EMPLOYEE HANDBOOK

October 1, 2021
TABLE OF CONTENTS

LETTER FROM THE PRESIDENT..............................................................................................2

KNIGHTSBRIDGE....................................................................................................................... 3

OUR MISSION....................................................................................................................3
OUR VALUES..................................................................................................................... 3

WORKING CONDITIONS HANDBOOK......................................................................................3

PROBATIONARY PERIOD.................................................................................................3
COMPENSATION............................................................................................................... 4
EMPLOYEE BENEFITS......................................................................................................4
TIME SHEETS.................................................................................................................... 4
WORK SCHEDULE, BREAK PERIODS AND MEALS........................................................4
ABSENSES and LATENESS..............................................................................................4
OVERTIME......................................................................................................................... 5
PAID STATUTORY HOLIDAYS..........................................................................................5
VACATIONS....................................................................................................................... 5
MATERNITY/PARENTAL LEAVE.......................................................................................6
SICK LEAVE....................................................................................................................... 6
OTHER CONDITIONS........................................................................................................6
TRAVEL AND EXPENSE POLICY……………………………………………………………………..7

BUSINESS EXPENSES………………………………………………………………………………..12

CORPORATE CHARGE CARD……………………………………………………………………….12

DRESS CODE…………………………………………………………………………………………...13

COMPANY CODE OF ETHICS.................................................................................................15

COMPANY RULES AND REGULATIONS................................................................................16

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LETTER FROM THE PRESIDENT

Dear Team Member,

We are pleased to welcome you to the Knightsbridge team!

This is a good opportunity to provide you a copy of the EMPLOYEE HANDBOOK, which will help you
get off to a good start. The objectives of the Handbook are to give you an overview of the organization
and the human resources practices of our company, and to ensure the efficiency of our operations and
the harmony of our team.

The Employee Handbook contains the following:

 Knightsbridge

 Working Conditions Handbook

 Company Rules and Regulations

 Code of Ethics

All employees, whether seasoned or new, may occasionally need to consult the Employee Handbook.

This document is intended as an easy-to-use reference tool containing the answers to frequently asked
questions. If you cannot find what you are looking for, please feel free to pass your questions on to me
or ask your immediate supervisor. We will be pleased to supplement the information in this Handbook
and provide you additional details.

Finally, the Employee Handbook is an evolving document that will be adapted as appropriate to reflect
cultural and organizational changes within the company, or to incorporate changes to government
regulations over time

On behalf of the whole team, welcome to Knightsbridge.

Will Smith, President and CEO

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KNIGHTSBRIDGE

Knightsbridge is committed to offering services that precisely match our customers’ specifications,
and to ensuring exceptional service.

We exist to serve our clients, who are at all times our number one priority. Indeed, our jobs depend on
providing quality services to these customers.

Knightsbridge Development Corporation is committed to excellence in high-performance building

design, advanced clean-technology integration, and low carbon strategies for the building construction
sector to keep pace with the unprecedented growth of sustainable buildings.

The respect that Knightsbridge has earned in the marketplace is due to the strength of our team We
are an experienced team which takes pride in its achievements and in which the company places its
ongoing trust for a prosperous future.

OUR MISSION
Knightsbridge Development Corporation provides client-focused real estate advisory services through
world-class intellectual capital and resources. Our mission is to design and execute customized
solutions that create value for our clients applying locally what we learn globally. We provide our clients
with a flexible and effective platform to support current and future opportunities. We challenge the
status quo with thoughtful consideration of a better future.

OUR VALUES
1. We value People, the heart of Knightsbridge Development Corporation’s success.
2. We are curious, innovative and creative.
3. We engage in intellectual rigor and attract the industry’s best minds.
4. We demand an environment of mutual respect, diversity and we empower everyone to
challenge traditional thinking.
5. We act with integrity and greatly value and honour relationships with our clients.
6. We build Teams through healthy interaction - Our clients learn as much from us as we do from
them.

WORKING CONDITIONS HANDBOOK

PROBATIONARY PERIOD
Before being classified as a permanent employee of the company and accumulating seniority, each
new employee must work for a probationary period lasting three (3) calendar months. During this
period, the company reserves the right to terminate a worker’s employment without notice if his/her
work is deemed unsatisfactory. The employee may also resign without giving prior notice. The
probationary period may be extended an additional three (3) months if the employee fails to
demonstrate possession of the skills required for his/her position.

During the probationary period, employees are not eligible for salary reviews and cannot participate in
the employee benefits program. New hires however, they are compensated for any statutory holidays

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occurring during this period, within the province in which they are based starting with their first day of
employment and based on a calculation establishing the compensation amount. The only requirement
for receiving this benefit is that the employee be employed on this date.

COMPENSATION
The wages of every employee are determined before they are hired. Management establishes the
amount in accordance with the applicable pay scales and taking into consideration the tasks to be
executed and the employee’s relevant recognized experience.

The employee must provide a void cheque so that their pay may be direct deposited in the appropriate
bank account. The pay is deposited to this bank account by-weekly and covers two weeks pay from
Sunday to Saturday.

Each employee will receive a pay stub when their wages are paid. If the pay statement contains any
errors, or discrepancies, or the employee has any questions about it, they must contact the payroll
administrator.

An annual salary adjustment may or may not be made, depending on the employee’s job appraisal and
the company’s overall performance.

EMPLOYEE BENEFITS
The employer contributes to all plans, insurance policies and other programs provided for by law, i.e.,
the Quebec Pension Plan (QPP), federal Employment Insurance (EI) and the Quebec Parental
Insurance Plan (QPIP).

Group life, health and disability insurance plans are fully paid for by the company with the exception of
long-term disability insurance, which will be paid for by the employee. Whenever a new employee joins
a group insurance plan, the insurance will not become active until after 3 months from their start date

TIME SHEETS
Every hourly rate employee is provided with a time sheet. This sheet is required for calculating his/her
wages and for corporate record-keeping. Consequently, it must stay at its designated location, be
handled carefully and not be used by any person other that the employee whose name appears on it.
The time sheet must be filled in by the employee.

WORK SCHEDULE, BREAK PERIODS AND MEALS

The standard work week is thirty-seven and a half hours, Monday through Friday. The standard
workday starts at 8:30am and ends at 5:00pm Two fifteen-minute break periods are allowed each day
and Employees are entitled to a half hour paid lunch period per standard workday.

ABSENCES AND LATENESS

Employees are sometimes required to be absent from, or late for, work. The company has provided a
procedure for such cases to ensure that all staff are treated fairly.

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Employees are responsible for advising their immediate supervisor of any absence or lateness as soon
as possible before the start of their work shift so that the supervisor can make the necessary
replacement arrangements and maintain good continuity of the department’s activities.

Unauthorized or excessive absences may result in the imposition of disciplinary measures by

management, depending on the seriousness of the situation.

OVERTIME
Hourly Employees will occasionally be required to work overtime in order to meet production schedules.
When this occurs, they must be available for a reasonable number of overtime hours, as required.

Employees are not authorized to approve their own overtime; therefore, all work which they perform
outside the usual schedule must receive prior approval from their immediate supervisor.

PAID STATUTORY HOLIDAYS

The paid statutory holidays are listed below:
 New Year’s Day
 Family Day
 Remembrance Day (BC, Alberta)
 Good Friday
 Victoria Day
 Fete Nationale (Quebec)
 Canada Day
 Heritage Day (Alberta, NS
 British Columbia Day (BC)
 Labour Day
 Thanksgiving Monday
 Christmas Day
 Boxing Day

VACATIONS

Below are the minimum vacation times prescribed by the Labour Standards:

Depending on hiring date Vacation Indemnity

Less than 1 year 1 day for each month of service 4%

performed in the reference year

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 1 year to less than 5 years 2 weeks 4%

More than 5 years 3 weeks 6%

Annual vacation days must be earned during the reference year, that is, from day/month to day/month,
and employees have 12 months in which to use them. Vacation days must be taken during the current
year because they do not carry over from one year to the next and cannot be cashed out. Employees
will be given a form at the beginning of each that each employee must fill out informing us of their
desired vacation time. Although we will try to accommodate the preferences of all employees, vacation
scheduling will be based on operational needs. Preference will be given to seniority to the extent
possible.

MATERNITY/PARENTAL LEAVE
The employer recognizes maternity/parental leave as continuous employment. For instance, an
employee who has an uninterrupted year of service when they go on a one-year maternity leave will be
credited with two years of continuous employment when they return from their leave.

Paternity leave varies by province of residency and Knightsbridge supports the use of parental leave
based on the provincial guidelines.

On return from maternity leave, the employee’s vacation time is calculated as specified in the Labour
Standards. The employee will then be free to use their vacation time for a gradual return to work in the
event they choose to do so.

SICK LEAVE
Employees are entitled to 6 sick leaves a year for one year of continuous service calculated from the
starting date to the end date; these leaves are non-refundable and cannot be banked. In the case of a
maternity leave or any other situation affecting the annual hours worked, sick leaves will be calculated
proportionally to the time worked. If an employee is off work for more than three (3) consecutive days,
the employer reserves the right to request a medical certificate from the employee.

OTHER CONDITIONS
Using the Internet and social media

The Internet and social media may be used during working hours only for purposes of carrying out job-
related requirements and responsibilities. When the Internet and social media are used for work
purposes, employees must act in a professional manner while also abiding by the organization’s Code
of Conduct. It is forbidden to play video games during work hours.

Social Media Policy

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Employees should separate their personal and professional social media presence. Social media posts
and “likes” can remain online forever. Employees should be mindful of the company’s reputation when
posting on its behalf.

Employees should assume that clients and future employers may also read information on their
personal accounts.

If an employee mentions Knightsbridge in the profile of their personal social media page, they are to
include a disclaimer saying their opinions and comments do not necessarily reflect the point of view of
Knightsbridge or its management.

Three distinct uses of social media

1. Official—Official use of social media on behalf of the company to communicate messages that
represent the brand
2. Professional—The use of social media in an employee’s professional role to build a network of
contacts and increase brand visibility
3. Personal—Use of social media in an employee’s private life

Posts made on behalf of the company should be consistent with the business’s marketing and public
relations practices and objectives. Employees should be especially cautious about revealing
confidential or proprietary information or engaging in discussions that could tarnish their reputation or
that of your company.

Employees sharing links online, should be sure the source of the content being shared is reputable.
They should also guard against plagiarism by properly crediting the sources of the material they use.

Employees should refrain from speaking to media. Only authorized delegates of the company may
respond to media inquiries inquiries.

Using computer software

Computer software must be approved by the management team and be compatible with the
technological options chosen by the company and must always be accompanied by a user license.

TRAVEL AND EXPENSE POLICY

Purpose

The purpose of this policy is to:

a) Describe the types of expenditures that are reimbursable by the company.

b) Inform employees of their responsibilities to control and report travel and entertainment.
c) Describe the process for an employee to file and obtain travel expenses and reimbursement.

Employee Travel & Business Expense Guide

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This guide is intended to aid the Knightsbridge business traveler and Knightsbridge management by
setting forth guidelines and reporting requirements related to Knightsbridge expectations and CRA
regulations.

All travelers and Managers bear responsibility for cost-effective business travel. Each Manager should
carefully review and approve all Expense Reports. Items not considered reimbursable should be
brought to the attention of each employee prior to being submitted to Accounting.

While these guidelines are intended to be comprehensive, it is impossible to anticipate every situation
encountered by a traveler. The traveler, is expected to apply these guidelines on a conservative basis,
consistent with normal living standards and, where the policy is silent, should exercise good business
judgment.

General Travel Policy

It is the Company’s policy to reimburse employees for all expenses necessary, reasonable and actually
incurred when traveling on authorized company business.

Travel expenses must be properly documented and approved on a Travel Expense Report. It is each
employee’s responsibility to adhere to policy when involved with expenditures on behalf of the
company. Further, it is the responsibility of the manager to be familiar with the reason for the
expenditures and to be satisfied that they have been reported in a manner consistent with the
recognized policy.

Employees are expected to:

a) Exercise good judgment with respect to expenses.

b) Spend the company’s money as carefully and judiciously as they would their own.
c) Report all expenses and advances promptly and accurately with required documentation.

Procedures:

Air Travel

All employees traveling via air carrier must utilize Lowest Fare Routing (LFR). LFR is quoted logical
lowest fare for the business trip, which will (where possible):

a) Provide cost savings for the round trip air ticket.

b) Result in total layover time not exceeding one hour.
c) Increase the one-way total elapsed trip time by no more than two and one-half hours.
d) Require no more than one interim stop each way.
Exceptions to this policy statement will be allowed with approval by the employees’ supervisor so that
additional cost is authorized.

International air travel outside of Canada. and to overseas locations will be by LFR.

All travel reservations should be made as far in advance as possible to take advantage of available
discounted airfares.

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Business and First Class travel is not allowed for domestic flights or any International flights shorter
than 5 hours in duration unless it is at the employee’s expense. Employees who are enrolled in airline
incentive programs are permitted to utilize their personal upgrades along with the Company’s booking
of the lowest available fare. Reasonable stopovers enroute may be approved provided that:

a) They do not interfere or adversely affect achievement of the desired business objective.
b) They do not result in any significant loss of work time.
c) The travel expense claimed from the Company does not exceed either the actual cost, or the
cost of the applicable air fare between the place of departure and the business destination,
whichever is the lesser.
d) Approval must be obtained in advance from the appropriate manager.

If such a stopover is made, the Company, assumes no responsibility or liability of any kind for any
employee actions or activities during or occasioned by the stopover.

Airline tickets are considered legal tender and care should be taken not to lose or destroy them. Return
any unused tickets or portions of tickets to the company. The tickets will then be returned for proper
credit. Do not return any unused tickets directly to the airlines.

Employees will be required to submit all company paid airfare receipts incurred while traveling. Used
airline tickets should be attached to your expense report.

Car Rental

All travelers should follow the listed guidelines:

Number of Travelers Class of Car

1-2 Compact

3 Intermediate

4-5 Full Size or Van

All drivers must hold a valid drivers license or a car may not be rented.

Car rentals are generally the most expensive mode of transportation and should only be used when the
nature of the trip or the locations of the customer being visited is such that the use of local
transportation (i.e. taxis or limousines ) is not practical or would be more expensive.

Personal Auto

An automobile personally owned by an employee and authorized for business use will be compensated
when actually driven for such purpose and will be reimbursed a fixed amount of $0.53 per mile.
Mileage should be fully documented as to date, starting location, ending location, persons visited, the
business purpose, and the business miles. All mileage calculations are calculated using the office
location as the starting point of the trip.

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Taxis

Taxis should be used when other reasonable and less expensive forms of transportation are not
readily available. In traveling away from home, overnight living accommodations should to the extent
practicable, be selected so as to eliminate or minimize the need to use taxis or other local
transportation. When taxis are used, they should be shared to the maximum extent possible by
employees traveling together on Company business. A receipt for the fare charged must be obtained
from the taxi driver.

Hotels

Hotel reservations should be made based on the best available rate with reasonable quality
accommodations, at the most convenient location. Upon arrival, the traveler should verify that the rate
that is shown on the itinerary is the rate they receive.

Meals

The employee should normally select restaurants which are reasonably priced for the locality and which
are consistent with normal living standards. Receipts must be attached for all meals purchase while on
business. A daily maximum per day has been established and set at $75.00CDN/day.

Business related meals for customers or with other employees must be described as follows: date,
amount, place and explanation of nature of business. A list of names of those entertained must be
included. A receipt is required for all entertainment expenses regardless of the amount. Business
conferences over meals may be reimbursed with proper approval. Wine and bar tabs are reimbursable
only if they are associated with a business meeting and are not excessive. Entertaining other
employees, unless for stated business purpose, is not a reimbursable expense.

Business Entertainment

Business entertainment is limited to the cost of meals and beverages furnished in a hotel dining room
or a restaurant.

Since the presumption is made by the CRA that entertainment is not related to the Company’s
business, it is generally necessary to demonstrate that such expenses are associated with the active
conduct Company’s business. Therefore, such entertainment must have either directly preceded or
followed a bona fide business discussion. Since the company must be prepared to substantiate this
expense, the following information is required when reporting company expenses:

a) Date and place of entertainment

b) The party’s name, title and firm must be stated on the Travel Expense Report.

Cellular Phones

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Cellular phones are provided to employees by the Company and paid for directly by Knightsbridge.
Raoming plans should be arranged for prior to business travel outside Canada, and wi-fi utilized where
secure and available to reduce data usage.

Miscellaneous

The company does not pay for dry cleaning expenses while on a trip of less than five (5) days duration.
However, where circumstances require these services, these expenses will be reimbursed. Please
document your explanations on the Expense Report.

The payment of tips and gratuities should be limited to those situations and services where such
payments are normal practice. The amount of percentage of any gratuity paid should not exceed that
which is reasonable and customary for the particular type of category of personal service. The range of
10-20% is considered applicable to most forms of personal service, including restaurant service.

The following are not reimbursable:

 Annual credit card fees

 In-room or in-flight movies
 Hotel Room phone charges
 Personal reading materials
 Airline, hotel and car rental club memberships
 Restaurant count club memberships

Receipts (Proof of Payment)

The Company request that receipts for all expenditures be submitted, and receipts must be submitted
for all expenses over $10.00. Knightsbridge will not reimburse expenditure greater than $10.00 without
a receipt.

Approval

All Expense Reports must be approved by the employee’s Manager in accordance with the
Supervisor/Manager’s expenditure authorization. Expense reports must be submitted to the Accounts
Payable Department within thirty (30) days of first expenditure incurred or reimbursement can be
delayed while current reports are processed.

EXPENSE REPORT
CRA regulations require that traveling personnel maintain an adequate record for each trip and post all
pertinent information in support of each expenditure (who, what, why, when and how much). Expense
Reports are due no later than thirty (30) days of first expenditure incurred.

Entertainment expenses incurred in the process of completing Knightsbridge business objectives

should be supported by receipts for all expenditures and documentation detailing dates and places of

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entertainment, names and number of people involved, business relationship of all involved, business
purpose, and amount of each separate expenditure.

All names should be listed including those of other Knightsbridge employees, unless it is a group clearly
identified by title. The date, nature of the business, and participants in the related discussion preceding
or following the entertainment must be shown.

CORPORATE CHARGE CARD

1) Corporate charge card (American Express Card) may be issued to frequent travelers. The
corporate card will be used for business travel related expenses (business, meetings, air, auto,
hotel, meals etc.) only.
2) To minimize the need for business advances, employees are expected to use corporate charge
cards for travel to pay for travel expenses.

APPROVER’S RESPONSIBILITIES
1) Ensure all expenses are reasonable, in support of business goals, and in accordance with
Company policy.
2) Approve expenditures for which no direct or indirect benefit (e.g. in attendance at the meeting) was
received.
3) Only authorize reimbursement for air, car, and hotel expense if booked through the agency under
contract.
4) Cost effective management of business expenses.

FINANCE DEPARTMENT’S RESPONSIBILITIES

1) Return all expense reports requiring additional substantiation.
2) Review expense reports for appropriate cost center codes, approving manager’s signature and
calculation accuracy.

DRESS CODE

DRESS CODE POLICY

Knightsbridge expects employees to dress appropriately in business casual or business attire. Because
our work environment involves frequent visits from customers, clients, and the public, business attire is
essential for our reputation.

Examples of business attire may include collared shirts, sports jackets, blazers, skirts, dresses and
dress shoes. The exceptions to these guidelines applies to employees visiting construction sites at
which time employees are expected to dress in accordance with the requirements set out by
Occupational Health and Safety, the Ministry of Labour, and the site rues set out by the Constructor.

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Employees are expected to demonstrate good judgment and professional taste. Courtesy to coworkers
and your professional image to clients should be the factors that are used to assess whether you are
dressing in business attire that is appropriate. In the event clarification or additional guidance may be
required; please consult with your manager if there is a concern you wish to discuss.

We will deal with employees who wear business attire that is deemed inappropriate in this workplace
setting on an individual basis rather than subjecting all employees to a more stringent dress code for
appropriate business attire.

COMPANY CODE OF ETHICS

Our company has adopted values that will allow us to achieve our growth objectives while also
promoting general workplace well-being. These values must be upheld by each and every one of us.
Management cannot, therefore, tolerate any conduct that contravenes these company values. Below is
the Code of Ethics by which all employees – workers and managers alike – must abide. We encourage
you to inform your manager of any conduct that is illegal or contrary to the Code of Ethics. The
company is committed to protecting employees against all forms of reprisals.

RESPECT
 Treat all of your colleagues and managers the same way, with respect and equality.
 Show an interest in your colleagues and be a good listener.
 Be courteous, polite and straightforward with your colleagues.
 Greet your colleagues in the morning.
 Respect other people’s work areas as well as their knowledge and skills.

HONESTY
 Honesty vis-à-vis all your workplace activities is essential.
 Theft is not tolerated and may lead to dismissal.
 It is important to avoid placing yourself in a situation of personal conflict of interest vis-à-vis your
employment obligations.

INTEGRITY
 Conduct ourselves ethically and in an inclusive manner
 Strive to offer best in class service
 Take pride in the work we do

PROFESSIONALISM
 Respect the confidentiality of information provided by customers, colleagues or management.
 Project a positive corporate image; any work-related problems must be settled internally rather
than outside the company.
 Employees must pay particular attention to cleanliness and are expected to maintain a
workplace-appropriate appearance. We rely on your good judgment to determine what is and is
not acceptable, within the bounds of safety and the public image that goes with your job.

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AUTONOMY
 Show initiative in terms of improving the workplace or the services provided to our customers.
 Be the best you can and work to perfect yourself in your current role

RESPONSIBILITY
 Look for solutions to work-related problems and submit these solutions to management.
 Admit your mistakes without looking for excuses.
 Know how to provide mutual support.
 Be sensitive to the needs and requests of your colleagues.
 Be ready to collaborate and offer constructive criticism.
 Refrain from saying anything that might damage the reputation of the company or management,
both within and outside the company.
 Be vigilant in everything you say so that the people around you will see that you stand in
solidarity with your employer and colleagues.

COMPANY RULES AND REGULATIONS

Knightsbridge expects staff to abide by certain rules and regulations in order to create a positive
working environment for everyone.

Employees are asked to follow the rules, regulations and guidelines laid out in this Handbook.

Workplace health and safety. As an employee, you shall:

• Follow the health and safety regulations.

• Observe hygiene standards.

• Wear protective equipment when required.

• Immediately report a workplace accident to your immediate supervisor.

• Show respect for your colleagues and/or not use abusive or disrespectful language.

• Avoid getting into fights or quarrels, running or shouting.

• Refrain from having or consuming alcohol or drugs on the company property and from working
under the influence of alcohol or drugs. (including consuming alcohol over lunch)

• Adhere to the new provisions regarding psychological harassment added to the Work
Standards Act in 2004. Company management will use the necessary means to enforce these
provisions.

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Respect in the workplace setting. As an employee, you are not allowed to:

• Smoke on indoor work premises and/or within nine metres of the outside entrance ways.

• Gamble on the company property.

• Engage in insubordination, or refuse to work, as this will result in an employee’s immediate

suspension for the remainder of their shift.

Company equipment and assets. As an employee, you are not allowed to:

• Use the company’s production equipment for personal reasons during working hours.
Permission to do so may be granted outside of working hours.

• Falsify files, documents, time sheets and production/quality reports.

• Possess or transport any assets belonging to the company off the company’s property without
written authorization.

• Park vehicles anywhere other than in specifically designated areas.

• Engage in fund-raising on the company’s property without prior authorization.

• Post non-work related items on the company billboard, or on Teams without authorization.

• Violate our ZERO TOLERANCE policy regarding threats, verbal or physical violence towards
representatives of the company and/or vandalism on the company’s property; such violations
will result in immediate dismissal.

The employer expects staff to exercise good judgment with regard to appropriate work conduct. In
order to ensure respect, harmony and safety for everyone in the workplace, employees who breach the
regulations may face disciplinary action that could lead to dismissal.

Since it is difficult to anticipate and list all situations that might arise in the course of your work, this
handbook makes broad reference to the Labour Standards Act and to other applicable employment
legislation in Quebec. Some parts have been transcribed or improved for easier consultation.

ENVIRONMENTAL AND SOCIAL GOVERNANCE

OUR ESG STATEMENT

We seek to manage our business with integrity and to balance economic goals with good corporate
citizenship to ensure the well-being and safety of employees and to be good stewards in the
communities in which we operate.

EMPLOYEE WELL-BEING
Meet or exceed all applicable labor laws and standards in jurisdictions where we operate, which
includes respecting human rights, offering competitive wages and implementing non-discriminatory
hiring practices.

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COMMUNITY ENGAGEMENT
Engage with community groups that might be affected by our actions to ensure that their interests,
safety and well-being are appropriately integrated into our decision-making.

HEALTH AND SAFETY

Aim to have zero serious safety incidents within our businesses by working toward implementing
consistent health and safety principles across the organization.

GOVERNANCE, ETHICS AND FAIRNESS

Operate with high ethical standards by conducting business activities in compliance with applicable
legal and regulatory requirements, and with our Code of Business Conduct and Ethics.

ENVIRONMENTAL STEWARDSHIP
Mitigate the impact of our operations on the environment and conduct business according to the
highest ethical and legal/regulatory standards. Strive to minimize the environmental impact of our
operations and improve our efficient use of resources over time.
Knightsbridge Development Corporation is committed to excellence in high-performance building
design, advanced clean-technology integration, and low carbon strategies for the building construction
sector to keep pace with the unprecedented growth of sustainable buildings.
We believe that the success of projects striving for energy conservation targets and high-performance
building standards such as, but not limited to LEED certification depends on a collaborative workforce
committed to greater dialogue, interaction, and teamwork amongst the owner, design consultants,
contractor, occupants, and operations staff.

PHILANTHROPY
Encourage our employees to participate in and give back to the communities in which we
operate.Selfless / random acts of kindness are also encouraged!

TRANSPARENCY
Be accessible to our internal and external stakeholders by being open and responsive to requests for
information and act timely with our communication.

HUMAN RIGHTS AND ANTI-HARASSMENT/DISCRIMINATION (HRAP)

1.0 Policy Statement

Under the Canadian Charter of Rights and Freedoms, every person has a right to equal treatment in
the provision of services and facilities, occupation of accommodation, contracts and in employment.
Under the Occupational Health and Safety Act Opens in new window, all employers are required to
have a workplace harassment policy, program, to provide information, instruction and to protect
workers from workplace harassment.

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Knightsbridge is committed to respectful, equitable service delivery and employment practices. Every
person has a right to equal treatment in the provision of services and facilities, occupation of
accommodation, contracts and in employment. This policy articulates Knightsbridge’s commitment to
prevent and address harassment and discrimination under the Canadian Charter of Rights and
Freedoms. The goal of this Policy is to recognize the dignity and worth of every person (whether
resident, service recipient or employee) and to create a climate of understanding and mutual respect.

Knightsbridge will not tolerate, ignore, or condone discrimination or harassment and is committed to
promoting respectful conduct, tolerance and inclusion. All employees are responsible for respecting the
dignity and rights of their co-workers and the public they serve. Knightsbridge’s Human Rights and Anti
Harassment/Discrimination Complaint Procedures provide a range of dispute resolution options for
employees, and service recipients who believe that they may have experienced discrimination and/or
harassment. All complaints shall be treated confidentially and there shall be no reprisal.

2.0 Application

This policy applies to all Knightsbridge employees and Officers. This policy should be read in
conjunction with the Complaint Procedures.

This includes refraining from discriminating and/or harassing Knightsbridge employees, and persons
acting on behalf of Knightsbridge. If such discrimination and/or harassment occur, Knightsbridge will
take action to ensure a harassment/discrimination-free workplace, facility and service provision,
including barring a harasser from its facilities, limiting services, discontinuing business and/or revoking
contracts with consultants or contractors.

Social Areas & Prohibited Grounds

2.1 Services and Facilities

Every person has a right to equal treatment with respect without discrimination or harassment because
of one or more of the following prohibited grounds:

 age
 ancestry
 citizenship
 colour
 creed
 disability
 ethnic origin
 family status
 gender expression
 gender identity
 level of literacy
 marital status
 place of origin
 political affiliation
 race
 sex (including pregnancy, breast feeding)
 sexual orientation

2.2 Contracts

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Every person having legal capacity has a right to contract on equal terms without discrimination
because of one or more of the following prohibited grounds:

 age
 ancestry
 citizenship
 colour
 creed
 disability
 ethnic origin
 family status
 gender expression
 gender identity
 level of literacy
 marital status
 place of origin
 political affiliation
 race
 sex (including pregnancy, breast feeding)
 sexual orientation

All contracts, agreements or permits for programs and services delivered by a third-party individual or
organization that has been contracted under Knightsbridge’s Purchasing Process, will include a signed
copy of the Declaration of Compliance with Anti-Harassment/Discrimination Legislation and Policy
Word file, and be subject to contract provisions regarding consequences for non-compliance.

2.3 Employment

Every person has a right to equal treatment in employment without discrimination or harassment
because of one or more of the following prohibited grounds:

 age
 ancestry
 citizenship
 colour
 creed
 disability
 ethnic origin
 family status
 gender expression
 gender identity
 level of literacy
 marital status
 place of origin
 political affiliation
 race
 sex (including pregnancy, breast feeding)
 sexual orientation
 workplace harassment**

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These grounds are included in Knightsbridge’s policy
** Workplace harassment as defined in the Occupational Health and Safety Act includes harassment
based on sex, gender identity, gender expression, sexual orientation and non-Code harassment, i.e.,
harassment that is not based on a prohibited ground listed above. The HRAP addresses this type of
harassment in section 4.10-4.13.

3.0 Roles and Responsibilities

All employees and Officers are responsible for:

 knowing this policy and complaint procedures,

 not engaging in harassment/discrimination,
 cooperating in good faith in dispute resolution processes including investigations, and
 abiding by confidentiality expectations – refer to section 1 in the Complaint Procedures

3.1 Employees
 ensure behaviour is civil and respectful in relation to all employment/service provision activities
 immediately report non-Code workplace harassment experienced or witnessed to division
management.

For clarity, reports of workplace harassment should be made to a manager who does not report to the
alleged harasser

4.0 Definitions

4.1 Allegation
An allegation is an unproven assertion or statement based on a person’s perspective that the policy has
been violated

4.2 Complainant
The person alleging that discrimination or harassment occurred. There can be more than one
complainant in a human rights complaint.

4.3 Complaint
A complaint is a written or verbal report by a complainant alleging that they have experienced or
witnessed harassment and/or discrimination based on one or more of the grounds identified in section
2.1-2.3 of this policy.

4.4 Discrimination
Discrimination is any practice or behaviour, whether intentional or not, which has a negative impact on
an individual or group protected in the Canadian Charter of Rights and FreedomsOpens in new window
(e.g., disability, sex, race, sexual orientation, etc.) by excluding, denying benefits or imposing burdens
upon them. Discrimination may arise as a result of direct differential treatment or it may result from the
unequal effect of treating individuals and groups in the same way. Either way, if the effect on the
individual is to withhold or limit full, equal and meaningful access to goods, services, facilities,
employment, housing accommodation or contracts available to other members of society and their
membership in a prohibited ground was a factor, it is discrimination.

4.5 Duty to Accommodate

The legal obligation to take steps to eliminate disadvantage caused by systemic, attitudinal or physical
barriers that unfairly exclude individuals or groups protected under the Canadian Charter of Rights and

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Freedoms. It also includes an obligation to meet the special needs of individuals and groups protected
by the Code unless meeting such needs would create undue hardship. Failure to accommodate a
person short of undue hardship is a form of discrimination (for service provision accommodation
obligations, refer to the Accessibility for Ontarians with Disabilities Act Opens in new window; in the
area of employment, refer to Knightsbridge’s Accommodation Policy, Accommodation Procedures and
Accommodation Guidelines.

4.6 Employee
For the purpose of this policy, the term employee includes Knightsbridge employees, job applicants and
individuals performing services directly on Knightsbridge’s behalf whether with or without compensation
or benefit, excluding individuals providing services by way of service provision/third party contracts –
see section 2.3

4.7 Equal Treatment

Equal treatment is treatment that brings about an equality of results and that may, in some instances,
require different treatment. For example, to give all employees equal treatment in entering a building, it
may be necessary to provide a ramp for an employee who requires the use of a wheelchair.

4.8 Incident
An incident is an event or occurrence in which discriminatory and/or harassing behaviour is exhibited in
the workplace. An incident includes situations where an individual knows or ought to have reasonably
known that the behaviour is contrary to this policy. An incident may not have to be raised to
management directly by a complainant (e.g., a manager is aware of sexualized banter between workers
through observation or this information is raised to the manager by a third-party, but no one has come
forward to complain).

4.9 Incivility
Incivility refers to conduct that is not harassment. It is subtle or overt, deviant behaviour where intent
can be ambiguous. It is characterized by rude, discourteous interactions that display a lack of regard for
others.

4.10 Harassment
Provisions regarding harassment are included in both the Canadian Charter of Rights and Freedoms,
referred to as “Code-based Harassment”, (see 4.11) and the Occupational Health and Safety Act,
referred to as “Workplace (non-Code) Harassment”, (see 4.12). It is a form of discrimination if it is
Code-based Harassment. Harassment may result from a single significant incident or a series of
incidents. Harassment can occur between co-workers, between management and employees.

This policy is not intended to interfere with normal social interaction between employees.

4.11 Code-based Harassment

Code-based Harassment is defined in the Canadian Charter of Rights and FreedomsOpens in new
window means engaging in a course or conduct that is known or ought reasonably to be known to be
unwelcome based on one or more of the prohibited grounds listed in the Canadian Charter of Rights
and Freedoms, that a person knows or ought to know would be unwelcome, offensive, embarrassing or
hurtful – see section 2.0 for a list of the prohibited grounds. See section 4.13 and 4.14 for examples

Examples of Code-based harassment that is based on a prohibited ground include, but are not limited
to:
 slurs or derogatory remarks;

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  threats;
 inappropriate jokes, innuendos, name-calling, teasing, embarrassing practical jokes;
 insulting gestures;
 displaying pin-ups, pornography, racist, homophobic or other offensive materials;
 use of electronic communications such as the internet and e-mail to harass;
 actions that invade privacy;
 spreading rumours that damage one’s reputation;
 refusing to work with another;
 condescending or patronizing behaviour;
 abuse of authority which undermines performance or threatens careers;
 unwelcome touching, physical assault or sexual assault

There is no legal obligation for an individual to tell a harasser to stop. The fact that a person does not
explicitly object to harassing behaviour, or appears to be going along with it does not mean that the
behaviour is not harassing or that it has been consented to.

4.12 (Non-Code) Workplace Harassment

(Non-Code) Workplace Harassment is harassment that is not related to a prohibited ground identified in
the Canadian Charter of Rights and Freedoms. Workplace harassment, defined in the Occupational
Health and Safety Act Opens in new window means engaging in a course of vexatious comment or
conduct against a worker in a workplace that is known or ought reasonably to be known to be
unwelcome. It also includes Workplace Sexual Harassment – see section 4.13

Workplace harassment often involves a course or grouping of behaviours. However, a single serious
incident of such behaviour that has a lasting harmful effect on an employee may also constitute
workplace harassment.

This policy is not intended to interfere with constructive feedback regarding performance or operational
directives provided to employees by their supervisors, managers or directors.

Examples of workplace harassment include a pattern of:

 frequent angry shouting/yelling or blow-ups
 regular use of profanity and abusive language
 verbal or e-mail threats (not including threats to exercise physical force which are covered by
the workplace violence policy)
 intimidating behaviours – slamming doors, throwing objects
 targeting individual(s) in humiliating practical jokes,
 excluding, shunning, impeding work performance
 spreading gossip, rumours, negative blogging, cyber-bullying
 retaliation, bullying, sabotaging
 unsubstantiated criticism, unreasonable demands
 frequent insults and/or name calling
 public humiliation
 communication that is demeaning, insulting, humiliating, mocking
 intent to harm
 a single, serious incident that has a lasting, harmful impact.
 Workplace harassment does not include:
 legitimate performance/probation management
 appropriate exercise and delegation of managerial authority
 operational directives/direction of workers or the workplace

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  other reasonable action(s) taken by management
 a disagreement or misunderstanding
 conflict between co-workers
 work related change of location, co-workers, job assignment
 appropriate discipline
 less than optimal management
 a single comment or action unless it is serious and has a lasting harmful effect
 rudeness unless it is extreme and repetitive
 incivility
 conditions in the workplace that generate stress (technological change, impending layoff, a new
boss, friction with other employees, workload, etc.).

4.13 Sexual Harassment

Sexual harassment is a form of discrimination based on the prohibited ground of sex under the
Canadian Charter of Rights and Freedoms. It is also prohibited under the Occupational Health and
Safety Act Opens in new window. Workplace sexual harassment means engaging in a course of
vexatious comment or conduct against a worker in the workplace because of sex/sexual
orientation/gender identity/gender expression, where the course of comment or conduct is known or
ought reasonably to be known to be unwelcome. It also includes making a sexual solicitation or
advance where the person making the solicitation or advance is in a position to confer, grant or deny a
benefit or advancement to the worker and the person knows or ought reasonably to know that the
solicitation or advance is unwelcome.

Sexual orientation

Refers to the sex/gender of those to whom one is sexually and romantically attracted. Categories of
sexual orientation typically have included attraction to members of one’s own sex/gender, attraction to
members of another sex/gender, and attraction to people of more than one sex/gender.

Gender Identity

Refers to each person’s internal and individual experiences of gender. It is their sense of being a
woman, a man, both, neither, or anywhere along the gender spectrum. A person’s gender may be the
same as or different from their birth-assigned sex.

Gender Expression

Refers to how a person publicly presents their gender. This can include behaviour and outward
appearance such as dress, hair, make-up, body language and voice. A person’s chosen name and
pronoun are also common ways of expressing gender.

 Examples of harassment related to the ground of sex, sexual orientation, gender expression
and/or gender identity include but are not limited to:
 sexually suggestive or obscene remarks or gestures
 use of homophobic or transphobic epithets, slurs or jokes
 insults, comments that ridicule, humiliate or demean people because of their sex, sexual
orientation, gender identity or expression.
 behaviour that polices and/or reinforces traditional heterosexual gender norms
 intrusive comments, questions or insults about a person’s body, physical characteristics,
gender-related medical procedures, clothing, mannerisms or other forms of gender expression.

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  negative stereotypical comments about an individual’s physical characteristics or mannerisms
and/or behaviours that reinforce traditional heterosexual gender norms
 circulation or posting of homophobic, transphobic, sexist, derogatory or offensive signs,
caricatures, graffiti, pictures, jokes or cartoons, display of pin-up calendars, objectifying images
or other materials
 leering (suggestive staring) at a person’s body,
 unwelcome physical contact,
 having to work in a sexualized environment (bragging about sexual prowess, or discussions
about sexual activities),
 exercising power over another person, making them feel unwelcome or putting them ‘in their
place’ – regardless of whether the behaviour is motivated by sexual interest
 spreading rumours about, “outing”, or threatening to “out” someone
 refusing to refer to a person by their self-identified name and personal proper pronoun
 other threats, unwelcome touching, violence and physical assault.

4.14 Racial Harassment

Racial harassment is harassment on the ground of race. It may also be associated with the grounds of
colour, ancestry, where a person was born, a person’s religious belief, ethnic background, citizenship or
even a person’s language. Racial harassment/discrimination can include:

racial slurs or jokes

 ridicule, insults or different treatment because of your racial identity
 posting/e-mailing cartoons or pictures that degrade persons of a particular racial group
 name-calling because of a person’s race, colour, citizenship, place of origin, ancestry, ethnicity
or creed.

4.15 Mediation

A confidential dispute resolution process, during which a neutral third party assists two or more parties
to resolve conflict. It is a voluntary process where parties in dispute consent to meet with a trained
mediator to determine whether the dispute can be resolved in a mutually satisfactory manner.
Mediation discussions between parties are treated as private and confidential to the full extent
permitted by law.

4.16 Poisoned Work Environment

A poisoned work environment is a form of indirect Code based harassment/discrimination. It occurs

when comments or actions ridicule or demean a person or group creating real or perceived inequalities
in the workplace. Pornography, pin-ups, offensive cartoons, insulting slurs or jokes, and malicious
gossip (even when they are not directed towards a specific employee or group of employees) creating
intolerable work conditions, have been found to “poison the work environment” for employees.

4.17 Prohibited (Protected) Grounds

Refers to the list of grounds for which a person or group is protected under the Canadian Charter of
Rights and Freedoms and Occupational Health and Safety Act. See Application section 2.0 for a list of
prohibited grounds. Under the Code, case law and this policy, there are protections where there is a
perception that one of the prohibited grounds applies or where someone is treated differently because
of an association or relationship with a person identified by one of the above grounds.

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4.18 Reasonable Person Test

This is an objective standard to measure whether a comment or conduct is discrimination or

harassment. It considers what a reasonable person’s reaction would have been under similar
circumstances and in a similar environment. It considers the recipient’s perspective and not stereotyped
notions of acceptable behavior. This standard is used to assess human rights complaints under this
policy.

4.19 Respondent

The person who is alleged to be responsible for the discrimination or harassment. There can be more
than one respondent in a human rights complaint.

4.20 Witness

An individual who may be able to provide information about workplace comments/conduct that are
alleged to have violated this policy. Witnesses are not entitled to investigation results or complaint
details unless the disclosure is necessary for the purpose of investigating allegations.

4.21 Workplace

The workplace includes all locations where business or social activities of the Company are conducted.
This Policy may apply to incidents that happen away from work (e.g., inappropriate social media posts,
phone calls, e-mails or visits to an employee’s home, incidents at luncheons, after work socials).

5.0 Harassment and Discrimination Prevention Resources

All staff are expected to be familiar with policy provisions and complaint resolution options. The Human
Rights Office has produced a variety of information and instructional training/resources to educate
employees about policy expectations.

Confidential Human Rights Enquiries are to be sent by email to hr@knightsbridgecorp.ca

COVID-19: Mandatory Vaccination Policy

Policy Statement
The health and safety of Knightsbridge employees is a priority. The Knightsbridge Group of Companies
is committed to taking every precaution reasonable in the circumstances for the protection of the health
and safety of workers from the hazard of COVID-19. Vaccination is a key element in the protection of
City employees against the hazard of COVID-19. This Policy is designed to maximize COVID-19
vaccination rates among employees as one of the critical control measures for the hazard of COVID-19.
To this end Knightsbridge employees, students and volunteers are required to be vaccinated against
COVID-19.

Background and Current Situation

Full vaccination has been shown to be effective in reducing COVID-19 virus transmission and
protecting vaccinated individuals from severe consequences of COVID-19 and COVID-19 variants
including but not limited to the Delta variant.

Given the continuing spread of COVID-19, including the Delta variant, within Canada, the compelling
data demonstrating a higher incidence of COVID-19 among the unvaccinated population and the

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increasing levels of contact between individuals as businesses, services, and activities have reopened,
it is important for City employees to be fully vaccinated in order to protect themselves against serious
illness from COVID-19 as well as to provide indirect protection to others, including colleagues.

Application
This policy applies to all Knightsbridge employees.

Employees in certain divisions may have obligations in addition to this policy under division-specific
policies regarding COVID-19 vaccination or under regulations, legislation or guidelines applicable to
them.

New Knightsbridge employees are required to be fully vaccinated against COVID-19 as a condition of
being hired by Knightsbridge.

Support for Vaccinations

The Knightsbridge Vaccination at Work policy supports employees in obtaining their COVID-19
vaccination. If operationally feasible and with the permission of their immediate supervisor, employees
can be released on work time to be vaccinated, either in the work location or at a designated
vaccination site, without loss of compensation or the requirement to use credits, to a maximum of one
day.

Continued Compliance with all Health and Safety Precautions

Unless a legislated or regulatory exemption applies, all Knightsbridge employees are expected and
required to continue to comply with applicable health and safety measures to reduce the hazard of
COVID-19, including but not limited to compliance with established workplace access controls (e.g.
screening), wearing a mask or face covering, using provided PPE, maintaining appropriate physical
distancing and self-monitoring of potential COVID-19 symptoms when at work or otherwise engaged in
company business.

Employees who remain unvaccinated due to a substantiated Human Rights Code related
accommodation request under Knightsbridge’s Accommodation Policy, procedures and guidelines, may
be required to take additional infection and prevention control measures, including providing proof of a
negative COVID-19 test, as well as self-isolate if exposed to COVID-19.

Responsibilities
All levels of management are responsible for the administration of this Policy.

Managers are expected to:

 lead by example, and;
 ensure employees complete any required education or training about COVID-19, including
regarding vaccinations and safety protocols.

Employees are expected to:

 follow all health and safety policies and protocols, and;
 complete any required education or training about COVID-19, including regarding vaccinations
and safety protocols.

Vaccination Requirement
All Knightsbridge employees are required to be fully vaccinated with a COVID-19 vaccine series by
October 30, 2021. For a two dose vaccine series, employees must receive one dose of COVID-19
vaccine by November 30, 2021 and two doses of COVID-19 vaccine by October 30, 2021. For a single

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dose vaccine series (e.g. Johnson and Johnson), employees must receive the dose by October 30,
2021.

Proof of Vaccination
The Knightsbridge requires proof of vaccination from all employees. Proof means documentation
verifying receipt of a vaccination series approved by Health Canada or the World Health Organization.

Employees must disclose their vaccination status to Knightsbridge in accordance with the established
process by no later than September 13, 2021.

Employees who, by September 13, 2021, disclose that they have not received two doses of COVID-19
vaccine (or a single dose in the case of a single dose vaccine series), or who have not disclosed their
vaccination status as required, shall attend mandatory education on the benefits of vaccination, in
addition to the obligations identified under “Vaccination Requirement” above.

Employees will be required to update their vaccination status in accordance with the established
process and by the dates set out in this policy, as they obtain each dose of COVID-19 vaccine.

Knightsbridge will maintain vaccination disclosure information, including documentation verifying receipt
of a vaccination series approved by Health Canada or the World Health Organization, in accordance
with privacy legislation. This information will only be used to the extent necessary for implementation of
this policy, for administering health and safety protocols, and infection and prevention control measures
in the workplace.

Employees may also be required to disclose their vaccination status by law or to otherwise give effect
to this policy, including, but not limited to, situations where employees are directed to stay home as a
result of the daily screening tool in order to comply with the clearance criteria to return to work (e.g.
after experiencing symptoms, a COVID-19 exposure, or a travel quarantine exemption).

Accommodations in Accordance with the Human Rights Code

Employees who are not able to obtain a COVID-19 vaccine for a reason related to a protected ground
set out in Knightsbridge’s Human Rights and Anti-Harassment Discrimination Policy (HRAP), can
request accommodation, using Knightsbridge’s Accommodation Request Form Word file and
cooperating in the accommodation process as set out in Knightsbridge’s Accommodation Policy and
Procedure.

All accommodation requests require written proof of the need for accommodation to be submitted along
with the Accommodation Request Form Word file (e.g. in the case of a request for a medical
accommodation, medical documentation from a physician or nurse practitioner, including whether a
medical reason is permanent or time-limited).

Ongoing Monitoring and Assessment of COVID-19 Workplace Safety Measures

Knightsbridge will continue to closely monitor its COVID-19 risk mitigation strategy and the evolving
public health information and context, to ensure that it continues to optimally protect the health and
safety of employees in the workplace and the public that they serve. To that end, and in consultation
with Toronto Public Health and occupational health and safety experts, Knightsbridge will continue to
assess other available workplace risk mitigation measures, including, for example, requiring proof of a
negative COVID-19 test, etc. If it is determined that additional precautions are necessary, Knightsbridge
may decide to deploy new measures (including at an individual level) to protect employees and the

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public from COVID-19, and may amend this policy accordingly and/or communicate the required
precautions to impacted employees.

Consequences of Non-Compliance with Policy

Employees who do not comply with this policy may be subject to discipline, up to and including
dismissal.

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ACKNOWLEDGEMENT OF HAVING READ THE EMPLOYEE HANDBOOK

I, _____________________________, attest that I have read the Employee Handbook and its various
components, including the following:

 Working Conditions Handbook

 Company Rules and Regulations
 Company Code of Ethics

I acknowledge having received all the relevant information that I needed in order to have a good
understanding of the content or scope of this Handbook.

__________________________________________ _______________________________

Employee’s signature Date

__________________________________________ _______________________________

Presidents signature Date

Please sign this letter and return a copy of Knightsbridge

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