Code of Conduct

Introduction

Aspen Grove Solutions exists to help organizations preserve and activate their most critical asset: knowledge. We do this by building knowledge infrastructure platforms, by advising clients on what they know and how to use it, and by partnering with people who trust us with information and systems of genuine importance.

With that trust comes responsibility. This Code of Conduct sets out how we expect everyone at Aspen Grove Solutions to behave — with our colleagues, our clients, our partners, and the communities where we work. It applies to all team members, contractors, and third parties acting on our behalf.

We are a small company with a long reach. Our work spans mining operations, government systems, and sensitive institutional environments. The standards we hold ourselves to must be equal to the weight of the work.

Our Purpose and Values

Our purpose is to transform institutional knowledge into living, queryable intelligence — so organizations never lose what they know, and always know what they have lost.

We pursue this purpose through three core values:

Integrity

We do what we say we will do. We are honest with clients about what is possible, transparent about our methods, and accountable when we fall short. We never misrepresent our capabilities or our findings to win a contract or to avoid a difficult conversation.

Respect for Persons

Every person we encounter — client, colleague, community member, or counterpart — is an end in themselves, never merely a means to our commercial goals. This principle shapes every relationship we build and every decision we make. We treat people with dignity, we listen with genuine attention, and we speak with candour and care.

Curiosity

We approach every engagement with intellectual humility and openness. Knowledge management is a human problem before it is a technical one. We stay curious about context, culture, and the lived experience of the people whose knowledge we are entrusted to preserve.

Our People

Health, Wellbeing and Safety

The wellbeing of our team members is not a policy obligation — it is a genuine priority. We work to create an environment where people can raise concerns without fear, take rest without guilt, and speak honestly without risk to their standing.

Every member of our team is expected to:

• Avoid work practices likely to harm their own health or the health of colleagues
• Report safety concerns immediately, whether physical, psychological, or digital
• Seek support when facing difficulties affecting their ability to work well

Equity, Diversity and Inclusion

Our strength comes from diverse perspectives. We do not discriminate on the basis of race, gender identity or expression, age, religion, national origin, disability, sexual orientation, or any other characteristic unrelated to a person's ability to contribute. We actively build a team and a culture where everyone belongs and can do their best work.

Each of us is responsible for:

• Treating colleagues and clients with equal respect and genuine kindness
• Recognizing our own biases and reflecting on how they may affect our decisions
• Speaking up when we witness behaviour inconsistent with these principles

Preventing Harm

We do not tolerate bullying, harassment, sexual harassment, racism, or any form of workplace violence. These are not merely legal prohibitions — they are incompatible with who we are. Anyone who witnesses or experiences harmful behaviour is encouraged to raise it immediately. Concerns can be brought to any member of leadership or reported confidentially.

When someone raises a concern, we respond with empathy, we investigate fairly, and we act on what we find.

Our Partners and Clients

We select our partners and clients with care. We work with organizations whose values are broadly compatible with our own, and we maintain the right to decline engagements where doing so would compromise our integrity or harm the communities we care about.

In all client relationships, we:

• Deliver honest assessments, even when the findings are unwelcome
• Protect confidential information with rigour and discretion
• Disclose any conflict of interest before it has an opportunity to affect our work
• Communicate clearly about scope, timelines, and limitations

Our Business Practices

Countering Bribery and Corruption

We do not offer, give, request, or accept bribes in any form. We do not use gifts or hospitality to improperly influence decisions. Where gifts or hospitality are appropriate to a business relationship, they are modest, transparent, and always declared. Facilitation payments are never acceptable.

Conflicts of Interest

Conflicts of interest arise when personal interests intersect with our professional responsibilities. We expect team members to disclose any actual or potential conflict without delay, so we can manage it appropriately. Undisclosed conflicts undermine trust and will be treated seriously.

Confidentiality and Data Privacy

Knowledge management work routinely involves access to sensitive institutional information. We handle all such information with care, using it only for the purposes for which it was shared, storing it securely, and never disclosing it beyond what is authorized. We comply with applicable privacy legislation — including Canada's PIPEDA and relevant provincial equivalents — and we respect the privacy rights of every individual whose data we touch.

Intellectual Property

We respect the intellectual property of our clients, partners, and competitors. We use others' proprietary methods or materials only when authorized to do so. We also protect the intellectual property we develop, recognizing it as a core asset of the company.

Cyber Security

Our platform and our client engagements depend on robust information security. Every team member shares responsibility for protecting our digital environment. We follow established security protocols, report suspicious activity immediately, and never circumvent security controls without authorization.

Transparent Communications

We communicate honestly with all stakeholders — clients, partners, funders, and the public. We do not make representations we cannot substantiate. We acknowledge uncertainty when it exists, and we share both good news and difficult news with equal clarity.

Raising Concerns

We cannot improve what we do not know about. Anyone who has a concern about conduct, a potential breach of this Code, or a practice inconsistent with our values is encouraged to raise it — through their direct lead, through a colleague they trust, or directly with the CEO.

We protect those who raise concerns in good faith. Retaliation against anyone who speaks up is a serious breach of this Code and will be treated accordingly.

Living This Code

This Code is not a compliance document to be signed and set aside. It is a living expression of who we are and how we intend to work. All team members are expected to be familiar with it, to apply it in their day-to-day decisions, and to raise questions when they are uncertain.

Leaders at Aspen Grove Solutions are expected to set the example — to create the conditions where this Code can be lived, not merely observed. When we fall short, we acknowledge it, we learn from it, and we do better.