POLICY

1.01. Employees must perform their duties in a manner that maintains and enhances public confidence and trust in the integrity, objectivity and impartiality of the Ocean Mechanical Inc. (the “Company).  Trust and mutual respect are the cornerstones of any relationship between an employer and its employees. As its most valuable and important asset, Ocean Mechanical’s employees therefore are expected to demonstrate the highest standards of behaviour.

1.02. Regulations for the acceptable conduct and behaviour of employees are necessary for the orderly operation of any business, for the benefit and protection of the rights and safety of employees and the protection of Ocean Mechanical’s assets. Employees are expected to govern their conduct and behaviour in a manner consistent with the guidelines set out herein.

1.03. Ocean Mechanical Inc.  is committed to maintaining a work environment that is free of illegal drugs, alcohol, firearms, explosives, or other improper materials. The possession, transfer, sale, or use of such materials on company premises or during the conduct of Ocean Mechanical’s business is prohibited. A breach of this policy will result in discipline up to and including discharge.

2. PURPOSE

2.01 The purpose of this Statement of Policy and Procedure is to provide guidelines, which may be changed from time to time, to promote understanding of what is considered acceptable and unacceptable conduct and behaviour; and to encourage consistency throughout the company.

2.02 This Code clarifies the Company’s expectations of its employees, and re-affirms our commitment to caring for our customers needs and maintaining fiscal responsibility on behalf of the public and our employees. It provides a guide for consistent behaviour in delivering services and goods. This Code is simply a formal statement of the policies and principles of conduct the Company has always embraced. Contravention of this Code is a serious matter to the Company and will be treated as such.

3. SCOPE

3.01 This Statement of Policy and Procedure applies to all employees, directors, executives, supervisors, managers, and officer. All should receive a copy of the Code and certify each year that they have complied with this Code.

3.02. All employees are expected to be aware of, and comply with, this Employee Code of Conduct and its related policies.

4. RESPONSIBILITY

4.01 Each employee including supervisors and managers is responsible for observing rules of conduct that are normally accepted as standard in a business enterprise.

4.02 Employees, Supervisors and Managers of the Company must follow the highest standards of ethical behaviour in the course of their work to ensure that public confidence and trust is maintained. The Company and all its employees must be above suspicion and beyond reproach, and must be perceived in this manner.

4.03 Supervisors and Managers are responsible for counseling employees promptly when their conduct or behaviour is inconsistent with the intent of this Statement of Policy and Procedure.

4.04 We all share the obligation to ensure a professional, respectful work environment

5. PROCEDURE

In order to earn and retain the trust and respect of each other within the Company as well as external stakeholders – including customers, suppliers, and the general public – principles of honesty, integrity, fair dealing and the highest ethical standards must underlie everything we do and every decision we make. We must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of facts, or any other unfair dealing or unethical activity. We will be judged not only in terms of how competent we are at conducting our business, but also on our integrity and how we behave at work, in community or political involvement and in the public expression of personal views. Accordingly, before embarking on any course of action we need to be able to answer “yes” to each of the following questions: Is it fair? Is it right? Is it legal?

Each of us needs to be aware of and comply with applicable laws, rules and regulations of all levels of government, related public and regulatory agencies, as well as Company policies that affect how we do our jobs. Corporately and individually, we must never knowingly violate laws or willfully blind ourselves to our legal or regulatory responsibilities or be a party to such actions or omissions

We must be aware of the policy framework that guides and governs our behavior in the performance of our day-to-day activities and conduct ourselves in a manner consistent with those policies and the Code.

The company’s reputation rests on how customers, suppliers and the public perceive us individually – not only in terms of how competent we are at handling their business, but also on our integrity and how we behave. The following are some examples of situations where our individual actions could affect that perception.

Those who, in good faith, report concerns of the kind described below will be protected by the company.

5.01 Appropriate Conduct and Behaviour includes but is not limited to:

• Adherence to published policies, practices and procedures;
• Competent performance of all job duties assigned;
• Prompt and regular attendance at work;
• Courtesy to and respect for co-workers, customers, suppliers or any other person who deals with Ocean Mechanical Inc. in the conduct of its business;
• Wearing proper business attire and footwear during working hours, appropriate to the job performed. For this purpose T-shirts, jeans, shorts, or other such casual attire are not acceptable office attire; tennis/running shoes, thongs, sandals, etc. are not acceptable business footwear.
• Employee must hold in confidence any information obtained about a customer, supplier or employee in the performance of their duties consistent with the requirements of the workplace and legislation.
• Employees must not engage in, or condone behaviour which causes unnecessary mental, physical distress or loss of dignity, privacy or autonomy to customers, suppliers or employees.
• Employees have a responsibility to promote and safeguard the well-being and safety of the customers, suppliers and fellow employees at all times by ensuring that no act or omission on their part places them at risk or in harm’s way.
  
  

5.02 Inappropriate Conduct and Behaviour includes but is not limited to:

• Loitering or loafing;
• Leaving work early or leaving department without supervisor’s permission;
• Using obscene, abusive language;
• Spreading malicious gossip or rumours;
• Harassing, threatening, intimidating, coercing any person at any time;
• Horseplay or throwing objects;
• Reporting to work or working while under the influence of alcohol, drugs, or prohibited substances;
• Creating or contributing to unsanitary conditions;
• Gambling, lotteries, or any other game of chance while on company premises;
• Insubordination;
• Excessive personal use of telephones or computer facilities.
  
  

5.03 Unacceptable Conduct or Behaviour includes:

• Perceived inappropriate comments directed at an individual related to the person’s sex, sexual orientation, racial background, religion, or physical ability.
• Possession of guns, weapons or explosives on company property;
• Possession, consumption or use of alcoholic beverages or illegal substances while on company premises;
• Solicitation of other employees, for any reason, during working hours, unless approved in advance by the Owners;
• Willful violation of safety rules and procedures;
• Willful neglect and/or mishandling equipment and machinery;
• Unsafe driving of company or in-plant vehicles;
• Theft and/or falsification of company records; Threat of/or actual physical contact of any kind when there is a perception of physical violence. For example: Violent grabbing, pushing, or shoving and throwing of instruments, materials or equipment of any kind.
• Sexual harassment of any kind. Types of conduct which may constitute sexual harassment include but are not limited to: Sexual remarks or jokes causing embarrassment or offence after the person making the joke has been informed that they are embarrassing or offensive or that are by their nature reasonably known to be embarrassing or offensive. Sexual solicitation or advance made by a person in a position to confer, grant, or deny a benefit or advancement where the person making the solicitation or advance knows or ought reasonably to know it is unwelcome. Sexually degrading words used to describe a person. Sexually suggestive or obscene comments or gestures. Leering, touching, advances, propositions or requests for sexual favours.
• Derogatory or degrading remarks, verbal abuse, or threats directed towards members of one gender or regarding one=s sexual orientation. Inquiries or comments about a person=s sex life, sexual prowess, or sexual deficiencies. The display of sexually suggestive material in the workplace. Persistent unwanted contact or attention after the end of a consensual relationship. Comments which draw attention to a person=s gender and have the effect of undermining the person’s role in a professional or business environment. Comments regarding a person’s physical appearance or attractiveness.
• Indecency;
• Fighting;
• Poor or careless work;
• Sleeping while on duty

Inappropriate and Unacceptable conduct could result in disciplinary action up to and including termination without notice or pay in lieu thereof.

5.04 Required Action

If we suspect an actual or potential breach of this Code – whether it be a conflict of interest, a breach of applicable law, regulations, rules or what appears to be unethical, fraudulent or other illegal behaviour on the part of a colleague – we must do something about it. Why? Because by simply looking away, we become part of the problem. In order to be part of the solution, we must all be alert to activities that may point to a breach of any laws, rules, and regulations, any Company Policies or this Code.

If we know of or suspect such breaches, either by ourselves personally or by another individual, we must immediately report to any one of the appropriate persons and departments indicated on the directory provided on the company’s website or contact our manager or  Corporate Compliance for guidance. Those persons and departments are responsible for appropriately receiving, retaining, handling and, where appropriate, reporting and escalating verbal and written complaints and reports in relation to such matters in accordance with company policies. If you have already taken a concern to the appropriate persons and departments referred to above and you are not satisfied with the response, you should promptly refer the matter to the highest level of the company or any other designated person such as an ombudsman.

Perceive and determine if any action is requested or required. It is not the intent of the Code to create a compulsion to report or an atmosphere of paranoia since this would not be in keeping with the spirit of the principles espoused.

The following list is not meant to imply any chronological order for action. The action taken should be entirely up to the concerned party or parties. Possible action includes:

• Reporting breaches of the Code on a confidential, anonymous basis. If you wish to report a potential or actual breach of this Code on a confidential, anonymous basis you should promptly submit a verbal or written report to the appropriate persons and departments who receive such confidential, anonymous reports as indicated on the directory provided on the company’s website.
• If you are unsure of the best way to proceed on reporting or making complaints relating to potential or actual breaches of this Code, you must immediately consult any one of the appropriate persons and departments.
• The designated person who received the complaint will speak to the individual(s) deemed responsible, directly identifying the problem, and seeking to resolve the concern.
• The designated person who received the complaint will speak to the appropriate supervisor, department head or manager for the individual or individuals about whom the complaint is being made;
• If further action is required, a meeting will be set up with the parties concerned and with the designated person in charge of applying, mediating and issuing orders or dispute resolution related to the code of conduct policy. Results of this meeting are to be held confidential by all parties with reports going only to those individuals acceptable to both parties.
• That designated person must establish a formal enquiry to validate the complaint and advise the head of the company or whoever is in authority in regard to an appropriate reaction. The nature of such an enquiry process will be at the discretion of head of the company or whoever is in authority.
• Before any action is taken, individuals will be advised that vexatious or frivolous accusations of abusive behaviour constitute another form of inappropriate interaction Persons found to be engaging in this will be dealt with at the discretion of head of the company or whoever is in authority.
• When, in the opinion of the designated person and head of the company or whoever is in authority a sufficient body of complaint has been built up to warrant it, he/she shall consult with the appropriate authority relating to the group or source of the problem in regard to establishing some form of educational experience aimed at heightening awareness of the issues in the group or unit as a whole without creating an atmosphere of accusation or defensiveness and to stop such behaviour subject in the complaint. Failure of this process, , (i.e., continuing complaints) shall be brought to the attention of the one in authority immediately for action.

• Need for further action or more stringent measures will be assessed and applied immediately or as soon as possible, taking into account the seriousness of the violation as well as any failure to cooperate in any investigation in relation to any violation. Disciplinary action can include, but is not limited to, counseling, an impact on the applicable individual’s record or remuneration, suspension or termination of employment, pursuit of any and all remedies available to the company for any damages or harm resulting to it from a violation (including injunctive relief), and referral to the appropriate legal or regulatory body. Generally, any employee who seriously breaches Ocean Mechanical Inc. policy will be dismissed. Where applicable, the company will refer the matter to the police.