Ethics and Anti-Corruption

SSR takes a zero-tolerance approach to bribery and corruption. Every SSR employee, and anyone authorized to work on our behalf, is expected to conduct business legally and ethically, and to comply with our Code of Business Conduct and Ethics, and Anti-corruption Compliance Policy, and all applicable laws. Principally, these include the Corruption of Foreign Public Officials Act (Canada) and the Foreign Corrupt Practices Act (United States).

In 2019, there were no legal actions taken against SSR or its subsidiaries in relation to anti-competitive or anti-trust behavior.

Anti-corruption is a key topic in our ongoing human rights assessment. In corporate risk assessments conducted in 2018 through 2019, we did not find significant risks from corruption and bribery, either at the corporate or operations level.

All directors, officers, and employees are annually required to acknowledge that they have read and understand the Code of Business Conduct and Ethics, the Anti-corruption Compliance Policy, and other corporate governance policies. All employees and Board members complete periodic training in our corporate governance policies.

In 2019, we engaged in additional anti-corruption training for our employees and reviewed our corporate governance policies, in conjunction with our Corporate Governance and Nominating Committee and Board of Directors.

Whistleblower Policy

We maintain anonymous channels for any employee to communicate concerns or complaints and without fear of negative consequences. Our complete Whistleblower Policy is available on our website.