Scope

This policy applies to all employees of Go Auto Corporation and its affiliates (collectively, “Go Auto” or the “Company)

Purpose

Go Auto is committed to promoting and protecting the health of our employees. Accordingly, we promote and maintain a smoke- and vape-free workplace in accordance with federal and provincial legislation.

Policy

In order to comply with local health bylaws (to meet insurance and safety standards) and in the interest of employee, customer and vendor health - we have designated our buildings as “non-smoking.” This policy applies to smoking or holding lighted tobacco or cannabis and use of an electronic cigarette or other vaping device.

Employees are asked to smoke only in designated smoking areas and must ensure that they are fully respecting local smoking bylaws and refrain from smoking within the bylaw specified distance from entrances and windows (which will be posted at each location).

This policy will also be enforced with any employee operating a Company vehicle, including (but not limited to):

• Shuttle vans
• Parts trucks
• Customer vehicles
• Any demonstration (demo) vehicles

Scope

This policy applies to all employees of Go Auto Corporation and its affiliates (collectively, “Go Auto” or the “Company”).

Purpose

Go Auto respects everyone’s right to represent themselves on social media. It’s a great medium for self-expression. In fact, when used appropriately, social media can actually help build Go Auto’s reputation! The goal is certainly not to hamper anyone’s ability to speak positively about where they work. We simply encourage all employees to use common sense and good judgment when spreading the word. And when you do, don’t position yourself as a representative of Go Auto.

Comments on social media are extremely public. These comments are visible not just to your friends and family, but employees, suppliers, current and potential customers - literally anyone with internet access. This policy is intended to help employees use social media platforms responsibly in a way that’s consistent with Company policies and values and any applicable laws.

Policy

For the purpose of this policy – “Social Media” is any internet or mobile device application, location or site that provides users with the opportunity and means to participate in, develop or share content (photos, videos, music, etc.) or views and opinions (forums, blogs, etc.) with others. A non-exhaustive list of such media can be found here: https://en.wikipedia.org/wiki/Timeline_of_social_media

Unless specifically authorized or instructed to do so, employees are not authorized to speak or issue statements on behalf of Go Auto on any social media. Employees cannot create or control any Go Auto related social media accounts without the express authorization of the Go Auto Management Team. If an employee creates or operates a social account using Go Auto’s name, trademarks, or taglines, they will be in violation of the policy.

Inappropriate Uses of Social Media

Employees will be considered in violation of the social media policy if they:

a) Represent themselves as speaking on behalf of the company without prior authorization by management;

b) Disclose any confidential information of the company, its clients, or suppliers;

c) Use social media to harass, gossip or make negative, critical or disparaging comments about the company or its employees, customers, or suppliers;

d) Disclose personal information of any other employee or customer;

e) Post company logos, trademarks or copyrighted material (however, retweeting/sharing posts created by Go Auto is encouraged); or

f) Post photographs, video or audio recordings of employees, company facilities, or individuals receiving services from or through the company that are not in line with the business practices of Go Auto.

Go Auto will not be responsible for any social media posts made by employees.

Consequences for Non-Compliance with Policy

Anyone suspected of violating the social media policy with be subject to possible legal or disciplinary action by Go Auto, up to and including termination of employment. Additionally, employees may be held liable to third parties for unlawful statements, harassments, copyright violations, etc.

Scope

This policy applies to all employees of Go Auto Corporation and its affiliates (collectively, “Go Auto” or the “Company”).

Purpose

The employees of Go Auto are our most valuable resource, and employee health and safety are of paramount concern. The Company has adopted this Drug & Alcohol Policy to communicate our expectations and guidelines surrounding drug and alcohol use and impairment in the workplace.

Employee Requirements

During working hours and/or during the course or conduct of business, employees are expected to:

• Refrain from the use of drugs and/or alcohol;
• Refrain from the manufacture, distribution, possession, transfer, storage, concealment, transportation, promotion or sale of drug and/or alcohol or related paraphernalia at the workplace or in/on Company property;
• Arrive to work fit-for-duty and remain fit-for-duty;
• Inform supervision immediately if they are unable to safely, efficiently or diligently perform their duties to the acceptable standard due to the consumption or after-effects of drugs and/or alcohol;
• Report any suspected instances of non-compliance with this policy to management; and
• Abide by all applicable laws pertaining to drugs and alcohol.

There may be periodic exceptions specific only to alcohol for business-related social events, hosting and training and travel situations. Employees are always expected to exercise moderation and professionalism during such occasions.

Medication

Use or possession of prescription or over-the-counter medication by an employee does not necessarily contravene this policy, provided that the employee: i) is taking the medication in the manner prescribed by the physician, pharmacist or manufacturer of the medication (as applicable), ii) informs management of any safety concerns associated with the use of the medication, and iii) is fit for duty. Further information may be required from the prescribing source in order to assesses safety considerations and determine fitness-for-duty. The intentional misuse of medication (e.g. using the medication not as it has been prescribed, using someone else’s prescription medication, combining medications and/or alcohol against direction) is considered a violation of this policy.

Substance Dependency – Self Disclosure

Employees who believe they may be unable to comply with this policy are encouraged to seek support or treatment, including through the Company-sponsored employee assistance program. Employees who believe they have a drug or alcohol dependency are encouraged to voluntarily disclose the dependency to management prior to any instance of non-compliance with any Company policy or other misconduct. Employees who disclose a dependency in this manner will not be subject to discipline for such disclosure. Employees who fail to disclose a drug or alcohol dependency prior to an instance of non-compliance with any Company policy or other misconduct may be subject to discipline, up to and including termination of employment for just cause, as a result of such non-compliance or misconduct even when a dependency may have contributed to the non-compliance or misconduct.

Management Responsibilities

Go Auto will:

• Take reasonable steps to inform all employees of the existence of this policy, including maintaining a copy of this policy on the Company’s employee intranet site; and
• Ensure that any employee who voluntarily discloses a drug or alcohol dependency, before any non-compliance with Company policy or condition of employment, is provided with reasonable support and is not disciplined as a result of such disclosure.

Alcohol and Drug Testing

Go Auto may require an employee to submit to drug and/or alcohol testing in the following circumstances:

• Reasonable Cause – When an employee’s appearance, behaviour or other factors give rise to a reasonable belief that the employee may be consuming, or impaired by, drugs and/or alcohol;
• Post-Incident - When an employee’s actions contribute to an incident involving significant property damage or personal injury. For clarity, post-incident testing is only applicable to employees who work in safety-sensitive roles or safety-sensitive workplaces or who are performing safety-sensitive tasks; or
• As part of a post-rehabilitation return-to-work/reinstatement program.

An employee will be considered non-compliant with this policy if the employee:

• Refuses to comply with a request to submit to an alcohol or drug test;
• Refuses to provide a sample for an alcohol or drug test; or
• Tampers with or attempts to tamper with a sample for an alcohol or drug test.

Confidentiality & Privacy

Go Auto will only collect, use and disclose employee personal information in accordance with applicable laws. As a condition of ongoing employment with Go Auto, each employee consents to, and agrees to provide any required written or verbal consent to, the collection, use and disclosure of any personal information reasonably required to administer and enforce this policy.

Go Auto may, if it has reasonable grounds to suspect non-compliance with this policy, conduct unannounced searches for drugs or alcohol at any Company workplace. Accordingly, employees should not have any expectation of privacy with respect to the use of Company lockers, offices, storage facilities, vehicles or any other Company property.

Consequences of Non-Compliance with Policy

Subject to applicable legislation, any violation of this policy may result in disciplinary action up to and including termination of employment for cause.

Scope

This policy applies to all employees of Go Auto Corporation and its affiliates (collectively, “Go Auto” or the “Company”).

Purpose

At Go Auto, we are trying to accomplish a business casual look, which includes proper attire. Although we want our employees to be comfortable at work and have room for self-expression - we still need to project a professional image for our customers, fellow employees, potential employees, and community visitors.

Policy

Clothing that works well for the beach, yard work, dance clubs, gyms, and sports contests is not appropriate for a professional appearance at Go Auto. Employees are also asked to refrain from wearing any clothing in a state of disrepair, clothing with inappropriate or offensive slogans/artwork, and/or revealing, suggestive or extremely tight clothing.

Some departments may have specific guidelines for dress – as deemed necessary for branding, safety or practicality. Such guidelines will be provided to you by your manager, if applicable.

Scope

This policy applies to all employees of Go Auto Corporation and its affiliates (collectively, “Go Auto” or the “Company”).

Purpose

Go Auto is committed to providing a safe, healthy, respectful, rewarding, and harassment and violence-free work environment for its employees.

Policy

Go Auto does not condone, and will not tolerate, harassment or workplace violence by or against any of our employees or contractors. All reported incidents of workplace violence or harassment will be investigated and, if deemed appropriate, corrective action will be taken. For more details on investigation procedures, refer to the Workplace Violence & Harassment Prevention Plans.

All employees are responsible for reporting workplace violence, harassment, bullying, and/or discrimination. This policy is not intended to discourage workers from filing complaints or exercising rights pursuant to applicable law, including provincial human rights legislation.

This policy will be reviewed by the Company on an annual basis or more often if required.

Definitions:

Harassment is any single incident, or repeated incidents, of objectionable or unwelcome conduct by a person that the person knows or reasonably ought to know would cause offense or humiliation to another person or adversely affects that person’s health and safety, including (without limitation):

1. Conduct, comment, bullying or action because of race, religious beliefs, colour, physical disability, mental disability, age, ancestry, place of origin, marital status, source of income, family status, gender, gender identity, gender expression, and sexual orientation; or
2. A sexual solicitation or advance.

Harassment is not:

1. Consensual, agreeable banter between two or more people
2. Normal physical contact that is necessary for the purpose of performing work duties
3. An employee in a supervisory capacity engaging in day-to-day workforce management actions, such as:

• Work assignments and allocations
• Enforcing rules, polices, procedures, legislation, processes, etc. 
• Progressive discipline
• Performance management

Harassment does not include every workplace conflict or interaction that an employee may find unpleasant.

Workplace Violence is the exercise of physical force, an attempt to exercise physical force, or a threat to exercise physical force against an employee or other individual in a workplace that causes, or could cause, physical injury to the employee or other individual.

Frivolous or Vexatious Complaints

• An investigation may determine that a complaint is not supported, is not presented in good faith or that there is no breach of this policy. Such a finding does not automatically mean that the complaint was frivolous or vexatious.
• Frivolous or vexatious complaints are those where the complainant or others know there is no foundation that would suggest a breach of this policy and where the complaint is filed with false information or for the purpose of bringing an adverse consequence to the respondent or another employee of the Company. These complaints are a breach of this policy and any employee engaged in the filing of such a complaint may be subject to disciplinary action up to and including termination.

Confidentiality:

All information gathered through investigation will be kept confidential. The name of the complainant and the details of the complaint will not normally be disclosed to any person except when necessary for the investigation of the complaint, reporting on the outcome of the investigation, taking disciplinary measures, dealing with the Joint Work Site Health and Safety Committee, where necessary to inform workers of a threat of violence or harassment, or other management of the workplace. Investigation information will be secured in Human Resources (separate from employee personnel files unless the subject of discipline). Exceptions may need to be made where necessary to inform workers of a specific or general threat of violence or potential violence or as required by law.

Consequences of Non-Compliance with Policy

An employee who subjects another individual to harassment, bullying, discrimination, or workplace violence will be subject to disciplinary action, up to and including termination.

Overview

Go Auto Corporation’s (“Company”) Employee Code of Conduct (“Code”) applies to all employees of the Company across all jurisdictions. Our independent contractors, consultants, agents, and other representatives will also be required to meet the standards set out in this Code. Employees are expected to proactively promote ethical behaviour as a responsible partner amongst peers in the work environment and community.

Fairness, Integrity and Respect in Business Conduct

Employees must always follow applicable jurisdictional laws, rules, and regulations. Employees must not engage in any professional conduct involving dishonesty, fraud, or deceit or commit any act that reflects adversely on their professional reputation, integrity, or competence with customers, vendors, or financial institutions.

Our employees will not, directly, or indirectly, offer or receive bribes, kickbacks, or other similar payments, nor promise any other improper benefit for the purpose of influencing any employees, competitors, clients, suppliers, customers, and vendors, financial institutions, or any other person.

Employees must be open and transparent with our lenders. Information collected for the purpose of securing lending (leasing, financing, credit, etc.) from our lending partners must be fully disclosed. Any alterations, inflations, and/or omissions to information provided by the end-user/beneficiary of such lending is against Company policy.

Diversity and Respect in the Workplace

The Company is committed to a unique and inclusive culture and wants to foster a safe, welcoming, and respectful work environment. The Company will endeavor to create a workforce that reflects the diverse population of the communities in which we operate. The Company will provide employees with a work environment free of discrimination, harassment, violence, intimidation, or coercion and respects all protections afforded to employees, potential employees, clients, suppliers, customers, and vendors under Human Rights legislation. Employees are expected to act and conduct themselves accordingly.

Conflict of Interest

Advancing the Company’s legitimate interests is a duty expected from all employees. A “conflict of interest” occurs when an employee's personal interest interferes with the best interests of the Company. While carrying out this duty, employees need to ensure that their outside business or personal interests do not conflict with the interests of the Company and critically consider actions which may be perceived as or give rise to any potential conflicts of interest. For employment-related matters, all employees must act for the benefit of the Company and not deprive their employer of the advantage of their skills, and abilities, divulge confidential information or otherwise cause harm to the Company.

Examples of conflict of interest:

• Use of Company property or information to take advantage of a business opportunity discovered through an employee’s position
• Use of Company property, facilities, holdings, or assets for personal gain
• Disclosure of sensitive or proprietary Company information for personal gain
• Direct competition with the Company
• Receiving money (cash or cash equivalent), gifts, discounts, entertainment, quid-pro-quo (this-for-that) consideration, favours, or any other benefits from a competitor, supplier, client, customer, vendor, lender, etc. which may create a sense of obligation or perceived sense or obligation from the employee to the initiating party
• Holding a financial interest in an outside Company (investments, shares, ownership, dividends, etc.) where the employee can impact our business with that Company
• Secondary employment (including consulting services) which directly conflicts with the interests of the Company
• Directing Company business to the business of a family member or friend

Disclosure requirement:

Employees are expected to be honest and ethnical in the handling of actual, apparent or possible conflicts of interest. Any applicable situations should be disclosed by the employee to his or her Vice President/General Manger for review

Protection of Personal Information and Data Privacy

We take the privacy of the information that employees, clients, suppliers, customers, and vendors entrust to us very seriously and we are committed to protecting this information. Such information will only be collected, used, and disclosed for legitimate business purposes and in administering the working or business relationship, for discipline purposes or as otherwise required by applicable law. We will comply with all applicable privacy and data protection legislation, as required. Employees are limited to using the CRM/Database for their assigned business only. Any use of these systems for unauthorized businesses in not permitted.

Intellectual Property

Our intellectual property - including copyrights, trade secrets, know-how, patents, technical inventions, design standards, guidelines and trademarks and related licenses are critical property. We will take appropriate actions to defend our intellectual property. We are also committed to respecting intellectual property that belongs our business partners, vendors, clients, our competitors, and our industry. Employees are expected to act and conduct themselves accordingly.

Company Policies

In addition to the general corporate guidance provided in this Code, we maintain a variety of policies, procedures and guidelines specifically addressing various matters. These can be found on the Company’s intranet site at https://www.goauto.ca/policies. All employees are expected to be familiar and compliant with these policies.

Responsibilities of Employees

Employees are responsible for adhering to this code, acting in good faith, with due care, competence and diligence without misrepresenting material facts or allowing their independent judgment to be subordinated. Employees are encouraged to report any violations confidentially to their Vice President, General Manager or Go Auto Employee Support at employeesupport@goauto.ca

Business Office/Sales Guidelines

Employees will uphold all Dealer Agreements held with financial institutions in accordance with the specific rules and regulations. Proper disclosure to the banks via the credit application and input into the portals must be in accordance with these agreements. Employees must not knowingly make any misrepresentations relating to the improper disclosure to all financial institutions of any criteria that would affect and or impede the lending source’s decision making. Employees must ensure that all down payments obtained from the customer under the loan agreement are exactly as specified in the final agreement and in the form, as stated.

All products are to be presented. This must be done in an ethical and professional manner. All Business Office personnel must act in compliance with section 459.1 of the Bank Act (regarding the practice of coercive-tied selling). More specifically, it is against the law to impose undue pressure on, or coerce, a person to obtain a product or service from a particular person, including the bank and any of its affiliates, as a condition for obtaining another product or service to obtain another bank product or service.

Proper disclosure of all facets of the deal must also be provided to the customer (i.e. Carfax reports/inspection reports) in compliance with provincial guidelines.