Code of Ethics

Honesty and Integrity. Mac-Tower Inc. serves its customers and treats its competitors, subcontractors and suppliers with honesty and integrity.

Competition. Mac-Tower Inc. competes fairly for contracts, avoiding any practice that might be construed to be in violation of the letter or spirit of federal or provincial competition or unfair business practices legislation. The firm does not seek nor accept information concerning a competitor's bid prior to bid closing nor does it attempt to modify its price after the bid closing. The firm avoids any activity that could be construed as *bid shopping, a **reverse bid auction or ***bid peddling.

Qualifications. Mac-Tower Inc. seeks to perform contracts only for projects for which the firm has the technical competence and experience. The firm does not accept contracts for which it is not qualified. The firm assigns staff to projects in accordance with their qualifications and commensurate with the demands of the services to be provided under the contract.

Standards of Practice. Mac-Tower Inc. provides materials and services in a manner consistent with the established and accepted standards of the construction industry and with the laws and regulations that govern it including the use of standard industry documents wherever feasible. The firm performs its contracts with competence, reasonable care and diligence.

Conflicts of Interest. Mac-Tower Inc. endeavors to avoid conflicts of interest, both corporate and individual. Where a corporate conflict exists, <Insert firm name> will disclose such conflict to its customer or prospective customer. <Insert firm name> regularly educates its staff about personal conflicts of interest and has established a procedure for internal disclosure.

Safety. Mac-Tower Inc. assures that the safety of its employees, the employees of others on the job site, and the general public at large, is given the highest priority in all aspects of the firm's activities. <Insert firm name> will strive to provide its employees with the proper training and education required to enable the company to meet the stated goals of a safe workplace.

Environment /Sustainability. Mac-Tower Inc. will endeavor to promote sustainable building practices and environmental considerations in all its operations and in the services, it provides to its clients. <Insert firm name> will strive to provide its employees with the proper training and education required to enable the company to meet the stated goals of a more sustainable built environment and more environmentally friendly business practices.

Service Providers and Suppliers. Mac-Tower Inc. treats its service providers and suppliers in an equitable manner, avoiding any activity that could be construed as *bid shopping, a **reverse bid auction or ***bid peddling. It assures that they are advised as soon as it is reasonable subsequent to bid closing as to whether or not their bid was successful. The firm awards contracts with dispatch to the successful bidder at the bid price. The firm provides clear direction and prompt payment for service provided.

Employees. Mac-Tower Inc. complies with the letter and spirit of laws relating to working conditions. The firm does not knowingly violate any law or regulation dealing with employment standards. It is committed to providing its employees with a work environment free of harassment and discrimination and has internal policies and procedures to deal with complaints and to enforce its policies.

Financial Disclosure. Mac-Tower Inc. strives to ensure that all financial information provided to its principals, partners, shareholders, lending institutions, bonding and, insurance providers, and the general public, if requested, is an accurate and true representation of the firm's financial status.

Public Information. Mac-Tower Inc. assures that all public statements and disclosures it makes are truthful. The firm also protects the proprietary interests of its customers.

Compliance with Laws. Mac-Tower Inc. does not knowingly violate any law or regulation.

Image of the Construction Industry. Mac-Tower Inc. avoids actions that promote its own self-interest at the expense of the construction industry and upholds the standards of the construction industry with honor and dignity.

Internal Procedures. Mac-Tower Inc. has established internal procedures under which its failure to conform to the above practices will be handled. Each year, the firm reviews this Code of Ethics and its internal procedures with each of its employees. If an employee, customer or other individual becomes aware of a circumstance in which Mac-Tower Inc. or an employee of the firm fails to conform to the above standards, he/she should immediately report such circumstance to Human resources. Human resources will initiate an investigation of and otherwise resolve the reported issue.

* For the purposes of this document, bid shopping is defined as any conduct whereby the one soliciting bids uses the bids submitted to it as a negotiating tool either expressly or in a more clandestine way, before the contract has been awarded, with a view to obtaining a better price or other contractual advantage from that particular bidder or any of the others.

** For the purposes of this document, a reverse bid auction is defined as a form of bid shopping in which the one soliciting bids is privy to the bid information prior to the bid closing and uses that information to encourage bidders to resubmit lower-priced bids by advising them of their ranking or relative position to the other submitted bids during the bidding process.

*** For the purposes of this document, bid peddling is defined as any conduct whereby a bidder, in an attempt to secure a contract, offers to lower its previously bid price in order to undercut known bid prices from other bidders.