies or laws governing fair competition

• Consult the company’s legal department before engaging in any new practice that may affect fair

• competition

• Refrain from price-fixing, bid-rigging, and any other anti-competitive activities

• Use only publicly available information to understand the business, customers, competitors, business

• partners, technology trends, and regulatory proposals and developments

• Advise their manager immediately of possible violations of fair competition practices

Bribery and Facilitation Payments

The company will not attempt to influence the judgment or behavior of a person in a position of trust by

paying a bribe or kickback. This applies to persons in government and in private business.

​

The company does not permit facilitation (or “grease”) payments to government officials or private

business in order to secure or speed up routine actions.

Employees are to:

​

• Select third parties carefully and monitor them continuously to ensure they comply with the

• company’s anti-bribery policies

• Keep accurate books and records at all times and monitor that funds are not being used for

• bribery or facilitation payments

• Refuse any offer or request for an unlawful payment and report the incident to the company’s

• ethics and compliance officer

Gifts and Entertainment

While gifts and entertainment among business associates can be appropriate ways to strengthen ties and

build goodwill, they also have the potential to create the perception that business decisions are influenced

by them. The company is committed to winning business only on the merits of its products, services, and

people and complies with all legal requirements for giving and receiving gifts and entertainment.

Employees are to:

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• Use sound judgment and comply with the law, regarding gifts and other benefits

• Never allow gifts, entertainment, or other personal benefits to influence decisions or undermine

• the integrity of business relationships

• Never accept gifts or entertainment that are illegal, immoral, or would reflect negatively on the

• company

• Never accept cash, cash equivalents, stocks, or other securities

​

Employees may accept occasional unsolicited personal gifts of nominal value such as promotional items

and may provide the same to customers and business partners.

When in doubt, employees should check with the ethics and compliance officer before giving or receiving

anything of value.

Political Contributions

The company does not make political contributions.

Employees are free to support any political party or entity on a personal level. However, this must be kept

separate from company business.

Charitable Contributions

The company may make charitable contributions to causes and organizations that are not politically affiliated. Employees should check with the Chief Executive Officer before making any charitable contributions on behalf of the company.

Record Keeping

All documents, databases, voice messages, mobile device messages, computer documents, files and

photos are records.

Employees are required to:

​

• maintain these records and protect their integrity for as long as required

• maintain official record-keeping systems to retain and file records required for business, legal,

• financial, research, or archival purposes

• dispose of your records according to the company’s records retention and disposition schedule

​

Employees should never destroy documents in response to, or in anticipation of, an investigation or audit.

Protection and Proper Use of Company Assets

The company requires all employees to protect its assets. All assets should be used for legitimate

purposes, efficiently, and for company business only.

​

Assets include facilities, equipment, computers and information systems, telephones, employee time,

confidential and proprietary information, corporate opportunities, and company funds.

​

Suspected incidents of fraud, theft, negligence, and waste should be reported to the VP Operations.

Money Laundering

The company complies with anti-money laundering laws. Money laundering is the process of concealing

illicit funds by moving them through legitimate businesses to hide their criminal origin.

Employees must never knowingly facilitate money laundering or terrorist financing and must take steps to

prevent inadvertent use of the company’s business activities for these purposes. Employees are required

to immediately report any unusual or suspicious activities or transactions such as:

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• attempted payments in cash or from an unusual financing source

• arrangements that involve the transfer of funds to or from countries or entities not related to the

• transaction or customer

• unusually complex deals that don’t reflect a real business purpose

• attempts to evade record-keeping or reporting requirements

Insider Trading

Employees may learn information about the company, associates, clients, business partners or other

companies that are not publicly available. It is illegal for any individual to use information obtained in this

way for personal gain or to share it with others.

Employees are prohibited from:

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• Buying or selling securities based on non-publicly available knowledge gained in the course of business

• Providing information or tips, or encourage another person to buy or sell securities based on inside information

Employees are required to report suspected insider trading immediately to the ethics and compliance

department.

Health and Safety

The company conducts business in accordance with applicable health and safety requirements and strives

for continuous improvement in its health and safety policies and procedures.

All employees are expected to perform their work in compliance with applicable health and safety laws,

regulations, policies, and procedures and apply safe work practices at all times in all locations.

Applicable safety and health requirements must be communicated to visitors, customers, or contractors at

any company location.

Employees are required to immediately report workplace injuries, illnesses, or unsafe conditions, including

“near-misses.”

Environment

The company is committed to operating in an environmentally responsible manner, from the provision of

products and services, to the operation of its offices and facilities, selection of suppliers, and other

business activities.

The company complies with all applicable environmental laws and regulations as well as self-directed

commitments to sustainable practices and environmental protection.

Information Technology

The company expects its employees to help it safeguard all computer equipment and data against

intentional malicious acts by individuals inside or outside the company. Cyber-security training is provided

to all employees to ensure compliance with computer security policies.

The company safeguards against inappropriate access by individuals or groups untrained incorrect

company policies or procedures

The company does not use software for which it does not have a license.

Internet Use

The company understands that occasional personal use of the internet during work hours is a reasonable

request and allows this, within reason. Employees can ask for clarification from their managers if in doubt.

However, the company does not allow internet users to support a personal business, political venture, or

embarrass the company and its customers.

Use of Social Media

The company respects the right of employees to use social media for personal and professional purposes.

Employees are responsible for complying with company policies and procedures when communicating on

social media. Employees are accountable for any information they publish online.

Employees are required to:

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• Reveal their relationship with the company when commenting online on issues related to the company

• Respect the privacy of other employees and refrain from publishing photos of them without their consent

• Ensure any information they post related to the company is accurate

• Comply with the rules of the social media sites they use

​

Employees must not:

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• “Pretext”, or pretend to be someone they are not online

• Speak on behalf of the company if they are not expressly authorized to do so

• Share confidential information about the company, its clients, stakeholders or suppliers

• Post comments or pictures that could harm the company’s brand, reputation or commercial

• interests

Corporate Social Responsibility

The company understands that corporate social responsibility extends to our entire supply chain. This

encompasses not only the products and services supplied but also the human rights, ethics, and social

practices of our company and its suppliers.

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One goal of the corporate social responsibility procurement program is to build partnerships with like-

minded organizations by actively seeking out business partners who are the most environmentally and

workforce friendly.

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Forced Labor: The company and its suppliers shall employ all employees under their own free will with no

one being subjected to bonded or forced labor. This policy applies to not only the supplier’s business

operations but also those of their supplier network with which the company conducts its business.

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Child Labor: The company and its suppliers shall not employ any people under the minimum legal working

age of the country in which they work.

​

Responsible Environmental Impact: The company and its suppliers shall produce measurable

environmental impact reports and conduct ongoing efforts to reduce environmental pollution while

increasing sustainability.

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The company encourages and supports involvement in the community that has supported it. This includes

supporting local business and talent by, for example, sourcing local products and services, where

appropriate, and showcasing the work of local artists in the company’s public spaces.

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Charitable involvement is important to the company and a charity committee meets once a month to

discuss and execute potential and ongoing charitable projects.