Policies

Disclaimer

​Visitors to our website and users in general should note that:

The use of our website is solely at their own risk on an "as is", "as available" basis. Information on our website is provided for general purposes only.

ONxpress makes no warranty or representation as to the accuracy, quality or completeness of any information on our website. ONxpress disclaims all warranties and conditions including merchantability and fitness for a particular purpose, either express or implied, and disclaims any liability for loss or damages which result directly or indirectly from the use in any form of any of the information on our website including any personal information provided by visitors and users in general. Where such warranties or conditions are legally incapable of exclusion, then ONxpress’s liability shall be limited to the sum of $100.00 in the aggregate regardless of the number of occurrences. Users assume all risks concerning the suitability to their needs and the accuracy of information on our website and any publications therein.

The use of this website or any e-mail communication to any one at ONxpress does not give rise to a client relationship notwithstanding receipt of such communication. A client relationship shall only arise upon our mutual agreement in writing.

Internet communications may not be confidential and ONxpress does not guarantee the confidentiality of any e-mail or internet transmissions. Users are cautioned not to send any information where confidentiality or privacy may be an issue via e-mail or the internet. ONxpress assumes no liability whatsoever for any confidential information sent to us over the internet.

ONxpress expressly disclaims any liability regarding links to other websites or any information, products, or services that they contain.

Any legal questions or disputes arising from the use of our website shall be governed by the laws of the Province of Ontario and the laws of Canada applicable therein. The courts of the Province of Ontario shall have primary jurisdiction over any such legal questions or disputes.

For the purposes of this Disclaimer, ONxpress shall include its partners, principals, officers, directors, employees, agents, authorized representatives as well as its affiliated corporations and their respective officers, directors, shareholders, employees, agents, and authorized representatives.

ONxpress reserves the right to make changes at any time to the website which may include information including these terms, services, and technical specifications, without notice. Users are responsible for checking such updates.

Privacy Statement

For the purposes of this Privacy Statement, ONxpress includes its partners and affiliated corporations.

This Privacy Statement was last updated: Mar. 29^th, 2023.

ONxpress may collect personal information from different sources depending on the services that we are providing or whether we are collecting this personal information for our internal business operations. For example, we may collect personal information directly from you when you retain us or your employer when your employer retains us. We may also collect personal information from you when you apply for employment or an internship with us. We may also collect personal information through third parties who perform background checks and credit checks for us. In addition we may collect personal information through third party analytics and advertising firms who assist us in our marketing. These businesses may provide us with data about your online activities on other sites where we show our advertising and marketing material.

We collect the following types of personal information:

• Contact information, such as your name, title, role, employer, telephone, email address, and mailing address.
• Visitor information when you attend at our offices or events, such as your name, company, and persons you visited at our offices and events.
• Public profile information, such as information that you have made public on LinkedIn or your company’s website.
• Communications, such as the content of your emails, voicemails, and other communications with us
• Communication preferences and interests, such as when you subscribe to receive our newsletters, updates, or other materials.
• Feedback, such as when you fill out client surveys or feedback forms at our events.
• Recruitment information, such as information contained in CVs and cover letters, references, and other information you may provide if you apply for employment or an internship, or that we collect as part of our recruitment activities.
• Background check information, such as credit checks, criminal records checks, economic, and other sanctions checks, credential checks and other background information.
• Portal/Vendor registration information, such as email address, password, and activities using our client portal, if applicable.
• Device and browser information when you use our website www.onxpress.com, such as your IP address, browser type and version, time zone setting, operating system, device type, hardware model, MAC address, and network information.
• Browsing information when you visit our website, URL clickstream data about your visit to, through and from our website, page response times, downloads, and length of visits and interaction information.
• Marketing interaction information, such as whether you opened one of our electronic newsletters or clicked on an advertisement or otherwise interacted with our marketing materials.

The purposes of our collection, use, sharing and disclosure:

We may collect, use, share or disclose personal information for the following purposes:

• Vendor management, such as managing the services that third parties deliver to us or to client(s) on our behalf.
• Legal and regulatory compliance, such as conducting screening for conflicts, complying with anti-money laundering laws, conducting sanctions checks, and to maintain books and records that are required by law or that assist us in meeting our legal and regulatory obligations.
• Relationship management, such as establishing, maintaining, and administering our relationship with you or your employer, and which may include client account opening, accounting, invoicing, risk analysis, conflict checking, and customizing the services we offer to our client(s).
• Recruitment, such as processing your application for employment or an internship or when we proactively recruit new employees or co-op placements.
• Communications, such as responding to your inquiries, sending you newsletters, updates, or other material, and managing your preferences.
• Events management, such as reserving your place at our events, noting dietary restrictions or choices, and other event related purposes.
• Feedback, such as client surveys, event feedback, and addressing concerns that you might have attended and shared your information with ONxpress.
• Security, such as monitoring who has had access to our premises, and protecting our website from misuse.
• Website management, such as monitoring what visitors, visit our website, and whether there are problems with features and functionality.
• Improvement of our business, understanding what our visitors, prospective employees and vendors find interesting, improving our website, improving how we use vendors to provide services to us or to our clients.

Sharing Personal Information: We may disclose or share personal information in order to fulfill legal requirements or to operate, market, and improve our business.

The following are examples of entities that may receive personal information with from us. These entities will only use your personal information in accordance with our instructions or as otherwise required by law:

• ONxpress members, stakeholders and partners, when necessary to vet services or products across multiple business units, to make referrals, to assess potential conflicts.
• Service providers, who provide outsourced business services to us, who assist us in marketing and advertising or events, or who assist us in providing or managing our information technology and communications systems.
• Screening service providers, who perform credit checks, sanctions screening, crime or anti-money laundering checks, and other background checks.
• Clients, as part of work product, such as when we are retained to conduct an audit or investigation or prepare a report or advice, and your personal information is relevant to that work product.
• Analytics providers and advertising networks, who support our analysis of the performance of our website, microsites and mobile apps and your interests, or who assist us in placing advertising on other sites.
• The following are examples of entities that we may disclose personal information to. In situations involving such disclosure, ONxpress has no control over how these entities may use your personal information: Emergency responders, emergency contacts, or public health authorities, when necessary to respond to an emergency, or address an urgent occupational health and safety issue or outbreak of communicable diseases.
• Law enforcement bodies and regulators, when required under applicable laws, such as anti-money laundering reports, or where we are reporting a contravention of laws.
• Other third parties, in the course of a commercial transaction involving the acquisition of or transfer of any part of our business.

Consent and other legal bases

There may be several reasons why we might collect, use, share or otherwise handle your personal information. These include:

• Your explicit or implicit consent, such as when you provide the personal information as part of a request for services or a product, when you provide the personal information for a specific purpose or we ask you to consent to our use of your personal information for a purpose or for the purposes set out in this Privacy Statement.
• With the consent of someone with authority to provide the information to us, such as your employer or a third party to whom you provided the information and who has the legal right to share it with us.
• Where necessary to fulfill our legal obligations, such as where we need to conduct client screening, anti-money laundering checks, or for other legal and compliance purposes where the law permits us to handle personal information with your consent.
• For the purposes of responding to legal claims against us.
• To conduct investigations where the law permits us to handle personal information without your consent.

We may use your business contact information to contact you in your business, role, function, or occupation without your consent. If we send you commercial electronic messages, we will comply with Canada’s Anti-Spam Legislation, subject to any exceptions permitting us to send unsolicited commercial electronic messages. You may unsubscribe from our communications at any time.

Security

We use physical, technical, and organizational security measures that are consistent with standards in our industry. These security measures are designed to protect the confidentiality and integrity of personal information in our custody. We use contractual or other means to require our service providers to protect the confidentiality and integrity of personal information we entrust to them. Unfortunately, no system of security measures can guarantee the security and privacy of personal information. If you are sharing highly sensitive information electronically with ONxpress, please speak with us about methods of secure file transfers.

Location and retention

Personal information is stored primarily in Canada. However, we may also use service providers or the assistance of partners, except where we are restricted by legal or contractual requirements. The laws of other jurisdictions may not be as protective as those in Canada and personal information held outside of Canada may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of these other countries in accordance with their laws.

We retain information for the purposes for as long as it is necessary to fulfill the purposes for which we collected it. We also retain personal information to meet obligations under applicable laws and regulatory requirements and to maintain records for possible litigation or investigations, where required.

Children and minors

We do not knowingly collect personal information from children or other persons who are under 14 years of age except as part of our engagements such as career exploration, bring your child to work days or where a child is brought into our office as a visitor and may require a visitor pass. Our website and marketing materials are only for use by individuals who have reached the age of majority in their province or country of residence.

Cookies

Below we provide information on how we may use website cookies on our website.

A cookie is a small data file of information offered to your computer or device by web servers to keep track of your browser as you navigate our websites.  Using this information, we learn how you interact with our websites, how we can improve the design and content of our websites and improve your experiences. We do not use cookies to access personal files on your computer or device.

Our website, advertisements, and email communications may use pixel files. Pixel files keep track of your browser or your interaction with our advertisements and marketing material. We may also use pixel files to determine when you have opened a promotional communication from us.

Our ad management providers may use cookies and pixel files to populate an advertisement for us when you visit certain other websites.

Analytics

Our websites may use analytics services, including Google Analytics, a web analytics service provided by Google, Inc. These analytics providers use cookies to help the website analyze how users use the site. In some cases, the information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by analytics providers on servers outside of Canada. This information is used for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Your choices

If you would prefer not to accept cookies, most browsers will allow you to:

(i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it;

(ii) disable existing cookies or delete cookies when you close your browser; or

(iii) set your browser to automatically reject any cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

You can opt-out of network advertising programs that track your activities across multiple websites to deliver personalized advertising content to you. Please visit Digital Advertising Alliance of Canada Opt-Out Page, NAI Opt-Out Page and the Ad Choices Opt-Out Page. These websites provide tools that identify member companies that have placed cookies on your browser and provides mechanisms to opt-out of those cookies. You will still receive other types of advertising from participating companies; however, it will not be based on your interests. Deleting browser cookies can remove your opt-out preferences, so you should use these tools periodically to ensure that your preferences are up-to-date.

Your rights:

Canadian privacy laws provide you with certain rights, including those listed below.  Please see “How to contact us” for the contact information of our Privacy Officer in order to exercise these rights.

• Access– you have the right to ask us if we have collected personal information about you and to obtain access to that information. Where you wish to exercise this right, we will ask you for information to confirm your identity and may ask you to assist us in describing your relationship with us so that we can locate the relevant personal information. Please note that we may withhold disclosure of personal information in certain cases under applicable laws.
• Correction – you have the right to ask us to correct any incorrect, incomplete or inaccurate personal information we hold about you.
• Withdrawal of consent – in some cases, you have the right to ask us to cease collecting, using, or sharing your personal information.
• Complaints – you have the right to make a complaint to about our compliance with this Privacy Statement or applicable privacy laws. Changes

We may change this Privacy Statement from time to time. Please refer to the date at the top of this Privacy Statement for the last date updated.

How to contact us:

To exercise your rights or to make a complaint, please contact:

Privacy Officer, ONxpress Transportation Partners

Via email: privacyofficer@onexpress.com

Or

Attn: Privacy Officer, ONxpress Transportation Partners

130 Adelaide Street West, 5th Floor

Toronto, ON M5H 0A1

1. PURPOSE

ONxpress Transportation Partners Inc. (known as the “Company” or “ONxpress”) code of conduct and professionalism document (the “Code”) is intended to provide guidelines for all Employees with respect to expected conduct, and to avoid real, potential, or perceived conflicts that would be seen as compromising the Company’s position with respect to its actions and general business decisions in the industry sector in which it operates. The Code provides a basis for good business ethics and practices which are expected and necessary for individual Employees.

The Code is not meant to be a complete list of all legal and ethical obligations of the Employees of the Company. The Code is neither a contract nor a comprehensive manual that covers every situation that might be encountered. The Company provides this Code to its Employees to offer guidance in properly recognizing and resolving the legal and ethical issues that they may encounter while conducting the Company’s business. Should an Employee be confronted with a situation where further guidance is required or a situation where the Employee knows or suspects that a violation of the Code has been or is likely to be committed, the matter should be discussed or reported, as the case may be, in accordance with the procedures set out under the heading “Duty to Report” below. No Employee will be subject to retaliation by the Company for reporting, in good faith, a violation or likely violation of this Code.

General Principles

Regulatory compliance is our starting point at ONxpress. We are committed to carrying out our business and professional activities in accordance with the pertinent legislation in force and the Company's rules and procedures, wherever we operate, including regulations related to international sanctions or restrictive measures, export or import control and dual use products, as well as the company's rules and procedures. In all our business activities we abide by the applicable laws, regulations, and standards, avoid conflicts of interest and show respect for the customs, traditions and social values of the countries, communities and cultural groups in which we operate. In our dealings with our customers, business partners and Employees we undertake to act fairly and with integrity at all times.

It is the responsibility of each Employee to become familiar with the principles set out in the Code and to integrate them into every aspect of the Company’s business. All Employees are required to comply with this Code.

2. SCOPE

The Code applies to all Employees of the Company and Seconded Employees, and their interactions with other Employees, applicants for employment, contractors, clients, partner organization Employees, and members of the public.

3. DEFINITIONS

Employee means all salaried, full-time employees of the Company and includes Seconded Employees.

First-Level Manager means the person who is responsible for managing the day-to-day duties of the relevant Employee.

Seconded Employee means an employee of an affiliate of the Company who has temporarily been seconded to the Company to meet an operational need, training/learning aim, career development purpose and/or knowledge transfer purpose.

Second-Level Manager means a person who provides leadership to the Employee’s First-Level Manager.

4. RESPONSIBILITIES

4.1 First-Level Managers are responsible for:

- Being familiar with the Code as well as procedures and resources available to handle   ethical inquiries, complaints, or violations.

- Promoting and driving a culture of integrity while maintaining a climate in which honest, ethical, and legal business conduct is the norm.

- Ensuring that annual training, as well as any other mandatory training, is completed by all team members and that violations of the Code are addressed consistently, and team members are held accountable for their behaviour at work or in connection with their work.

- Identifying risks of non-compliance with the Code within their area of responsibility and take appropriate steps to address such risks.

- Creating and maintaining a work environment where team members feel comfortable speaking up and having open discussions without the fear of retaliation or reprisal.

- Communicating regularly with their team and emphasizing the importance of compliance and demonstrate visibly and actively – through words and behaviour their personal commitment to the Code and Company policies.

- Using the Company’s performance development process to evaluate and recognize team members not only on the business objectives achieved, but also on how they are achieved.

4.2 Each Employee’s responsibilities are as follows:

Employees are required to read, understand, apply, and comply with the Code, and any and all other Company policies that may be in effect from time to time, and any other legal or legislated requirements applicable to their position.

If Employees are aware of something that may be a violation of the Code, ONxpress’ policies more generally, or the law, they are required to discuss or report it, as the case may be, in accordance with the procedures set out under the heading “Duty to Report” below.

All Employees must conduct themselves with the Company’s core values in mind:

• Safety first and always
• We collaborate with full transparency
• We foster an inclusive and diverse work environment
• We dedicate to a healthier and more sustainable region
• We serve our community with passion and commitment

4.3 Human Resources are responsible for:

- Supporting First-Level Managers and their Employees by ensuring they have access to all information pertaining to the Code.

- Ensuring that any complaints related to the Code are dealt with appropriately.

- Working with First-Level Managers to ensure a fair review is conducted and that all follow-up documentation is complete.

5. PROCEDURE

5.1 Human Rights

Respect for the dignity of individuals and their basic rights is a cornerstone of ONxpress. The Company values the diversity of its Employees, customers and suppliers and is committed to providing equal treatment in all aspects of the business. Within the scope of its business activity, ONxpress complies with the internationally recognized human rights and fundamental freedoms.

All Employees are required to support this principle, carrying out ONxpress’ professional activities with absolute respect for, and guaranteeing, human and civil rights. Honesty and compliance with legislation and the rules of the Company must be a permanent feature in the day-to-day conduct of all Employees, and particularly of the management.

Discriminatory, abusive, harassing or offensive conduct is unacceptable, whether verbal, physical, visual or otherwise. The Company will not tolerate any conduct that is discriminatory or harassing or otherwise compromises an individual’s human rights.

5.2 Diversity and Inclusion

The Company is committed to an inclusive culture that fully enables all Employees to be authentic and to tap into their full potential. The Company recognizes that people bring different qualities, abilities, skills, knowledge, experiences, perspectives, and attitudes to work and that valuing and making the most of these differences can improve the workplace for individuals and enhance our overall performance.

All Employees are expected to demonstrate behaviours that create an inclusive environment in which all people are heard, respected, valued and able to bring their full selves to our workplace.

In line with our commitment to creating a workplace which is free from harassment, violence, and safety risks, all those covered by this Code are expected to observe minimum standards of behaviour that include but are not limited to:

• Being polite and courteous to others
• Being respectful of the differences between people and their circumstances
• Ensuring that we do not assist, or encourage others, in the workplace or in connection with the workplace, to engage in discriminating behaviour of any type.

Reporting any harassing or discriminating behaviour in the workplace, or connected with the workplace, in accordance with the complaint procedure as outlined in the Respect in the Workplace - Harassment Policy or in accordance with the procedures set out under the heading “Duty to Report” below.

Reporting any workplace violence in accordance with the complaint procedure as outlined in the Respect in the Workplace - Violence Policy or in accordance with the procedures set out under the heading “Duty to Report” below.

Respecting the confidentiality of information regarding ONxpress’ Employees, including but not limited to information arising from investigations pursuant to the Respect in the Workplace - Harassment Policy.

5.3 Occupational Health & Safety

We are committed to complying with all applicable health and safety laws and regulations as part of our commitment to providing Employees with a safe and healthy work environment. The Company is committed to the health, safety, and wellbeing of our Employees, including maintaining an environment that is free from workplace illnesses, injuries and/or factors that create physical, mental and/or emotional distress.

The Company and all Employees must take all reasonable steps to necessary to meet or exceed the requirements under the Occupational Health and Safety Act (OHSA) of Ontario and all legislative requirements.

Employees have a responsibility to maintain a safe work environment. Employees receive information, training, and competent supervision in their specific work tasks to protect their health, safety, and wellbeing. Employees are expected to work in a safe manner with due regard for their personal safety as well as that of their co-workers and to report accidents, injuries, hazardous equipment and unsafe practices.

Each Employee is accountable for always operating in a safe manner. This includes, but is not limited to:

(a) Attending to work fit for duty;

(b) Following safety practices and procedures;

(c) Using safety equipment appropriately at all times;

(d) Immediately reporting incidents, including near misses and unsafe working conditions, to a First-Level Manager;

(e) Encouraging safe behaviour by those around them; and

(f) Immediately identifying unsafe behaviour to their First-Level Manager.

The Company promotes and values a strong safety culture that is always shared

and practiced by all Employees, whether in the office, travelling, at a customer site

or at home.

5.4 Environmental Responsibility

We are committed to conducting all business operations in an environmentally responsible manner and in a manner that strives to conform with all applicable environmental laws and regulations and to promote the respect of the environment in our activities. It is the responsibility of each person of the Company to support the Company’s efforts to develop, implement and maintain procedures and programs designed to protect and preserve the environment.

5.5 Conduct to Reflect the Spirit of the Code

Adherence to this Code does not, in and of itself, release an Employee from being responsible for considering how their behaviours may be perceived and how those behaviours may affect ONxpress’ reputation. As a result, Employees are expected to carefully consider public perception and exercise responsible judgment when applying the Code to their behaviours. A similar approach is expected with respect to all codes or policies that regulate individual behaviours for purposes that include public perception, including but not limited to, the Business Travel Policy and the Conflict-of-Interest Policy.

5.6 Confidentiality

Employees shall not, during their term of employment or thereafter, knowingly take advantage of, or benefit from, information that is obtained in the course of their official duties and responsibilities and that is not generally available to the public nor use any such information in a manner that is inconsistent with the best interests of ONxpress and the proper fulfillment of their employment responsibilities. In carrying out business activities, the Company’s Employees may become knowledgeable about information or documents of a private, confidential, or proprietary nature relating to ONxpress’ activities or to a customer, supplier, or competitor. Any such information or documents belongs to the Company and are private and confidential.

These obligations and duties on Employees respecting confidential information and documents will continue even after an employment relationship with ONxpress has ended.

5.7 Avoiding Conflicts of Interest

Employees have a duty of loyalty to the Company and are therefore expected to always act in the Company’s best interests. A conflict of interest arises when the personal interests or activities of an Employee influence or have the potential to influence the exercise of his or her judgment in the performance of his or her duties.

Conflicts of interest and even the appearance of a conflict of interest may compromise the Company’s reputation and must be avoided.

Every Employee must, therefore, ensure that a conflict does not exist and exercise diligence to avoid entering situations in which his/her personal interest might conflict with or be perceived to be in a conflict with those of ONxpress. More specifically, Employees should avoid acquiring an interest or participating in activities that may create an obligation that could potentially affect their judgement or ability to act in the Company’s best interests or would tend to deprive the Company of the time or attention required to perform their duties properly.

Employees shall not have private interests that would particularly or significantly affect or conflict with ONxpress’ business or actions taken by ONxpress in connection with its business operations. If such a conflict does arise between the private interests of an Employee and his/her employment duties and responsibilities, the conflict shall be resolved in favour of the Company’s interest. Each Employee is responsible to report any potential conflict of interest to his/her First-Level Manager or the Chief Human Resource Officer. If an Employee is unsure whether a conflict exists, he/she is responsible to request clarification from the Human Resource Department.

When a conflict has been reported, the Human Resources Department will conduct a review and determine if a potential, perceived or actual conflict exists. It is then the Employee’s responsibility to resolve and eliminate the conflict immediately and provide proof that the conflict has been resolved. The Human Resources Department can assist in exploring appropriate compliance measures.

In a situation where the conflict has been ongoing and/or the Employee did not disclose the conflict, disciplinary action up to and including termination may result.

Although the principles above refer only to Employees of the Company, Employees must also exercise care to avoid actual or potential conflicts of interest that may arise because of the activities of their immediate family members and other members of their household.

5.8 Whistleblowing

5.9 Personal Benefits, Gifts, Bribes and Kickbacks

ONxpress’ values its reputation for integrity and every Employee must deal with customers, suppliers and other third parties in a way that maintains and does not impair that reputation. At the same time, ONxpress wishes to maintain strong working relationships, including acceptable hospitality, business courtesy and social conduct. Employees may not use their position as an Employee of the Company to derive or secure any personal, financial or other benefit for themselves or their relatives. An Employee may not solicit and/or accept any gift or favour from or on behalf of any competitor, current or prospective supplier, customer, subcontractor, competitor, or any public official, or their representatives, except to the extent customary and reasonable in amount and not in consideration for any improper action by the recipient. Finally, the offering or accepting of bribes, payoffs or kickbacks made directly or indirectly to obtain an advantage in a commercial sense are strictly prohibited.

Employees are required to make all reasonable efforts to comply with this requirement.

Full and immediate disclosure to ONxpress’ management of suspicious, unusual, or questionable cases will always be taken as an indication of good faith compliance with the Code.

Employees shall not step out of their official roles to assist private entities or persons to obtain preferential treatment in their dealings with ONxpress.

Employees shall not act, after they leave the employment of ONxpress, in such a manner as to take improper advantage of their previous employment with the Company, nor because of such prior employment to cause others to receive preferential treatment by ONxpress.

5.10 Politics and Political Parties

ONxpress leaves decisions about individual expressions of political activity, on their own time, as personal, voluntary matters for its Employees. No untoward relationships or endorsements will be raised or implied that inappropriately link the Company to such personal political beliefs or practices.

Employees who engage in individual expressions of political activity are expected to do so on their own personal time and to not use Company facilities, equipment, or resources to support such activities. Partisan politics at the local, provincial, or federal level are not to be introduced in the workplace.

5.11 Family and Other Personal Relationships

Employees should be aware of family members employed by ONxpress and should not be seeking to transfer to an area where a direct or indirect reporting relationship between family members would exist or could potentially exist. It is the obligation of the Employee to inform the Human Resource Department of any newly formed relationship which may lead to a violation.

5.12 Community Activity

ONxpress supports Employees who take part in community activities. However, Employees must be mindful that such service may at times, place the Employee in a real or perceived conflict of interest situation which could result in the Employee being deemed non-compliant with the Code.

5.13 Donations / Sponsoring

The granting of any donations must always be transparent, documented and in compliance with this Code. Donations may be made only on a voluntary basis and not in anticipation of any consideration in return. In principle, we do not make political or religious donations.

5.14 Intellectual Property

Intellectual property is comprised of, but is not limited to, trademarks, domain names, patents, designs, ideas, processes, copyrights, inventions, and data. Employees and contractors have a duty to protect the ONxpress’ intellectual property. Subject to applicable laws, any inventions, discoveries, or improvements made by Employees during the course of their work at ONxpress is and shall become the property of the Company.

5.15 Insider Trading

Employees are not permitted to use any information which they receive in the course of their work for ONxpress and which is not in the public domain in order to achieve financial or commercial benefits for themselves or for third parties.

5.16 Fraud

Fraud includes a deliberate false misrepresentation or deception that is intended to result in unfair or unlawful financial or personal gain. Fraud will typically involve a dishonest act or omission in an attempt to gain some personal benefit or advantage (or to gain some personal benefit or advantage for a family member or friend). It can also include the abuse of authority, assigned to, or entrusted upon, an individual by ONxpress, to achieve an improper end. Any suspected incidents of fraud should be immediately reported for investigation in accordance with the procedures set out under the heading “Duty to Report” below.

5.17 Duty to Report

Employees who are confronted with a situation where further guidance is required should discuss the matter with, and Employee who know of or suspect that a violation of this Code or of any applicable laws or regulations has been or is likely to be committed have an obligation to immediately report this information to, as the case may be and where that person is available, as follows:

(a) In the case of a situation that does not involve management of the Company (Human Resource Department);

(b) In the case of a situation that involves management of the Company (Head of Legal – PCo).

No Employee will be subject to retaliation by the Company for reporting, in good faith, a violation or likely violation of this Code. An Employee may make a report anonymously, in which the Employee should write a letter and include as specific details as possible, including back-up documentation where feasible, in order to permit adequate investigation of the concern or conduct reported. Vague, nonspecific or unsupported allegations are inherently more difficult to pursue. All reported violations will be promptly investigated and treated confidentially to the extent possible. Employees are expected to cooperate fully in internal investigations of misconduct.

5.18 Disciplinary Action

Employees of ONxpress must follow the Code and comply with ONxpress policies and the law while conducting business on behalf of the Company. If an Employee violates the Code, ONxpress’ policies, or the law, it may result in disciplinary action up to and including termination of employment.

6. MONITORING AND REVIEW

This Code will be reviewed as necessary and at least once every year. The Chief

Human Resource Officer, or successor thereof, is responsible to monitor and

review this Code.

7. REFERENCES

Ontario Human Rights Code

Occupational Health and Safety Act

Business Travel Policy

Conflict-of-Interest Policy

Respect in The Workplace Policy

Corporate Health and Safety Policy

ONXPRESS TRANSPORTATION PARTNERS, is committed to supporting our employees' overall well-being, including their mental health. We offer a comprehensive Employee Health and Wellness program that provides access to professional resources, educational materials, and benefits, including their spouses, and dependents. The organization’s Employee Assistance Plan (EAP) provides support during difficult life events.

We also encourage our employees to participate in our sponsored events, and to prioritize their personal health and wellness.

ONXPRESS TRANSPORTATION PARTNERS understands that maintaining emotional resiliency and well-being is crucial for everyone. The Canadian Mental Health Association offers practical advice, articles, and information, while Mental Health Services - Canada provides support for those in crisis, including Indigenous peoples, veterans, Canadian Armed Forces members, and federal employees.

Your Primary Health Care Provider is also an excellent resource and can assist you with your health needs, including connecting you with appropriate support and access to specialist health care providers. Taking Control of Your Mental Health: Tips for Talking with Your Health Care Provider

Community resources

• Wellness Together Canada
• Free online resources, tools, apps and connections to trained volunteers and qualified mental health professionals when needed. You can also access educational resources and immediate support crisis lines.

Government of Canada Mental Health and Wellness Resources

Learn about mental health related services in Canada. Find ways to improve your mental health at work and in your daily life and identify which factors protect or put your mental health at risk.

ONxpress vision of health & safety excellence is committed to ensuring all reasonable precautions are taken to protect employees, subcontractors, partners, clients, the public, property, and the environment from any health and safety risks arising out of, linked with, or occurring in the execution of our business activities. Safety is our #1 core value. We take great pride in ensuring our workers return home safe every day, and demonstrate our commitment by:

• Engaging our leadership at all levels to ensure clear roles and responsibilities for the advancement of our Health & Safety Management System and its annual objectives.
• Developing a culture that engages and empowers our workforce to identify, report and control any physical or psychological hazards that are critical to their personal health and safety.
• Proactively identifying, assessing, controlling and eliminating risks by responding to inquiries, conducting audits and inspections, working closely with our employees, Joint Health & Safety Committees (JHSC) and Health and Safety representatives, and supporting training and learning opportunities to ensure a competent workforce to execute our work safely.
• Providing the time, budget and resources needed to ensure each employee is competent for the job they are performing, is aware of EHS Management System requirements and their responsibilities.
• Meeting or exceeding the legislative and other requirements in the jurisdictions in which we operate.
• Continuously improving our Health and Safety Management System through results analysis, the sharing of lessons learned, benchmarking, innovation, feedback, to review and set annual objectives including the development and implementation of action plans.

All ONxpress employees are required to fully support and actively participate in the ongoing implementation of this policy.

1. PURPOSE

ONxpress Transportation Partners Inc. (the “Company” or “ONxpress”) is committed to treating all people in a way that allows them to maintain their dignity and independence. We believe in integration and equal opportunity. We are committed to meeting the needs of people with disabilities in a timely manner and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). We strive to operate our business in a manner that respects the dignity and independence of persons with disabilities.

The purpose of this accessible customer service policy (the “Policy”) is to set out the principles that guide ONxpress on its path to accessibility through compliance with the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) and, in particular, its Integrated Accessibility Standards (Ontario Regulation 191/11). The AODA and its standards are not a replacement or substitution for the requirements of the Human Rights Code (Ontario).

2. SCOPE

This Policy applies to all Employees of ONxpress (including for certainty Seconded employees while seconded to ONxpress) as well as persons who provide goods, services or facilities on behalf of ONxpress. For clarity, this Policy does not apply to the Company’s affiliates or shareholders. Additionally, this Policy applies to ONxpress’ provision of goods and services in Ontario to its customers, members of the public and other applicable third parties. This Policy will be implemented in accordance with the timeframes established by the Integrated Accessibility Standards.

3. COMMITMENT STATEMENT

ONxpress is committed to identifying and meeting the accessibility needs of persons with disabilities in an effective, appropriate, and timely manner through compliance with the Integrated Accessibility Standards. ONxpress’ goal is to foster an inclusive organizational culture that is guided by the principles of the AODA and the Integrated Accessibility Standards, which include: (i) dignity; (ii) independence; (iii) integration (except when alternate measures are necessary to meet the needs of people with disabilities); and (iv) equal opportunity.

ONxpress strives at all times to provide its goods and services to the public and applicable third parties in a way that respects the dignity and independence of persons with disabilities. ONxpress is also committed to giving persons with disabilities the same opportunity to access and benefit from its goods and services as other members of the public.

4. DEFINITIONS

Accessible formats are formats that are an alternative to standard print and are accessible to people with disabilities. They may include, but are not limited to large print, recorded audio and electronic formats, Braille, and other formats usable by persons with disabilities.

Accommodation means the special arrangement(s) made, or assistance provided, so that persons with disabilities can participate in the experience available to persons without disabilities, subject to reasonable limits prescribed by the Ontario Human Rights Code. Accommodation will vary depending on an individual’s unique needs.

Communications supports are supports that individuals with disabilities may need to access information. They may include, but are not limited to, captioning, alternative and augmenting communication supports, plain language, sign language, and any other supports that facilitate effective communications.

Assistive Devices are auxiliary aids such as communications aids, cognition aids, personal mobility aids, and medical aids (e.g. canes, crutches, wheelchairs or hearing aids).

Disability according to the Ontario Human Rights Code, as referenced by the AODA means:

• any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
• a condition of mental impairment or a developmental disability;
• a learning disability or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
• a mental disorder; or
• an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Employees – mean all salaried, full-time employees of the Company and includes Seconded Employees.

Persons with Disabilities – are individuals who have a disability as defined under the Ontario Human Rights Code.

Seconded Employee – means an employee of an affiliate of the Company who has temporarily been seconded to the Company to meet an operational need, training/learning aim, career development purpose and/or knowledge transfer purpose.

Service Animals – are animals used by a person with a disability for reasons relating to their disability.

Support Persons – are means, in relation to a person with a disability, another person who accompanies the person with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods, services or facilities.

5. PROCEDURES

5.1 Accessibility Policy

ONxpress has prepared and will maintain this Policy to describe the principles that  guide our path to accessibility as an organization and identify what ONxpress will do to meet the requirements of the Integrated Accessibility Standards.

5.2 Providing Goods and Services to Persons with Disabilities

 ONxpress is committed to excellence in serving all clients, including persons with disabilities. It will provide its services and communicate with customers, members of the public and applicable third parties to whom it provides goods and services at its Ontario premises, if any, in a manner that takes into account a person’s disability. In particular:

Communication: The Company recognizes that persons with disabilities may require the use of assistive devices. As such, the Company will take all reasonable measures to ensure that its premises are conducive to the use of such devices. ONxpress employees will make all necessary accommodations, up to the point of undue hardship on the Company, to enable clients to use assistive devices as required to access its services. Further, we will be trained and familiar with various assistive devices that may be used by clients with disabilities while accessing its services.

Telephone services: The Company is committed to providing fully accessible telephone service to our clients. We will train employees to communicate with clients over the telephone in clear and plain language and to speak clearly and slowly. The Company will offer to communicate with clients by e-mail, or letter if telephone communication is not suitable to their communication needs or is not available.

Assistive devices: The Company is committed to serving persons with disabilities who use assistive devices to obtain, use or benefit from our goods and services. ONxpress will ensure that our employees are trained and familiar with various assistive devices that may be used by clients with disabilities while accessing our goods or services.

Billing: The Company is committed to providing accessible invoices to our client if needed.

5.3 Use of Service Animals and Support Persons

ONxpress is committed to welcoming persons with disabilities who are accompanied by a support person. Any person with a disability who is accompanied by a support person will be allowed to enter ONxpress’ premises with his or her support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on our premises. Permission will be obtained from the person with the disability prior to a discussion of a confidential nature taking place with the support person present. To the extent permitted by law, the Company will also be sensitive to any accommodations that may be necessary as a result of the use of a service animal.

When ONxpress’ employees cannot easily identify that an animal is a service animal, employees may ask a person to provide documentation (letter or form) from a regulated health professional that confirms the person needs the service animal for reasons relating to their disability. A service animal can be easily identified through visual indicators, such as when it wears a harness or a vest, or when it helps the person perform certain tasks. In cases where a service animal is excluded by law from the premises, the Company will ensure that other measures are available to enable a person with a disability to obtain, use or benefit from the provider’s goods, services or facilities.

5.4 Notice of Temporary Disruption

ONxpress will provide appropriate parties with notice in the event of a planned or unexpected disruption in the facilities or services provided by ONxpress which are usually used by persons with disabilities, if any. This notice will include information about the reason for the disruption, the anticipated duration, and a description of alternative facilities or services, if available. The notice will be placed at all public entrances and reception counters on our premises.

5.5 Training for Employees

ONxpress will ensure that the following persons receive training about its goods, services, or facilities, as the case may be, to persons with disabilities:

(a) all of its employees and volunteers;

(b) all persons who participate in developing ONxpress’ policies; and

(c) all other persons who provide goods, services or facilities on behalf of ONxpress.

Training will include a review of the purposes of the AODA and the Integrated Accessibility Standards as well as instruction about the following:

• How to interact and communicate with persons with various types of disabilities;
• How to interact with persons with disabilities who use an assistive device or require the assistance of a service animal or a support person;
• How to use equipment or devices available on ONxpress’ premises or otherwise provided by ONxpress that may help with the provision of goods, services or facilities to a person with a disability; and
• What to do if a person with a disability is having difficulty in accessing ONxpress’ goods, services or facilities.

Employees will also be trained on an ongoing basis when changes are made to these policies, practices, and procedures. New employees will also be provided with such training upon hire.

Where third parties are engaged to perform services in Ontario on behalf of ONxpress, ONxpress may require that such third parties provide an acknowledgement that their principals, employees, agents and volunteers receive any applicable training required by the AODA.

5.6 Employment

ONxpress’ policies and practices are intended to build an inclusive and accessible work environment that is free from discrimination and harassment.

• Recruitment: In our recruitment processes, ONxpress will advise our employees and the public about the availability of accommodation for applicants with disabilities.
• Recruitment, Assessment or Selection Process: ONxpress will notify job applicants, when they are individually selected to participate further in an assessment or selection process, that accommodations are available upon request in relation to the materials or processes to be used. If a selected job applicant requests accommodation relating to their participation in the hiring process, ONxpress will consult with the individual and provide or arrange for the provision of suitable accommodation that takes into account the applicant’s disability-related needs.
• Notice to Successful Applicants: When making offers of employment, ONxpress will notify successful applicants of our policies for accommodating employees with disabilities.
• Informing Employees of Supports: We will notify our employees of ONxpress’ policies (and any updates to those policies) for supporting employees with disabilities, including our policies regarding the provision of job accommodations that take into account an employee’s accessibility needs due to disability. This information will be provided to new hires as soon as practicable after they commence employment.
• Accessible Formats and Communication Supports for Employees: If an employee with a disability asks for information in an accessible format or to receive communication supports, ONxpress will consult with the employee to provide, or arrange for the provision of, accessible formats and communication supports for information that the employee needs to perform his/her job, as well as information that is generally available to other employees. In determining the suitability of an accessible format or communication support, ONxpress will consult with the employee making the request.
• Workplace Emergency Response Information: ONxpress will provide individualized workplace emergency response information to employees with disabilities where the disability is such that individualized information is necessary and ONxpress is aware of the need for accommodation. ONxpress will provide workplace emergency response information as soon as practicable after learning of the need for accommodation due to an employee’s disability. Where an employee who receives individualized workplace emergency response information requires assistance, ONxpress will designate a person to provide assistance and, with the employee’s consent, ONxpress will provide the workplace emergency response information to such person. ONxpress will review individualized workplace emergency response information, at minimum, whenever:

- the employee moves to a different location within ONxpress,

- the employee’s overall accommodation needs or plans are reviewed, or

- ONxpress reviews its general emergency response policies.

• Performance Management, Career Development and Advancement & Redeployment: ONxpress will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting performance management, providing career development and advancement to employees, or when redeploying employees.
• Documented Individual Accommodation Plans: ONxpress will develop and maintain a written process for the development of documented individual accommodation plans for employees with disabilities. If requested, information regarding accessible formats and communications supports provided will also be included in individual accommodation plans. Additionally, the plans will include individualized workplace emergency response information (where required). Plans will also identify any other accommodation that is to be provided.
• Return to Work Process: ONxpress will develop and maintain a documented return to work process for its employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work. The return-to-work process will, as part of the process, outline the steps that ONxpress will take to facilitate the return to work and will include documented individual accommodation plans. This return-to-work process will not replace or override any other return to work process created by or under any other statute (for example, the Workplace Safety and Insurance Act, 1997).

5.7 Questions about this Policy

This Policy exists to achieve service excellence for all customers, including people with disabilities. If anyone has a question about the Policy, or if the purpose of the Policy is not understood, questions may be posed to ONxpress Human Resources

5.8 Feedback Process

An ultimate goal of ONxpress is to meet or surpass customer expectations while serving all clients, including people with disabilities. Comments on how our goods and services are provided to persons with disabilities in Ontario are welcome and appreciated. ONxpress will continue to ensure that its processes for receiving and responding to feedback are accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communications supports, upon request. Members of the Public, our Client and Third Parties may provide feedback via various methods

Mail: ONxpress Project Co. Human Resources Department

130 Adelaide St West, Toronto ON M5J 2T3

Email: communications@onxpress.com

The feedback and complaints processes has been developed in inclusive modes, catering to the needs of persons with accessibility needs due to disabilities.

When complaints and/or feedback are received, they will follow the usual path of being responded to, as quickly as practicably possible.

ONxpress will make best efforts to acknowledge all complaints within 7 business days.

5.9 Notice of Availability of Documents

This document is posted on ONxpress’ website in an accessible format. ONxpress will post a notice on the Company website for any changes to the procedures, practices, or policies.

ONxpress will provide this document in an accessible format or with communication support, on request. We will consult with the person making the request to determine the suitability of the format or communication support. We will provide the accessible format in a timely manner and, at no additional cost.

6. MONITORING AND REVIEW

This Policy will be reviewed as necessary and at least once every year. The Chief Human Resource Officer, or successor thereof, is responsible to monitor and review this Policy. No changes are made to this Policy before first considering the impact on persons with disabilities. 7.

7. REFERENCES

Ontario Human Rights Code Employment Standards Act, 2000 Accessibility for Ontarians with Disabilities Act, 2005 O. Reg. 191/11 – Integrated Accessibility Standards under Accessibility for Ontarians with Disabilities Act, 2005

ONxpress is committed to an inclusive culture that fully enables all Employees to be authentic and to tap into their full potential. The Company recognizes that people bring different qualities, abilities, skills, knowledge, experiences, perspectives, and attitudes to work and that valuing and making the most of these differences can improve the workplace for individuals and enhance our overall performance.

All Employees are expected to demonstrate behaviours that create an inclusive environment in which all people are heard, respected, valued and able to bring their full selves to our workplace.

In line with our commitment to creating a workplace which is free from harassment, violence, and safety risks, all those covered by this Code are expected to observe minimum standards of behaviour that include but are not limited to:

Being polite and courteous to others
Being respectful of the differences between people and their circumstances
Ensuring that we do not assist, or encourage others, in the workplace or in connection with the workplace, to engage in discriminating behaviour of any type.
Reporting any harassing or discriminating behaviour in the workplace, or connected with the workplace, in accordance with the complaint procedure as outlined in the Respect in the Workplace - Harassment Policy or in accordance with the procedures set out under the heading “Duty to Report” below.

Reporting any workplace violence in accordance with the complaint procedure as outlined in the Respect in the Workplace - Violence Policy or in accordance with the procedures set out under the heading “Duty to Report” below.

Respecting the confidentiality of information regarding ONxpress’ Employees, including but not limited to information arising from investigations pursuant to the Respect in the Workplace - Harassment Policy

To learn more about our workplace policies please click here.