Our Policies

Contents:

Our Customers
Our Human Resources
Our Acquisition of Goods and Services and Contract Conditions
Our Business Partners
Our Finances
Our Assets
Our Environment
Our Social Role
Our Management
Our Security
Financial Disclosure

 

 

Our Customers

1.    Introduction

This policy sets out Ivy's commitment to its customers. It presents the orientations that the company intends to adopt to guide its practices, including product and service offerings, pricing, and customer relations. 

2.    General Principles

Ivy adopts strategies and business practices that meet its customers’ needs by offering quality products and services in a cost- effective manner. Thus: 

Products and services

To provide customers with quality products and services, Ivy undertakes to:

  • supply renewable electricity;
  • ensure a reliable, secure power supply that meets the standards in effect;
  • supply products, energy efficiency advice and high-quality customer service;
  • continuously improve the quality of its products and services in line with industry standards and a changing business context. 

Price

Given the regulatory framework and rate context which governs in each market, Ivy intends to:

  • maintain uniform rates throughout its service territory for each customer category, taking the special features of off-grid systems into account;
  • offer the same conditions for service where possible;
  • adjust the structure of each rate to offer a better price signal promoting energy efficiency;
  • offer rate options, depending on the business context, that enable optimal management of electricity consumption. 

Customer relations

To maintain quality relations with its customers, Ivy undertakes to:

  • communicate regularly with its customers in a clear and coherent fashion;
  • give customers information enabling them to make informed decisions on electricity use and the service conditions in effect;
  • take into account the changing needs, expectations and characteristics of each customer category;
  • measure customer satisfaction and include this aspect in its objectives;
  • make customers aware of the uses of electricity and the advantages of adequately managing their energy consumption;
  • suggest mechanisms to efficiently resolve customer dissatisfaction and support the improvement process to prevent similar complaints from recurring. 

3.    Accountability 

Responsibility

Each manager is responsible for applying the general principles of this policy and for reporting the results to management. 

Exceptions

Any deviation from one or more of these principles should be indicated in recommendations submitted for approval to the Board of Directors. 

Concerns

In the case of a specific concern, the Board of Directors or the President and Chief Executive Officer may at any time request a report on the application of a given general principle of this policy. 

Action

The President and Chief Executive Officer and the Board of Directors will review, on an annual basis, the application of the general principles contained in this policy.

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Our Human Resources

1.    Introduction

This policy sets out Ivy’s commitment to its employees. Ivy operates in a work environment based on respect for the individual. It is an environment characterized by strong leadership and organizational capability that take into account the realities of each unit of the company and allow all employees to develop and maintain their skills, to be involved and to contribute to the achievement of the company’s business results.

In return, Ivy expects its employees to maintain work relations that respect others and to contribute to the achievement of the company’s business objectives. 

2.    General principles

In Ivy’s overall strategy, employees are deemed essential to the realization of the corporate vision. Employees’ skills, motivation, working conditions and relations, performance, health and safety are factors related directly to its success. Accordingly, Ivy’s commitment to its employees is as follows: 

Skills

To maintain and enhance the skills needed to achieve its business objectives, Ivy undertakes to:

  • attract, recruit, integrate and retain a diversified and competent work force that shares its values and is motivated to help improve the company’s competitive advantage;
  • offer its employees the best opportunities and strategies for professional development to ensure a high level of skill, expertise and leadership at all times;
  • ensure succession planning and the continuity of know-how;
  • ensure that women, Aboriginal peoples, visible and ethnic minorities, and handicapped persons are equitably represented within the organization.

Employees, for their part, are responsible for their own development and for helping maintain know-how within the company. 

Motivation

To motivate its employees, Ivy undertakes to:

  • communicate regularly and openly, and in a coherent and clear fashion, its vision, orientations, expectations and achievements, in an environment where everyone actively participates in discussions and in sharing information, while maintaining the confidentiality of strategic information;
  • create a dynamic, people-focused organizational environment where performance, whether individual, team or corporate, is encouraged and recognized, and where individuals take responsibility and develop their own autonomy;
  • develop a climate of trust and openness where all employees grow and develop, innovate and express creativity, and are recognized for contributing to their full potential;
  • listen to employees’ expectations and concerns and take steps to improve their level of satisfaction;
  • encourage, insist on and value employees’ contribution to the company’s growth;
  • provide employees with the tools essential to their work so they can contribute to the company’s commercial success.

Employees, for their part, have an obligation to contribute to the achievement of their unit’s objectives related to motivation. 

Working conditions

To offer working conditions adapted to the company’s social and commercial environment, Ivy undertakes to:

  • give employees competitive and fair working conditions, in line with the company’s compensation guidelines, so as to improve work organization, flexibility and efficiency, while recognizing employees’ needs regarding their quality of life;
  • guarantee equitable relations and a healthy work climate that is free of discrimination, violence, abuse of power and harassment and where each person develops and maintains relations based on respect, is treated with dignity and has the opportunity to participate fully in the realization of the corporate vision;

Employees, for their part, must show integrity, loyalty and diligence toward the company by respecting people and the environment. They shall respect the rules of ethics, protect confidential information and deal equitably and courteously with customers, suppliers and partners. 

Performance

To aim for excellence in all its operations, Ivy undertakes to:

  • pursue the development of a business culture focused on results and profitability, where all understand their role and the contribution expected in the implementation of their unit’s business plan and the company’s strategic orientations;
  • manage employees’ performance and presence at work.

Employees, for their part, are obliged to be present at work and to contribute, through the quality and quantity of their work, to the achievement of their unit’s business plan.

Health and safety

To be proactive in health and safety, Ivy undertakes to:

  • provide a safe, healthy work environment and take the necessary measures so that employees can perform their duties in a manner that does not jeopardize the physical and mental health or safety of themselves, others or the public;
  • put in place adequate means to eliminate hazards, reduce and control risks and ensure that employees have health and safety information and training relevant to their work;
  • ensure that its facilities, equipment, processes and operations comply with the laws, regulations and guidelines in effect.

Employees, for their part, must contribute fully to create and maintain a healthy, safe work environment by:

  • applying the work methods and safety rules specific to their area of activity;
  • adopting safe behavior to protect the health and safety of themselves, others and the public;
  • participating actively in health and safety prevention, information and training activities;
  • reporting any situation that may present a risk to the health and safety of themselves, others or the public. 

3.    Accountability 

Responsibility

Each manager is responsible for applying the general principles of this policy and for reporting the results to management. 

Exceptions

Any deviation from one or more of these principles should be reported to the Board of Directors. 

Concerns

In the case of a specific concern, the Board of Directors or the President and Chief Executive Officer may at any time request a report on the application of a given general principle of this policy.

Action

The President and Chief Executive Officer and the Board of Directors will review the application of the general principles contained in this policy on an annual basis.

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Our Acquisition of Goods and Services and Contract Conditions

1.    Introduction

This policy sets out Ivy's commitment regarding the acquisition of goods and services. Ivy aims to efficiently acquire the goods and services needed for the conduct of its day-to-day business and strategic operations; strategic goods and services are those required for its basic mission, that is, the generation of renewable energy. This policy lays down the general principles the company applies in the acquisition of goods and services, as well as in the terms and conditions of its contracts. 

2.    General Principles

Ivy must obtain its goods and services at the appropriate time and location, in the necessary quantities and of the necessary quality, and at the best cost. To this end, it deals with competent and effective goods and services suppliers and ensures equitable and confidential treatment of those suppliers, while avoiding any conflict of interest. Thus: 

Security of supply

To ensure a secure supply of strategic goods and services needed to carry out its basic mission, Ivy undertakes to:

  • help maintain an adequate number of competent suppliers to maintain the required level of know-how. 

Sustainable development

To make its acquisitions in a sustainable manner, Ivy undertakes to:

  • specify its sustainable development requirements to its suppliers, where applicable, notably by taking preservation of the environment and natural resources into consideration. 

Quality

To obtain quality goods and services with a view to continuous improvement, Ivy undertakes to:

  • verify the qualifications of its suppliers and their ability to meet the company's requirements;
  • specify its technical, commercial and other needs and requirements to its suppliers, as well as the safety rules required by the company;
  • manage the quality of goods and services needed for its basic mission by detailing its needs in terms of quality, by ensuring that its suppliers have an adequate quality management system and by carrying out adapted monitoring to ensure the quality of goods and services;
  • evaluate the performance of its suppliers according to criteria known by them, to inform them of this evaluation, and to use it in making decisions regarding future acquisitions. 

Efficiency

To obtain the best terms on the market, Ivy undertakes to:

  • optimize procurement management by planning and grouping together its needs with respect to goods and services;
  • generally favor acquisition methods that encourage competition among suppliers;
  • award contracts to suppliers who meet the specified requirements at the best cost;
  • develop long-lasting business relations with its suppliers if such relations will further common objectives in terms of cost reduction, quality improvement or technological development, with a view to increased profitability.

3.    Accountability 

Responsibility

Each manager is responsible for applying the general principles of this policy and for reporting the results to management. 

Exceptions

Any deviation from one or more of these principles should be indicated in recommendations submitted for approval to the Board of Directors. 

Concerns

In the case of a specific concern, the Board of Directors or the President and Chief Executive Officer may at any time request a report on the application of a given general principle of this policy. 

Action

The President and Chief Executive Officer and the Board of Directors shall review the application of the general principles contained in this policy on an annual basis.

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Our Business Partners

1.    Introduction

This policy sets out Ivy's commitment to and its expectations of its business partners. The company establishes partnerships based on mutual respect and on an equitable and sustainable sharing of risks and benefits. This policy lays down the principles and orientations that guide the development and deployment of such partnerships. 

2.    General Principles

Ivy intends to form business partnerships in line with its values and strategic orientations, based on true mutual interests and with a view to generating profits or savings. Thus:

  • To ensure the development and deployment of profitable partnerships, Ivy undertakes to: 

Development of partnerships

  • give preference to business partnerships in marketing its know-how, technology and assets;
  • favor business partnerships that include the pooling of complementary expertise and, if necessary, the pooling of assets;
  • favor business partnerships that promote renewable technology;
  • use standard procedures and known, recognized criteria in choosing the preferred form of partnership and in selecting partners. 

Deployment of partnerships

  • sign formal agreements with its partners, clearly stipulating the terms, conditions and obligations binding the parties;
  • recognize and respect the degree of autonomy conferred by the partnership agreement;
  • conduct financial and commercial transactions with its partners on a business basis.

3.    Accountability 

Responsibility

Each manager is responsible for applying the general principles of this policy and for reporting the results to management.

Exceptions

Any deviation from one or more of these principles should be indicated in recommendations submitted for approval to the Board of Directors. 

Concerns

In the case of a specific concern, the Board of Directors or the President and Chief Executive Officer may at any time request a report on the application of a given general principle of this policy. 

Action

The President and Chief Executive Officer and the Board of Directors will review the application of the general principles contained in this policy on an annual basis.

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Our Finances

1.    Introduction

This policy sets out Ivy's commitment regarding financial management. Ivy manages its finances so as to meet the expectations of its shareholders, protect its assets at all times and support its growth. Specifically, this policy covers activities related to financial management and operations, accounting, and protection of financial resources. 

2.    General Principles

Ivy maintains a management environment that enables it to increase the long-term value of its assets and its equity, ensure its financial viability, safeguard its financing capability, and protect its funds and securities. Thus: 

Financial management

To consolidate its financial position and provide the latitude needed for expansion, Ivy undertakes to:

  • protect its principal sources of revenue and develop its business in accordance with its Business Strategies;
  • rigorously manage its costs through continuous improvement and process control;
  • rigorously gauge the profitability of its investments and maintain their overall economic value;
  • maintain a capital structure in keeping with the nature of its activities and its business risks;
  • establish financial plans that will help to ensure an overall return comparable to that of the most successful companies in its industry;
  • meet its fair share of the fiscal obligations related to its activities at home and abroad;
  • optimize working capital management;
  • set up an insurance program that will safeguard the continuity of its sources of revenue;
  • optimize its financial results while maintaining an acceptable level of risk compatible with prudent management;
  • manage its financial risks on an integrated basis and using the appropriate coverage, as required. 

Financing and investments

To ensure timely and optimal-cost availability of the funds needed for operations, Ivy undertakes to:

  • develop and maintain an annual borrowing program;
  • establish rigorous criteria to justify its financing decisions;
  • use the sources of financing most likely to ensure that funds are available when needed, in the quantity required, and in the right currency according to business and market conditions;
  • adopt a financing strategy that takes financial risk into account;
  • establish rigorous criteria for choosing financial counterparties;
  • make investments that offer optimum return while ensuring availability of the funds when needed, assuming acceptable risk compatible with prudent management;
  • stay at the leading edge of this field with the goal of maintaining the highest level of proficiency needed to achieve its objectives. 

Protecting resources

To ensure the safety of its funds and securities, Ivy undertakes to:

  • take the necessary steps to ensure the secure transfer of its funds and securities;
  • manage the risk of financial losses by using various forms of protection, when judged necessary. 

Accounting

To allow monitoring of its financial position by its shareholder, lenders, energy regulatory agencies, business partners and other stakeholders, and to support the quality of their decisions, Ivy undertakes to:

  • produce quality financial information at the appropriate time and in the appropriate form;
  • ensure at all times the integrity and completeness of the data underlying the financial information it produces and regularly verify the quality and reliability of such data through control evaluations;
  • influence and remain constantly abreast of new accounting conventions, standards and practices with the aim of maintaining the highest possible level of knowledge and ensuring compliance of its financial information with these concepts, standards and practices;
  • provide the managers of business units with an appropriate information structure for managing their operations. 

3.    Accountability 

Responsibility

Each manager is responsible for applying the general principles of this policy and for reporting the results to management. 

Exceptions

Any deviation from one or more of these principles should be indicated in recommendations submitted for approval to the Board of Directors.  

Concerns

In the case of a specific concern, the Board of Directors or the President and Chief Executive Officer may at any time request a report on the application of a given general principle of this policy. 

Action

The Chief Financial Officer produces the following reports each year:

  • quarterly and annual consolidated financial statements; and,
  • periodic corporate reviews of expected results.

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Our Assets

1.    Introduction This policy sets out Ivy commitment regarding its assets.

Ivy intends to acquire, manage and dispose of its assets in the best interests of the company. 

2.    General Principles

Tangible and intangible assets

Ivy acquires, manages and disposes of all its tangible assets (property and inventory) and intangible assets (software, intellectual property,) profitably, while ensuring the quality of the services provided to its customers. Thus:

Ivy undertakes to:

  • acquisition
    • acquire its assets just in time according to the company's business planning and needs, the particular context and market conditions; 
  • management
    • manage all its assets based on the risks they represent in terms of customer service quality, health and safety, and respect for the environment;
    • maintain them in the state of availability and reliability required for their operation;
    • operate them according to their design characteristics so as to ensure long-term operability;
    • protect them according to their nature and value;
    • make them profitable, when deemed appropriate, by prolonging their useful life, reusing or disposing of them;
    • free assets from any environmental or other constraint prior to their disposal. 

Information resources

To ensure that its information resources (essentially financial and management information, data on its employees, customers, suppliers and business partners) are managed effectively and safely, Ivy undertakes to:

  • manage their access according to responsibilities and risks, safeguarding their integrity;
  • protect them in accordance with their strategic importance and sensitivity;
  • respect the confidentiality of personal and commercial information on its employees, customers, suppliers and business partners. 

3.    Accountability 

Responsibility

Each manager is responsible for applying the general principles of this policy and for reporting the results to management. 

Exceptions

Any deviation from one or more of these principles should be indicated in recommendations submitted for approval to the Board of Directors. 

Concerns

In the case of a specific concern, the Board of Directors or the President and Chief Executive Officer may at any time request a report on the application of a given general principle of this policy. 

Action

Each year, on the basis of information supplied by the division presidents or group executive vice presidents, the Executive Vice President – Finance or Chief Financial Officer presents the report on assets, to comply with the accountability requirement of this policy.

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Our Environment

1.    Introduction

This policy sets out Ivy's orientations and commitment toward the environment. Ivy emphasizes the judicious use of resources from a sustainable development perspective. 

2.    General Principles

Ivy is a leader in the environmental field. By using renewable resources to generate electricity, Ivy protects the environmental heritage for future generations. It develops profitable, environmentally acceptable projects that are well received by host communities. It practices rigorous environmental management with a view to continuous improvement. Thus: 

Sustainable development

To contribute to sustainable development, Ivy undertakes to:

  • promote more efficient use of electricity;
  • give preference to sources of renewable energy, such as wind power;
  • use resources as efficiently as possible, promote responsible consumption and practice reduction at source, reuse and recycling. 

Continuous improvement of environmental performance

To improve its environmental performance, Ivy undertakes to:

  • include environmental concerns in its decision-making processes and at all stages in the life cycle of its products, services and facilities, in such a way as to prevent pollution, manage impacts at source, mitigate negative impacts and maximize positive impacts;
  • adopt a transparent approach by encouraging the participation of local communities in the environmental assessment of its activities, programs and projects;
  • make its business partners and suppliers aware of the need for responsible environmental management of their activities, products and services;
  • carry out or support technological innovation and research on the environmental impacts of its operations.


3.    Accountability 

Responsibility

Each manager is responsible for applying the general principles of this policy and for reporting the results to management. 

Exceptions
Any deviation from one or more of these principles should be indicated in recommendations submitted for approval to the Board of Directors. 

Concerns

In the case of a specific concern, the Board of Directors or the President and Chief Executive Officer may at any time request a report on the application of a given general principle of this policy. 

Action

The President and Chief Executive Officer and the Board of Directors will review the application of the general principles contained in this policy on an annual basis.

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Our Social Role

1.    Introduction

This policy sets out Ivy's commitment regarding its social role from a sustainable development perspective. As a responsible corporate citizen, Ivy makes a significant contribution to the economic, social and cultural growth of the society in which it operates. 

2.    General Principles

As an owner, manager of society’s resources, purchaser and good corporate citizen, Ivy considers its social role paramount and fundamental. The company practices social responsibility by taking the entire life cycle of its products and services into account. Thus: 

Economic, regional and social development

To effectively perform its role as an economic generator and a responsible corporate citizen, Ivy undertakes to:

  • contribute to the economic and social development of host communities where new generating and transmission facilities are built;
  • contribute to research and development in fields related to its Vision;
  • contribute to social and cultural vitality and collective well-being by supporting various humanitarian, community, educational and health- related activities, and by partnering with various cultural, environmental, socioeconomic or sports events. This commitment is detailed in the company's Donation and Sponsorship Policy;
  • support employees who do volunteer work in their community;
  • open some of its facilities to the public to make its issues, technologies and heritage known, while contributing to the development of regional tourism.

Development of society's resources

To properly assume its role as a corporate owner and manager of society's resources, Ivy undertakes to:

  • favor the multi-purpose use by third parties of its equipment and property, without jeopardizing their reliability, security and profitability. 

Communities and interested parties

As a company that pays attention to the needs of communities and other stakeholders interested in its activities, Ivy undertakes to:

  • work in concert with communities,  in its planning, design, construction and operating activities; and, as required, to conclude agreements that are of mutual benefit. 

3.    Accountability 

Responsibility

Each manager is responsible for applying the general principles of this policy and for reporting the results to management. 

Exceptions

Any deviation from one or more of these principles should be indicated in recommendations submitted for approval to the Board of Directors. 

Concerns

In the case of a specific concern, the Board of Directors or the President and Chief Executive Officer may at any time request a report on the application of a given general principle of this policy. 

Action

Ivy will produce an annual report on sustainable development that includes its key achievements related to its social role. It will also produce an annual activity report containing profiles by region, including information on its economic and social participation. In addition, it files an annual statement of donations and sponsorships.

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Our Management

1.    Introduction

This policy sets out Ivy's commitment to ensuring rigorous management that is transparent and respectful with regard to the Board of Directors and the various stakeholders. This policy presents the company's commitments as they pertain to its management principles, risk management, control of activities, ethics, communications  and communication. 

2.    General Principles 

Management

To engage in strategic management focused on growth and profitability, Ivy undertakes to:

  • ensure that the company’s development in terms of equity, markets, assets and resources, as well as the objectives of its administrative units, are designed, carried out and evaluated according to the desired strategic positioning;
  • develop and improve its management practices with a view to achieving its business objectives. 

Integrated business risk management

To ensure its continuity and the achievement of its objectives, Ivy undertakes to:

  • strengthen its ability to create value;
  • manage the risks related to each of its activities and operations according to a tolerance level that is acceptable to the company and in keeping with the expectations of its shareholder, its creditors and its customers;
  • manage its risks in an integrated and proactive manner so as to obtain a complete picture and thus improve its ability to react quickly and effectively to changes;
  • consider integrated business risk management to be an explicit and permanent component of its decision-making process.


Control

To ensure that its management system facilitates the achievement of its business objectives and, consequently, its financial results, Ivy undertakes to:

  • establish and maintain control methods in all its spheres of activity, and pay particular attention to areas where the risks and stakes are high;
  • continuously improve its internal system of controls, based on, among other things, the recommendations of the various recognized organizations in the field;
  • implement and monitor the complaint handling process concerning irregularities related to internal control and fraud;
  • regularly evaluate its control mechanisms and immediately correct any shortcomings. 

Ethics

To ensure ethical behavior, Ivy and its employees undertake to:

  • carry out their functions in accordance with laws, regulations, corporate guidelines and other specific rules of ethics adapted to particular situations;
  • refuse to conduct any transaction, conclude any agreement or take any action that goes against the policies governing their activities or the rules of sound administration and good conduct;
  • treat all company employees and customers, suppliers and other parties associated with the company with courtesy, attention, good faith and fairness;
  • avoid all conflicts of interest as well as any situation likely to create a conflict of interest;
  • maintain records and files that accurately reflect the reality of the subjects involved and that accurately and fairly depict the nature of transactions and the use of the company's assets;
  • take actions that can be openly discussed in public if required.

Ivy also acknowledges that its employees may participate in community activities in an individual capacity. 

Communications

To communicate effectively, Ivy undertakes to:

  • have the necessary information regarding all its activities, in order to make sound decisions;
  • properly inform its shareholders, the general public, its customers and employees, communicating in a respectful, consistent and transparent manner, while taking business imperatives into account;
  • maintain a presence with its various publics and partners so as to facilitate access to the company and its representatives, in a spirit of openness.


3.    Accountability 

Responsibility

Each manager is responsible for applying the general principles of this policy and for reporting the results to management. 

Exceptions

Any deviation from one or more of these principles should be indicated in recommendations submitted for approval to the Board of Directors. 

Concerns

In the case of a specific concern, the Board of Directors or the President and Chief Executive Officer may at any time request a report on the application of a given general principle of this policy. 

Actions

  • Management

At regular intervals, the company reports to the Board of Directors on its plans and on the assessment of its risk portfolio and level of residual risk.

  • Control

Each year, the external auditors submit their observations and recommendations regarding the company’s internal controls related to financial information.

  • Ethics

The President and Chief Executive Officer and the Board of Directors will review the application of the general principles contained in this policy on an annual basis.

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Our Security

1.    Introduction

This policy sets out Ivy’s commitment with regard to security. Ivy takes every step to ensure the security of its employees and others against the risks, threats, dangers, emergency situations and exceptional circumstances that could occur during the course of its operations. It also ensures maximum security and protection of all its tangible assets needed to accomplish its Vision. This policy outlines Ivy’s orientations with regard to the security and safeguarding of persons and assets. These orientations are established by the President, the Chief Executive Officer and the Board of Directors. 

2.    General principles

In keeping with the strategic importance of its assets for the purposes of its Vision, Ivy plans and implements risk and vulnerability analysis programs as well as a security plan for its installations, which is monitored continuously. Thus:

To maximize protection of persons and assets, Ivy undertakes to:

  • constantly improve the physical, technological and human means of protection;
  • anticipate, evaluate and mitigate risk and threats, together with all electricity industry authorities, and in close collaboration with all organizations involved in prevention and security;
  • promote a culture of security within the company and in the host environments of Ivy assets, and raise public awareness and the awareness of its partners regarding the key principles of security. 

Optimization and performance

To optimize its security performance, Ivy undertakes to:

  • integrate security into all its decision making;
  • monitor and analyze global security trends;
  • draw inspiration from the industry’s best practices in the field;
  • constantly improve its security services;
    maintain, and exceed, industry standards. 

Scope

To assume its leadership role in the field of security, Ivy undertakes to:

  • share its expertise with its partners;
  • participate in the large gatherings and important associations of the North American electricity industry. 

Research and development

To excel in security, Ivy undertakes to:

  • encourage and support research and development in the fields of security and related science and technology. 

3.    Accountability 

Responsibility

Each manager is responsible for applying and following the general principles of this policy and for reporting the results to management. 

Exceptions

Any deviation from one or more of these principles should be indicated in recommendations submitted to the Board of Directors. 

Concerns

In the case of a specific concern, the Board of Directors or the President and Chief Executive Officer may at any time request a report on the application of a given general principle of this policy. 

Action

The President and Chief Executive Officer and the Board of Directors will review the application of the general principles contained in this policy on an annual basis.

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Financial Disclosure

1.    Financial disclosure

This policy sets out Ivy’s commitment with regard to the disclosure of financial information.

The policy applies to Ivy employees, executives and directors.

The policy is aimed at the disclosure of financial information contained in the following statutory documents of a financial nature: Annual Report and Quarterly Reports of the Company and in the forms and documents submitted to securities regulators. More specifically, it covers news releases and press conferences and presentations given at industry or investor conferences related to the disclosure of statutory documents of a financial nature. It also extends to information appearing on Ivy’s Web site related to these documents. 

2.    General Principles

Ivy subscribes to the principles of transparency, rigor and respect for confidentiality in its communications. It communicates complete, non¬selective information to its investors, the media and the general public and discloses accurate, timely information that complies with the laws to which it is subject. Thus: 

Legal obligation to disclose

To comply with the laws to which it is subject, Ivy undertakes to:

  • submit its financial statements each year as well as any other information required ;
  • within the scope of its financing activities, submit the forms, reports and any other documents prescribed by the relevant authorities in jurisdictions where required. 

Uses of disclosure

To ensure transparency in its communications, Ivy undertakes to:

  • publicly communicate the quarterly and annual financial statements;
  • communicate in a timely fashion the important facts pertaining to its financial information;
  • communicate important unfavorable facts about the Company’s financial information as quickly as it communicates important favorable facts about its financial information, and in a non-selective way. Senior management determines what is deemed to be an important fact.


Confidentiality of financial information

To respect the duty of confidentiality, Ivy undertakes to:

  • adequately protect the Company’s financial information. 

Dissemination

To ensure coherent dissemination of financial information, Ivy undertakes to: 

Spokesperson

  • for the disclosure of statutory documents of a financial nature, appoint Ivy’s President and Chief Executive Officer; the Executive Vice President – Finance ; or, the Chief Financial Officer or any other person designated by them as official spokesperson for Ivy. 

Approval of news releases and presentations given at press conferences

Statutory documents of a financial nature are approved by the Executive Vice President – Finance; the Chief Financial Officer; or, by the President and Chief Executive Officer and, if applicable, by the Board of Directors.

Presentations related to statutory documents of a financial nature prepared for release at press conferences are approved by the Controller of the Company and by the Executive Vice President – Finance or  Chief Financial Officer.

Ivy Web site

Ivy’s Web site – Investor Centre at www.ivyenergy.ca  assists with the dissemination of news releases and statutory documents of a financial nature.

All documents to be added to Ivy’s Web site must be submitted to the President and Chief Executive Officer for examination before being presented to the public. 

Control and validation of information

To ensure the disclosure of reliable financial information, Ivy undertakes to:

  • maintain a control process to validate the financial information that is disclosed and to ensure that the information that is disseminated is accurate and timely.

3.    Accountability to the Board of Directors 

Responsibility

Each manager is responsible for applying the general principles of this policy and for reporting the results to management. 

Exceptions

Any deviation from one or more of these principles should be indicated in recommendations submitted for approval to the Board of Directors. 

Concerns

In the case of a specific concern, the Board of Directors or the President and Chief Executive Officer may at any time request a report on the application of a given general principle of this policy. 

Action

The President and Chief Executive Officer and the Board of Directors will review the application of the general principles contained in this policy on an annual basis.

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