SPEAKING UP

You must speak up if you:

  • Need advice on what to do.
  • Think someone is not following the Code, a policy, or a law.
  • Believe you may have acted against the Code.

Asking questions and raising concerns shows accountability. Honest mistakes happen; honest cover‑ups do not.

If you are unsure whether something violates the Code, contact Compliance or HR.

How to ask questions or report concerns

Start with any of the following: 

  • Your supervisor
  • Your department head
  • Human Resources
  • The Compliance Office

If you feel uncomfortable or want to be anonymous, use the Compliance Hotline (run by an independent company). It is open 24/7/365.

Compliance Office Contacts:

  • Primary Compliance Manager (International) & Compliance Manager (USA) – CODELCO@tmlcorp.com
  • Secondary: EVP & General Counsel – gc@tmlcorp.com

Compliance Hotline Toll‑Free:

  • 844.280.0005 (English – Canada/US)
  • 855.725.0002 (French – Canada)
  • 800.216.1288 (Spanish – US/Canada)
  • 844.301.0005 (Other languages – US/Canada)
  • Website: www.lighthouse-services.com/tmlcorp
  • E‑mail: reports@lighthouse-services.com (include Company name)
  • Fax: (215) 689‑3885 (include Company name)

You may report anonymously. Include as many details as possible to help an investigation.
You can also send written concerns about accounting, auditing, internal controls, financial reporting, bribery, accounting fraud, insider trading, or other financial wrongdoing to the executive chair:

  • Mail: 725 Baransway Drive, London, Ontario, Canada N5V 5G4
  • Private/Confidential E‑mail: gbaranprivate@tmlcorp.com. Add “Private and Confidential” to the envelope or subject line.

Please also see the Reporting Compliance Concerns policy – Direct to Legal/Compliance to obtain copy.

  • Reporting Compliance Concerns Policy

Yes. The Compliance Office (and HR if needed) will follow up. Investigations are confidential as much as possible and follow the law. If you report anonymously, we may need more information to proceed.

Use the reporting form on the intranet or ask HR for a blank copy to fill out. You do not need to be certain a violation happened—raise concerns in good faith. Do not make bad‑faith reports.

If your name appears in a Compliance matter, you may have rights to access and correct personal data about you, based on local law. Contact HR to exercise these rights.

We do not tolerate retaliation. Anyone who retaliates against a person for asking questions, raising concerns, reporting issues, or helping an investigation will face discipline, up to and including termination. If you believe you have been retaliated against, contact Compliance, HR, or the Hotline right away.

Policies and laws
The Workplace