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At Pomerleau, we take very seriously our role in preventing, detecting, and abolishing corruption, anti-competitive behaviour, and non-com- pliance of all kinds.

To give us the means to achieve our ambitions, we are currently deve- loping a comprehensive ethics and compliance program. For example, we have started aligning our anti-corruption management system with ISO 37001 standards, which will make Pomerleau one of the first construction companies in Canada to implement this international standard. We are aiming for ISO 37001 certification in 2023.

In 2022, we plan to introduce rigorous organizational policies and control mechanisms to support our high ethical standards. We will establish a 100% anonymous and confidential reporting line, adopt an anti-corruption policy, analyze our vulnerabilities, and implement means to mitigate them, including internal audits and sound gover- nance practices, among other measures.

Protecting the information that our teams, our partners, and our clients entrust to us is a fundamental issue. Here, too, we have chosen to trust ISO expertise for the implementation of recognized cybersecurity practices.

Pomerleau successfully obtained ISO 27001:2013 certification in 2021 for its Information Security Management System (ISMS) which covers the management of information security controls and supporting IT infrastructure, to protect the confidentiality, integrity, and availability of information for our clients in our Ottawa office.

Pomerleau is one of the first companies in North America to implement an information security program that meets the requirements of ISO 27001 certification in our industry, and we now want to align the IT security of our eight regional offices to this same standard.

We are also part of a group that includes all the major Canadian players in our industry sharing best practices in computer security. Among our recent improvements:

A secure access system for employees has been put in place.

Specialized training was provided to more than 2,000 employees in 2021, notably to counter phishing and to promote best practices in the protection of information (ISO 27001 standards).

The majority of employees employed by Pomerleau who practice a construction trade (excluding those in supervisory positions) are unionized. We approach our union relationships as collaborations, and we are proud to offer all workers respectful, advantageous, and fair working conditions.

Business ethics, a key issue Being proactive about cybersecurity

A sense of partnership with trade unions