Competition & Antitrust Compliance Policy Statement

Global Assessment Corp. 

Competition & Antitrust Compliance Policy Statement 
Effective Date: October 30, 2025 

1 Purpose & Scope 

Global Assessment Corp. (“GAC,” “we,” “us,” “our”) is committed to full compliance with the competition, antitrust, and anti-corruption laws of every jurisdiction in which we operate. This Policy applies to:

• All directors, officers, and employees (permanent, temporary, or contract); and

• All third-party agents, consultants, and business partners acting on our behalf (collectively, “Personnel”).

2 Policy Statement 

GAC requires Personnel to uphold the highest ethical standards and to avoid any conduct that could even appear to restrict fair competition or improperly influence a business decision. Zero tolerance is maintained for violations.

Analytical Integrity and Independence
To reinforce our commitment to lawful and impartial market conduct, Global Assessment Corp. employs a proprietary methodology for market and trade data analysis, integrating multi-source data validation, transparency scoring, and benchmark reconciliation based on OECD, UN Comtrade, and World Bank frameworks.
This structured approach ensures that all analytical outputs are developed from independent, verifiable, and publicly traceable data sources and remain free from influence by any market participant or commercial interest.
By embedding methodological transparency into our compliance culture, GAC promotes accuracy, neutrality, and accountability across all analyses, reports, and market assessments.

3 Prohibited Conduct 

Personnel must never:

• Exchange or discuss commercially sensitive information (e.g., pricing, discounts, margins, customer lists, product roadmaps) with competitors formally or informally.

• Agree, whether expressly or tacitly, with competitors to fix prices, divide markets, allocate customers or territories, limit production, or boycott suppliers / customers.

• Share a customer’s confidential information with other customers or competitors, or seek such information from them.

• Attend “social” meetings or events with competitors if there is a realistic risk that anti-competitive topics could arise.

• Provide or accept hospitality or entertainment of a nature or value that could reasonably be perceived to influence business judgment.

• Retaliate against anyone who raises a competition-related concern in good faith.

4 Required Conduct 

Personnel must always: 

• • Seek pre-clearance from the Legal & Compliance Team before joining trade associations or industry working groups, speaking on panels or webinars where competitors may be present, or attending events at which competitively sensitive topics might surface.

  • Keep accurate, contemporaneous notes when industry meetings are unavoidable, clearly recording agenda, attendees, and any competition-sensitive topics raised.

  • Politely exit any discussion if competitors begin to broach prohibited matters, stating that GAC’s policy forbids participation.

  • Limit information sharing with customers and suppliers to what is strictly necessary for legitimate business purposes and covered by NDA or contract clauses.

  • Report immediately (Section 6) any suspected breaches or “red flags,” even if inadvertent.

(Thresholds may be adjusted for local cost-of-living and statutory limits.) 

6 Reporting & Whistleblowing 

• Channels – Concerns may be raised to a Director, the General Counsel, or via the confidential Compliance Hotline (email), (613)-896-2175 

• Confidentiality – Reports are treated in strict confidence; anonymity will be protected where legally possible. 

• No retaliation – GAC prohibits retaliation against anyone who reports a concern or participates in an investigation in good faith. 

7 Training & Awareness 

• Mandatory onboarding course for all new Personnel within 30 days of start date. 

• Annual refresher e-module and certification. 

• Targeted workshops for high-risk roles (sales, market-analysis, procurement). 

8 Monitoring, Audits & Discipline 

• The Compliance Team conducts periodic reviews of communications, bid records, and meeting minutes.
  As part of these reviews, the methodological framework referenced in Section 2 is periodically audited to confirm that all analytical outputs continue to align with competition-law principles and data-governance standards.

  Violations may result in disciplinary action up to and including dismissal, plus civil or criminal liability for the individual and GAC.

9 Policy Maintenance 

• Reviewed at least annually or sooner if legislation changes. 

• Updates communicated company-wide; the latest version is always available on the intranet and globalassessment.ca/policies. 

10 Questions 

Contact [email protected] for guidance before acting if there is any doubt about whether conduct may infringe competition laws. Acting first and asking later is not acceptable.