Code of Ethics
To all Directors, Officers, and Employees of Israel Canada (T.R.) Ltd. and related companies:
Introduction
Israel Canada (T.R.) Ltd. is a public company whose shares are traded on the Tel Aviv Stock Exchange. The Company operates directly and indirectly through subsidiaries and associate companies in a large number of real estate projects. This document specifies the principles of ethical conduct in the Company and details the Company's policy in relevant areas. The Code of Ethics and Rules of Business Conduct set forth below bind all Directors, Officers, and Employees of Israel Canada (T.R.) Ltd. and its related companies (collectively, hereinafter: "Israel Canada" or "the Company").
Code of Ethics
1. Professionalism, Excellence, and Responsibility Towards Customers
The success of the Company depends on its ability to provide its customers with a high level of service experience and customer satisfaction with the Company's products and services.
The Company's relationships with its customers are long-term relationships based on trust, integrity, professionalism, and mutual respect.
Professionalism and excellence must be maintained at all times, thereby ensuring a high level of achievement and the satisfaction of the Group's customers.
The utmost efforts must be made to provide the Company's customers with products of a high standard and quality, as well as personal and professional service, and to justify the great trust the Company's customers place in it.
The Company operates and will operate to be the preferred choice for its customers, a choice based on quality and service at the highest standards it provides to its customers.
Service provision shall be carried out through continuous improvement, identification of customer needs, provision of substantive and appropriate responses, provision of full and clear information, and strict adherence to the preservation and advancement of the professional knowledge and skills of every Company employee.
2. Business Integrity
The success of the Company depends on its ability to stay ahead of its competitors. However, not all means are legitimate to achieve this goal, and even under constraints of severe competition, the Company must conduct itself with fairness, integrity and strict adherence to ethical rules.
The Company has a reputation as a decent, fair, and honest company, and in order to continue and maintain the Company's good name among customers, partners, competitors, and the public, every employee is obligated to strictly adhere to the following principles of conduct:
Fairness towards customers - Customers and partners must be treated equally and fairly. If a conflict arises in the market among several partners or customers, it must be resolved based on equality and fairness, while safeguarding the long-term interest of the Company.
Integrity and trust - False information regarding the Company, its strategies and work techniques, its products, their quality, and other business aspects must not be provided to customers, partners, the press, or the public, with the intention to deceive or misrepresent.
Unfair competition - False, misleading, or defamatory information regarding competitors and their businesses in matters such as their stability, financial position, capabilities, product quality, or reliability as suppliers must not be disseminated. Misuse of commercial secrets or classified business information of competitors must be avoided.
Avoidance of political activity - Company funds or equipment provided to the employee for work purposes must not be used to support political activity of any kind.
3. Full and Fair Disclosure
The Company is a public company whose shares are traded on the Tel Aviv Stock Exchange. This requires bringing to the attention of the Company's shareholders, potential investors, and the public as a whole any material information or information regarding significant events or developments in connection with the Company, as well as any other information required by law, and requires that reporting to the Israel Securities Authority, the Stock Exchange, the shareholders and the public be accurate and provided in a timely manner.
The Company is committed to ensuring that public announcements required by law are brought to the public's attention in accordance with the provisions of the law, and that the Company's financial statements reflect the Company's decisions and its business position.
4. Compliance with Applicable Law
The Company and all those affiliated with Israel Canada are required to strictly comply with all laws, regulations, and rules applicable in Israel and in other locations around the world where the Company operates.
5. Avoidance of Conflicts of Interest
When making and/or executing decisions, the benefit of the Company must be considered, and considerations of personal or group benefit, or considerations arising from personal relationships, must be avoided. Furthermore, activities that may create a conflict of interest between an employee and the Company must be avoided.
Examples of conflicts of interest:
Business opportunities – Generating personal profits or assisting others in generating profits from business opportunities that were discovered utilizing the Company's business information, or by virtue of an employee's role in the Company.
Business relationships with other companies – Conducting private business with the Company's customers, partners, suppliers, or competitors. Investing time and resources in any external business activity that consumes an employee's time.
Personal relationships with other entities – Making decisions on matters related to the Company's relations with another entity, when personal relationships (family, friends) exist with the other party, without obtaining the required approvals.
6. Prohibition on Use of Inside Information
During an employee's employment with the Company, "material non-public information" regarding the Company may come to the employee's attention. In such a case, restrictions apply to the employee concerning the exploitation of the information for the purpose of trading in the Company's shares. As a rule, this means that the employee is legally precluded from trading in the Company's shares, or from conveying recommendations based on this information to any person, including family members and acquaintances, unless this information becomes public knowledge, or alternatively, with the passage of time, becomes obsolete and valueless.
Information is not "public knowledge" if it has not been included within the framework of an immediate report by the Company or any other public document. "Material" information is any information in connection with the business and affairs of the Company that causes, or that can reasonably be expected to cause, a change in the price of the Company's securities or their market value, or information that a reasonable investor is highly likely to consider important for the purpose of making investment decisions.
7. Anti-Bribery and Anti-Corruption
The Company shows zero tolerance for cases of corruption in business with suppliers, customers, or various officials of authorities and government, for which the Company has adopted a broad definition of the term: any person holding a constitutional, administrative, or judicial position of any kind, whether appointed or elected, and whether directly or indirectly by the government; including a member of a political party, and any candidate for any government office, as well as any senior officer, manager, agent, or employee of a government-owned or government-controlled entity.
The Company requires its employees to act with full transparency and in accordance with the strictest rules, including consultation and reporting on any knowledge or suspicion of unethical conduct.
8. Respect for Employees
Every employee enjoys fundamental basic rights as well as rights granted to them under various labor laws, and must be treated with respect, equality, and appreciation. Every employee is entitled to freedom of thought, conscience, religion, and expression of opinion, as long as it does not infringe upon the feelings or rights of other employees. The Company is committed to giving respect to every employee and equal opportunity to every candidate in all areas of work, in appointment to positions, and in professional advancement. The Company prohibits discrimination based on age, race, ethnicity, gender, religion, disability, sexual orientation, marital status, political opinion, or reserve service.
9. Code of Conduct during the Performance of Work
Proper conduct and honorable representation of the Company must be strictly maintained.
Company employees should treat other employees, and any other party with whom they interact with, with politeness, tolerance, and respect.
Employees shall perform their work professionally, efficiently, and reliably, in accordance with their authority and with cooperation among the employees and the various units in the Company.
10. Prevention of Harassment
The Company views negatively and will ensure that behaviors of verbal violence, physical violence, or any other type of harassment and threat, are handled. The Company's employees undertake to act in accordance with the regulations for the prevention of sexual harassment published in the Company.
11. Use of Company Assets
The Company has material, business, commercial, and other assets. Any use of the Company's assets shall be carried out legally and ethically, solely for the purpose of the Company's business advancement.
12. Privacy
Many countries have applied, or intend to apply, laws and regulations aimed at maintaining privacy of information and establishing the requirements for the handling and retention of private information (any information that enables the identification, location, or contacting of an individual).
The Company is committed to reasonably safeguarding the privacy of anyone with whom it does business, including customers, suppliers, and employees.
13. Community Involvement
The Company attaches great importance to the connection with the community and is careful to contribute to various needs. The Company views favorably volunteer activities of the Company's employees in various projects for the community, which are consistent with the Company's social commitment.
14. Consultation with Relevant Parties in the Company
In cases where there is doubt regarding the decision to be made or the course of action to be taken, the employee required to make the decision must consult with the relevant parties in the Company, whether they are superiors or the relevant professional authority.
15. Implementation of the Code of Ethics
Enforcement of the provisions of this Code - Every Director, Officer, and Employee shall be personally responsible and obligated to comply with the provisions of this Code. The Company will take appropriate disciplinary measures in the event of a breach of the provisions of this Code. Disciplinary measures may also be applied against the manager responsible for the violation of the Code's provisions, in the event the Company determines that a flaw also occurred in the behavior or omission of this party.
If an employee becomes aware of, or has a reasonable suspicion of, any violation of laws, regulations, or rules applicable to the Company, of the provisions of this Code, or of the provisions of other Company policy, including evidence of fraud occurring within their field of operation or in the department where they work, pertaining to any employee or representative of the Company, they are obligated to report this information immediately to their supervisor, or to the appropriate officer, or to the Internal Auditor, or to the Appointee for the Code of Ethics, as deemed appropriate.
The Appointee for the Code of Ethics - The Company's Board of Directors appointed Mr. Guy Kende (hereinafter: the "Appointee") as the Appointee for the operation of the Code of Ethics in the Company (including subsidiaries). The Appointee is at the disposal of employees for direction, training, guidance, and advice in everything involved in proper conduct according to the rules of the Code of Ethics. Furthermore, for anonymous inquiries, employees may also contact the Internal Auditor of the Company, CPA Haim Halfon, Amit, Halfon & Co. Firm, Hashahar Tower, 15th floor, 4 Ariel Sharon Street, Givatayim, Zip Code: 5320047, Telephone: 03-6123939, Fax: 03-6125030, Email: haim@ahcpa.co.il
Distribution of Information – A document will be distributed to all employees, and new employees will receive a copy upon signing the employment agreement, and will confirm by their signature, prior to the commencement of their work in the Company, that they have read the Company's Code of Ethics and undertake to act in accordance with it.