Exhibit 1
CODE OF BUSINESS CONDUCT
The Code of Business Conduct is our guide to ethical and lawful conduct in our daily business. It requires all of us, from members of our board of directors to new hires, to adhere to a level of ethical business conduct well in excess of the legal minimum. Our compliance with both the letter and spirit of the Code of Business Conduct is essential to protecting Enerplus’ business and reputation.
INTRODUCTION
Enerplus’ Commitment
Enerplus Resources Fund and all of its affiliates (“Enerplus” or the “Fund”) is committed to maintaining the highest of business standards in our operations, wherever they may be. Our Fund recognizes the importance of credibility, integrity, and trust to our success as a business.
Purpose of the Code
This Code of Business Conduct summarizes a number of Enerplus policies for appropriate employee behavior. The Code will help us meet our business practice standards and comply with applicable laws and regulations. It is essential that this Code of Business Conduct be observed. The Code is very important to protecting Enerplus’ business and reputation.
The Code of Business Conduct is a general guideline for making certain that:
• | A work environment is maintained that promotes the dignity and self-respect of each employee. |
• | All employees are aware of and fully observe the laws and regulations that impact their business activities. |
• | A standard of behavior is in place that reflects the values and integrity of Enerplus and its board of directors, officers, and employees. |
• | Enerplus is protected from financial loss and legal liability. |
This Code of Business Conduct does not replace any other published rules and policies of Enerplus, including other work rules and personal conduct policies. While this Code of Business Conduct provides guidance and explains what is considered unacceptable behavior, the Code of Business Conduct does not describe every specific act that is unacceptable. Because a specific act is missing from the Code, it does not mean that act is acceptable or condoned. Ultimately, we must rely on our judgment about the right thing to do in order to maintain our personal and corporate integrity.
Applicability of the Code
This Code of Business Conduct applies to all employees, consultants, officers, and directors of Enerplus and as such, each of us must comply with the policies of this Code.
The Code is to be used as a guide for appropriate conduct and to prevent improper conduct. Enerplus will not tolerate any conduct that is unlawful or damaging to Enerplus’ reputation.
Employee Responsibilities
All employees are responsible for reading this entire Code of Business Conduct and ensuring their conduct is consistent with both the letter and the spirit of Enerplus’ business practices.
This Code will help employees deal with specific situations. In some cases, a situation may be so complex or circumstances so unique that additional guidance is needed. If such a situation occurs and is not included in this Code, it is each employee’s duty to contact his/her supervisor, the Human Resources Department, or our General Counsel immediately.
This Code and any detailed Enerplus policy statements and procedures will be updated from time to time. All employees are required to stay informed of any updates and to comply with all requirements.
Management Responsibilities
Managers must exhibit the highest standards of corporate responsibility and business conduct and create a work atmosphere that supports our corporate values and policies, including this Code. It is the duty of each member of management to take into account an employee’s willingness and commitment to comply with this Code when making promotion and other employment decisions.
Compliance Requirements
Employees must work honestly and in good faith. Employment with Enerplus depends on an employee’s ability and willingness to comply with this Code. Adherence to these standards carries the highest priority. All employees are required to acknowledge compliance when they are hired and again on an annual basis when requested by management to do so.
GLOBAL BUSINESS CONDUCT GUIDELINES
Our Employees
Discrimination & Workplace Harassment
Employees are forbidden to discriminate against or harass other employees as defined under our Anti-Harassment Policy. No employee is permitted to act in a way that is considered or could be considered illegal or harassing.
It is the responsibility of each member of management to be aware of any behavior or conduct that could be considered workplace harassment or discrimination. Management is also required to enforce these policies and immediately contact the Human Resources department regarding any situation that could be considered workplace harassment or discrimination.
It is the responsibility of each employee to maintain a work environment free of discrimination and harassment and to report any situation that the employee believes may be workplace harassment or discrimination to his/her supervisor, his/her department head, Human Resources department, or the Senior Vice President of Corporate Services.
Employment of Family Members
Enerplus allows an employee’s spouse, parents, children, and other family members to work for Enerplus, both during and after the employee’s career with Enerplus, provided the employment is in Enerplus’ best interest. Family relationships, however, will not be considered in hiring decisions (exclusive of the Summer Student Program). All Enerplus hiring decisions will be made strictly on the basis of individual qualifications. To avoid the possibility or appearance of preferential treatment, Enerplus will not have one family member placed in a position of influence over another family member.
Health & Safety
The health and safety of our personnel and the safe operation of our facilities are principal objectives of Enerplus. We are committed to providing safe and healthy places of employment and will follow operating practices that eliminate or minimize exposure to hazardous and unhealthy conditions. The success of our health and safety efforts depends on the cooperation, support, and active involvement of all Enerplus personnel. Each employee is responsible for working safely and complying with all safety rules and protocols at all times.
Employees should refer to the Enerplus Environment, Health and Safety Website for minimum safety standards. Questions or concerns should be reported immediately to a supervisor or to the Environment, Health and Safety Department.
Workplace Safety
Enerplus is committed to maintaining a safe and secure work environment. Threats, intimidation, harassment, assaults, and acts of violence are unacceptable. If an employee has any concerns, he/she should contact the Human Resources department.
Prohibited Items
The use, sale, possession, distribution, manufacture, and/or presence in the body of illegal drugs or inhalants, or the improper use of alcohol or prescription drugs by employees or contractors is strictly forbidden while on Enerplus premises, in Enerplus vehicles, or conducting Enerplus business on or off Enerplus premises.
The use of alcohol in any environment is prohibited to the extent that it has a detrimental effect on job performance, safety, or efficiency while conducting Enerplus business on or off Enerplus premises, or while in Enerplus owned or leased vehicles. The approval of an Enerplus officer is required to consume or possess alcoholic beverages on Enerplus premises.
The possession, use, or distribution of firearms, weapons, and explosives is prohibited while on Enerplus premises, while conducting Enerplus business, or while in Enerplus vehicles on or off Enerplus premises, without prior written authorization by an Enerplus officer.
If evidence supports a reasonable suspicion of use, possession, or distribution of prohibited items, Enerplus reserves the right to conduct searches on Enerplus premises or in Enerplus owned or leased vehicles for such items.
Our Company
Document Retention
Employees must comply with Enerplus’ department specific document retention guidelines to ensure that any applicable laws and regulations are met. Each employee should become familiar with and adhere to these guidelines. Additionally, when litigation or an investigation is pending, employees are prohibited from modifying or destroying relevant documents or records including employees’ personal files and electronic records. The consequences of modifying or destroying any relevant documents or records are severe and may include prosecution. An employee who has any doubt about the legality or propriety of modifying or destroying any document or record should contact his/her supervisor or General Counsel before proceeding.
External Communications
From time to time, employees may be contacted by government representatives or legal counsel representing other companies, government agencies, or individuals in connection with investigations that concern Enerplus, its businesses, clients, employees, or suppliers. While Enerplus cooperates with all reasonable requests from government agencies and authorities, all requests for information other than what is provided on a routine basis should be reported to our General Counsel immediately. An employee who is contacted should decline to respond and should refer the requester to our General Counsel. Likewise, if an employee receives a subpoena or other request to testify or produce documents, a copy of the subpoena or request should be forwarded immediately to our General Counsel.
General Counsel’s guidance should be received before responding to any request, and all responses must be coordinated through our General Counsel. All information provided should be truthful and accurate. Employees must never mislead any investigator and must never modify or destroy documents or records in response to an investigation.
Disclosure of Corporate Information (Insider Trading & Selective Disclosure)
Employees must not trade Enerplus securities while in possession of material, nonpublic corporate information. Employees must not use such material, nonpublic corporate information for their benefit or the benefit of others. Material corporate information is any information that, if known, might influence a reasonable investor’s investment decision to buy, sell, or hold securities of Enerplus. Nonpublic means any corporate information that has not been released by Enerplus for public dissemination and which is intended to remain confidential until such
authorized dissemination. Employees should not share material, nonpublic corporate information with anyone outside Enerplus (including family members) until it has been made public, regardless of how the information may or may not be used. These restrictions also apply to trading in securities of any other company (including, but not limited to, competitors, suppliers, and customers) if an employee learns of any material, nonpublic information about that company during the course of his/her employment with Enerplus.
Employees and directors must adhere to blackout restrictions posted on published blackout calendars. Trading blackouts are implemented to ensure that “insiders” do not have the advantage of information that has not been announced to the general investing public. “Insiders” are considered to be anyone who has access to information that has not been released to the public realm. Applicable securities laws dictate the protection of the entire investing public to ensure trading equity. Should an individual breach insider trading rules they may be subject to significant penalties by regulatory authorities.
Announcements of material information will include scheduled and unscheduled announcements. Scheduled announcements will include the release of quarterly financial statements, annual financial statements and annual reports of the Fund, and in that regard, trading in the securities by Enerplus personnel will be prohibited for a certain time before and after the release of financial statements. Unscheduled announcements may include the release of information relative to changes in the Fund of a financial or structural nature, which may or may not require trading blackouts.
Management will make every attempt to inform employees of changes to blackout periods. However, blackout periods may change without notice. Should you have any questions or require clarification regarding trading restrictions, it is the individual’s responsibility to direct these questions to Enerplus General Counsel prior to trading any Enerplus securities.
Employees must report violations or misuse of material, nonpublic corporate information to our General Counsel immediately.
Employees are prohibited from making selective disclosures of material, nonpublic corporate information to third parties. All inquires regarding information about Enerplus’ activities must be referred to the Investor Relations department.
Directors and officers of Enerplus are required by securities regulations to make certain filings with securities commissions to report their holdings and transactions in Enerplus’ securities. Questions about these laws should be directed to the General Counsel and Corporate Secretary.
For further information please refer to the Disclosure Policy.
Conflicts of Interest
Employees are not permitted to do anything that does not support the best interests of Enerplus. For example, an employee should not, on his/her own behalf:
• | Use Enerplus property for his/her own material benefit |
• | Influence Enerplus’ contractors or consultants for his/her own personal gain |
• | Act on business opportunities or investments presented to Enerplus, other than for the benefit of the Fund, that are not available to the public without written permission from General Counsel |
• | Make or recommend decisions for Enerplus that might benefit the employee, his/her family members, or friends financially without first telling the Fund that such benefits may result |
• | Own a five percent (5%) or more equity interest in any entity that sells supplies, furnishes services, or otherwise does business with Enerplus without written permission from General Counsel |
• | Own a five percent (5%) or more equity interest in any entity that is a competitor of Enerplus without written permission from General Counsel |
Before acknowledging compliance to this Code, an employee must report in writing any conflicts of interest to the Human Resources department. If conflicts of interest arise after the employee has acknowledged compliance, the employee must report the conflicts in writing to the Human Resources department immediately, who will in turn disclose such conflicts to General Counsel.
During business hours, employees should devote their full time and attention to Enerplus and their assigned job duties. Unrelated outside activities, business, or secondary employment are not permitted during business hours.
No officer or employee of Enerplus should serve on the board of any corporation that Enerplus does not own or control without the written approval of Enerplus’ President and CEO. It is acceptable to serve on the board of a non-profit, charitable, religious, or civic organization without prior written approval, provided it does not interfere or impair their ability to perform their duties at Enerplus and represents a commitment of personal time.
To avoid potential conflicts of interest, it is against Enerplus’ policy for Enerplus to extend loans to officers or directors. It is acceptable, however, for Enerplus to extend loans to employees in certain instances (e.g. loans to purchase personal computers).
Confidential & Proprietary Information
Occasionally, employees may know confidential information concerning Enerplus’ customers, suppliers, business contacts, employees, or technical operations. Employees must keep this information confidential during and after their employment with Enerplus. Personal information relating to Enerplus customers, suppliers, business contacts or employees must be treated in accordance with Enerplus' Privacy Policy.
Generally, any information stored by and/or processed by Enerplus is proprietary information. This confidential information includes computerized data, methods, techniques, and documentation relating to Enerplus’ computing services, developed software, and third-party software.
Employees must be aware of their responsibilities regarding access to Enerplus’ computer services, and the access, use, and disclosure of confidential information. Confidential and proprietary information must be used for Enerplus purposes only, never for personal gain. Enerplus prohibits employees from releasing or misusing any confidential and proprietary Enerplus information.
Accounting & Reporting
Accurate documents are important during audits and other internal or external reviews. All employees must comply with Enerplus’ accounting and reporting procedures and make sure all books, records, accounts, and supporting papers are accurate and complete. Employees are forbidden to forge, falsify, or leave out important facts to mislead auditors or other internal or external reviewers intentionally on any business documents of Enerplus.
Expense Accounts
Employee expense accounts should be used only to reimburse employees for items and activities that are purchased for Enerplus business. Each employee must submit an accurate expense report of the money spent for this purpose.
Electronic Communications
Enerplus’ technological resources are an Enerplus asset and should be used by employees in pursuit of Enerplus’ business. While limited use of these resources for personal purposes is acceptable, employees should not expect their use of these resources to be private or confidential, including their use of voice mail and email. Enerplus may access these
technological resources at any time and may disclose the information it accesses to law enforcement or other third parties without prior consent of the sender or the recipient. Employees should take the same care in their electronic communications as they take when they communicate in person or by paper. Employees are forbidden from engaging in the following activities utilizing Enerplus’ technological resources:
• | Sending e-mail or other communications that masks the sender’s identity |
• | Using another employee’s password to access any technological resources |
• | Sending or saving offensive material |
Any electronic communication of personal information must be in accordance with Enerplus' Privacy Policy. Electronic sources (laptop, desktop, computer disk, recordings) of personal information must be kept under security measures appropriate for the sensitivity of the information.
An employee’s logon ID and password are intended for his/her use only. While Enerplus can require employees to disclose passwords and security codes at Enerplus’ discretion, employees should not disclose their passwords or logon ID combinations to anyone else.
Copyrighted Material & Software
Enerplus does not allow its employees to copy or distribute copyrighted material (for example, software, database files, articles, or graphics files) through Enerplus’ email system or by any other means without confirming in advance from appropriate sources that Enerplus has the right to copy or distribute the material. Employees are not permitted to install public software on Enerplus computers without the express written consent of the MIS department.
Internet/Intranet Site Development
Enerplus’ Internet and Intranet are important platforms to communicate Enerplus information to employees, customers, and the public.
As such, the company’s Information Systems department and the Investor Relations department shall be solely responsible and shall administer all creation and development of any company internet site and intranet site. However, any employee or stakeholder suggestions for enhancement to the sites are encouraged.
Company Logo
The logos of Enerplus and its business units are considered property of Enerplus and must only be used for business purposes. Only the approved logos, which are available through the Investor Relations department, may be used, and approval must be obtained from this department prior to using any Enerplus logo. Re-creation or alteration of Enerplus’ logos is not permitted. Furthermore, all logo items, such as apparel and office items, must be purchased through Investor Relations.
OUR BUSINESS PARTNERS & CUSTOMERS
Relationships with Contractors & Suppliers
Contractor and supplier relationships must be managed in a fair, equitable, and ethical manner consistent with the Code of Business Conduct and all applicable laws and good business practices.
Enerplus promotes competitive procurement to the maximum extent practical and evaluates every supplier’s products and services on the basis of technical excellence, quality, reliability, service, price, delivery, and other relevant objective factors. Enerplus prohibits employees from making purchasing decisions on the basis of personal relationships, friendships, or the opportunity for personal financial gain.
Employees must respect the terms of supplier and contractor contracts and licensing agreements and safeguard all confidential information received from a contractor or supplier,
including pricing, technology, or proprietary design information. This confidential information must not be disclosed to anyone outside Enerplus without the written permission of the supplier or contractor.
All contractors who exchange or receive personal information from Enerplus must have Privacy Policies and Practices in compliance with applicable Canadian Federal and Provincial Laws.
Gifts & Entertainment
Reasonable gifts and entertainment are a part of normal business courtesy and are not prohibited. In many cultures, exchanging gifts or entertainment is designed to foster trust in a business relationship. However, employees should always use good judgment and discretion to avoid the appearance of impropriety or obligation. Enerplus employees should be certain that any gifts given or received, or entertainment hosted or attended as a guest do not violate the law, customary business practices, or this Code of Business Conduct.
While employees may exchange or accept gifts with their customers and suppliers as part of a normal business courtesy, no gifts, favors, or payments should be accepted which imparts a future obligation on the employee or was given in an attempt to influence decisions regarding the business of Enerplus. Additionally, the value of the gifts exchanged should be reasonable, and the exchanges should occur infrequently.
Likewise, while employees may be participants in entertainment with their customers and suppliers as hosts or guests in the normal course of a business relationship, employees must not be participants when the entertainment is an attempt to influence decisions regarding the business of Enerplus or imparts a future obligation of the employee. Additionally, the value of the entertainment should be reasonable and the employee’s participation should occur infrequently. Finally, employees are prohibited from participating in inappropriate entertainment as either a guest or a host. An employee who has any doubt about the propriety of a gift or entertainment should contact his/her supervisor, the Human Resources department, or our General Counsel before exchanging the gift or participating in the proposed activity.
Generally, any gift with a value of up to $200 must be disclosed in writing to the manager of your department. If, given the circumstances, the gift is determined to be inappropriate, your manager may require the gift be returned to the originator. Gifts and entertainment in excess of $200 may be accepted, if approved in advance by an executive officer.
Obtaining & Using Competitor Information
While information about our competitors, customers, and suppliers is a valuable asset, the law and our standards of appropriate business conduct require that our employees obtain this information legally. It is not unusual to obtain information about other organizations, including our competitors, through legal and ethical means such as public documents, public presentations, journal and magazine articles, and other published and spoken information. However, employees are prohibited from obtaining proprietary or confidential information about our competitors, customers, or suppliers through illegal means, or from using any proprietary or confidential information acquired during a prior employment relationship. It is also not acceptable to use or seek to acquire proprietary or confidential information when doing so would require anyone to violate a contractual agreement, such as a confidentiality agreement with a prior employer. Employees are prohibited from taking any improper actions to gain information about our competitors, customers, and suppliers.
Our Communities
Environmental Compliance
Enerplus is dedicated to complying with all relevant environmental laws and regulations and requires employees to comply with these laws and regulations as well. It is the duty of each employee to report what he/she believes to be environmental violations to his/her supervisor, the Environment, Health and Safety department or our General Counsel.
Political Contributions
Only Enerplus’ President and CEO may authorize a use of the Fund’s resources to support political activities. Employees must not use Enerplus’ money, credit, property, or services for political activities. Outside of Enerplus business hours, employees may participate in any political activities of their choice, but Enerplus will not support or reimburse employees financially.
Requests for Information from the Media & Public
The Investor Relations department is the only department authorized to work with the media directly. When Enerplus provides information to the news media, Enerplus has the obligation to report accurately and completely all related material facts. In order to ensure that Enerplus complies with its obligations, employees who are contacted by the media for information regarding Enerplus’ business activities and plans, financial information, or Enerplus’ position on public issues must refer the request to the Investor Relations department. Likewise, all requests from the media for interviews must be directed to Investor Relations. Employees who have participated in Enerplus’ media training program must consult with Investor Relations before answering any questions from any member of the media.
Public Speaking & Publishing Articles
Speeches and articles offer excellent opportunities for Enerplus and its employees to present topics, ideas, and information of interest to business and professional audiences. These communications provide the public with a clearer understanding of Enerplus and its various business units. A speech or article on a professional topic written by an employee for delivery to an audience or publication represents Enerplus. Speeches and articles must be approved by the Investor Relations department prior to the speaking engagement or submission for publication.
Press Releases
Press releases allow Enerplus to announce important and relevant information to the public through the media. If a business unit or department within Enerplus anticipates the necessity for a press release to be created, the business unit or department must contact the Investor Relations department to discuss the appropriateness of such a release and to provide the needed information. All press releases must be written and issued by the Investor Relations department and are subject to application of the Disclosure Policy protocols.
Community Involvement
Enerplus directly and through its employees contributes to the general well-being and improvement of towns, cities, and regions where it has operations. Enerplus provides support to worthwhile community programs in areas such as social welfare, health, education, and arts and culture to promote the development of positive relationships in the areas where we have business interests. Enerplus also encourages the recruitment of qualified local personnel where practical. All Enerplus community involvement and requests for corporate contributions must go through the Investor Relations department.
While Enerplus encourages employees to participate in charitable organizations and other community activities of their choice, these outside activities should not interfere with job duties and as such prior approval from your manager should be requested. Approval from your manager should be requested when participation is supported by Enerplus and when utilizing Enerplus resources (including work time, e.g. days of caring). Where participation is on personal time and does not conflict with job duties then approval is not required. No employee may pressure another employee to express a view that is contrary to a personal belief or to contribute to or support political, religious, or charitable causes.
Community Projects
When a new project or business issue affects a local community, the business unit should seek the guidance of the Investor Relations department to help facilitate communications with the affected community. The Investor Relations department will serve as support, proactively building and maintaining relationships with local communities as project development occurs. This will include developing a consistent platform to help educate landowners and communities on Enerplus’ operations and safety programs.
Reporting Violations and Resources for Guidance
This Code and other Enerplus policies provide general information for seeking guidance or reporting violations of the Code to supervisors, department heads, the Human Resources department or our General Counsel. For more serious breaches of this Code, or if you have not received a satisfactory response, please refer to the Whistleblower Policy discussed below.
Whistleblower Policy
Enerplus has instituted a Whistleblower Policy to provide for the reporting and review of concerns relating to accounting and auditing matters, as well as other corporate misconduct and breaches of this Code of Business Conduct. Like the Code of Business Conduct, the Whistleblower Policy is designed to encourage ethical behaviour by all Enerplus personnel. Further details, and procedures for submitting a report, are set out in the Whistleblower Policy.
Disciplinary Action
This Code is intended to help employees conduct themselves in a manner consistent with our values. Employees may face disciplinary action if they:
• | Violate this Code |
• | Encourage or help other employees to violate this Code |
• | Condone other employees who violate this Code |
• | Fail to report a Code violation |
• | Retaliate against any employee who reports a Code violation in good faith |
• | Fail as an officer, director, manager, or supervisor to take appropriate steps to ensure compliance with this Code |
Disciplinary action may include one or more of the following:
• | A warning |
• | A written reprimand |
• | Mandatory reimbursement of losses or damages |
• | Suspension |
• | Demotion |
• | Termination of employment with Enerplus |
• | Referral for criminal prosecution or civil action |
Management has the discretion to determine the level and type of discipline that is appropriate in any given circumstance.
For more information please refer to Positive Discipline Policy.
Monitoring
Enerplus will monitor compliance with its policies and procedures, including this Code.
Questions/Effect of this Code of Business Conduct
This Code is not a comprehensive listing of every Enerplus policy or applicable law. If questions arise about what this Code means or how it should be applied, employees should contact their supervisor, department head, the Human Resources department or our General Counsel.
Sources of Information
General Counsel | (403) 298-4413 |
Human Resources, Employee Relations Manager | (403) 298-1257 |
Information Technology, IT Manager | (403) 298-1726 |
Environment, Health and Safety Manager | (403) 298-2229 |
WHISTLEBLOWER POLICY
We, at Enerplus, have always been dedicated to the principles of strong corporate governance combined with the highest standards of honesty and integrity in all matters concerning the conduct of our business. We fully expect and believe that all of our employees and contract personnel share this commitment.
The U.S. and Canada recently implemented new rules applying to publicly listed entities. One of the new regulations requires that the chief executive officer and the chief financial officer of Enerplus certify the correctness of all financial reports filed with securities regulators. Each report must also include a statement attesting to the effectiveness of Enerplus’ internal controls. While we are confident that our controls are effective, we encourage all employees or contractors to offer suggestions as to how we might improve them. The regulations also require that procedures be established for the receipt, retention and treatment of complaints received regarding accounting, internal accounting controls and auditing matters.
The Audit & Risk Management Committee of Enerplus has implemented this Whistleblower Policy in order to ensure accurate financial reporting and to encourage ethical behaviour by Enerplus personnel. The Policy requires that any person who observes or has knowledge of a misrepresentation of financial information, misappropriation of assets, or any other corporate indiscretion or behaviour in contravention of the Code of Business Conduct report such events. Any person who makes such a report in good faith or participates in an investigation is protected, by law, against any form of retaliation by Enerplus’ directors, management, or staff.
Accordingly, and in reaffirmation of our Code of Business Conduct, which we are all party to, personnel are encouraged and directed to inform us of any improprieties in the organization that you know of now, or become aware of in the future. Such issues should be reported by sending an email or letter, marked “Private and Confidential”, as follows:
Mr. David A. McCoy
Vice President, General Counsel & Corporate Secretary
3000, 333 - 7th Avenue S.W.
Calgary, AB T2P 2Z1
email: dmccoy@enerplus.com
Telephone: (403) 298-4413
or
Mr. Doug Brennan
Manager, Employee Relations
3000, 333 - 7th Avenue S.W.
Calgary, AB T2P 2Z1
email: dbrennan@enerplus.com
Telephone: (403) 298-1257
or
Mr. Robert L. Normand
Chairman of the Audit & Risk Management Committee
of the Board of Directors
177 Grande Cote
Rosemere, Quebec J7A 1H5
email: robnormand@videotron.ca
Telephone: (450) 435-2038
or
Mr. Gordon J. Kerr
President & CEO
3000, 333 - 7th Avenue S.W.
Calgary, AB T2P 2Z1
email: gkerr@enerplus.com
Telephone: (403) 298-1745
Any concerns that you raise will be handled confidentially and in a consistent manner, in accordance with legal requirements and our privacy policy. If a report is made anonymously, Enerplus undertakes to maintain anonymity to the extent possible, consistent with the need to conduct an adequate investigation. Where required, case numbers will be assigned for ease of future reference and periodic updating. Reports should contain sufficient detail of the conduct in question to permit a complete examination of the issue. Upon receipt of a report, an assessment will be made as to whether the behaviour in question is wrongful or otherwise falls within the Code of Business Conduct and is deserving of sanction. Depending upon the nature of the complaint, it may be dealt with at a supervisory level. However, if the matter is of sufficient gravity to merit further inquiry, it will be directed as follows:
A. Matters relating to financial integrity (including fraud, misappropriation of assets or other financial misconduct), corporate reporting and disclosure, accounting and auditing controls and procedures, and compliance with securities laws
- Chairman of the Audit Committee;
- Chief Executive Officer;
- Chief Financial Officer; or
- General Counsel
B. | Non-financial matters |
- Chairman of the Human Resources Committee;
- Chief Executive Officer;
- Manager, Employee Relations; or
- General Counsel
If necessary, external investigators also will be involved. The reporting individual will be notified of the outcome of the complaint only if a request is made and adequate contact information is given at the time of the initial complaint.
We firmly believe that it is the responsibility of all employees and management to ensure that Enerplus’ assets are adequately protected and that our investors are provided with accurate and timely information. Inappropriate behaviour will not be tolerated. This Policy will ensure that any perceived acts or circumstances of financial or ethical misconduct will be addressed and corrective action taken where required.