Business Ethics Policy

This Business Ethics Policy sets out the ethical principles that guide the decisions, services and professional relationships of Smokybrands Marketing Agency Inc.

It applies to directors, officers, employees, contractors and other individuals acting on behalf of Smokybrands Marketing Agency Inc. It also informs the standards we consider when selecting and working with clients, suppliers, technology providers, professional advisers and other business partners.

This Policy complements our Code of Business Conduct and other applicable policies, service terms and written agreements. It does not replace applicable law or create contractual rights beyond those established by a binding agreement.

1. Purpose

The purpose of this Policy is to support ethical decision-making throughout our business activities. We aim to conduct business in a manner that is lawful, honest, responsible, transparent and consistent with professional standards.

Ethical conduct requires more than technical compliance. It requires sound judgment, accountability and consideration of the effects that business decisions may have on clients, colleagues, business partners and the public.

2. Our Core Ethical Commitments

Smokybrands Marketing Agency Inc. is guided by the following commitments:

• Integrity in business decisions and professional communications.
• Honesty in marketing, pricing, proposals and performance claims.
• Respect for clients, colleagues, contractors and business partners.
• Protection of privacy, confidentiality and intellectual property.
• Fairness in competition, procurement and commercial relationships.
• Accountability for decisions, deliverables and professional conduct.
• Responsible use of technology, data and artificial intelligence.
• Compliance with applicable laws, regulations and contractual obligations.

3. Integrity and Good-Faith Decision-Making

Business decisions should be made honestly, in good faith and for legitimate commercial purposes.

Individuals acting on behalf of Smokybrands Marketing Agency Inc. must not knowingly conceal material facts, misrepresent information, manipulate records, misuse authority or place personal benefit ahead of their professional responsibilities.

When a situation is not addressed by a specific rule, individuals should consider:

• Whether the proposed action is lawful.
• Whether it is honest and capable of being explained openly.
• Whether it respects the rights and legitimate interests of others.
• Whether it is consistent with our written commitments.
• Whether it could create avoidable legal, financial, security or reputational risk.

4. Honest Marketing and Accurate Representation

As a marketing and professional services company, we recognize a particular responsibility to communicate accurately and avoid misleading representations.

Advertising, proposals, website content, portfolio materials, case studies, testimonials, pricing information and promotional statements should be clear, supportable and presented in appropriate context.

We do not knowingly:

• Make false or materially misleading claims.
• Fabricate reviews, testimonials, endorsements or performance data.
• Guarantee rankings, revenue, leads, conversions, profitability or business growth where such outcomes cannot reasonably be guaranteed.
• Hide material limitations, exclusions or eligibility conditions.
• Use deceptive urgency, false scarcity or misleading pricing practices.
• Misrepresent the source, authorship, licensing or ownership of content.

Where outcomes depend on external factors, that dependency should be communicated appropriately.

5. Professional Advice and Client Interests

Recommendations should be based on the client’s objectives, available information, confirmed project scope and professional judgment.

We seek to recommend solutions that are proportionate to the client’s needs. We do not intentionally add unnecessary complexity, services or costs solely to increase fees.

We aim to:

• Explain material recommendations and assumptions.
• Distinguish between established facts, estimates and professional opinion.
• Identify foreseeable limitations, dependencies and risks.
• Communicate changes in scope or cost before proceeding where reasonably possible.
• Respect the client’s right to make informed commercial decisions.

6. Fair Dealing

Clients, suppliers, contractors, competitors and other business partners should be treated fairly and professionally.

We do not support:

• Fraud, deception or deliberate concealment of material information.
• Improper pressure, intimidation or retaliation.
• Manipulation of procurement or tender processes.
• Collusion, bid-rigging or unlawful restrictions on competition.
• Misuse of another organization’s confidential information.
• False or malicious statements about competitors or business partners.

Competitive information should be gathered through lawful and ethical means.

7. Conflicts of Interest

Actual, potential or perceived conflicts of interest must be disclosed promptly.

A conflict may arise when personal, financial, family or outside business interests could affect, or appear to affect, objective professional judgment.

Examples include:

• Holding a financial interest in a client, supplier or competitor.
• Directing work to a related person or business without disclosure.
• Accepting outside work that competes with or interferes with company responsibilities.
• Using confidential information or business opportunities for personal benefit.
• Participating in a decision involving a close personal relationship.

Disclosure allows appropriate safeguards to be considered. Depending on the circumstances, a conflict may be approved, restricted or prohibited.

8. Bribery, Corruption and Improper Benefits

Smokybrands Marketing Agency Inc. prohibits bribery, kickbacks, secret commissions, fraudulent incentives and other improper payments or benefits.

No person acting on our behalf may offer, promise, provide, request or accept anything of value for the purpose of improperly influencing a business or government decision.

Reasonable business hospitality may be acceptable when it is lawful, proportionate, infrequent, transparent and connected to a legitimate business purpose.

Cash gifts, cash equivalents, hidden referral payments and benefits intended to influence professional judgment are not acceptable.

9. Privacy, Confidentiality and Data Responsibility

We are committed to handling personal and confidential information responsibly.

Information should be collected, accessed, used, retained and disclosed only for authorized and appropriate purposes.

Individuals acting on our behalf must:

• Respect applicable privacy obligations and client instructions.
• Limit access to information based on legitimate business need.
• Use reasonable safeguards when storing or transmitting information.
• Avoid discussing confidential matters in public or insecure environments.
• Report suspected loss, misuse or unauthorized access promptly.
• Dispose of information securely when no longer required.

Confidential information may include strategies, proposals, pricing, credentials, analytics, personal information, source code, unpublished materials and internal business records.

10. Information Security

Company and client systems must be used responsibly and protected against unauthorized access, misuse and avoidable security risk.

Individuals must not knowingly:

• Share credentials without authorization.
• Bypass security controls.
• Install unauthorized or malicious software.
• Access information beyond what is required for their role.
• Use company systems for unlawful or deceptive activity.
• Ignore known or suspected security incidents.

Security concerns should be reported promptly through the appropriate internal process.

11. Responsible Use of Artificial Intelligence

Artificial intelligence and automated tools may support research, analysis, content development, software development, automation and creative workflows where appropriate.

The use of these tools must remain subject to professional oversight and appropriate safeguards.

Individuals using AI-assisted systems should:

• Consider privacy, confidentiality, security and intellectual property before submitting information.
• Avoid uploading confidential, personal or restricted information without authorization.
• Review outputs for factual errors, bias, unsupported claims and inappropriate content.
• Verify important information before relying on it.
• Ensure final client deliverables meet the agreed professional standard.
• Disclose material AI-related use or limitations where required by law, contract or policy.

Responsibility for final work remains with the individual and organization approving or delivering it.

12. Intellectual Property and Creative Integrity

We respect copyright, trademark, licensing and other intellectual property rights.

Only properly licensed, authorized or lawfully usable materials may be included in client or company work.

Individuals must not:

• Copy protected content without permission or another lawful basis.
• Present another person’s work as their own.
• Remove ownership, attribution or licensing notices without authorization.
• Use client materials outside the authorized engagement.
• Use company intellectual property for an outside purpose without approval.

13. Respect, Inclusion and Equal Treatment

Smokybrands Marketing Agency Inc. supports professional relationships based on dignity, respect and equal opportunity.

Discrimination, harassment, bullying, threats, retaliation and other abusive conduct are inconsistent with this Policy.

Employment, contracting and business decisions should be based on legitimate considerations such as qualifications, experience, performance, capability, reliability and commercial suitability.

We seek to identify and address barriers affecting people with disabilities and to consider accommodation obligations where applicable.

14. Human Rights and Labour Standards

Smokybrands Marketing Agency Inc. does not support forced labour, human trafficking, unlawful child labour or other serious human rights abuses.

Our primary business activities involve professional and digital services. When selecting suppliers and business partners, we seek to work with reputable organizations and may consider credible ethical or human-rights concerns.

Where significant concerns arise, we may request clarification, require corrective action, suspend work or end a relationship, subject to applicable agreements and law.

15. Responsible Supplier and Partner Relationships

Suppliers, contractors and business partners should be selected through fair and commercially reasonable processes.

Relevant considerations may include:

• Professional capability and service quality.
• Price and commercial suitability.
• Privacy and security practices.
• Legal and contractual compliance.
• Conflicts of interest.
• Reputation and ethical concerns.

Business partners remain responsible for their own operations. This Policy does not create an employment, agency, partnership or fiduciary relationship with any third party.

16. Environmental Responsibility

We seek to conduct our professional services with reasonable regard for environmental impact.

Where practical, we support:

• Digital workflows that reduce unnecessary printing.
• Responsible use of equipment and technology.
• Remote collaboration where appropriate.
• Reduction of avoidable waste.
• Accurate and supportable environmental communications.

We do not make unsupported environmental claims or represent that our operations achieve a specific environmental certification or outcome unless that statement is accurate and verifiable.

17. Financial Integrity and Recordkeeping

Business records must be accurate, complete and maintained in accordance with applicable requirements.

No person may knowingly:

• Create false invoices, expense claims, time records or accounting entries.
• Conceal material information in company records.
• Use company funds or property for an unauthorized purpose.
• Destroy or alter records to obstruct a lawful review, audit or investigation.

Expenses should be legitimate, documented and connected to an authorized business purpose.

18. Public Communications and Social Media

Official statements on behalf of Smokybrands Marketing Agency Inc. may be made only by authorized individuals.

Personal communications and social-media activity must not disclose confidential information, misrepresent personal opinions as company positions or misuse company or client branding.

Individuals should communicate professionally and avoid unlawful, deceptive, harassing or discriminatory conduct.

19. Speaking Up and Reporting Concerns

Anyone who becomes aware of suspected unlawful, unethical or improper conduct connected with Smokybrands Marketing Agency Inc. should raise the concern promptly.

Concerns may be submitted to:

• Email: info@smokybrands-marketing.ca
• Phone: +1 (416) 302-4098

Reports should be made in good faith and include sufficient factual information to support a reasonable review. Knowingly false or malicious reports are not protected by this Policy.

20. Non-Retaliation

Smokybrands Marketing Agency Inc. does not support retaliation against an individual who raises a genuine concern in good faith, requests guidance or participates honestly in a review.

This does not prevent proportionate action where a report is knowingly false, made in bad faith or where the reporting individual has independently engaged in misconduct.

21. Review and Corrective Action

Reported concerns may be reviewed internally or with assistance from legal counsel, professional advisers, insurers, technology providers or other appropriate parties.

Where misconduct or a material ethical concern is identified, Smokybrands Marketing Agency Inc. may take corrective action appropriate to the circumstances. This may include guidance, training, removal of access, reassignment, termination of employment or contract, termination of a business relationship, recovery of losses or referral to authorities.

22. Responsibility for This Policy

Directors, managers and other decision-makers are responsible for supporting the standards described in this Policy and for responding appropriately when concerns are raised.

Every individual acting on behalf of Smokybrands Marketing Agency Inc. remains responsible for their own conduct and professional judgment.

23. Relationship to Other Policies and Agreements

This Policy should be read together with applicable privacy policies, security policies, service terms, employment or contractor agreements, confidentiality obligations and the Code of Business Conduct.

If there is a conflict between this Policy and a binding written agreement or applicable law, the binding agreement or applicable law will prevail to the extent of the conflict.

24. No Contractual Rights or Guarantees

This Policy communicates expected ethical standards. It does not create contractual employment rights, guarantee continued employment or engagement, create third-party beneficiary rights or establish a fiduciary duty beyond what may exist under applicable law or a binding agreement.

25. Changes to This Policy

Smokybrands Marketing Agency Inc. may update this Business Ethics Policy from time to time to reflect changes in its business, technology, professional practices, risk environment or legal obligations.

The current public version will be published on this website.

Last updated: August 2026