Ethics and Compliance

Adopted by our Board of Directors and updated in 2020, our Ethics Code of Conduct applies to everyone across the ACT network, employees, executive officers, members of our Board of Directors, consultants, intermediaries, lobbyists and anyone working on our behalf. Together, we are building a company where people want to work, grow and succeed – and that is something we can all be proud of.

The Ethics Code of Conduct contains rules and guidelines for personal conduct and ethical behavior at ACT. We have based it on our values, and the laws, regulations and rules, both local and global, that apply to our business.

ACT With Respect

Respect is at the heart of all that we do – how we interact with our customers, each other and the world around us. No matter where we are in the world and which logo we wear, this is part of what defines us, and what has helped us welcome so many people into the Alimentation Couche-Tard / Circle K (“ACT”) family as we have grown over the last 40 years.

Whistleblower Policy and Procedures

Adopted by our Board of Directors, the purpose of the Whistleblower Policy and Procedures is to ensure that all directors, officers and employees have the means to report complaints or concerns regarding material financial matters, compliance with legal and regulatory requirements and violations of the Corporation’s Ethics Code of Conduct, while at the same time providing protection against retaliation for reports made in good faith.

The procedures set forth in this Policy set forth how and where to submit a complaint or concern, who deals with a complaint and how that complaint will be handled, processed and documented. This Policy also describes the standards and principles that will govern the processing of all complaints and concerns whether they are received from people within the Company or external parties.

ACT Hotline

Your voice matters in protecting and nurturing our culture of respect. It is important to speak up about unethical or inappropriate behaviour that could harm our people or our business. Reports can be made anonymously by contacting our ACT Hotline using a local toll-free number or via the web. If you share your identity and contact information, this information will be kept confidential to the extend it is possible to do so, consistent with applicable federal and/or local law and the need to conduct a thorough investigation. The information you provide will be relayed to the proper ACT resource for follow-up.

Compliance

Our Human Resources and Corporate Governance Committee is responsible for monitoring compliance with our Ethics Code of Conduct. All management level and above employees undergo an annual certification process, and all new employees are required to read and sign the Ethics Code of Conduct as part of their onboarding process.