ETHICS

"We set the security standard with stringent training and an exacting code of ethics".

Our overarching principle is to conduct our business in a legal, ethical, and moral manner. This basic canon consists of three separate obligations:

Conducting Business in a Legal Manner:

• Comply with all laws relevant to companies that contract with the Indian Government. The laws related to contracting with the Indian Government are far-reaching and complex, placing burdens on Triple Canopy that are in addition to those faced by companies without government contracts.
• Conduct our business in accordance with the letter and spirit of all other applicable laws and regulations, including the applicable laws and regulations of the countries in which we do business, and applicable international law and international human rights law.
• Never engage in harassment or discrimination of any kind and especially involving race, colour, religion, gender, sexual orientation, age, national origin, disability, and veteran or marital status. Any discrimination is unacceptable in our work place environment.
• Regard proprietary Company information as a valuable corporate asset, avoid the unauthorized disclosure of the Company's business activities, and respect proprietary information belonging to others.
• Promptly report violations of law or the principles set forth in this document to appropriate personnel identified in the Code.
• Make full, fair, accurate, timely and understandable disclosures in all communications required by law or regulation.
• Help ensure accountability for adherence to the Code.
• Remember that compliance with the law does not comprise our entire ethical responsibility. Rather, it is a minimum, absolutely essential condition for performance of our duties.

Conducting Business in a Moral Manner:

• Recognize the importance of social norms and cultural values in guiding proper conduct, and avoid purposeful actions that will violate them.
• For the communities in which we live and work, act as a concerned and responsible neighbour, and reflect all aspects of good citizenship.
• Remember that, when we perform our jobs, we each are an ambassador of the Company and hold the Company's reputation in our hands. Avoid conduct that places that reputation at risk.
• Use sound judgment and discretion in the performance of job duties, and report any conduct or actions that you feel do not meet the requirements of the Company's Canon of Ethics.

Conducting Business in an Ethical Manner:

• Maintain the highest standards of professional conduct, both externally and within the Company.
• Conduct our operations with an understanding of the ultimate goals and objectives of our customers, and avoid conduct or practices that compromise those goals and objectives.
• Avoid misrepresentation, false promises, misleading advertising, or any promotion of our work that might lead to misconception on the part of our customers, potential customers or third parties.
• Conscientiously avoid conflicts of interest and refuse to accept, or offer, any gift, favour, or service in the performance of our duties.
• Maintain the Company's active role in shaping and promoting ethics within our industry, and lead by example.
• Maintain respect for all competitors, and seek no unfair advantage by unethical or questionable means.
• If you believe that someone is engaged in activity or conduct contrary to the spirit of the Canon of Business Ethics, report it to your supervisor, the Ethics Board or the Legal Department.