Canada ADDENDUM—March 2022
 
NOTE: All references to Citadel includes CIG Canada ULC and Citadel Securities Canada ULC. This Handbook Addendum is meant to supplement the North America Employee Handbook for Canadian employees. The North America Employee Handbook and this Handbook Addendum supersede all previous Canadian employee handbooks, policies, practices, and procedures. In addition, this Handbook supplements Citadel and its affiliates, including its affiliated broker-dealers, compliance policies, manuals, procedures, benefits information and bulletins, which are available on Citadel’s Legal & Compliance webpage. Citadel reserves the right to amend or change the policies set forth herein.

Canada employees are subject to the Citadel North America Employee Handbook, except to the extent the terms of the Handbook are contrary to applicable employment standards legislation and/or other laws in your province of employment. These include, but are not limited to:
 
  • The employment of Canadian employees is not at-will.
  • To the extent Canadian statutory employment entitlements (such as leave of absence, overtime, vacation, vacation pay, hours of work etc.) are more generous under applicable employment standards legislation, the requirements of that legislation will apply.
  • Please refer to the “My Benefits” tab on the company Intranet for an overview of the firm’s benefits programs. If you have any questions about the benefit programs please contact HRBenefits@citadel.com.

Table of Contents
 
WORKPLACE LEAVE AND TIME-OFF BENEFITS
WORKPLACE VIOLENCE AND HARASSMENT POLICY
Purpose
Scope
Definitions
Information about a person with a History of Violent Behaviour
Reporting Incidents of Violence
Information and Instruction
For more information
OCCUPATIONAL SAFETY AND HEALTH POLICY
 
WORKPLACE LEAVE AND TIME-OFF BENEFITS
 
Citadel recognizes that employees may need to request time off in the form of a leave of absence from work for a variety of reasons and Citadel will grant employee leave requests in accordance with its policies and applicable provincial employment laws. Benefits that exceed the minimum statutory requirements are available to employees regularly scheduled to work a minimum of 30 hours, during at least four days each workweek. In such cases, such benefits may be pro-rated, at the discretion of Human Resources, for regular employees who work less than 37.5 hours per week. In no circumstance will employees be subject to any reduced leave eligibility than that prescribed by the applicable provincial employment legislation.

In Ontario, the Employment Standards Act, 2000 sets out various categories of job-protected leaves, which include, but are not limited to, the following:
  • Family Caregiver Leave
  • Pregnancy Leave
  • Parental Leave
  • Family medical Leave
  • Critical Illness Leave
  • Organ donor Leave
  • Reservist Leave
  • Domestic or Sexual Violence Leave
  • Crime-related disappearance leave
  • Child death Leave
  • Sick Leave/ o Bereavement Leave
  • Family Responsibility Leave
  • Declared Emergencies and Infectious Disease Emergencies Leave

    Employees should contact a member of the Human Resources Department or HR Benefits if they have any questions about any of the leaves listed above, including whether they apply.

    If the employee is located in a province other than Ontario, please contact Human Resources or HR Benefits if you have any questions about the statutory leaves of absence that apply to you. Any paid leave (other than vacation/PTO) provided under Citadel’s policies shall count toward the employee’s entitlement to leave under applicable employment standards legislation (see Citadel North America Employee Handbook).
 
WORKPLACE VIOLENCE AND HARASSMENT POLICY
 
Please note that this section supplements the workplace harassment and discrimination policy covered under the North America Handbook.
 
If you believe that you require an accommodation for a religious dress and/or grooming practice, please contact Human Resources. The Company reserves the right to deny an accommodation request if the requested accommodation would cause the Company undue hardship or jeopardize health and safety.

Purpose

Citadel has developed this policy to prevent harassment and violence, and to address occurrences quickly and effectively.

Scope

This policy applies to all Citadel employees in Canada (including those who are part-time, fixedterm, temporary and probationary), as well as contractors and consultants.

Citadel is concerned about the increased violence in society, and recognizes that this trend has filtered into many workplace environments. Citadel desires to prevent such incidents from occurring in our workplace. Accordingly, you are strictly prohibited from any act or threat of violence against any person, including employees, customers, vendors, service providers or other visitors, in or about Citadel’s facilities or while you are engaged in Citadel business.

Further, you may not bring weapons of any type onto Citadel premises at any time, regardless of whether they are in your personal possession or whether they are properly licensed. If you violate this rule, you will be subject to separation of employment up to and including separation for cause as well as possible legal prosecution. Citadel will take appropriate action where such conduct does occur, including notifying law enforcement officials.

Citadel annually prepares and reviews a workplace violence policy and develops and maintains a program to ensure the implementation of the policy. The policy is posted in the Citadel office.

Purpose

Citadel has developed this policy to prevent harassment and violence, and to address occurrences quickly and effectively.

Definitions

Workplace Violence

Workplace violence means the use or attempted use of physical force against a person that causes or could cause physical injury. It includes a statement or behavior that a person could reasonably interpret as a threat to use physical force against him or her that could cause physical injury. It includes threats of violence.

Summonsing Immediate Assistance:

To summon emergency assistance, please call 911. For all other situations requiring immediate assistance, employees should contact their supervisor/manager, security personnel (312-395- 4848 or dial x4848 from any Citadel phone), or a member of Human Resources.

Risk Assessment:

Citadel is committed to a workplace that is free from workplace violence, and ensuring the safety of our employees. However, there are circumstances that Citadel has identified as potentially high risk for workplace violence when and if they were to exist at a workplace:

  • arrival to and departure from the office when it is dark outside,
  • public access to the building office space, and
  • limited building security.

    Citadel controls these risks at First Canadian Place (managed by Brookfield Properties) in the following manner:

  • The First Canadian Place building has limited the public’s ability to enter the premises by requiring the use of (i) a pass card to use the elevators, (ii) a pass card to enter any floor and (iii) a key to enter any office, all contributing to the security of the building work space(s).
  • First Canadian Place has security personnel on site 24 hours per day, every day of the year. If any security assistance is needed, security should be contacted via phone or alarm.

    Information about a person with a History of Violent Behaviour

    Citadel will provide workers with information (which may include personal information) related to a risk of workplace violence from a person with a history of violent behaviour. However, this only applies where: (i) the worker can be expected to encounter the violent person in the course of his or her work; and (ii) the risk of workplace violence is likely to expose the worker to physical injury. Citadel will not disclose more information than is reasonably necessary for the protection of a worker from physical injury.

    Reporting Incidents of Violence

    We all have an interest in maintaining a safe and secure workplace that is free from violent acts. In keeping with Citadel’s commitment, a person who is directly affected by, witnesses, or otherwise has personal knowledge of any violence in the workplace must immediately report the incident to a manager, supervisor, or other appropriate person as soon as it is possible to do so safely.

    As a Citadel employee, you should warn appropriate personnel, e.g., your supervisor/manager, security personnel or a member of Human Resources, if you observe or are made aware of any suspicious behaviour in the workplace. Your reports in this regard will be held in confidence to the maximum extent possible and you will not suffer any retaliation for making a report in good faith under this policy. Such claims are serious, however, and if Citadel determines that your complaint is not made in good faith or that you knowingly provided false information regarding the complaint, disciplinary action may be taken, up to and including separation of employment.

    If you believe that you are being subjected to violence, or if you have reason to believe that someone else is being subjected to violence, you must immediately report the offending incident(s) or conduct to your manager, Human Resources, your Business COO, a member of Legal & Compliance, or any other member of Firm management with whom you are comfortable. The contact information for these individuals can be found in Citadel’s Intranet.

    Reports of violence may be made verbally or in writing, in accordance with the Complaints of Discrimination, Harassment and Retaliation procedure outlined in the North America Handbook.

    Investigation:

    Citadel will perform a thorough investigation into all allegations of workplace violence and harassment. The employee will be requested to document their experience and observations.

    In certain circumstances, where the allegations warrant it, Citadel may hire a third party to perform the investigation or Citadel may contact the local police.

    Citadel will investigate all reports, complaints and incidents of workplace violence and harassment. While complete confidentiality is not always possible, Citadel will protect the confidentiality of those involved to the extent this is possible and will not disclose identifying information about any individuals involved unless the disclosure is necessary for the purposes of investigating or taking corrective action with respect to the incident or complaint, or is otherwise required by law. Citadel strictly prohibits any form of retaliation against a person who reports, makes a complaint or participates in an investigation.

    Citadel may impose discipline on any person found to have violated the Company’s policies, up to and including discharge. Appropriate action will also be taken with respect to any acts by others who visit Company premises (e.g. clients or suppliers).

    Citadel will inform any worker who has allegedly experienced workplace violence and/or harassment and the alleged harasser (if he or she is a worker) of the results of the investigation and of any corrective action that has been taken or that will be taken as a result of the investigation, in writing (which includes by email).

    Information and Instruction

    We will provide information and instruction that is appropriate to the worker and their position within the Company concerning the contents of this policy and the program with respect to workplace violence and harassment. This information and instruction may be delivered in many different ways, including in-person training, one-to-one or group instruction by a manager or supervisor, e-learning, and reviewing and acknowledging Company policies. It may be provided on its own, as part of other training (such as policy, handbook or code of business training, or other Health and Safety Training), or as part of other efforts to provide information and instruction (e.g. a supervisor or manager providing a new employee with orientation).

    For more information

    Employees who have questions about this policy or about the Company’s workplace violence and harassment prevention program may contact Human Resources or Legal & Compliance for more information.


    OCCUPATIONAL SAFETY AND HEALTH POLICY

    Citadel is committed to providing a safe and healthy work environment for our employees and other visitors to our facilities. In this regard, Citadel complies with the applicable provincial occupational health and safety laws with the goal of minimizing exposure to health or safety risks. To help accomplish this, you are expected to work diligently to maintain safe and healthy working conditions and to adhere to practices and procedures designed to prevent injuries and illness.

    To support this commitment, both Citadel and its workers are jointly responsible for maintaining an environment that promotes health and safety, preventing occupational injuries and illnesses.

    The objectives of our health and safety program are as follows:
  • ensure all workers are aware of and understand their duties and responsibilities under applicable occupational health and safety legislation;
  • prevent injuries, equipment damage and property loss;
  • establish accountability for occupational health and safety responsibilities;
  • effect recommendations for the continuous improvement of our health and safety program;
  • provide guidelines for consistent implementation of our health and safety program;
  • educate and train workers on the policies and procedures in place at our organization as well as known job-related hazards and unsafe situations; and,
  • cultivate a positive safety culture for our workers.


    Citadel is responsible for the provision of information, training, equipment, and resources to ensure compliance with all relevant statutes, this policy and our internal health and safety programs. Managers and supervisors are accountable for the safety of workers within their area and for compliance with statutory and Citadel’s health and safety requirements. Workers are required to work in compliance with statutory and Citadel’s health and safety requirements and to report unsafe conditions, accidents, and incidents to their supervisor immediately.

    Occupational health and safety legislation also provides for the right of every worker to refuse to do work that he or she believes to be unsafe. Any such dangerous or hazardous circumstances shall be immediately reported to the worker’s direct supervisor. The supervisor will investigate and follow the procedures set out in the applicable occupational health and safety legislation.

    Citadel values each and every worker and is committed to health and safety. We encourage and require every worker not only to be concerned about their own health and safety, but also to ensure healthy and safe work practices on the part of other workers with whom they work, our clients, and the public. Occupational health and safety is everyone’s responsibility. We ask and require 9 you to do your part in complying with the objectives of our Health and Safety Program and the provisions of the applicable occupational health and safety legislation.

    Ensuring full compliance with applicable occupational health and safety legislation will not only mean that Citadel has a healthier and safer workplace, but it will also improve worker morale and encourage other good business practices. Citadel seeks to encourage a cooperative attitude and approach to health and safety in the workplace by all persons. Maintaining effective communication and a proactive approach to health and safety will make our workplace healthier, safer, and more enjoyable as we seek to serve our customers and the public.

    Your responsibilities with regard to health and safety at Citadel include:
  1. Exercising maximum care and good judgment at all times to prevent accidents and injuries.
  2. Reporting to supervisors and seeking first aid for all injuries, regardless of how minor.
  3. Reporting unsafe conditions, equipment or practices to supervisory personnel.
  4. Observing conscientiously all safety rules and regulations at all times.
  5. Promptly notifying an HR Benefits that you are taking medication that may cause drowsiness or other side effects that could impact your effectiveness at work.


    Citadel reserves the right to request that you leave the premises if, in our judgment, your injury or illness poses a direct threat to the health and safety of others in the workplace, in accordance with applicable law.

    Citadel annually prepares and reviews an occupational health and safety policy and develops and maintains a program to ensure the implementation of the policy. The policy is posted in the Citadel office.

    If you have further questions about this policy, contact Human Resources and/or the Health and Safety worker representative(s) or committee, as applicable.