Ethical Business Principles

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

These principles are intended to provide a clear and practical foundation for responsible conduct. They apply to directors, officers, employees, contractors and other individuals acting on behalf of Smokybrands Marketing Agency Inc. They also inform the standards we consider when selecting and working with clients, suppliers, technology providers, advisers and other business partners.

These principles complement our Code of Business Conduct, Business Ethics Policy, Corporate Responsibility Statement and other applicable policies and agreements. They do not replace applicable law or create contractual rights beyond those established in a binding written agreement.

1. Integrity

We act honestly, in good faith and for legitimate business purposes.

Integrity requires more than technical compliance. It requires us to consider whether a decision is accurate, fair, supportable and capable of being explained openly.

We do not knowingly:

• Misrepresent material facts.
• Conceal information that should reasonably be disclosed.
• Manipulate records, evidence, results or communications.
• Use professional authority for an improper personal purpose.
• Place short-term gain ahead of legal and ethical responsibilities.

2. Honesty in Marketing and Communication

We communicate accurately and avoid false or materially misleading representations.

Advertising, proposals, website content, case studies, testimonials, portfolio materials, performance figures and promotional statements should be presented in appropriate context and based on information reasonably believed to be accurate.

We do not knowingly support:

• Fabricated reviews, endorsements or testimonials.
• False scarcity, deceptive urgency or fabricated discounts.
• Unsupported performance or environmental claims.
• Misleading comparisons or omitted material conditions.
• Guarantees of rankings, revenue, leads, conversions or growth where such outcomes cannot reasonably be guaranteed.

3. Professional Responsibility

We accept responsibility for the quality, accuracy and professional appropriateness of the work we approve and deliver.

Professional responsibility includes:

• Working within the agreed scope.
• Communicating material limitations and dependencies.
• Using appropriate professional judgment.
• Seeking clarification when requirements are unclear.
• Escalating legal, privacy, security or ethical concerns where appropriate.
• Correcting material errors when reasonably possible.

Tools, automation and third-party services do not remove individual or organizational accountability.

4. Client-Centred Judgment

We seek to understand the client’s objectives, audience, commercial context and practical requirements before making recommendations.

We aim to recommend solutions that are proportionate to the client’s needs and the confirmed project scope.

We do not intentionally recommend unnecessary complexity, features or services solely to increase fees.

5. Transparency

We seek to communicate clearly about scope, pricing, responsibilities, assumptions and material project conditions.

Where reasonably possible, clients should understand:

• What is included and excluded.
• Which responsibilities remain with the client.
• Which third-party services or fees may be required.
• Which factors may affect timing, cost or performance.
• Which statements are estimates, opinions or expectations rather than guarantees.

6. Respect and Dignity

We treat clients, colleagues, contractors, suppliers and business partners with dignity and respect.

We do not support discrimination, harassment, bullying, threats, retaliation or other abusive conduct.

Professional disagreements should be handled constructively, factually and without personal attacks.

7. Fairness and Equal Opportunity

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

We seek to avoid decisions based on unlawful discrimination, improper favouritism or undisclosed personal interests.

Where applicable, we consider reasonable accommodation obligations and accessibility needs.

8. Privacy and Confidentiality

We protect personal, confidential and proprietary information entrusted to us.

Information should be collected, accessed, used, retained and disclosed only for legitimate, authorized and reasonably necessary purposes.

We seek to:

• Limit access according to business need.
• Use reasonable safeguards.
• Respect contractual confidentiality obligations.
• Avoid unnecessary collection or retention.
• Report suspected loss, misuse or unauthorized access promptly.

9. Information Security

We use company and client systems responsibly and take reasonable steps to protect them against unauthorized access and misuse.

We do not knowingly:

• Share credentials without authorization.
• Bypass required security controls.
• Install malicious or unauthorized software.
• Access information beyond what is required for our role.
• Ignore known or suspected security incidents.

10. Responsible Use of Artificial Intelligence

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

AI-assisted work remains subject to professional oversight.

We seek to:

• Protect confidential and personal information.
• Review outputs for errors, bias and unsupported claims.
• Verify material factual and technical information.
• Respect copyright, licensing and contractual restrictions.
• Ensure final deliverables meet the agreed professional standard.
• Disclose material AI use where required by law, contract or policy.

11. Respect for Intellectual Property

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

Only properly licensed, authorized or otherwise lawfully usable materials should be used in client or company work.

We do not knowingly:

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

12. Avoidance of Conflicts of Interest

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

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

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

13. Anti-Bribery and Improper Influence

We do not support bribery, kickbacks, secret commissions, fraudulent incentives or improper payments.

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, transparent and connected to a legitimate business purpose.

14. Fair Competition

We compete through professional capability, service quality, responsible communication and legitimate commercial practices.

We do not support:

• Collusion or bid-rigging.
• Improper restriction of competition.
• Unauthorized acquisition of competitor information.
• False or malicious statements about competitors.
• Deceptive pricing or promotional practices.

Competitive information should be obtained through lawful and ethical means.

15. Accurate Records and Financial Integrity

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

We do not knowingly create false invoices, expense claims, time records, accounting entries or other misleading business records.

Company funds, assets and resources must be used only for authorized and legitimate purposes.

16. Responsible Supplier and Partner Relationships

We seek to work with suppliers, contractors and business partners that demonstrate professionalism, reliability and lawful conduct.

Relevant considerations may include:

• Capability and service quality.
• Commercial suitability.
• Privacy and security practices.
• Legal and contractual compliance.
• Conflicts of interest.
• Reputation and credible ethical concerns.

17. Human Rights

We do not support forced labour, human trafficking, unlawful child labour or other serious human-rights abuses.

Our primary activities involve professional and digital services. Even so, we seek to work with reputable suppliers and business partners.

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

18. Accessibility and Inclusion

We support the ongoing improvement of accessibility and usability in our website, services and digital work.

Where relevant and within the agreed scope, we consider matters such as:

• Clear structure and navigation.
• Keyboard accessibility.
• Readable content and colour contrast.
• Alternative text for meaningful images.
• Clear labels and forms.
• Responsive design and scalable content.

Unless expressly agreed in writing, our services do not constitute accessibility certification or legal compliance advice.

19. Environmental Responsibility

We seek to use resources responsibly and avoid unsupported environmental claims.

Where commercially reasonable, we support:

• Digital workflows that reduce unnecessary printing.
• Responsible use and replacement of equipment.
• Reduction of avoidable waste.
• Remote collaboration where appropriate.
• Efficient technical solutions suited to the project.

We do not claim carbon neutrality, environmental certification or specific environmental outcomes unless those claims are accurate and supportable.

20. Community Responsibility

Smokybrands Marketing Agency Inc. is based in Barrie, Ontario and serves commercial clients in Canada and other markets.

Where commercially appropriate, we support responsible local and regional participation through professional collaboration, selected community initiatives and services that help businesses communicate and operate more effectively.

Any sponsorship, discount or community support remains subject to availability, eligibility review and written confirmation.

21. Responsible Technology and Digital Development

We seek to develop and manage digital systems with appropriate consideration for maintainability, performance, security and future use.

Depending on the agreed scope, this may include:

• Structured planning before implementation.
• Appropriately licensed software.
• Reasonable performance-conscious development.
• Practical access controls and security configuration.
• Technical SEO foundations.
• Documentation and handover where agreed.

No website, system or service can be guaranteed to be completely free from defects, vulnerabilities, downtime or third-party failure.

22. Accountability

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

Managers and decision-makers are expected to model these principles, communicate expectations clearly and respond appropriately when concerns are raised.

23. Speaking Up

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 detail to support a reasonable review.

24. Non-Retaliation

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

This does not protect knowingly false, malicious or fabricated allegations or misconduct committed by the reporting person.

25. Practical Ethical Decision Test

When a proposed action is uncertain, individuals should consider the following questions:

• Is it lawful?
• Is it honest and accurate?
• Is it consistent with our written commitments?
• Does it respect privacy, confidentiality and intellectual property?
• Could it create an undisclosed conflict or improper benefit?
• Would we be comfortable explaining the decision to a client, colleague or regulator?
• Could it cause avoidable harm to another person, organization or the public?

If the answer remains unclear, guidance should be requested before proceeding.

26. Relationship to Other Policies

These Ethical Business Principles should be read together with our:

• Code of Business Conduct.
• Business Ethics Policy.
• Corporate Responsibility Statement.
• Privacy Policy.
• Accessibility Statement.
• Responsible Disclosure Policy.
• Terms and Conditions.
• Service-specific terms and written agreements.

If these principles conflict with applicable law or a binding written agreement, the applicable law or written agreement will prevail to the extent of the conflict.

27. No Contractual Rights or Guarantees

These principles communicate our general ethical expectations. They do 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.

28. Changes to These Principles

Smokybrands Marketing Agency Inc. may update these Ethical Business Principles 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