Guiding Principles

To our Valued Customers and Employees,

You know we sell cars, trucks, vans and SUV’s in Saskatchewan, but we aren’t really car salesmen. Here is why?

Leadership Message

As the market has evolved, so has our values evolved to meet customer needs. We strive to have the highest levels of customer satisfaction. We conduct our decisions and business as if our family members were our only customers.

These values have driven our decisions and operations and we are still constantly improving. We have a firm commitment to ethics and compliance and remaining accountable to what’s fair. As we continue to grow our great company, it’s important that we remain a positive part of the community. Below we have a Code of Conduct of what is expected by our employees, and what’s appropriate in the O’Brians business and the community.

O’Brians mission is to save customers money by providing high quality used vehicles with low prices. O’Brians is driven to help every customer, regardless of their credit history, by providing the financing necessary to meet their automotive goals. Car buying should be fun, fast and stress free. By having integrity O’Brians can help transform the public perception of the used car industry into one that is honest and fair. Our Code of Conduct confirms that we will conduct our business ethically, honestly, and with transparency. Our goal is to provide a great experience for every single customer.

Thank you, Brett and Paul

THE CODE.

The principles reflected in our Code of Conduct are perfectly aligned with our consumer satisfaction mission. The Code gives you the fundamental principles of conducting business ethically and outlines our employees’ responsibilities under the polices and the law. Consult the Code of Conduct any time you have a question or concern or when something just doesn’t feel right. All decisions affect one and other and the perception of our business and our industry. The Code of Conduct applies to all of us including sales people, managers, detailers, mechanics, accountants and senior leadership, and to contractors who work on our behalf. We also prefer to work with business partners who share our principles. The Code of Conduct reflects the kind of company we want to be and the way we want to do business, O’Brians takes violations of the Code of Conduct very seriously.

INTRO.

Asking questions and raising concerns is not always the easiest thing to do but, we are counting on you to be leaders. While don’t expect ethical misconduct to arise at O’Brians, we must be prepared to respond if it does.

Anyone who works at O’Brians is expected to recognize and report misconduct or unethical behavior if it occurs. It’s part of your job. If you have questions or are concerned about something that has happened, or has the potential to happen, talk to your manager as soon as possible. You can also reach out to the executive management team at info@ofinance.ca. Don’t’ hesitate to make the company aware of an issue, or a potential issue. The sooner we know, the sooner we can work to resolve it.

FEEL CONFIDENT.

O’Brians will never retaliate against someone for raising a genuine concern. If you report a concern, or potential concern, we will immediately begin to gather information to address it and take steps to keep your concerns as confidential as possible.

TREAT PEOPLE WITH RESPECT.

Working together respectfully brings our best out and translates to a healthy and co-operative working environment. Always demonstrate mutual respect toward co-workers, customers, business partners, or anyone else we meet on behalf of O’Brians.

DO IT RIGHT - Be considerate of those around you. Be respectful of other people’s opinions and beliefs. Never mistreat someone because of the way they look, their background, or what they believe. Harassment and bullying have no place at O’Brians.

RECOGNIZING HARRASSMENT

As a rule of thumb, harassment is any conduct (including words, actions, pictures, or physical contact) that is not welcome. To be safe, avoid behavior that shows hostility or intimidation, or uses words, pictures or actions that someone else might find offensive.

Examples of harassment include: - Unwelcome physical contact. Racial, ethnic or sexual jokes. Offensive emails, photographs or videos.

Harassment can also be sexual in nature, like making unwelcome romantic advances or displaying sexually explicit images on your phone or workstation screen.

WE PROMOTE AN INCLUSIVE WORKFORCE.

We hire the best people for the job. We choose to work with people who contribute positively to our culture and have the right experience and skills to help us grow.

DO IT RIGHT - Choose candidates based on character, ability and work performance. Hire people that diversify the perspectives and experience of our teams and select those who think creatively and are most likely to make a meaningful impact. Never make employment decisions based on characteristics protected by the law. The law doesn’t allow companies to discriminate against individuals based on certain personal characteristics that are unrelated to a person’s ability to do a job well.

Some examples include: Race or ethnicity. Gender or gender identity. Age, Religion, Disability, Veteran status, Sexual orientation, Marital or family status.

KEEP OUR WORK ENVIRONMENT SAFE

O’Brians takes the safety of our work environment and our employees seriously. We will never tolerate violence, threats or use of illegal drugs in our workplace.

DO IT RIGHT - Don’t make threats or show signs of physical violence. - If you see violent or aggressive behavior, report it. - Use common sense if you drink alcohol and never drive while impaired. - Remember that the use or sale of illegal drugs is never OK. Use common sense and be responsible. Although there may be times when hosted events include alcohol, we share a mutual understanding that alcohol should consumed responsibly.

WE PLAY FAIR.

At O’Brians, when we sell a vehicle to a customer or enter into a business relationship, we mean what we say. We will never be sneaky or try to disguise our intentions.

DO IT RIGHT - Remember that our customers trust us to be accurate, truthful and transparent. If you work with customers, contractors, or business partners, understand what you can and can’t promise. Get help from your manager if you have questions about any type of customer arrangement.

PROUD TO BE FAIR.

We are straightforward and transparent about the terms of our loans. We help to ensure the confidentiality and accuracy of documents, and we communicate with our customers about how we are using their credit information to make lending decisions. At O’Brians, we don’t discriminate against applicants for credit, or existing customers, based on race, gender, age or any other characteristic protected by the law.

DO IT RIGHT - Communicate clearly and as required by law with customers about details of their vehicle purchase. Treat all customers and applicants equally and with fairness. Never try to discourage a customer or applicant from applying for financing because of a personal characteristic that has nothing to do with creditworthiness.

BE DILIGENT.

At O’Brians, good customers are critical to our longevity as a business. We comply with laws that help detect criminal activity, such as money laundering through cash-based transactions.

DO IT RIGHT - Comply with all policies that help us screen and verify the identity of our customers. Watch for transactions over $10,000 that use cash or cash equivalents (e.g. cashiers checks) and if you see one, report it to the appropriate resource. Raise your hand if you have concerns that potential customers might be submitting false or falsified personal information.

Keep in mind that cash equivalents include certified checks, cashiers’ checks, money orders, wire transfers, drafting instructions, ACH, and debit cards.

BUILD BUSINESS RELATIONSHIPS.

Our company’s success is built on our innovative ideas and our talented people, and the amazing and consumer-friendly service we provide. We win customers on these merits, and not through attempts to gain an inappropriate advantage. We also want business partners who are focused on providing a transparent and fabulous customer experience. We expect our business partners to exhibit the same high standards of ethical behavior that we expect of ourselves.

DO IT RIGHT - Don’t bribe anyone - ever. Use good judgment if you enjoy business lunches, dinners or entertainment events in connection with business relationships or transactions. Never offer or accept something of value in exchange for influence in a business decision.

TELL THE TRUTH.

At O’Brians, we believe in creating full transparency in the car-buying process and in earning our customers’ trust every step of the way. We don’t engage in unfair, deceptive or abusive acts in advertising or any other part of our car-buying process.

DO IT RIGHT - Always do your best to ensure our customers can make informed decisions based on accurate information that conveys the true nature of our products and services. Never act in any way that could interfere with a customer’s ability to understand one of our products or services. Never present comparison data in a misleading way. Always ensure comparisons to competitor or industry rates and practices are done with specific factual documentation to support them.

MAKE FINANCIAL DISCLOSURES.

At O’Brians we make complete, accurate and timely disclosures of our financial information and we maintain accurate books and records that support our filings.

DO IT RIGHT - Record all financial information truthfully and accurately. Be diligent with all expense reporting and ensure that you file truthful reports in a timely manner. Never change a financial entry to align numbers with other corporate documents. Talk to your manager immediately if you have concerns related to accounting.

COMMUNICATE WITH THE PUBLIC.

Demonstrate good judgment when using social media - whether in your personal life or for business. Remember these important tips: Use common sense whenever you are using social media. Don’t forget that anything you say could be seen and commented on by thousands of people. Always be clear that your personal views are your personal views, and not the views of our Company. Don’t speak on behalf of O’Brians through social media outlets unless you have been authorized to do so. Do not disclose confidential or non-public information about O’Brians or about any of our customers or business partners while using social media.

PROTECT THE COMPANY’S INTEREST.

We put our Company, our Customers and our Communities first. At O’Brians, being part of our team requires us to ensure that our personal interests do not interfere with the best interests of the Company. If we have any type of interest that could conflict with the best interests of O’Brians, we disclose it to our manager or another appropriate compliance resource.

DO IT RIGHT - Avoid interests, activities or relationships that prevent you from remaining objective and fair when you make decisions that relate to O’Brians. Share conflicts of interest, or potential conflicts, with your manager or another appropriate compliance resource as soon as possible.

Some types of personal interests will always pose a conflict with our business. If you recognize one of these in your own life, disclose the situation to the Company right away.

EXAMPLES: Outside employment that limits your ability to meet your O’Brians responsibilities. Working for competitors, business partners or customers of O’Brians. Using O’Brians facilities or other property for reasons unrelated to your job. Holding a financial interest in a competitor. Hiring or directly supervising someone who is a close friend, romantic interest or a member of your immediate family. -Romantic relationship with a O’Brians co-worker

PROTECT THE COMPANY’S ASSETS.

Our customers trust us, and we trust one another to protect the Company’s property and assets from theft, damage, loss or misuse. Whether we are treating our office space with care or ensuring that we use Company vehicles only for Company-related business and within guidelines set out. Responsible use of our assets enables our business to run effectively.

DO IT RIGHT - Treat the Company’s property as if it were your own. Do not use company office space or other property for personal benefit.

PROTECT OUR CUSTOMER INFORMATION.

Our customers trust us to handle their personal information in the same way we would want our personal information treated. At O’Brians, we have policies in place to ensure that we protect customer information from loss, theft, or accidental disclosure. We also protect the personal information of our employees.

DO IT RIGHT - Be extremely careful when handling confidential information about our customers or our employees. Only access personal information of customers and employees if you need it to do your job. Don’t share or disclose customer or employee information unless you have a business reason and it’s permitted by our policies and the law. To protect our systems and networks, follow all information security policies, including Internet use and secure passwords.

SUPPORT OUR COMMUNITIES AND CARE FOR THE ENVIRONMENT.

We understand that part of our responsibility as a company means helping to take care of our surrounding communities. We are active in our local communities, promoting employee community service by supporting non-profit organizations. These initiatives help make our communities a better place to live.

DO IT RIGHT - Participate in Company-sponsored volunteering when you can. Let your voice be heard and share ideas for worthy causes. Pursue your passions and pitch in where you feel like you can make an impact. Be the kind of neighbor you’d want to live next door to.

WHEN IT COMES TO BUILDING A GOOD COMPANY, WE DO IT TOGETHER.

We’re relying on your good judgment always. The ultimate responsibility for complying with the O’Brians and all applicable laws and regulations rests with each of us. If you have questions or concerns about the Code of Conduct, contact info@ofinance.ca before taking any action.