CODE OF CONDUCT & POLICIES

Confidentiality Policy

In the course of your employment, you may receive confidential information about the Company and its clients (including client names and contact information) and employees (collectively, “confidential information”). Disclosure of any confidential information would be highly detrimental to the Company's best interests. As such, all employees, volunteers and other agents shall:

• Take precautions to protect and maintain all confidential information;

• Only release confidential information to those authorized to receive it;

• Not disclose, publish or distribute (including by way of social media) confidential information to any unauthorized persons, including the media, at any time;

• Not remove confidential information from its premises or your workplace without its express permission;

• Not make improper use of confidential information, either directly or indirectly; and,

• Safeguard against unintentionally disclosing confidential information – that is, by not discussing confidential information in public and by not working with confidential information on a laptop in public or transmitting such information by unsecured means.

When your employment ends, you must immediately return all materials or property belonging to Mellenger Interactive. You agree not to retain, reproduce or use any confidential or proprietary information or property belonging to the Business, including lists of its clients and/or employees.

HANDLING CONFIDENTIAL INFORMATION

The following rules govern how all employees, independent contractors, volunteers, and other agents shall handle and store confidential information:

1. Confidential information shall be circulated in sealed envelopes or storage cases.

2. Address and mark confidential envelopes with the words “PERSONAL AND CONFIDENTIAL”. These envelopes are to be opened only by the persons to whom they are addressed or by persons designated by management as being responsible for handling confidential material.

3. If applicable, handle confidential information with care and, where appropriate, place documents in the shredding receptacles located throughout the office.

4. If applicable, when faxing confidential material, the sender should inform the intended recipient and confirm that the fax machine is intended to receive confidential information. Where possible, fax numbers should be programmed into the speed dialling feature of fax machines to avoid the risks of misdialing.

5. At the end of the working day, individuals must lock doors, desks, filing cabinets and any other storage cabinets containing confidential information. Such cabinets and storage facilities must always be closed and secure.

PROTECTION OF ELECTRONIC DATA

If applicable, the following rules govern the handling of electronic data:

1. Individuals must log off their computer at the end of every shift or workday or when they are to be away from their desks for an extended period of time.

2. Computer passwords are to be changed semi-annually.

3. Individuals must safeguard and must not disclose their computer access codes or any other access mechanisms they have. In that regard, each person is responsible for all activity that occurs while using their access codes or other mechanisms, except where this information was obtained by fraudulent means and the individual in question could not have prevented such unauthorized use through diligent precautionary measures.

4. Where possible, computer monitors should be positioned so that they cannot be seen easily by anyone other than the user.

BREACHES OF CONFIDENTIALITY

Anyone who becomes aware of a breach of confidentiality, or who suspects that a breach has occurred, must report the incident to their manager or to another member of management immediately. An investigation will then be conducted as expeditiously as possible to determine how the breach occurred and, if possible, who was responsible for the breach. Anyone who becomes aware of an unauthorized or fraudulent use of their access codes or access mechanisms must immediately notify their manager or another member of management.

ACCESS TO PERSONNEL FILES

All personnel files are private and confidential. Unless specifically provided for in this policy, or as may be required by law, no person shall be permitted to access to these files. Employees may be permitted reasonable and timely access to their personnel file upon submitting a request to their manager. Personnel files are the property of the Company. At no time shall such files be removed, copied, or destroyed without appropriate authorization.

USE OF PERSONAL DATA

The Personal Information Protection Act (“PIPA”) regulates our use of your personal data, in addition to any other privacy legislation that is applicable. As an employer, it is our responsibility to ensure that the personal data we process in relation to you is done so in accordance with the required principles. Any data held will be processed fairly and lawfully and in accordance with the rights of our employees. We will process data in line with the applicable legislation in relation to both job applicants and employees.

You have certain rights in relation to your data. More information about these rights is available in our Privacy Policy. We are committed to ensuring that your rights are respected in accordance with the law and have appropriate mechanisms for doing so. We may ask for your consent for processing certain types of personal data. This includes use of software for tracking human resources and login data. In these circumstances, you will be fully informed as to the personal data we wish to process and the reason for the processing.

You may choose to provide or withhold your consent within the software itself. Once consent is provided, you can withdraw consent at any time.

You are required to comply with all Company policies and procedures in relation to processing data. Failure to do so may result in disciplinary action up to and including dismissal.

Social Media Policy

Mellenger Interactive recognizes that social media use is widespread and that employees use social media to communicate and interact with others. The Social Media Policy (the “Policy”) is intended to safeguard our brand’s reputation and encourage employees to use social media responsibly by setting out expectations around proper online conduct.

Mellenger also recognizes that the projects which employees and contractors work on form a part of an individual’s personal portfolio. However, employees and contractors are required to contact Andrew before posting Mellenger Interactive's client work on their personal social media channels, to ensure that client launches and privacy are protected. Mellenger Interactive also reserves the right to announce, promote or profile client work first, immediately following the client’s own announcement, promotion or profile.

SCOPE

This Policy applies to all employees of the Company.

DEFINITIONS

For the purposes of this policy,

• “Social Media” means forms of electronic communication (such as websites for social networking and microblogging) through which users create online communities to share information, ideas, personal messages, and other content;

• includes but is not limited to LinkedIn, Twitter, Facebook, Instagram, YouTube, and any other similar means of communication.

• “Use” Includes posting content or viewing the posts of others, sending/reading messages, watching videos, and any other similar use by means of computer, mobile phone, or any other device.

• “Sensitive, Private, or Confidential Business Information” means Information, knowledge, or data of any nature and in any form relating to the past, current, or prospective business or operations of the Business that, at the time(s) concerned, is non-public information.

POLICY STATEMENT

When using social media (whether during approved breaks or outside of work), employees must conduct themselves in accordance with the following rules and expectations:

• Be aware that others will associate you with your employer when you identify yourself as such.

• Do not post or share comments about a co-worker, client, or contractor/vendor that could be perceived as offensive, harassing, threatening, retaliatory, or discriminatory. 

• Do not post or share sensitive, private, or confidential business information. 

• Do not express opinions which claim to be the opinion of Mellenger Interactive. Any personal blogs should contain a disclaimer that the views expressed on it are personal views of the author only.

• Do not post or share comments representing your own views about the Company.

• Do not upload photographs to social networking sites of yourself or any other employee taken in a work situation or in a work uniform.

• Respect client privacy. Never give out personal client information.

• Ensure that you are always complying with your employment contract, Employee Handbook, and all other policies of the Business.

• Even if you act with the best intentions, remember that anything you put on socia; media can potentially harm the Business.

• Always respect others. Do not use ethnic slurs, personal insults, obscenity, or engage in any conduct that would not be acceptable in our workplace. 

• Show proper consideration for the privacy of others and for topics that may be considered objectionable or inflammatory (like religion or politics).

• You may be legally responsible for the content you post, so respect brands, trademarks, and copyrights. Remember that social media sites and applications have access to and control over everything you have disclosed to or on that site or application. Any information might be turned over to law enforcement without your consent or knowledge. Use strict privacy settings on all social network profiles. 

• Always exercise caution and common sense. If you are unsure whether a post is appropriate, speak to your manager. 

• If you accidentally put the Company's reputation at risk, or if you fall prey to an online attack, inform your manager immediately.

MONITORING INTERNET USAGE

Mellenger Interactive may monitor your internet usage regularly and may undertake more in-depth monitoring where considered necessary. This includes monitoring the websites you visit, and any other matters referred to in this Policy.

CONTRAVENTIONS OF THE POLICY

Contraventions of the Policy may lead to disciplinary action up to and including dismissal.

Workplace Bullying & Harassment

Workplace conduct

Bullying and harassment is not acceptable or tolerated at Mellenger Interactive. All workers will be treated in a fair and respectful manner. 

Bullying and harassment 

(a) includes any inappropriate conduct or comment by a person towards a worker that the person knew or reasonably ought to have known would cause that worker to be humiliated or intimidated, but

(b) excludes any reasonable action taken by an employer or supervisor relating to the management and direction of workers or the place of employment.

Examples of conduct or comments that might constitute bullying and harassment include verbal aggression or insults, calling someone derogatory names, harmful hazing or initiation practices, vandalizing personal belongings, and spreading malicious rumours.  

Workers must: 

• not engage in the bullying and harassment of other workers

• report if bullying and harassment is observed or experienced

• apply and comply with the employer’s policies and procedures on bullying and harassment

Application

This policy statement applies to all workers, including permanent, temporary, casual, contract, and student workers. It applies to interpersonal and electronic communications, such as email and Slack. 

Annual review

This policy statement will be reviewed every year. All workers will be provided with a copy.

Date created: January 5, 2024. Date reviewed: January 14, 2025.

Next review date: January 14, 2026