Code of Business Conduct and Ethics
The Board of Directors of the Corporation has adopted a Code of Business Conduct and Ethics (the “Code”)
to reflect the Corporation’s commitment to a culture of honesty, integrity and accountability and to outline the
basic principles and policies with which all directors, officers and employees of Onex and its operating
companies are expected to comply. A copy of the Code is available on written request made to the Corporation at 161 Bay Street, 49th Floor, Box 700, Toronto, Ontario M5J 2S1, Attention: Managing Director, General Counsel and Secretary.
The Board recognizes that it is ultimately responsible for monitoring compliance with the Code. This
monitoring is achieved through systems and processes implemented by Onex management that are designed to result in wide dissemination of the Code, to encourage compliance with its provisions, to encourage consultation with appropriate members of management to the extent that guidance is necessary or desirable, and to facilitate the reporting of actual or suspected breaches. Any breach or concern would be investigated by management as appropriate and, depending upon the circumstances, either dealt with by management with the results reported to the Board or referred to the Board for further action. The Code specifies that no individual who reports a violation or potential violation or who cooperates in the investigation of a violation or potential violation will be subject to harassment, discipline or retaliation as a result of such report. The chief executive officer of each of Onex’ operating companies is required to certify annually that he or she has caused the Code (or a comparable code of business conduct and ethics adopted by the Board of the particular operating company) to be disseminated to all employees and is not aware of any instance of non-compliance or breach.