Code of Ethics

Accord Financial is committed to conducting its business in accordance and compliance with applicable laws, rules, regulations and the highest standards of business ethics, and to full, prompt and accurate disclosure in compliance with applicable laws, rules and regulations. This code of ethics applies to all directors, officers and employees of Accord Financial and sets forth specific policies.

You must not only comply with applicable laws, rules and regulations; you also must engage in and promote honest and ethical conduct and abide by the policies and procedures that govern the conduct of the Accord’s business. Your responsibilities include helping to create and maintain a culture of high ethical standards and commitment to compliance, and, in the case of directors and officers, maintaining a work environment that encourages employees to raise concerns to the attention of management and promptly addressing those concerns.

Compliance
You are required to comply with the laws, rules and regulations that govern the conduct of Accord’s business, including all laws prohibiting insider trading, money laundering, bribery and improper payments, and to report any suspected violations in accordance with the section below titled "Compliance with code of ethics."

Conflicts of Interest
You may not make any investment, accept any position or benefits, participate in any transaction or business arrangement or otherwise act in a manner that creates or appears to create a conflict of interest unless you make full disclosure of all facts and circumstances to, and obtain the prior written approval of either the CFO, in the case of employees, or the chairman of the Audit committee, in the case of directors and officers. A "conflict of interest" arises when you take actions or have interests that conflict in any way with Accord’s interests. These conflicts may make it difficult for you to perform your work objectively and efficiently. The following are examples of actual or apparent conflicts of interest that should be avoided:

  • You or a member of your family has an ownership interest in, is employed by or serves as a director of a company that competes with Accord, does business with Accord (such as a customer, supplier or business partner) or is a recipient of charitable contributions made by Accord. (However, it is not typically considered a conflict of interest to make investments in competitors, customers or suppliers that are listed on a stock exchange, so long as the total value of the investment is less than one percent (1%) of the outstanding stock of that competitor, customer or supplier and the amount of the investment is not so significant that it would affect your business judgment on behalf of Accord.)
  • You or a member of your immediate family participates in a joint venture, partnership or other business arrangement or investment either (i) with Accord or (ii) that you learned of through the use of Accord property or information or your position at Accord; and
  • You or a member of your family receives improper personal benefits as a result of your position in Accord.

Confidential information
You are required to maintain the confidentiality of all confidential information that you receive or become privy to in connection with Accord’s business, except when disclosure is authorized or legally mandated. Confidential information includes all non-public information that might prejudice the ability of Accord to pursue certain objectives, be of use to competitors or harmful to Accord, its suppliers or its customers, if disclosed. It also includes any information relating to Accord’s business and affairs that results in, or would reasonably be expected to, result in a significant change in the market price or value of any of Accord’s securities, or any information a reasonable investor would consider important in making an investment decision. You must not use confidential information for your own advantage or profit.

Disclosures
It is Accord's policy to make full, fair, accurate, timely and understandable disclosure in compliance with all applicable laws and regulations in all reports and documents it files with, or submits to, the Canadian securities regulators and in all other public communications it makes. Accord’s management is responsible for preparing such filings and such other communications and shall ensure they comply with all applicable laws and regulations. Employees must provide all necessary information to management when requested and must inform management if they become aware that information in any such filing or communication was untrue or misleading at the time such filing or communication was made, or if they have information that would affect filings or communications to be made in the future.

Protection and proper use of Accord assets
You should protect Accord’s assets and ensure their efficient use. Theft, carelessness and waste have a direct impact on Accord’s profitability. Its assets should be used for legitimate business purposes only.

Compliance with code of ethics
If you know of or suspect a violation of applicable laws, rules or regulations of this code, you must immediately report that information to the CFO, in the case of employees, or the chairman of the Audit Committee, in the case of directors and officers. Reports of suspected violations should identify as many relevant facts as possible, including, if applicable: (1) the date(s) relevant to the issue; (2) the name of any persons involved; (3) the specific facts that give rise to the concerns expressed; and (4) any suggestions for resolving or dealing with the problems. Accord recognizes that resolving reported problems or concerns will advance its overall interests and will help to safeguard its assets, financial integrity and reputation. No one will be subject to retaliation because of a good faith report of a suspected violation. 
Violations of this code may result in disciplinary action, up to and including discharge. Accord’s Audit Committee shall determine or designate appropriate persons, who will determine appropriate action in response to violations. Violations of this code may also violate certain laws.

Waivers of code of ethics
If you would like to seek a waiver of this code of ethics, you must make full disclosure of your particular circumstances to the CEO, in the case of employees, or the chairman of the Audit Committee, in the case of directors and officers. Amendments to and waivers of this code will be publicly disclosed as required by applicable laws, rules and regulations.

Documenting compliance with the disclosure policy
Accord will maintain appropriate records evidencing compliance with this code, including copies of correspondence relating to requests for, and determinations relating to, waivers of this code and copies of documents relating to its violations.

No rights created
This code of ethics is a statement of certain fundamental principles, policies and procedures that govern the directors, officers and employees of Accord in the conduct of its business. It is not intended to, and does not create, any rights in any employee, customer, client, supplier, competitor, shareholder or any other person or entity.