Heather Ostertag and Associates has adopted this code of ethics (the “Code”), which is applicable to all its Associates (as defined in paragraph 2 below), to

  • promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest;
  • promote compliance with applicable governmental laws, rules and regulations;
    deter wrongdoing; and

The code may be amended as required.

2. Relevant Officers

The Code is applicable to

  • Heather Ostertag, C.M.
  • All Associates of Heather Ostertag and Associates
  • All individuals acting on behalf of Heather Ostertag and Associates
  • For the purposes of the Code, employees from time to time holding any of the above positions shall be a Relevant Officer.

3. Honest and Ethical Conduct

Each Relevant Officer owes a duty to the Company to act with integrity. Integrity requires, among other things, being honest and candid. Deceit, dishonesty and subordination of principle are inconsistent with integrity. Service to the Company should never be subordinated to personal gain and advantage.

Specifically, each Relevant Officer must:

  • Act with integrity, including being honest and candid while still maintaining the confidentiality of Company information where required or in the Company’s interests.
  • Observe, fully, applicable governmental laws, rules and regulations.
  • Comply with the requirements of applicable accounting and auditing standards and Company policies in the maintenance of a high standard of accuracy and completeness in the Company’s financial records.
  • Adhere to a high standard of business ethics and not seek competitive advantage through unlawful or unethical business practices.
  • Avoid conflicts of interest wherever possible. Anything that would be a conflict for a Relevant Officer will also be a conflict if it is related to a member of his or her family or a close relative. Examples of conflict of interest situations, if material, include the following:
  • any significant ownership interest in any supplier or customer;
  • any consulting or employment relationship with any customer, supplier or competitor;
  • any outside business activity that detracts from an individual’s ability to devote appropriate time and attention to his or her responsibilities with the Company;
  • the receipt of any money, non-nominal gifts or excessive entertainment from any company with which the Company has current or prospective business dealings;
  • being in the position of supervising, reviewing or having any influence on the job evaluation, pay or benefit of any close relative; and

4. Disclosure

The Company strives to ensure that the contents of and the disclosures in the reports and documents that the Company files as required by the provincial and federal governments shall be full, fair, accurate, timely and understandable in accordance with applicable disclosure standards, including standards of materiality, where appropriate.

Each Relevant Officer must;

not knowingly misrepresent, or cause others to misrepresent, facts about the Company to others, whether within or outside the Company, including to the Company’s independent auditors, governmental regulators, self-regulating organizations and other governmental officials, as appropriate;

in relation to his or her area of responsibility, properly review and critically analyze proposed disclosure for accuracy and completeness.

5. Compliance

It is the Company’s policy to comply with all applicable governmental laws, rules and regulations. It is the personal responsibility of each Relevant Officer to, and each Relevant Officer must, adhere to the standards and restrictions imposed by those laws, rules and regulations, including those relating to accounting and auditing matters.

Copyright © 2010 Heather Ostertag and Associates. All Rights Reserved.