PURPOSE

TLS is committed to promoting integrity, ethics, accountability, and transparency in what we do. TLS recognizes it is in the best interests of the organization to maintain and enhance public confidence and the relationship with our trusted partners by encouraging the reporting of wrongdoing taking place within TLS and/or our extended supply chain network to designated individuals at the organization.

The purpose of this policy is to provide guidelines for reporting wrongdoing, and to provide reasonable protection from reprisal for those individuals who, in good faith and with reasonable belief, report wrongdoing in accordance with this policy.

SCOPE

This policy applies to all TLS Employees including those that work on a full-time, part-time or temporary basis for the organization, all members of our management team, our broker partners, customers, clients and our trusted retail partners.  Where applicable TLS may be required to share any reports of wrongdoing by suppliers, customers and retail partners through the Grocery Code of Conduct.

VALUES

All TLS policies, including this policy, are based on the core values in our organization. In addition, TLS and our partners adhere to our Code of Conduct (found on our website) which outlines the principles that our company abides by, including the protection of human rights and the prevention of Child and Forced Labour.

TLS expects employees to use proper judgment and act in a way that reflects our core values and company policies. Employees should also support the high standards expected of a corporation established to deliver high quality service to our customers, clients and retail partners. TLS is committed to maintaining an environment where people can raise concerns about improper behavior without fear of reprisal. The effectiveness of these commitments and TLS’ policies, procedures, and directives, are dependent on people being able to report suspected cases of wrongdoing without fear of reprisal for doing so. 

DEFINITIONS

Whistleblower: A person who reports misconduct, unethical behavior, or violations of laws and regulations.

Misconduct: Includes, but is not limited to, fraud, corruption, financial irregularities, harassment, discrimination, safety violations, conflict of interest and other illegal or unethical practices.

Employee: All full-time, part-time employees and temporary employees in the organization.

Reprisal: Actions taken against another person as a direct result or in retaliation for making a report under this policy, being suspected of making a report under this policy, or participating in an investigation under this policy. Reprisal includes harassment, discrimination, intimidation, dismissal, suspension, demotion, discipline, termination, suspension, coercion, discipline, imposition of another penalty, or, in the case of an employee, any other action which adversely affects their working conditions.

Fraud: A dishonest act that results in actual loss or risk of loss, deception, misappropriation of resources, or the manipulation of data to the advantage or disadvantage of a person or entity.

Wrongdoing: any illegal or inappropriate conduct, including but not limited to crime or suspected criminal activity, fraud and/or theft, the wrongful or unauthorized acquisition, use of information, data, materials, labour or equipment, falsification, alteration or manipulation of the corporation’s documents, records or computer files and/or risks to the health and safety of employees or visitors to the facilities.

REPORTING PROCESS

All Employees have a responsibility to report serious violations or breaches of TLS policies and procedures; allegations of criminal activity; and any other misconduct which may be detrimental to the best interests of the organization, our trusted partners and employees in the organization.  Employees are encouraged to report such matters to their manager/supervisors using established channels but may report them anonymously through the Whistleblower Program when they fear reprisal. An independent, objective and impartial investigation of any suspected acts or allegations of misconduct will be conducted, regardless of the Whistleblower’s position, title or length of service or the relationship with any party who might be involved in such an investigation.

REPORTING MECHANISM

Reports of misconduct can be made through the following channels:

Phone: 905-754-3524

Website: https://thomaslargesinger.com

Email: Whistleblower@tlscanada.com OR HR@tlscanada.com

Confidential Drop Box: 7825 Winston Churchill Blvd., Brampton ON, L6Y 5Z4 (main entrance lobby)

An anonymous report can be submitted through a form on the TLS website. The Whistleblower should include as much information as possible, including the nature of Misconduct; which Party/Parties are alleged to be involved (Broker, Client, Customer, Employee, Retail Partner); specific dates, times and locations; and any relevant evidence. 

CONFIDENTIALITY

TLS will make all reasonable efforts to protect the identities of whistleblowers. Where the individual completing the Whistleblower report chooses to share their identity through the reporting process, TLS will take all necessary precautions to ensure the identity of the individual is protected.  The company will not share a whistleblower’s identity, or information that could reasonably be expected to reveal the whistleblower’s identity, with another regulator or law enforcement agency without the whistleblower’s explicit consent.

INVESTIGATION PROCESS

Complaints will be investigated by a member of the Whistleblower Committee, a member of the HR team, and where necessary an independent third-party investigator. Legal Services, in consultation with the Committee, will make this determination. In all cases, an appropriate, qualified independent team will be assigned, and an objective investigation will be conducted.   If additional information is requested during the investigation and the Whistleblower chooses not to participate/respond, the investigator may decide not to investigate further, and the report will be updated accordingly. All individuals are expected to cooperate fully with any investigation.  At the conclusion of each investigation, the investigative team or staff investigator will document the results in a confidential report and provide the report to the President.

COMPLIENCE AND MONITORING

TLS will not tolerate wrongdoing or reprisals against anyone who reports wrongdoing, and all employees have a duty to report suspected wrongdoing. No employee or member of the management team will take any action in reprisal against a Whistleblower for making, or being suspected of making, a report of wrongdoing under this policy. No employee or member of the management team will take any action in reprisal against any person who participates in an investigation under this policy.

An employee who is found to have engaged in reprisal behavior prohibited by this policy shall be the subject of discipline, up to and including dismissal for cause. An employee who knowingly makes a false or misleading report under this policy, or who knowingly makes a false or misleading statement in an investigation under this policy, may be the subject of discipline, up to and including dismissal for cause.  Employees and trusted partners are expected to co-operate fully in an investigation under this policy.

GOVERNING LEGISLATION

• Employment Standards Act
• Ontario Human Rights Code
• Occupational Health and Safety Act
• Criminal Code

An anonymous report can be submitted here through the form below. Please include as much information as possible, including the nature of Misconduct; which Party/Parties are alleged to be involved (Broker, Client, Customer, Employee, Retail Partner); specific dates, times and locations; and any relevant evidence.  If you are comfortable being contacted for more information, please include the relevant contact information below.