Code of Conduct-Ethics

The Code of Business Conduct and Ethics outlines the legal and ethical obligations of all JUST LED US Inc. directors, officers and employees, sales representatives, regardless of where they work and what their jobs duties entail. We have several entity-level and local policies that employees should read and understand in addition to this common code which stated objective is to be adhered to.

While the Code of Conduct-Ethics and policies strive to identify the most common situations and circumstances, they don’t explicitly cover every possible situation or circumstance. If you’re an employee or a sales representative and are unsure of how to apply yourself in an honest and ethical way concerning any particular circumstance, or what the “right thing to do” is in any circumstance, your Managers, Human Resource, Legal Department and Compliance are available to provide guidance.

JUST LED US administration staff are considered Leaders and are expected to model appropriate ethical behavior.  We always encourage transparency which includes providing our employees and sale representatives with the resources they need to ensure that everyone understands this Code and all obligations. We hold our administration staff to the highest standard that requires an ethical and compliant quality at the top of the organization. As leaders, managers are also required to manage and, where it is appropriate, we will escalate employee and sales representative concerns, reports and allegations. If you have any questions about your role as a manager in this organization, please ask your supervisor or Legal entity.

At every level of the company we must comply with all applicable laws and JUST LED US Inc. Policies.

As JUST LED US continues to grow throughout Canada and the USA we must respect and comply with all of the laws that apply to our operations, wherever business is being contributed to.  This means we must not only abide by the laws of the country of Canada and its individual provinces/territories, the United States of America and its individual states and other local jurisdictions in which we do business, but also some laws of some jurisdictions that apply to us globally.

Each of us is responsible for abiding by all applicable written JUST LED US policies and guidelines. All JUST LED US Inc. policies apply to all JUST LED US administration staff, directors, officers and employees and sales representatives regardless of geographic location or job position.

When we’re engaged in JUST LED US business, we must act in JUST LED US composition and best interests, as our acronym reads, “Judiciously Uniting Strengths Together as Leadership (&) Education Develops Understanding (of) Sustainability”.  Sustainability has an underlying definition in morale, with all who are involved at every level of the company and we extend this welcoming attribute to customers and clients as well.

It is each of our responsibility to work for the best interests of ourselves and JUST LED US Inc. This means each of us should avoid conflicts between our personal interests and the interests of JUST LED US. The following are some examples of potential conflicts and the rules that each of us should follow:

•Outside Employment or Business Activities: We must not participate in any outside business opportunities or jobs that materially impact our ability to complete our JUST LED US duties or that compete with JUST LED US in any way. To protect against such conflicts, we must report to a supervisor and receive approval for any outside employment in which we participate. If our outside business opportunity is approved, we must not use JUST LED US resources to fulfill any obligation to the outside business opportunity;

•Outside financial interests/investments: absent prior written approval from a supervisor and excluding modest investments in public securities exchanges, we may not have a direct or indirect financial interest in a competitor, customer or supplier or receive loans or guarantees personally that conflict with JUST LED US interests;

•Personally pursuing corporate opportunities that are discovered through our work with JUST LED US: We are prohibited from (a) taking for ourselves personally any opportunities that properly belong to JUST LED US or are discovered through the use of corporate property, information, or position; (b) using corporate property, information, or position for personal gain; and (c) competing with JUST LED US;

Conflicts of interest are prohibited as a matter of JUST LED US policy, except under guidelines approved by the board of directors or by committees of the board. While the list above is intended to provide some guidance on the situations that may create a conflict, there may be other situations you encounter where your personal interests are not aligned with JUST LED US’ interests.  In such cases, you must consult with JUST LED US administration office, your manager, legal or the Board.

JUST LED US may direct you or others to terminate any relationship or interest that gives rise to a conflict of interest that cannot otherwise be resolved.  In the case of Directors, if the Board determines that a conflict of interest cannot be cured, the Board of Directors may request that the director resign and, upon the board chair’s request, the director shall tender his or her resignation from the board of directors.

Each of us has a responsibility to do our part to provide a safe, orderly and tolerant work environment.We promote ‘positive encouragement’ and must grant others the same respect, cooperation and dignity that we wish for ourselves.

JUST LED US’ work environment encourages respect for individuals. We should deal fairly with our fellow directors, officers, employees, sales representatives and customers/clients. JUST LED US does not tolerate at any level of discrimination or harassment against any individual with respect to race, religion, age, gender (including pregnancy and childbirth-equal rights and opportunities and recognizes the dignity and worth of every person), marital status, family status, sexual orientation, national or ethnic origin, non-qualifying disability, veteran status, conviction for which a pardon has been granted or any activity specifically protected under a JUST LED US policy, such as expressing our good-faith opposition to prohibited discrimination or harassment, or participating in making a good-faith complaint of discrimination or harassment.