Confidentiality Policy

Privacy Policy

Thank you for visiting the Baseline Telematics website. This online privacy policy is designed to tell you about how we will collect and use information from our site so that you can make an informed choice about using this site. Please be advised that your use of this site constitutes your acceptance of the provisions of this privacy policy. If you do not agree to these provisions, you should immediately terminate your access to and not use the site. Baseline Telematics reserves the right to change the provisions of this privacy policy at any time but will alert you that changes have been made by indicating on the privacy policy the date it was last updated. Your use of the site following the posting of such changes or revised policy shall constitute your acceptance of any such changes. We encourage you to review our privacy policy whenever you visit our website to make sure that you understand how your information will be used. Baseline Telematics Inc. is a company incorporated in the province of Quebec, Canada and controls this site from its Laval offices, according to Canadian law.

What information do we gather?

Information on baselinetelematics.com is gathered in two ways: (1) passively (for example, through our site’s technology); and (2) actively (for example, if you send us an e-mail request). When you visit our site, our software automatically collects some information from your computer. The information includes the unique Internet address assigned to your computer, your Internet service provider, your browser type and version, and your operating system. We also collect information when you voluntarily submit it to us. For example, if you ask for more information on the services that Baseline Telematics provides, we may store and use the information you provide for marketing purposes. If you submit a technical question to us, we may store your question and we may contact you if we need clarification on the question. Also, we may post your question along with our answer on our site. However, we will not include your last name or e-mail address if we post an answer to your question. Similarly, if you contact us through our site to inquire about employment opportunities with Baseline Telematics, we may collect and store the information you provide for recruiting purposes. On the recruiting site, you will be asked for information necessary for the recruiting process such as your name, contact information and technical experience. Because different jurisdictions have different privacy laws and Baseline Telematics is committed to complying with such laws, when applying for positions in some locations, you will need to indicate your consent to the following uses of your CV/Resume by Baseline Telematics before you can submit your candidacy: (1) Baseline Telematics, its affiliates, and agents will store, access, and use the information in any jurisdiction, including jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction; and (2) Baseline Telematics, its affiliates and agents, may use this information to evaluate your eligibility for employment and to contact you for recruiting purposes. Please note that people under 18 years old are not authorized to submit recruiting information.

What about sensitive personal data?

We do not generally seek to collect sensitive personal data through this site. If we do seek to collect such data, we will ask you to consent to our proposed uses of the data. We may also collect some sensitive personal data incidentally. By providing us with unsolicited sensitive personal data, you consent to our using the data subject to applicable law as described in this privacy policy. The references to “sensitive personal data” are to the various categories of personal data identified by European and other data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent. These categories comprise personal identity numbers, personal data about personality and private life, racial or ethnic origin, nationality, political opinions, membership of political parties or movements, religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, genetic code, addictions, sexual life, property matters or criminal record (including information about suspected criminal activities).

Do we give you access to your information?

You are entitled to know whether we hold information about you and, if we do, to have access to that information and require it to be corrected if it is inaccurate. You can do so by sending us an e-mail to support@baselinetelematics.com.

How do we use the information we collect?

We may collect the information you voluntarily submit to us and use it for the purposes for which it was submitted. We may also use the information that you voluntarily submit to us in the following ways:

  • to provide you with information about Baseline Telematics;
  • to request feedback and to enable us to develop and improve the features and content of the site and the services available from Baseline Telematics;
  • to contact you regarding your use of the site, changes to the terms of use, privacy policy, or other policies; and our use of the information you submit; and
  • to inform you regarding new site features, news about Baseline Telematics, events, marketing offers, products, services, and other opportunities.

If we wish to use the information for other purposes, we will notify you prior to such use. If you object to any such use, you can e-mail us at support@baselinetelematics.com and let us know of your objection, and we will not use your information for such purpose. If you wish to have any personal information you have sent to us removed from our database, please e-mail us at the same address.

What are cookies and how do we use them?

A cookie is a small file of information that our server may send to your computer when you visit our site. Cookies allow our server to track how you navigate through our site, such as what pages you viewed. If you are uncomfortable regarding cookies use, please keep in mind you can disable cookies on your computer by changing the settings in the preferences or options menu in your browser. However, disabling cookies may impair your ability to participate in certain activities on our site.

How do we use the information we collect passively and with cookies?

We may analyze the information we collect passively and with cookies to determine what is most effective about our site, to help us identify ways to improve it and, eventually, to determine how we can make it more effective. Baseline Telematics will not sell, lease, or rent information we collect passively or with cookies. Nor will we sell, lease, or rent information you provide to us directly. Baseline Telematics may disclose information it has collected if required to do so by law or in the good-faith belief that such action is reasonably necessary to (1) comply with legal process; (2) respond to any claims; or (3) protect the rights, property, or personal safety of Baseline Telematics, our customers, or the public. In addition, if Baseline Telematics or substantially all of its assets are acquired, information you have provided to us will be one of the assets that is transferred.

Disclosure of Personal Information

We will not disclose to unaffiliated companies any information we gather from you that could be used to personally identify or contact you (“Personal Information”), except as set forth in this privacy policy or as disclosed to you at the time you provided such information. Baseline Telematics may disclose such Personal Information to independent contractors, service providers or consultants who are engaged by or working with Baseline Telematics. We request that any third parties who obtain access to such information comply with the terms of this privacy policy.

Disclosure of Aggregate Information

We may provide information we collect that does not allow you to be personally identified or contacted (“Aggregate Information”) to third parties, including without limitation, information about your access and use of the site. For example, we might provide such Aggregate Information to a third party to inform the party of the number of users of the site and the activities they conduct while on the site.

Questions?

If you have any questions now or during your visit, please contact us at support@baselinetelematics.com.

Code of Business Ethics

1. Our Core Values

values that we embrace and consistently strive to implement in our daily work.

  • Act with integrity, dignity and respect
  • Achieve through teamwork
  • Focus on customers
  • Connect globally
  • Demonstrate a passion for technology
  • Build the Baseline Telematics experience

These core values serve as a compass to guide our decision-making at the company level as well as the individual level. Together, we put these values into practice to build a deeply skilled, world-class, global company. Our on-going commitment to these values is necessary to ensure that we will operate with the highest ethical standards and achieve our vision. The Baseline Telematics Code of Business Ethics describes and reinforces conduct that is based on our guiding core values, consistent with our policies and practices, and essential to our legal and regulatory compliance obligations. On our website, under Terms & Conditions, the Code provides references to underlying Baseline Telematics policies, which offer detailed, up-to-date ethical, legal and policy guidance which are central to our business activities and essential to us as representatives of Baseline Telematics. The Code of Business Ethics applies to all Baseline Telematics officers and employees. It also applies, as appropriate, to members of our Board of Directors, and to others, including individuals such as temporary support staff, third party contractors, and other service providers, when they act on behalf of Baseline Telematics. Each of us has a duty to become familiar with and abide by these principles in all of our business relationships and activities. Any waiver to the Code may only be granted by the Board or a special committee of the Board. Likewise, any amendment to the Code will be disclosed promptly in accordance with any applicable legal or listing requirements. We share responsibility as Baseline Telematics personnel and, as such, will we not hesitate to report any violations and protect from retaliation those who communicate their concerns.

2. Customers and the Marketplace

Baseline Telematics strives to create value for its customers. In so doing, it is essential that we conduct our business activities in a manner that is lawful and fair, with the highest level of integrity, to our employees, our customers, other stakeholders, and our communities. Customer Value Creation Baseline Telematics commits to provide quality service to its customers and collaborate with them to shape opportunities that are value-driven. Baseline Telematics places its customers’ interests first, and provides excellence in delivery. Competition and Fair Dealing Baseline Telematics abides by all laws and regulations that promote fair and open competition among companies. In no case will Baseline Telematics engage in activity that has the effect of restraining competition, such as agreements to fix prices. While Baseline Telematics personnel are encouraged to compete vigorously in the marketplace, each person must conduct our business affairs in a fair and lawful manner and avoid all forms of deceptive conduct or unfair advantage through manipulation, concealment, misrepresentation of material fact or otherwise. Treatment of Competitors> Baseline Telematics will always compete aggressively, but will treat its competitors fairly. It will market its services and solutions on their merits and will not disparage its competitors or provide misleading information about them. While gathering information about Baseline Telematics’ competitors is a legitimate business activity when done lawfully and ethically, it is never appropriate for Baseline Telematics personnel to obtain information about a competitor through improper means. Improper means can include:

  • misrepresenting one’s identity;
  • inducing an employee of the competitor to divulge confidential information; or
  • gaining improper access to a competitor’s confidential information, directly or through third parties.

Protection of Customer and Third-Party Information and Intellectual Property Baseline Telematics expects its members to take appropriate measures to protect copyrighted or licensed information as well as any confidential or otherwise protected information of our customers and other third parties. This includes understanding and abiding by any applicable contractual restrictions Baseline Telematics has agreed to follow with its customers or other third parties. We will not discuss, disclose, copy or otherwise use any copyrighted, licensed or confidential customer or third-party information without proper authorization from the owner, and then only as authorized and required as part of our work with Baseline Telematics and under no circumstances should be used for Baseline Telematics personnel may not use copyrighted, licensed, or confidential customer or third-party information for personal or other gain or advantage, or to advance the interests of Baseline Telematics, except where specifically authorized by Baseline Telematics and the affected customer or third party. It is the responsibility of each of us to take appropriate precautions to make sure unauthorized people do not have access to or use such information. Any third-party software used must be properly licensed. Government Contracting Almost every country and governmental entity with which Baseline Telematics conducts business has laws and regulations setting forth procedures and requirements for contracting with it. Baseline Telematics is committed to complying with all applicable government contracting laws and regulations. All personnel who serve government customers are responsible for understanding the legal requirements and restrictions that apply to such work. Accurate Invoicing Baseline Telematics personnel responsible for creating customer invoices use utmost care to prepare accurate invoices. Each and every invoice Baseline Telematics issues should be based upon accurate and complete information and should be in compliance with the underlying contractual arrangements. Gifts and Hospitality In order to maintain the highest standards of integrity and objectivity in dealing with customers and vendors, gifts or hospitality given or received must be of nominal value and in compliance with applicable law, the giver’s and receiver’s policies on the matter, and local business custom and practice. Generally, Baseline Telematics discourages providing gifts to public officials or inviting them to attend Baseline Telematics-sponsored events. Entertainment and meals offered or received as part of legitimate business activities are generally allowed, but must be within the boundaries of reason and moderation. Gifts of cash or cash equivalents to or from any current, former or potential customer or vendor are not permitted. Cash equivalents include checks, money orders, stocks and securities. Generally, raffles and prizes that are part of a business activity are not considered gifts, but approval must first be obtained. All gifts and hospitality offered by Baseline Telematics personnel must be recorded in accordance with its expense and reporting policies. Although gift giving is not prohibited among employees, it is important to use reason and good judgment when giving or accepting a gift. In most cases, gifts should be of a nominal value, and people should only be asked to contribute to a gift voluntarily. A gift should never be given to another employee to influence or show favoritism. Baseline Telematics-approves items provided to its employees as recognition for a business achievement or part of a sponsored event, but are subject to all applicable tax requirements. If a question arises, one should consult with the appropriate management personnel and disclose the situation. Questions concerning the permissibility of gifts should be referred to the local Baseline Telematics Legal Group representative or the Office of Ethics and Compliance.

3. Professional Conduct

Personnel must conduct themselves professionally in the workplace and appropriately in their work-related activities. Professional conduct is an integral part of Baseline Telematics’ image and business impact globally. Meritocracy All personnel have the right to be treated equitably and to work in an environment that is free from unlawful or unfair discrimination. To achieve this goal, Baseline Telematics personnel must support and promote the principles of meritocracy. Career decisions must be driven by an individual’s talents, skills, and abilities, in addition to the business need. Baseline Telematics is committed to preserving and enhancing diversity within the organization. Anti-Harassment Harassment in any form is unethical and can expose the company to legal liability if based on sex, race, religion, color, age, non-disqualifying physical or mental disability, national origin, sexual orientation, or any other category protected by law. Harassment can take the form of verbal comments, physical touching or other inappropriate conduct, and will not be tolerated. It could seriously undermine the integrity of the professional environment as one in which each person can grow and succeed as much as possible. Personnel have the right to work in an environment that is free from harassment and to report inappropriate behavior without fear of retaliation. Conflicts of Interest and Corporate Opportunities Personnel must avoid situations where they could potentially act in a way that is not in the best interest of Baseline Telematics and should endeavor to avoid even the appearance of a conflict of interest. Employees are responsible for ensuring that their personal interests, investments and activities (including those of family members) do not conflict with :

  • their objectivity or independent judgment;
  • Baseline Telematics’ best interests; or
  • any of Baseline Telematics’ relationships with its customers or vendors.

Personnel are not permitted to make decisions for, or recommendations to, Baseline Telematics concerning third parties in which it has any direct or indirect financial or other interest without full disclosure, as such an interest creates a potential for bias. Third parties include customers, alliance partners, venture portfolio companies, vendors and others. In any situation where there is a potential for bias, the decision maker should disclose the conflict of interest to an appropriate member of the management team. Personnel may not take opportunities for themselves that are discovered or created through the use of Baseline Telematics’ property, information, relationships or position, or use them for their own personal gain. It is not possible to identify all situations that could create a conflict of interest or the appearance of one, and Baseline Telematics places primary reliance on the good judgment and integrity of its people. It is always better to come forward before taking action than to have to explain your decision after the fact. Maintaining a Safe Workplace Violent conduct or threats of violent conduct in the workplace are never appropriate and will not be tolerated. Anyone who, while doing work for Baseline Telematics, engages in such actions or threats in the workplace, brings weapons or harmful or threatening materials into the workplace; or otherwise engages in such conduct outside the workplace while performing work on behalf of Baseline Telematics, will be subject to appropriate disciplinary action, which may include termination. Baseline Telematics endeavors to avoid unsafe working conditions that could affect its personnel, regardless of who owns the worksite. Any unsafe condition should be immediately reported to a supervisor or to the appropriate local Baseline Telematics security official. For the safety and health of employees and others, employees and their customers and guests who are present at Baseline Telematics facilities are required to be familiar with and follow all safety and emergency procedures posted or adopted by Baseline Telematics. Personnel must also be familiar with and follow the safety and emergency procedures applicable to them at customer sites. Prior Employment Obligations Baseline Telematics respects the continuing obligations that new and prospective personnel may owe to a prior employer, including restrictions on use or disclosure of confidential information and the solicitation of customers or employees. We expect them to uphold their valid and enforceable obligations to their prior employers and to notify us immediately if they believe any job activity may conflict with such obligations. Baseline Telematics requires that all incoming employees resolve any impediments to their employment before accepting an offer with our company. Personal Data Privacy Baseline Telematics is committed to respecting and protecting the legitimate interests of its people and of third parties in the privacy of their personal data. Many countries in which Baseline Telematics operates have specific laws and regulations dealing with the treatment of personal data. The European Union, in particular, has enacted very complex and detailed data privacy laws. All personnel are expected to follow these laws and regulations, as well as our own Data Privacy Policy. Internet, E-mail, and Voice Communications Personnel must exercise good judgment and act in a professional manner when using Baseline Telematics resources. This includes e-mail, Internet access and other external electronic systems. This expectation also extends to activities on customer systems or with customer provided access. All communications relating to business or using Baseline Telematics’ information technology resources are company property and must conform to internal policies for acceptable use of the Internet, e-mail, voice communications, and similar electronic media systems. Personal Activities Personnel are urged not to participate in outside activities that have a negative impact on the performance of their job, and because we do not want to damage our business, image, or reputation, we conduct our personal activities, which include our personal financial and tax affairs, in the same way that we conduct our business activities – with the utmost integrity.

4. Protection of Baseline Telematics Assets

Personnel are expected to use the highest level of care to safeguard, protect, and enhance Baseline Telematics’ assets, and to use them only for legitimate business purposes including real and personal property, intangible assets such as brand, intellectual property, reputation, and employees. Baseline Telematics Name and Brand Baseline Telematics’ name and brand identity are powerful and valuable assets that differentiate us from our competitors. Our name and brand identity represent us in the global market, and we reflect that market by having a global attitude. Our words and actions support and advance Baseline Telematics’ name, brand identity, brand positioning, and our personality as a company. We must treat the name and the brand in a globally consistent manner in all our activities and transactions. No third party has the right to use our name or brand without our prior written approval, and that approval must be granted in accordance with our naming and branding policies. Baseline Telematics Intellectual Property Personnel are expected to help develop and protect Baseline Telematics’ intellectual property. Baseline Telematics endeavors to protect its intellectual property rights to the greatest extent permissible and seeks appropriate protection in its contracts and in following copyright and patent laws. All work product created by Baseline Telematics personnel in the course of their employment should be the exclusive property of Baseline Telematics, and our people are expected to help identify and secure protection for these innovations. Baseline Telematics Confidential and Proprietary Information Personnel have a responsibility to protect Baseline Telematics’ confidential and proprietary information from disclosure and improper use which includes the information of its parent companies, its business associations, and of its customers. We expect our personnel to strictly adhere to our internal information security policies, communication policies, and agreements governing proper use and disclosure. Personnel may only disclose confidential and proprietary information if they have proper authority to do so, and even then, only to those with a legitimate business need to know it. Confidential and proprietary information includes but is not limited to any information or material not generally available to the public that is generated, collected or used by Baseline Telematics. Certain obligations with respect to Baseline Telematics’ confidential and proprietary information continue to apply even after association with Baseline Telematics ends. Baseline Telematics Financial Information Baseline Telematics is committed to full, fair, accurate, timely, and understandable disclosure in reports and documents submitted to regulatory bodies and its stockholders and in other public communications. Personnel should not share Baseline Telematics’ financial information with any third party unless the information has already been publicly reported, or a request has been sent to and approved by management. Baseline Telematics Computer Hardware and Electronic Device Protection Personnel are responsible for keeping their assigned computer equipment and other electronic devices and should take appropriate safety precautions when their equipment is unattended. Equipment must be protected at all times from theft and use by unauthorized persons. Certain security measures are detailed in internal policies, including the User Security Policy, and further information is included on the ITS and the Client Data Protection sections of this site. Financial Integrity and Reporting Baseline Telematics is required to comply with Generally Accepted Accounting Principles (“GAAP”), and its personnel are required to comply with internal accounting and auditing controls and obey applicable laws. Records and reports must accurately and fairly reflect, in reasonable detail, Baseline Telematics’ assets, liabilities, revenues and expenses. All transactions must be recorded accurately using the proper charge number and in the proper accounting period and be supported by precise documentation. Time and Expense Reporting Employees are responsible for submitting timely, accurate, and complete time and expense reports in accordance with internal policies and applicable regulations, using valid reporting tools designated for each country. If any discrepancy exists, the matter will be investigated. In certain instances, time and expense reports must also comport with our customers’ policies. If this is the case, it is the consultant’s responsibility to be aware of and to comply with those policies. Commitment to Customers Personnel must ensure appropriate approval and authorization are obtained when engaging customers or making commitments on behalf of Baseline Telematics. The approval process ensures that the appropriate people review proposals to commit the company, that business engagement is valid and goods and services can be provided based upon the required specifications, and that contract meets legal requirements and is otherwise compliant with our policies. Purchasing and Payments Personnel must ensure appropriate approval and authorization are obtained before purchasing commitments and invoice payments are made. Baseline Telematics will purchase goods and services only on the merits of price, quality, performance, and suitability. No Baseline Telematics person may knowingly cause or direct the company to purchase goods or services of any kind, for itself or its customers, from vendors owned or controlled by Baseline Telematics personnel or their immediate family members. Archives and Records Management Baseline Telematics maintains, manages, stores, and disposes of its archives and records in compliance with its contractual obligations and applicable legal and regulatory requirements, such as tax or data privacy laws. Certain company records, such as tax materials or documents required in legal proceedings, may be retained for extended periods. If you receive a notice from the Baseline Telematics Legal Group to preserve certain records (a “Hold Notice”), you must comply strictly and preserve all electronic and paper records described in the Hold Notice, including e-mails and drafts, until you receive further instructions from the Baseline Telematics Legal Group. Baseline Telematics prohibits the destruction or alteration of any materials relevant to such an investigation or litigation. If you become aware that a government investigation, a dispute, or litigation involving Baseline Telematics has been threatened or initiated, you must immediately contact your direct supervisor and the Baseline Telematics Legal Group. Until you have legal guidance, you should not destroy or delete electronic or paper records related to the subject matter of the investigation, dispute or litigation

5. Baseline Telematics as a Local and Global Citizen

Every member of Baseline Telematics must understand that Baseline Telematics is committed to being a good local and global citizen, as grounded in our core values. Compliance with Laws Baseline Telematics and its personnel have a responsibility to comply with all applicable laws. If a local law conflicts with the Code of Business Ethics, we will comply with the law. If a local business practice conflicts with our Code, we follow our Code. When in doubt, ask for assistance from our legal department. Improper or Questionable Payments Baseline Telematics prohibits any undisclosed, unrecorded or falsely recorded transactions as well as any payments made for other than their stated purpose. Baseline Telematics will not pay bribes or make improper payments to obtain new business, to retain existing business or to secure any improper advantage. Moreover, we will not use others to act on our behalf. Accepted local business practices that ignore or even condone bribery are irrelevant. Bribery is illegal in every country where Baseline Telematics operates. Local requirements vary, but all Baseline Telematics personnel must adhere to the same high standards regardless of work location. When in doubt, contact the Area President and the Baseline Telematics Legal Group. Insider Trading Many countries have laws prohibiting the purchase or sale of a security on the basis of material information that is not publicly known, and that, if publicly known, would have affected the market price of the security. Generally speaking, information is considered material if a reasonable investor would likely consider it important in deciding whether to buy or sell the security and it could affect the price of the security. Personnel possessing such material information about a security may not buy or sell the security (whether it be Baseline Telematics securities or the securities of a customer or third party) or provide that material information to others, until such time as the information becomes public. Immigration Baseline Telematics complies with the immigration laws of the locations in which its people are working. Everyone Baseline Telematics hires must have current, valid authorization to work in the country of their employment. When working outside their home country, Baseline Telematics personnel must obtain all required visas and work permits before they arrive in the host location. Export Control Laws and Boycotts Baseline Telematics complies with applicable export control and anti-boycott laws and regulations in the countries within which Baseline Telematics operates. Export control laws may restrict the export or re-export of goods, software and technology that originate in a country in which Baseline Telematics operates. Export laws may also restrict shipments of certain foreign-made products incorporating Baseline Telematics technology and software, as well as transfers of controlled technology to certain foreign nationals, whether in the local country or abroad. The anti-boycott laws and regulations may prohibit Baseline Telematics from entering into contracts or agreements or to refuse to do business with certain countries or companies, provide information about its business relations with certain countries or companies, or discriminate against, or provide information about, individuals or companies on the basis of race, religion, gender, national origin, nationality, or any other classification prohibited by law. In some cases, Baseline Telematics may be required to file a request to participate in any of the above to the government. Sanctions and Embargoes Various governments have programs of economic and trade sanctions against certain countries, terrorists, terrorism-sponsoring organizations, entities involved in the proliferation of weapons of mass destruction, and international narcotics traffickers. In some cases, even an indirect facilitation of a transaction is prohibited. The Environment Baseline Telematics is committed to the protection of the environment and will comply with all applicable environmental laws and regulations of the countries in which it conducts business. Political and Charitable Contributions and Activities The law in many countries sets strict limits on contributions by corporations and government contractors to political parties and candidates, and violators are subject to very serious penalties. Because of the complexity, variability, and severity of laws governing corporate political activities, Baseline Telematics, its people and agents will not engage in any corporate political activities without first obtaining written consent from the Baseline Telematics Legal Group and, in all cases, only for proper and legal purposes. Personnel remain free to make political contributions in their personal capacity as they deem appropriate. Baseline Telematics will not reimburse such expenditures. Cash or in-kind contributions to political candidates and organizations using Baseline Telematics resources are prohibited. Use of the Baseline Telematics name or brand to endorse a political activity or event is not permitted. Baseline Telematics supports community involvement by its people as private individuals. Use of the Baseline Telematics name to endorse a charitable organization or event is not permitted without prior approval by an appropriate member of the management team.

6. Our Responsibility

As employees of Baseline Telematics, we acknowledge that violating the Code of Business Ethics, including our obligation to report violations or to cooperate in any investigation of suspected violations, constitute a breach of confidence with Baseline Telematics and our customers and open the door to individual disciplinary action, including termination, and perhaps to legal liability. All personnel are expected to become familiar with our Code and policies and must comply with them at all times. Nothing in the Code constitutes a contract of employment with any Baseline Telematics person. Any violations of this nature should be reported through normal channels to any member of management, or through the Baseline Telematics Business Ethics Line described in the next section. All personnel must speak up or take action if they are aware of any potentially unlawful, unethical, or fraudulent activity. Each of us certifies our compliance with this Code when we file our time reports. We may also be asked periodically to certify our compliance with the Code or specific policies regarding other employment duties. The Code shall apply to all employees, members of the Board of Directors, temporary support staff, third-party contractors and service providers when they act on behalf of Baseline Telematics.

7. Where to Go for Help

In the event that you have questions about the Baseline Telematics Code of Business Ethics, any policy, or whether past or contemplated conduct may present ethical or legal issues, you may avail yourself of the following resources depending on the circumstances:

  • discuss the issue with a direct manager, a Human Resources representative, or a member of the Baseline Telematics Legal team; or
  • send your questions to support@baselinetelematics.com

Reporting Responsibility Employees who come forward with concerns play an important role in maintaining our ethical workplace and high performance business, as well as in protecting our shareholder value. Retaliation will not be tolerated against any employee on the basis that the person raised a concern or used the Baseline Telematics Business Ethics Line (or any other appropriate channel) to report an ethical or legal issue in good faith. Audit Committee Reporting In addition to the Business Ethics Line telephone and web reporting, employees may direct concerns about certain matters to the Audit Committee Chairperson by e-mailing the concern to ethics@Operasoft.com if your concerns involve the following:

  • Financial affairs;
  • Accounting practices;
  • Auditing matters; or
  • Potential corruption or fraud.

The importance of Ethics and Compliance If you find yourself facing a situation where the decision does not feel “right” and no Code principle or Baseline Telematics policy seems to address the situation or you need more guidance or information, or have any questions about policies, please contact support@baselinetelematics.com.