PRIVACY/CONFIDENTIAL AND CLIENT INFORMATION

Rayment & Collins Ltd. is committed to ensuring that all employees, clients, and partners understand our commitment to privacy and data protection. This policy sets forth our commitments to our employees and clients regarding the manner in which we will handle this information.

Protecting the privacy and confidentiality of personal information is critical to Rayment & Collins business practices. Rayment & Collins daily operations are predicated on the collection, use, and disclosure of personal information in an appropriate, responsible, and ethical manner.

SCOPE

Our business relies on employees and business partners to properly develop, maintain, and operate our systems, networks, and processes that ensure the security and proper use of our sensitive information. This means that every individual and organization that handles our information bears the responsibility to safeguard it, regardless of its location. This category includes computer systems, networks, paper copies, business processes, and verbal information transmission.

POLICY

Rayment & Collins requires all employees to handle sensitive personal client information in a confidential and appropriate manner in accordance with the Privacy Act and Personal Information Protection and Electronic Documents Act (PIPEDA).

We understand that employees will come into contact with confidential information about our clients during the course of their employment.

Employees acknowledge that if confidential information is not adequately protected, Rayment & Collins operations may be jeopardized, and our clients’ well-being and privacy may suffer irreparably.

The rules governing the handling of information are determined by applicable regulations, business requirements, and company commitments. Only the information necessary to accomplish a business objective will be collected and maintained in confidence.

Each employee, vendor, contractor, supplier, agent, or representative of Rayment & Collins must understand the importance of the information being handled and ensure that appropriate controls are in place to prevent data copying, disclosure, or other misuse.

Employees are required to keep all confidential information, both about the Company and our clients, confidential both during and after their term of employment. Employees shall not divulge, disclose, provide or disseminate confidential or private Information to any third party not employed by Rayment & Collins at any time, unless Rayment & Collins gives written authorization.

Failure to follow this policy may result in disciplinary action up to and including termination of employment.