Code of Ethics

Respect the laws in force, fully and completely, as well as the highest standards of honesty and integrity.

Refrain from any reprehensible gesture or omission that may have negative repercussions on the company, our employees, our customers and other people with whom we interact.

Contribute to a fair, safe and productive work environment by refraining from and rejecting any form of discrimination, defamation, slander or harassment. Every individual has the right to the same treatment and opportunities, regardless of age, gender, sexual orientation, race, beliefs, religion, nationality, civil status or any kind of handicap or disability.

Be fair and honest in interpersonal relations, refraining from any manipulation, concealment or misuse of privileged information, distortion of facts and any other unfair behaviour.

Respect the Company’s high standards with regard to workplace health and safety, sanitation and hygiene, and respect for the environment. Each of us must bear Groupe Grandio’s obligation to effectively protect its customers, staff and facilities.

Each of us must make quality products and service excellence personal goals. We must strive to do our jobs well the first time. As such, we will succeed not only in meeting our customers’ expectations, but also in making our company more competitive and stronger on the market.

Respect the Company’s property and assets, ensuring that they are used efficiently only for the purposes for which they are intended. No individual may damage the assets of Groupe Grandio, its customers or its suppliers, nor use, steal or misappropriate them for personal purposes or for malicious or illegal purposes.

Avoid any conflict of interests, i.e. any situation that would favour certain personal interests (financial or otherwise), or those of close relations or third parties, to the detriment of the best interests of the Groupe Grandio. In addition, under no circumstances may we solicit or offer, for ourselves or anyone else, gifts, favours, any form of = benefit or any other unjustified gratuity, no matter the nature or value of the item or service.

Protect the confidential information of Grandio Groupe and its clients, suppliers and any other third party.

Never participate in or condone questionable financial or accounting practices. It is imperative that all questionable practices suspected on serious grounds be reported promptly. (See the Whistleblower Policy in Financial Matters section.)

The preparation and disclosure of financial reports must meet the highest standards of corporate governance and disclosure regulations.

Insider trading is illegal and unethical. No matter one’s position or role at Groupe Grandio, a person who has knowledge of information on the Company that has not yet been made public cannot directly or indirectly trade in the Company’s securities on the stock exchange or disclose such information inappropriately until such information becomes public knowledge.

Reporting. When faced with a worrying situation or one that causes discomfort that is difficult to tolerate, you have the right to take action to stop behaviour that does not comply with professional ethics.

If your actions or gestures stop this behaviour, you do not need to report it. However, if you are aware of any misconduct or other breach of the Code or have serious suspicions in this respect and do not consider that you are in a position to intervene effectively, you must promptly report such a situation following the procedure established in this Code.

The Groupe Grandio promotes reporting any misconduct or breach of the Code without any risk of sanctions or reprisals to the person making the report.  Under no circumstances can you be punished for such a report or expression of justified suspicions.  The Groupe Grandio undertakes to support any person who contributes to compliance with the Code and does not tolerate any form of reprisal against these persons by anyone else.

All reports may be made verbally, in writing or by any other means enabling you to communicate with the Ethics Officer or, alternatively, a member of management.

The report may be sent by fax at (450) 641-9742 or by email at ethique@cage.ca. To ensure confidentiality, written communications may be sent in a sealed envelope marked “Strictly
Confidential” to the Ethics Officer.

All reports may be made anonymously, and the associated information will be kept as confidential as possible.

Any misconduct or breach of the Code may lead to disciplinary measures up to and including dismissal.

The application of the Code is entrusted to an Ethics Officer, currently the Company’s Director of
Corporate Affairs, Sylvie Paradis. The Ethics Officer is granted full powers and authority to apply
the Code with the terms and conditions.

Ethics Officer
Groupe Grandio
1180 Place Nobel, Office102
Boucherville, Quebec J4B 5L2