Scope 1 Emissions
2022 Communication on Progress
QSL Canada Inc.
Published date
May 31, 2022
No. of questions
65
Supplemental files
CEO Statement
Signed
Governance
Policies and Responsibilities
1. Does the Board / highest governance body or most senior executive of the company:
Optional commentThe board signed off on organizational sustainability targets regarding employee health and safety, and environmental incidents, as well as the timelines for ISO 45001 and 14001 implementations. They also have reviewed a recent PESTEL analysis conducted to assess QSL’s corporate risks, including environmental, social and governance risks.2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Optional commentQSL’s Code of Ethics mentions our commitment to Human Rights, Labour Rights and Anti-Corruption, available to all employees via the QSL Intranet. They are also integrated into collective agreements with QSL’s unionized team members, which are publicly available. Finally, the Sustainable Development policy, dictating QSL’s actions as they pertain to the environment, are available on QSL’s website at the following address: https://qsl.com/commitment/3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Optional commentQSL has a Code of Ethics, mentioning labour and human rights, as well as anti-corruption initiatives. QSL’s Sustainable Development Policy is in place to govern its approach to environmental topics.4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Optional commentQSL’s Environment and Health and Safety dossiers are overseen by the Vice President Compliance, who also sits on QSL’s board. His team is responsible for ensuring that company-wide objectives are met regarding these two topics. Within the VP Compliance’s Environment team, one manager and two coordinators focus on air quality, avoiding environmental incidents, environmental improvement, and waste management. The VP – Human Resources is responsible for ensuring that all employees are trained on and knowledgeable of the QSL Code of Ethics which all employees commit to, and which is overseen by the Human Resources teams.5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Optional commentAlthough there is not a formal committee or structure specifically pertaining to each topic, QSL’s strategy team is comprised of individuals with a diversity of backgrounds, who ensure that all relevant human rights, labour rights, environment or anti-corruption issues are monitored continuously and brought to the attention of the executive and board as necessary.Prevention
6. Does the company have a process or processes to assess risk?
Optional commentThe board assesses risk at the business level (PESTEL) and monitors the most relevant indicators (environmental and health and safety leading and lagging indicators). Furthermore, a weekly meeting is held with all terminal directors and leadership to assess the main risks and any major incidents, in order to mitigate risk in real-time and respond as necessary.7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?
Optional commentFor each operation, a risk analysis is conducted with regards to potential environment and safety incidents, with each incident scored based on its probability. A risk management Standard Operating Procedure is then produced per role, with controls integrated into operations. Within the management system, directors have access to the lists of the most important controls to monitor, as well as real-time key performance indicators. Inspections are integrated into the system, as is corrective action management. QSL is currently improving its inspection action plans and customized operational employee training approach.Concerns and grievance mechanisms
8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?
Optional commentQSL has developed a process to democratize the reporting of dangerous behaviours or non-conformities with regards to employee health and safety and environmental risks. When an incident is witnessed, any employee or on-site individual can scan a QR code and fill in a form detailing the situation. As a result of this program, incident reporting has increased by 800% in 2021 compared to 2020, winning QSL the Occupational health and safety awards at the Quebec Chamber of Commerce Mercuriades business competition in 2022. QSL also has a dedicated email address that all employees can use to bring any problematic matters directly to the attention of the company executive team.8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.
Optional commentThe QR code near miss disclosure system can or can not be anonymous, it is the person choice to put her/his name on the form. The disclosure email address, on the other hand, is not anonymous at this point in time. The QR code near miss disclosure system pertains to the disclosure of any witnessed risky behaviour with regards to labour rights (health and safety) or environmental protection. The role of the QR Code is to raise the number of reports for those kinds of situations and prevent them. We give the opportunity to anybody to report those situations to increase awareness. In regards of incidents reports, it must be raised by QSL Staff only and in most of the time, the initial reporter is the superintendent being the first informed of the incident.9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?
Optional commentIn order to react effectively, information about accidents is passed on to the manager very quickly. Incident report are sent to site managers every 15 minutes allowing them to react preventively. Moreover, a disclosure email is brought to VPs and President for remediation.Lessons
10. How does the company capture lessons regarding each of the following sustainability topics?
Optional commentThe environmental topics are released publicly therefore communication and disclosures are undertaken at the corporate level. Most of the time, communications are performed by the CEO. For issues relating to Human rights, labour rights and anti-corruption, QSL follows general procedures, i.e. internal processes, applied within the company since we are not specifically confronted with these issues.Executive Pay
11. Is executive pay linked to performance on one or more of the following sustainability topics?
Optional commentQSL executive compensation is not currently directly linked to sustainability performance, however environment and health and safety indicators are considered in executive performance reviews.Board Composition
12. Percentage of individuals within the company’s Board / highest governance body by:
13. Do you produce sustainability reporting according to:
Optional commentQSL is in the process of developing our first comprehensive ESG strategy with a first report planned for release in early 2023.Data Assurance
14. Is the information disclosed in this questionnaire assured by a third-party?
Optional commentThe information disclosed in this questionnaire is not assured by a third-party however documentation is available to support our answers.Human Rights
Materiality / Saliency
1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?
Optional commentOccupational health and safety remains amongst the company’s key priorities, for which many initiatives are deployed across the company. These values are further enshrined in our Code of Ethics, which all new employees, contractors and suppliers must commit to, and which also underlines our commitment to digital security.Commitment
2. Does the company have a policy commitment in relation to the following human rights issues?
Optional commentQSL include the topics mentioned above within its Code of Ethics. Notable excerpts include: Data management and electronic communication tools have been designed to meet the requirements of our business. QSL’s electronic communication systems are a relatively sensitive and fragile environment. It is forbidden to change the configuration of a workstation or the nature of software, processes or technologies that are available to you in connection with your employment2.1. For each human rights policy, is it:
Optional commentThis Code of Ethics presents QSL’s expectations regarding to the behaviour of employees, directors, officers, and managers. It also regulates relations with suppliers, partners, and agents. It is based on the values of the company, reflects our mission and the need to act according to the highest standards of ethics. The Code does not necessarily provide concrete answers to all the situations the regulated persons and partners may face. However, it provides the parameters needed to make informed decisions that are respectful of our guidelines. The Code aims, finally, to underline QSL’s commitment to act according to the highest ethical standards. New policies or any changes to our current policies requires approval from our President and CEO. While not currently available on our website, the Code of Ethics is available publicly through our collective agreements, and excerpts are included in all job postings.Prevention
3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights issues?
Optional commentWhile QSL’s Code of Ethic structures our stance and expectation that all stakeholders respect and uphold human rights, QSL remediates issues on an ad-hoc basis.4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights issue?
Optional commentTo mitigate risks, all employees must commit and adhere to our policies when they are hired (The Code of Ethics and other QSL policies are an integral part of all job offers). New hires participate in a mandatory on-line training program on their first day which covers QSL’s Code of Ethics and policies. Furthermore, in 2021 a new on-line training program which covers QSL’s Code of Ethics and policies was also made mandatory for all existing QSL employees and contractors.5. Who receives training for the following human rights issues?
Optional commentPlease see description in HR4.6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights issues?
Optional commentIndicators tracking the number of employees trained on the Code of Ethics are monitored internally, with a maintained 100% compliance amongst new hires and on the 2021 Code of Ethics refresher course. Furthermore, 100% of administrative and operational employees with internet access completed a cybersecurity training in 2021.Response
7. During the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to adverse impact associated with the following human rights issue(s)?
Optional commentQSL follows up on minor incidents on an ad-hoc basis to ensure their appropriate resolution, however no major incidents occurred during the reporting period related to the identified topics.8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
As previously outlined, these principles are embedded across QSL’s culture thanks to their inclusion in the Code of Ethics adopted by all new hires, contractors and suppliers.Labour
Commitment
1. Does the company have a policy commitment in relation to the following labour rights principles?
Optional commentOur non discrimination commitment is included in all our job postings: As an equal opportunity employer, we are committed to diversity and inclusion. We are pleased to consider all qualified applicants for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, protected veterans status, Aboriginal/Native American status or any other legally-protected factors. Disability-related accommodations are available on request for candidates taking part in all aspects of the selection process. Our guiding principles about working conditions are stated in our Intranet, accessible to all employees: We are dedicated to ensuring that the remuneration rewards performance in achieving our business objectives and provides competitive and fair working conditions to attract and retain seasoned leaders and talented staff. Our commitment to abide by laws governing the country where we operate is stated in our Code of Ethics: Forced Labour and child labour are prohibited by law. All our collective agreements include a section recognizing the Union to represents the employees and confirming our commitment against discrimination1.1. For each labour rights policy, is it:
Optional commentThe Code of Ethics presents the expectations of QSL Canada Inc. with regards to the behaviour expected from its employees, directors, officers, and managers. This Code is intended, in all circumstances and without exception, for regulated persons and our partners when they are dealing with or on behalf of QSL. While not currently available on our website, the Code of Ethics is available publicly through our collective agreements, and excerpts are included in all job postings.Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?
3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?
Optional commentHealth and safety in a number one priority for QSL. It is closely managed across all terminals, with KPIs, targets and procedures implemented by terminal directors and their teams. In fact, QSL’s commitment to Health and Safety was recognized by the Quebec Chamber of Commerce’s Mercuriades business competition in 2022. QSL actively collaborates with our 17 employee unions, ensuring healthy and productive dialogue between teams and management.4. Who receives training for the following labour rights issues?
Optional commentTo mitigate risks, all employees must commit and adhere to our policies when they are hired (The Code of Ethics and other QSL policies are an integral part of all job offers). New hires participate in a mandatory on-line training program on their first day, and discuss the Code of Ethics and policies as part of the onboarding process. Furthermore, in 2021 a new on-line training program which covers QSL’s Code of Ethics and policies was also made mandatory for all existing QSL employees and contractors.5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?
Optional commentMonitoring and follow up occurs weekly for all indicators pertaining to occupation health and safety and working conditions. QSL has extensive procedures to reduce work accidents and other safety incidents, including operational risk assessments, Standard Operating Procedures, employee training and on-site inspections. Beyond this, the Code of Conduct, which covers QSL’s commitment to legal compliance (implicitly including forced or child labour), non-discrimination, health and safety and working conditions, is adopted by all new employees, contractors and suppliers. The code also states that any employee with knowledge of violations (including with regards to labour rights) must report the incident to their immediate supervisor or human resources representative. QSL takes all appropriate steps to remedy any incidents on an ad-hoc basis.Performance
6. What is the percentage of employees covered under collective bargaining agreements?
7. What is the percentage of employees in a trade union or other workers' organization?
8. In the course of the reporting period, what was the percentage of women in:
9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
11. In the course of the reporting period, what was the company’s incident rate?
Response and Reporting
12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?
Optional commentWhile QSL deals with any minor incidents on an ad-hoc basis, no major incidents occurred during the reporting period with regards to the identified topics.13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.
As QSL moves into the next stage of its ESG strategy and roadmap development, labour conditions will feature heavily as a part of the “Workforce, reimagined” strategic priority. Over the coming months, QSL will assess and develop initiatives focused on bringing together positive working conditions, well-being and health and safety to help employees thrive.Environment
Commitment
1. Does the company have a formal policy on the following environmental topics?
Optional commentQSL’s Sustainable Development Policy is a set of guidelines that guide our approach and fundamental values with regards to the environment, though without mentioning specific topics. The policy is available online here: https://qsl.com/commitment/environmental-sustainability-2/ This policy is supplemented by QSL’s adherence to the Green Marine sector-specific environmental certification program, which requires participants to submit performance indicators and undergo external verifications. The Green Marine framework, against which QSL reports, does cover the entirety of the topics listed above. QSL is in the process of creating an ESG roadmap, following a materiality assessment and topic prioritization exercise undertaken in Winter 2022. Climate Action (including energy + resource use), and Ecosystem Protection (including protection of waterways, land use and air pollution), feature amongst the strategic priority topics to be highlighted in the forthcoming initiatives and policies.Prevention
2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?
Optional commentQSL engages and collaborates with many stakeholders across multiple platforms. First, we are members of many local groups and committees. For example, in the Quebec City region alone, QSL sits on the Regional Round Table for the Integrated Management of the St Laurent River in the Quebec City Area (TCRQ | CMQuébec (https://cmquebec.qc.ca/gestion-integree-saint-laurent/tcrq/), the Intersectoral Committee on Environmental Contamination and Air Quality in the Borough of La Cité-Limoilou (https://cvap.quebec/wp-content/uploads/2015/01/Plan-daction-CICEL-2018-2021_2019-06-20.pdf) and the group My environment, my health (Mon environnement, ma santé | CIUSSSCN (https://www.ciusss-capitalenationale.gouv.qc.ca/sante-publique/sante-environnement/monenvironnementmasante)). In each case, membership allows QSL to exchange directly with community members, environmental groups, government agents and other economic actors to ensure monitoring of environmental and social impacts. QSL also sits on a number of industry-specific committees, such as the board of the Green Marine sector-specific certification and numerous committees. Outside of these more formal committees, QSL exchanges with stakeholders directly through our community email address and other more local initiatives. Though community inquiries go through the local port authority in many areas, stakeholder engagement is especially notable in Sorel Tracy where we operate a private terminal. In preparation for an expansion project, we have launched extensive community consultations through events, social media, brochures, and local media. In this way, we have been able to have a productive dialogue with stakeholders to address any environmental concerns regarding the expansion.3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?
Optional commentAt QSL, we have implemented a number of actions in line with the environmental topics listed. More specifically, with regards to Climate Action we have implemented our first Scope 1 inventory for on-site operations, tracking GHG data, as well as air pollutant information for certain sites (depending on the nature of activities performed). We have an extensive management system for preventing environmental incidents with regards to water, land or air contamination. More specifically, we assess all activities for spill risks, put in place mitigation plans, and have dedicated coordinators who ensure compliance across operations. As we strive to meet our company-wide stretch goal of zero reportable environmental incidents, we collaborate with government bodies and ensure that environmental compliance remains a key priority for our company. Furthermore, as a part of our Green Marine sector-specific certification, we ensure that adequate maintenance is performed on all vehicles and machinery to prevent spills. The reflection on the energy and sources used is also part of the certification, therefore we engage in several discussions about fuel consumption in order to find alternatives to move away from it, notably through electrification. We have also implemented a system to prevent the discharge of contaminated wash water, including a full water filtration and management system on certain sites, and other innovative equipment to prevent releases into waterways. We work in collaboration with the port authorities on water management but also on tree planting to remedy the deforestation of the area. Finally, regarding waste, we have eliminated the use of single-use plastic water bottles across all sites, instead providing reusable water bottles and refill stations to all employees. We have also recently switched from traditional plastic tarps to liquid polymer tarps where appropriate, reducing the footprint of these materials.4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
Optional commentAs part of the Green Marine certification, we are required to monitor progress on each of the above topics and manage the risks that may arise. We track environmental incidents across all the terminals, with a company-wide stretch goal of zero reportable environmental incidents (including discharges into the land, air or water). We have numerous real-time indicators and processes in place allowing us to measure and mitigate these environmental incidents. For example, in 2021 we deployed a mobile water cannon, evaluated the technical feasibility of switching to biodegradable lubricants for mobile equipment and increased the protection of waterways by using the sewer protection mechanisms such as physical water treatment basins and mechanical water collection systems in the case of a spill. Finally, to increase the robustness of these environmental processes, we are in the process of deploying ISO 45001 and 14001, which are projected to be fully implemented by the end of 2024. We have also recently achieved out company-wide target of zero single-use water bottles across all operations.5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?
Optional commentQSL adopts many actions to minimize the chances of a spill or leak and comply with all relevant regulations. (water cannons to minimize air emissions, patented ship side deflectors to prevent spills of bulk material). Systems such as chemical and mechanical water filtration systems are in place to ensure that any leaked products never make their way to waterways. In general, QSL has emergency procedures that allow operations to be stopped. Before operations can be restarted, a reassessment of the situation is necessary. For each actual or probable incident, the authorities inform the government through the environmental hotline. The authorities then decide whether or not to open an investigation or to impose a penalty on the company. In the last year, QSL has experienced some events but none of them resulted in penalties.Climate Action
6. What were the company’s gross global greenhouse gas emissions for the reporting period?
Scope 2 Emissions
Scope 3 Emissions
7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?
Optional commentNo research and development activities specifically related to low-carbon products/services was undertaken during the reporting period.8. Has the organization acted to support climate change adaptation and resilience?
Optional commentLike any company who operates outdoors, QSL has felt the effects of hotter, drier summers and we have revised our activities as a result. Most specifically, we have increased the frequency of tarping and other dust mitigation measures to ensure that, as we have always done, we adapt our practices to the climactic conditions to prevent negative outcomes.Energy / Resource Use
9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.
Technology
10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?
Sector-specific Questions
11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.
Sector-specific: Water
12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.
Water withdrawal (volume of water in megaliters):
Water consumption (volume of water in megaliters):
13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.
Sector-specific: Air pollution
17. Where applicable, please report the company's emissions of the following pollutants during the reporting period.
Optional commentCurrently, air pollutants are calculated for the Beauport Terminal only, in application of Canadian Obligations (NPRI). Please note that values provided are for 2020, as 2021 calculations are still in progress. PST: 17,55 ; PM2,5: 2,072Sector-specific: Waste
18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.
19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.
20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.
Optional commentWe consider the following to be our sources of single-use plastic: water bottles, tarps, containers, packaging, etc. In 2021, QSL took action to eliminate the use of single-use plastic bottles on our sites, providing all employees with reusable water bottles and filling stations. This initiative was successful, allowing us to eliminate an estimated 500 000 bottles in 2021 compared to 2020.Overall Environment
21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.
QSL has successfully implemented multiple environmental initiatives in recent years. Most notably, we have eliminated the use of single-use plastic water bottles on our sites, certified all of our terminals under the Green Marine certification, and even won an environmental prize for our operations in the Sorel Tracy River Yamaska region. 2021 also saw the implementation of multiple initiatives and pilot projects. Our biofuel “task force” was assembled to research new technologies, following a 2019 pilot project. We are currently in the process of identifying potential alternative fuel products to build a roadmap over the course of 2022. To further reduce our greenhouse gas footprint, we implemented more electric conveyer belts across our operations. This technology, combined with vehicle telemetry and other operational optimizations, allowed us to reduce the Scope 1 greenhouse gas emissions of our Beauport terminal by 25% from 2019 to 2020, and a further 35% from 2020 to 2021. We have also developed and implemented improved ship side deflectors which maintain consistent tension to even more effectively prevent spills of bulk products during loading and unloading. We are currently in the process of patenting this innovation. As we move forward into the next phase of our new ESG strategic reflection, we will further strengthen our approach to climate change, and develop new initiatives related to the protection of ecosystems.Anti-corruption
Commitment
1. Does the company have an anti-corruption compliance programme?
Optional commentQSL’s anti-corruption position is housed in our Code of Ethics, which outlines the expected behaviour from employees, suppliers, partners and other stakeholders. Amongst other topics, this code stipulates the expected behaviour as it pertains to conflict of interest to “promote fairness and avoid favoritism, embezzlement, breach of trust or other misconduct of the same nature.” Furthermore, QSL’s strict stance against illegal payments, bribes, gratifications or any other form of corruption is outlined. All new employees, suppliers or contractors must review and commit to the Code of Ethics prior to commencing their work with QSL.2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?
Optional commentThe Code of Ethics highlights each individuals’ duty to report any witnessed violations, and stipulates the guidelines for recognizing unethical action, including the questions employees can ask themselves when in doubt. The code goes on to underline the importance of reporting any witnessed offense to the individual in question’s immediate superior, the superior of their immediate superior, or a human resources representative.Prevention
3. Who receives training on anti-corruption and integrity?
Optional commentAll of QSL’s employees must commit to our Code of Ethics and policies when they are hired (The Code of Ethics and other QSL policies are an integral part of all job offers). New hires participate in a mandatory on-line training program on their first day which covers QSL Code of Ethics and QSL Policies. Furthermore, a new on-line training program which covers QSL’s Code of Ethics and policies was also made mandatory for all QSL employees and contractors in 2021. Direct suppliers and partners of the organization are also subject to the code.3.1. How often is such training provided?
Optional commentTrainings are provided when a new employee is hired and when the company engages a new supplier or contractor. All existing employees also participated in a refresher course in 2021.4. Does the company monitor its anti-corruption compliance programme?
Response and Reporting
5. Please report the company's total number and nature of incidents of corruption during the reporting year.
6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?
Optional commentThere were no suspected or investigated incidents of corruption during the reporting period. As mentioned, employees, contractors and suppliers are all subject to the QSL Code of Ethics which highlights the importance of disclosing any witnessed or suspected incidents. However, because of the rarity of such an event, incidents and their ensuing investigations would be managed on a case-by-case basis.7. Does your company engage in Collective Action against corruption?
Optional commentAlthough QSL collaborates closely with partners, communities and government on a range of topics, no Collective Action against corruption specifically was undertaken in the reporting period.8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.
To date, QSL’s mandatory commitment to the Code of Ethics by all new employees, contractors and suppliers has been its main tool by which to highlight the importance of avoiding conflicts of interest. The newly updated mandatory refresher training helps further emphasize this point for existing employees.