STORM CARES – CORPORATE RESPONSIBILITY POLICY

PURPOSE
Storm Internet Services (“Storm”) is built on a foundation of trust and maintaining positive relationships with its clients, employees, contractors and suppliers within the communities in which we operate. We recognize the reach of our business and we take our role as a responsible corporate citizen seriously, seizing opportunities to change people’s lives for the better. This Corporate Responsibility Policy (the “Policy”) outlines our commitment to achieving the highest standards of corporate citizenship and provides a set of core principles that apply to our employees. We deliver on these commitments and bring these principles to life through our Storm Care (Corporate Responsibility) Program.

FIVE ESSENTIAL PARTS OF STORM CARES
STORM CARES is supported by the five essential parts described below:

  • Our People. We respect the dignity and fundamental human rights of our employees. We are committed to providing a safe, supportive, and inclusive work environment in which all individuals are treated with dignity. We provide equal opportunity in employment based on individual merit and personal qualifications and we prohibit unlawful discrimination or harassment of any kind. We invest in programs to engage and energize our employees, and we support and reward their career development.
  • Our Community. We are committed to making a difference in our communities in which we service. We proudly contribute financially to organizations and causes that we believe will have a significant impact on the greater public good. We believe that donating our time, talent, and resources is equally as important. In that regard, we provide a work environment that presents opportunities for our employees to volunteer in local communities.
  • Our Ethics and Compliance. Storm promotes high ethical standards, institutional integrity, and effective corporate governance throughout our organization. Our values and culture inspire our people and guide them to do the right thing. We are committed to conducting ourselves in a legal, ethical, and trustworthy manner, and complying with both the letter and spirit of our business policies.
  • Our Environmental Sustainability. We recognize the importance of protecting the natural environment and our shared responsibility in addressing critical environmental issues facing the planet. Opportunities to reduce our environmental impact include using resources efficiently, minimizing waste, preferentially purchasing products that can demonstrate reduced life cycle impacts and fostering a culture of environmental sustainability.
  • Our Procurement and Use of Third Party Vendors. We rely on the services and products of many different vendors to help us meet the needs of our business. Our expectations for ethical practices reach beyond our employees and extend to our contractors and vendors. We seek to develop and strengthen partnerships based on transparency, collaboration and mutual respect. Although we understand that our vendors are independent businesses, the actions of our business partners can be attributed to our Company and affect our reputation and the level of trust we earn from our clients.

SUPPORTING POLICIES AND PROCEDURES
Storm has implemented a range of policies and procedures that establish clear performance expectations for responsible business conduct in our organization, including the following:

Corporate Governance Guidelines. Our Corporate Governance Guidelines provide a set of governance guidelines to promote the functioning of our Board of Directors and Advisory Committee. These guidelines also set forth a common set of expectation as to how our Board should perform its functions with integrity while delivering value to our clients and stakeholders. The Board regularly reviews Storm’s governance policies and practices.

Human Rights Statement. Storm supports fundamental principles of human rights throughout its business.

Privacy Policy. Storm provides telecommunications services to clients including internet access services. Throughout Storm’s interactions with Clients and Employees, we are committed to respecting the privacy, confidentiality and security of personal information. Our Privacy Policy is a formal statement of principals and guidelines that govern our practices and ensure that we meet and, wherever possible, exceed the requirements of the Personal Information Protection and Electronic Document Act, the privacy rules established by the Canadian Radio-Television and Telecommunications Commission (“CRTC”) and all other applicable federal and provincial laws and regulations. Storm will continue to review its Privacy Policy on an on-going basis to ensure that it remains current with evolving technology and the needs of Storm, its Clients, its Employees and the public at large.

Workplace Violence and Harassment Prevention Policy and Program. Storm is committed to providing employees with a positive working environment free from any form of hostile, offensive, intimidating, discriminatory or harassing conduct. We provide a process for the confidential filing of complaints regarding such conduct and conduct proper and timely investigation of any such complaints.

Updated: February 16, 2021