Gifts and Entertainment & Political Contributions

All employees and Representatives of Calfrac are required to understand the legal and ethical issues associated with providing gifts and entertainment, and how such activities can affect Calfrac’s reputation and relationships with its customers, suppliers, stakeholders and the general public. The decision to offer gifts or entertainment should be made only in compliance with legal requirements, ethical considerations and Calfrac’s Anti-Bribery & Anti-Corruption Policy (the “Policy”), and, where required by the Policy, only following disclosure to and the approval of the appropriate manager and the Chief Compliance Officer (“CCO”), as applicable.

When a government official is involved, the issue of gifts or hospitality may have serious legal implications. Laws prohibiting the bribery or corruption of government officials define government officials broadly to include any appointed, elected or honorary official or any employee of a government or of a government owned or controlled company. All employees and Representatives of Calfrac should be aware that gifts or entertainment involving these parties may be perceived as bribes or kickbacks. Serious consequences can result from mishandling these relationships. Offering or accepting bribes and/or kickbacks is strictly prohibited. Calfrac’s Policy provides guidelines and standards to which Calfrac employees and Representatives are required to adhere to in conducting business. All employees and Representatives of Calfrac should ensure they comply with this Policy, and are required to communicate or report any potential or actual violation of this Policy.

Business gifts and entertainment are courtesies designed to build goodwill and sound working relationships among business partners. We do not, however, want to obtain business through improper means as to gain any special advantage in a relationship.

Business gifts or entertainment that compromise or even appear to compromise our ability to make objective and fair business decisions are inappropriate, and in certain cases, may be considered a bribe and in violation of anti-corruption laws—putting Calfrac and the employee providing the gift or hospitality at risk of prosecution, fines or imprisonment.

In appropriate circumstances, reasonable gifts, meals, entertainment or other normal business hospitality may be provided, but only if in accordance with the Policy. The difference between appropriate and inappropriate gifts and entertainment is not always easy to determine and Calfrac’s Policy should be reviewed to determine whether the item is appropriate and what disclosures and approvals are required.

Undefined terms used in this Disclosure Form shall have the meaning ascribed to them in the Policy.

When to Use this Form

• Following the provision of any gifts, meals, entertainment or other normal business hospitality to a government official, including but not limited to, employees of state-owned business enterprises. For such items, please provide details as to the government officials’ (or employee of a government owned or controlled company) role with the government entity and relationship to Calfrac in the Additional Information section under the “Details of the Exchange” heading below. Note that the pre-approval of the CCO must be obtained for any gifts, meals, entertainment or other normal business hospitality for a government official that is anticipated to be in excess of $250(CAD) per government official.
• Prior to offering anything that can be used as a substitute for cash (such as a gift certificate) to a government official, including but not limited to employees of state-owned business enterprises. Note that the pre-approval of the CCO is required for any such items, regardless of quantum.
• Prior to offering to provide travel, expenses and per diems or cash allowances to a government official, including but not limited to employees of state-owned business enterprises. Note that the pre-approval of the CCO is required for such items.
• Prior to offering any gifts, meals, entertainment or other normal business hospitality to a non-government business contact that exceeds $500(CAD) per customer/contact. Note that the pre-approval of the CCO must be obtained for any gifts, meals, entertainment or other normal business hospitality for any non-government business contact that is in excess of $500(CAD) per customer/contact.
• Prior to offering any contribution (money, assets, property or other things of value contributed, loaned or made available) to any candidate, party or political committee. Note that the pre-approval of the CCO is required for any political contributions.