Anti-Corruption & Anti-Bribery Policy

Effective Date: 04/01/2024

Approved By: Jason Levesque, President, Adirondack Information Management Inc. (Adirondack)

Review Cycle: Annually or as required by legislative change

1. Purpose

This Anti-Corruption and Anti-Bribery Policy (“Policy”) establishes the standards of conduct expected of all employees, contractors, officers, and representatives of Adirondack (“the Company”). The Company is committed to conducting business ethically, transparently, and in full compliance with all applicable anticorruption and anti-bribery laws, including the Canadian Corruption of Foreign Public Officials Act (CFPOA), the Criminal Code of Canada, and equivalent legislation in jurisdictions in which we conduct business. As a supplier of knowledge-based consulting services to the Government of Canada, and as a partner/reseller to large technology firms, the Company maintains zero tolerance for bribery, improper influence, or corrupt practices of any kind.

2. Scope

This Policy applies to:

  • All employees, contractors, subcontractors, directors, officers, and agents of the Company.
  • All business activities, whether domestic or international.
  • All interactions with clients, government officials, public-sector representatives, vendors, suppliers, distributors, and partners.

3. Policy Statement

The Company strictly prohibits:

  1. Offering, giving, soliciting, or receiving any bribe, kickback, or improper payment.
  2. Attempting to influence any decision-maker—especially government employees or officials—through gifts, hospitality, or anything of value.
  3. Using third parties (consultants, agents, intermediaries) to engage in conduct that would be prohibited if performed directly by the Company.
  4. Facilitating payments, “speed payments,” or unofficial payments to secure or expedite routine government actions.
  5. Improper inducements made in connection with procurement, contracting, or partner/reseller relationships.

4. Definitions

  • Bribe: Anything of value offered to improperly influence a decision or gain an unfair advantage. This includes cash, gifts, entertainment, services, employment opportunities, discounts, or donations.
  • Government Official: Any employee or representative of a federal, provincial, municipal, or Indigenous public body, Crown corporation, or international public organization.
  • Facilitation Payment: An unofficial payment made to expedite a routine action by a government official. These are prohibited.

5. Gifts, Hospitality, and Entertainment

The Company recognizes that modest business courtesies may occur in the course of normal business; however:

Permitted

  • Low-value, infrequent hospitality that is transparent, reasonable, and not intended to influence a decision.
  • Promotional items of nominal value (e.g., branded pens, notebooks).

Not Permitted

  • Gifts or hospitality intended to influence, or appearing to influence, a business decision.
  • Any gifts or hospitality offered to Government of Canada personnel, regardless of value, unless permitted under federal ethics rules and pre-approved by management.
  • Cash or cash equivalents (gift cards, vouchers).
All gifts or hospitality above a nominal value (e.g., $50 CAD) must be declared to management and may require prior written approval.

6. Working with Government Clients

Because the Company predominantly provides services to the federal government, all employees and contractors must:
  • Act in full compliance with Government of Canada procurement rules.
  • Avoid any appearance of preferential treatment, undue influence, or conflict of interest.
  • Never offer anything of value to a government official for the purpose of obtaining or retaining work.
  • Report any request for improper payments immediately to management.

7. Working with Technology Partners

The Company maintains business relationships with large technology firms, distributors, and channel partners. When interacting with partners:
  • All engagements must be transparent, documented, and free from improper incentives.
  • Rebates, referral fees, and partner incentives must be openly declared and aligned with written partner agreements.
  • No employee may offer or accept incentives that violate partner policies or applicable laws.

8. Reporting Concerns

Employees, contractors, and partners are encouraged—and required—to report suspected violations of this Policy. Reports may be made directly to:
  • A manager or executive
  • Human Resources
  • The compliance officer (if designated)
Retaliation against anyone reporting in good faith is strictly prohibited.

9. Consequences of Violations

Violations of this Policy may result in:
  • Disciplinary action, up to and including termination of employment or contract
  • Termination of business relationships
  • Civil or criminal liability for the individuals involved
  • Mandatory reporting to government authorities or impacted partners

10. Review and Updates

This Policy will be reviewed annually and updated as necessary to reflect legal requirements, industry standards, and partner compliance expectations.