VIOLATIONS AND REPORTING
Each of us has a duty to report violations of this Code. PotashCorp engages in business activities that are rooted in public trust. Our continued success depends on maintaining our ethical reputation.
Reasons such as, "everyone does it," or "it's not illegal," are unacceptable as excuses for violating our Code. The Code of Conduct will be enforced at all organizational levels. Violations of the Code will be taken extremely seriously and will result in prompt disciplinary action, which may include termination of employment. If any breach of the Code violates the law, civil or criminal legal proceedings may also result.
1. What to Do if You Have Contravened the Code
If you believe you may have contravened the Code, you are required to advise your supervisor, your local Human Resources Department or the Law Department immediately.
2. What to Do if You Know or Suspect Someone Else Has Contravened the Code
If you know or have a good faith belief that another employee, representative or director of PotashCorp, or any joint venture partner, has contravened the Code, you are required to report it immediately to your supervisor, your local Human Resources Department, a member of the Law Department, or a member of PotashCorp's Compliance Committee (Sr. VP, Administration; Sr. VP, General Counsel; VP, Internal Audit).
Reports may also be made through the company’s ComplianceLine, which is equipped to handle anonymous reporting:
Main ComplianceLine Number: 1-800-861-7990
Calls From Trinidad: 1-800-921-8403
Vendor Line (not toll-free): 704-973-0313
The Chair of the Audit Committee is advised of all reports involving financial or business integrity.
Employees also may submit concerns regarding financial statement disclosures, accounting, internal accounting controls or auditing matters directly to the Chair of the Audit Committee of the Board of Directors, in care of the Corporate Secretary, 500 - 122 1st Avenue South, Saskatoon, SK, S7K 7G3, Canada, and may make such report anonymously or confidentially.
3. Report Handling Procedures
As appropriate, an impartial investigation will be conducted. We will strive to protect the anonymity of anyone who in good faith reports suspected Code infractions. All concerns, questions and complaints will be taken seriously and handled promptly, confidentially and professionally.
No retaliation will be taken against any employee for raising any concern, question or complaint in good faith. We wish to encourage an open culture where all concerns expressed in good faith will be investigated and, if appropriate, acted upon.
ComplianceLine Procedures
ComplianceLine calls are directed to an independent call center operated by a vendor, Global Compliance. Callers may remain anonymous if they wish. Global does not require callers to give their names and calls are never traced. The information provided is summarized in a report and forwarded to members of the PotashCorp Compliance Committee. Claims involving financial or business integrity also go to the Chair of the Audit Committee of the Board of Directors. The Compliance Committee discusses the report and decides what type of investigation, if any, is warranted. After a course of action is determined, the company provides Global with a message that can be read back to the caller on a pre-arranged call-back date. If the caller has provided his or her name, follow-up communications may take place directly by letter or phone call.
Annual Acknowledgment
Each year, each of us will be asked to reaffirm our commitment to comply with the Code, and to provide assurance that we have complied with it over the last year.