SaskEnergy Code of Conduct and Ethics Policy

Code of Conduct and Ethics Policy

Code of Business Conduct and Ethics Policy

Table of Contents 1.1 Purpose..................................................................................................................................3 1.2 Living the Values ..................................................................................................................4 1.3 Leaders ..................................................................................................................................5 1.4 How to Uphold the Code .....................................................................................................6 1.5 Speaking Up ..........................................................................................................................7 1.6 Decision Making ...................................................................................................................9 2.0 Safety...........................................................................................................................................10 2.1 Workplace Health & Safety ...............................................................................................11 2.2 Drugs and Alcohol ..............................................................................................................12 3.0 Integrity.......................................................................................................................................13 3.1 Conflicts of Interest ............................................................................................................14 3.2 Ethical Behaviour................................................................................................................19 3.3 Information Technology & Social Media..........................................................................20 3.4 Handling Company Assets.................................................................................................21 4.0 Stewardship................................................................................................................................24 4.1 Environment........................................................................................................................25 5.0 Spirit ............................................................................................................................................26 5.1 Respectful Workplace ........................................................................................................27 6.0 Relationships ..............................................................................................................................28 6.1 Interactions with the Public ..............................................................................................29

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1.1 Purpose This Code of Business Conduct & Ethics Policy ("Code") is designed to reaffirm SaskEnergy's commitment to integrity as a cornerstone of the behavior of our employees and all others who act on our behalf. SaskEnergy's employees are expected to exhibit corporate values as well as the utmost of honesty, objectivity, care and responsibility while they perform their duties. The Code is intended to provide both general and specific provisions to protect and guide employees faced with ethical, moral and legal circumstances during the course of their employment. SaskEnergy has a respected name and good reputation for providing safe and reliable natural gas service to the people of Saskatchewan. Public confidence can be eroded when employees’ conduct or the expectations of SaskEnergy as to their conduct is not of the highest standards. Moreover, both civil and/or criminal liability may be incurred by an employee or by the Company in situations where the employee is involved in a breach of the law or conflict of interest. What to Remember Employees shall not use SaskEnergy’s name when purchasing goods or services for other than corporate use when it could be inferred that the purpose in doing so is to solicit a material benefit not customarily available to others.

What You ShouldKnow

Throughout the Code, any reference to SaskEnergy, or the Company, includes SaskEnergy Incorporated and each of its direct and indirectly wholly owned subsidiaries. The Code applies to all employees (including Board of Directors, officers, in-scope and out-of-scope employees), as well as every supplier, agent, contractor and any other individual or organization that acts on behalf of SaskEnergy or its subsidiaries.

This symbol, found throughout the Code, indicates that additional information can be found by reviewing applicable SaskEnergy policies. This symbol provides added insight on what you should know.

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1.2 Living the Values SaskEnergy's values are the fundamental beliefs that the Company holds about how all employees should act while conducting business and accomplishing the vision and mission. SaskEnergy's values are safety, integrity, stewardship, spirit and relationships.

SaskEnergy lives by the following values:

Safety: We are always committed to our personal safety, the safety of our team and the public. Integrity: We are accountable for our decisions, our actions, and the results. Stewardship: We are responsible in our use of all resources. Spirit: We support a respectful, dynamic and a diverse work environment that encourages achievement. Relationships: We succeed through strong internal and external collaboration, trust and open communication. Employee conduct is guided not only by living the values but by adhering to company policies and practices.

The Company values are to guide the conduct of all employees. It is important that everyone embraces these values as they are fundamental to how business is conducted.

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1.3 Leaders The leadership and management team at SaskEnergy establishes and promotes SaskEnergy’s culture, and leads by example in exhibiting the values and principles of the Code by: • modelling appropriate behaviour consistent with the Code and the Company’s values; • understanding the link between the Code and the policies and practices that apply to the teams they lead; • promoting open communication and trust in the workplace so that their people feel secure about raising concerns and identifying improvements and opportunities; • fostering a positive work environment where principled and respectful actions are the norm; • holding employees accountable for compliance with the Code; and • responding promptly when concerns are raised and escalating those concerns when necessary to the Executive member responsible for Human Resources and/or Legal.

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1.4 How to Uphold theCode C o m p Compliance It is the duty of every employee to exercise proper care and judgment in the course of their employment, as well as good faith in all transactions involving SaskEnergy or its property when acting as its representative. l i

Enforcement Employees who contravene this Code or Company policies are subject to disciplinary action, which in certain cases may include termination of employment and/or prosecution. In addition to any other requirement, employees who cease to be employed by SaskEnergy for any reason agree they will keep all SaskEnergy confidential and proprietary information confidential, and will not disclose, show, demonstrate, reproduce, copy or use such information, or communicate it or any part of it to any third party, except as required by law. Annual Compliance Training On an annual basis, employees are to review the applicability and importance of the Code, as well as the consequence of any violation.

a n c e I t

i s Compliance with the Code is a condition of employment for all SaskEnergy employees. The Code is updated from time to time and employees are responsible to regularly familiarize themselves with the contents of the Code. The Company complies with the applicable laws and regulations in all of its operating jurisdictions. Employees are to have sufficient knowledge of these laws and regulations in order to identify potential risks, and to seek advice if they are unclear regarding their responsibilities. o f expected to abide by the codes of ethics to which licensed professional employees (e.g. lawyers, accountants, engineers) are legally bound, and SaskEnergy recognizes the primary responsibility of professionals to act in accordance with these codes. i s Professional Codes of Conduct In addition to the Code, employees are t h e d u t y

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1.5 Speaking Up

Guidelines SaskEnergy is committed to conducting business ethically while promoting a work environment that fosters mutual respect, open communication andintegrity. Everyone is expected to speak up, ask questions and raise concerns about business practices that may indicate illegal or unethical behaviour. This includes raising concerns about actual or suspected violations of this Code, company policies, practices and/or legal or regulatory standards. The Company is committed to investigating all good faith concerns raised in accordance with this Code. This includes protecting those who come forward to report such activities. Employees are expected to bring concerns into the open so that problems can be quickly resolved. When in doubt about an issue, speak up . Reporting Resources If an employee suspects illegal or unethical behaviour, or believes this Code is being violated, they are responsible for raising their concern. They can raise their concern to: • their manager; • the Executive member responsible for Human Resources; • the Executive member responsible for Legal. Investigations in whatever manner deemed appropriate will be conducted and, based on the findings of the investigation, action may be taken.

Whistleblower Policy Employees and the public can also access the Whistleblower Policy and utilize the third-party confidential, anonymous reporting mechanism by clicking on this link: https://www.clearviewconnects.com/home

For more information, refer to the Whistleblower Policy

What to Remember If a specific corporate policy directs an employee to report to someone other than the Executive member responsible for Human Resources and/or Legal, then the employee shall follow the reporting procedures in that corporate policy. commit a wrongdoing of these kinds. PIDA disclosures must be made through the prescribed form and must be submitted by the employee to either the Executive member responsible for Human Resources and/or Legal, or the Public Interest Disclosure Commissioner of Saskatchewan. Further information regarding PIDA, including the prescribed form, is available at www.saskpidc.ca. Public Interest Disclosure Act (PIDA) SaskEnergy employees may also disclose a wrongdoing under The Public Interest Disclosure Act (PIDA). PIDA defines wrongdoing as a contravention of any federal or provincial legislation; acts or omissions that create substantial and specific danger to life, health, safety or the environment; gross mismanagement of public funds or a public asset; or knowingly directing or counselling someone to

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Retaliation SaskEnergy employees who report

violations of the Code or other unethical conduct will be protected from reprisal provided they act reasonably and in good faith, and the matter is not frivolous. Any reprisal or attempted reprisal against someone reporting a suspected violation of the Code or unethical conduct is considered a breach of the Code. Employees who feel that they have been subject to retaliation as a result of reporting a violation should report the actions directly to the Executive member responsible for Human Resources and/or Legal.

What You ShouldKnow

All concerns must be raised in a timely manner and you should always provide as much and as specific information as possible. Remember that it is always better to self-report than to be the subject of another person’s allegation. Reporting in good faith means you are providing all the information you have, and you believe it to be true.

What to Remember Speak up if you see something wrong or have concerns. You will not be retaliated against.

If you suffer negative consequences after reporting a concern, speak up .

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1.6 Decision Making

Ethical Decision Making Ethical decision making starts with good judgment and common sense. It is not possible to produce a detailed list to cover every ethical, moral or legal circumstance that a SaskEnergy employee may face.

In many situations, common sense must prevail. Employees must use their individual good-faith judgment in deciding on the proper course of action.

What to Remember In all cases, if employees are unsure how to proceed, they should contact their manager or the Executive member responsible for Human Resources and/or Legal.

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2.0 Safety

We are always committed to our personal safety, the safety of our team and the public.

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2.1 Workplace Health & Safety

Safety Principles SaskEnergy has adopted the following principles and expectations: • All staff will practice due diligence with respect to safety, occupational health, protection of the environment and regulatory requirements. • Each employee is responsible for safety and health through performance of proper work practices, and will be provided with the necessary guidance, information, training and resources. • Each manager/supervisor is to ensure, insofar as reasonably practicable, the health and safety at work of all workers under their direct supervision and direction. • Persons responsible for safety and health leadership shall be provided with the guidance, information, training and resources necessary to address these matters. • In all matters relating to safety and health, communications shall be open and effective, and undertaken in a spirit of trust. • Staff are expected to meet the worker and supervisor obligations generally, as defined in legislation including The Saskatchewan Employment Act and the Criminal Code .

Guidelines Safety is a core value in all aspects of planning, building and operating our natural gas utility. SaskEnergy is committed to safety, particularly the safety of our team and the public, and this is to be demonstrated in the performance of all of our duties. SaskEnergy is committed to establishing and maintaining safe and secure working conditions, conducting all operations in an environmentally responsible manner, and applying consistent standards in training programs to support this principle. It is the responsibility of every employee to review and comply with the Company's health, safety and environmental policies and all relevant legislation including The Saskatchewan Employment Act , its regulations and all SaskEnergy safety policies and practices.

For more information, refer to the SaskEnergy Safety Manual

Driver’s Licence Employees operating a vehicle are required to have a valid driver’s licence of the proper classification for the type of vehicle being driven. Employees whose licence has been revoked, suspended or becomes void, and holding a valid licence is a requirement of their position, are required to advise their manager immediately and to cease operation of all vehicles while on corporate business. An employee’s loss of driving privileges may jeopardize continued employment with the Company.

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2.2 Drugs and Alcohol SaskEnergy is committed to maintaining a safe and healthy workplace, free from the negative effects of alcohol, drugs or other substance use. The Company does not tolerate the use, distribution, sale or

Employee Responsibilities

Employees must report to work fit for duty. Employees performing safety-sensitive work must disclose a substance abuse disorder to Employee Health Services. Employees are encouraged to report a substance abuse disorder to Employee Health Services. No discipline or dismissal for self- disclosing a substance abuse disorder before an incident . Disclosing a substance abuse disorder after an incident will not prevent discipline up to and including dismissal. Employees cannot possess unlawful and/or unauthorized substances while conducting company business. Consult with the prescribing physician regarding job duties and the potential impact of any authorized substance.

possession of illegal/unauthorized drugs or alcohol on its premises or in its vehicles. Employees are not permitted to work or report to work when under the effect of illegal/unauthorized drugs or alcohol.

What You ShouldKnow

Fit for work means being able to safely and acceptably perform assigned duties — including while assigned to standby, call-out or overtime work — without any limitations due to the use or after-effects of Unauthorized Substances and/or Unlawful Substances.

For more information, refer to the Drug and Alcohol Policy

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3.0 Integrity

We are accountable for our decisions, our actions, and the results.

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3.1 Conflicts of Interest

Guidelines A conflict of interest, or even the appearance of a conflict, can negatively affect SaskEnergy’s business and reputation. As SaskEnergy operates in the public sector, employees must act in the best interest of the Company at all times. Business decisions must be based on sound and objective judgment, without any concern or possibility that our decisions or objectivity could be influenced by personal considerations. Employees have a responsibility to guard against situations where conflicts of interest may arise. Even the appearance of a conflict of interest must be avoided. Whether or not an actual or potential conflict of interest exists depends upon the facts of each case. An employee who believes or becomes aware that a conflict of interest might exist should immediately cease the activity and contact the Executive member responsible for Human Resources and/or Legal.

Prizes Employees or their guest(s) shall not retain a prize that exceeds $500 in value at an event where SaskEnergy has funded the employee’s attendance or requested the employee attend on its behalf, or the employee has been invited to participate as a result of their employment. Where a prize with a value in excess of $500 is received, the employee shall have the option of retaining the prize, provided the employee either pays to the Company the value of the prize in excess of $500, or returns the portion of the prize that is in excess of $500, where possible. Nothing in this Code of Conduct shall prevent an employee, employee's spouse or employee's guest from retaining a prize with a value in excess of $500, if such prize is won in a skill-based competition (e.g., hole-in-one competition) or a game of chance (e.g., raffle draw).

What You ShouldKnow

What to Remember Employees have a duty to ensure that nothing interferes with their ability to make all business decisions in the best interest of the Company.

A conflict of interest is defined as a situation that exists where the personal activities, interests or dealings of an employee may impair that employee’s ability to perform their duties or where such activities, interests or dealings may negatively impact on SaskEnergy's reputation in the community or result in a personal gain or advantage by virtue of their job position.

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3.1 Conflicts of Interest

Gifts Employees cannot give or receive a gift or benefit of any kind when conducting business on behalf of SaskEnergy if it: (i) might be perceived to create an obligation on the part of the employee; (ii) might appear to improperly influence the employee in the performance of duties; or (iii) might give the perception a favour or special treatment is expected. In no situation shall an employee retain a gift that exceeds $200 in value. Where an employee receives a gift with a value in excess of $200, such tangible gifts become corporate property and will be submitted to the Company.

Business Hosting Employees may from time to time receive the benefit of activities in relation to the Company’s business purposes, or may act as a host to others in furtherance of the same. The only acceptable reasons for giving and receiving of entertainment are:

to build and reinforce relationships with other parties in pursuit of corporate business objectives; or

• to offer or receive normal courtesy while doing business, including colleagues within the Corporation from other locations. Business hosting of any kind must not be given nor received by an employee or their immediate family where it might be perceived that an obligation is created or a favour is expected. Where the Company acts as a host all expenses must be reasonable. Reasonable business expenses incurred will be reimbursed in compliance with the Corporation's business expense guidelines. In the event an employee has been asked to participate in an event that will bestow a favour on them in excess of $500 in value, such participation must be pre-approved by the President and Chief Executive Officer, or by the Chair of the Board of Directors in the case of the President and Chief Executive Officer.

What You ShouldKnow

Business Hosting includes business meals and business-related social events (i.e, sporting events, theatre events and concerts).

What to Remember If there is any question as to the appropriateness of an employee keeping a particular prize or gift, contact either the Executive member responsible for Human Resources and/or Legal.

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3.1 Conflicts of Interest

Outside Employment and Work for Volunteer Organizations Employees owe their primary employment allegiance to SaskEnergy. Employees involved in outside employment or self-employment must declare all such involvements to the Corporation by completing and submitting the appropriate form to the Legal Department to review whether a conflict of interest situation exists. Employees may engage in outside activities such as a personal business, a second job, board service or community work provided it does not:

Political Activities The Code does not limit an employee’s right to be an active participant in politics if they so choose. Employees shall not participate in political activities during working hours, or on SaskEnergy premises, or in a manner that may otherwise interfere with their duties. Leaves for the purpose of seeking public office will be granted in accordance with the applicable legislative rules and corporate policy. Employees should not make or recommend the contribution of SaskEnergy's funds, property or services to any candidate for or holder of office of government at any level, nor should employees make such contribution with personal funds in the name of SaskEnergy.

cause an actual or apparent conflict of interest; appear, by the way in which it is performed, to be an official act or to represent SaskEnergy or the Government of Saskatchewan; interfere with their time, attention and exercises required in the performance of employee’s regular duties; involve the use of SaskEnergy premises, assets, equipment, or supplies; involve activities that might damage SaskEnergy’s business or reputation.

Employees involved in decisions affecting sponsorships must declare if they volunteer with an organization to whom sponsorship dollars are to be allocated.

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3.1 Conflicts of Interest

Outside Business Involvement Employees must not directly or indirectly, including through family members, have a financial relationship with, or derive a financial benefit from, an individual or organization doing business with SaskEnergy where the employee is in a position to influence a decision within the Company pertaining to the individual or organization. Employees shall not, either directly or indirectly, enter into a contract to provide SaskEnergy with any materials or labour. Inquiries regarding outside business involvement should be directed to Executive member responsible for Human Resources and/or Legal.

Contracting Employees in a position of affecting the rights of third parties must not, either for themselves, or indirectly through family members or friends, have a financial relationship with, or derive a financial benefit from, an individual or organization doing business with SaskEnergy, where such employee is in a position to influence a decision. When an employee responsible for handling a matter on behalf of SaskEnergy learns that they may be in a conflict of interest situation, the employee must promptly inform the Executive member responsible for Human Resources and/or Legal in any case where the rights or interests of the public are concerned. For example, persons responsible for debt collection are not required or entitled to handle the accounts of their friends and relatives. An employee having the authority to contract on behalf of or otherwise make decisions on behalf of SaskEnergy affecting the rights of third parties must act with the highest degree of objectivity.

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3.1 Conflicts of Interest

Economics and Interests All dealings with suppliers are to be in the best interests of SaskEnergy and provide the best possible value to the Company. The Company's purchasing practices, and the employees who implement them, must be governed by the highest ethical standards. If an employee's job entails buying, leasing or renting on behalf of SaskEnergy, the employee must ensure that identical information is requested and received from suppliers with regard to quotations for material, equipment and work, whenever possible. All suppliers will receive equal consideration, as the employee’s choice will be based upon the quality of the product or service and the price charged unless otherwise indicated by SaskEnergy's policies and procedures permitted herein. Where a business seeks access to SaskEnergy premises for the purpose of selling its products and/or services to a group of SaskEnergy staff, the access must be in accordance with Crown Investments Corporation Workplace Business Solutions Guidelines.

Personal Relationship Disclosures SaskEnergy expects employees to disclose in a timely fashion, any personal or family relationships that might create an actual, perceived or potential conflict of interest. Employees are to exclude themselves from the process of selecting or hiring someone as contractor, supplier, vendor or employee at SaskEnergy if they have a personal or family connection with that person and are to ensure the individuals responsible for the selection or hiring process are made aware of the relationship. The Company expects all employees to avoid situations where they could manage, supervise or evaluate the performance of someone who they have a personal or family connection.

What to Remember SaskEnergy employees shall not handle their own account or handle the accounts of friends or relatives.

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3.2 Ethical Behaviour

Fraud The Company does not tolerate fraud in any form, whether initiated by employees or others. SaskEnergy is committed to investigating all cases of fraud and, where appropriate, will take disciplinary action including referral of the matter to appropriate authorities. All employees have the responsibility to review all transactions prior to submitting/approving expenditures for payment or reimbursement. Any employee who believes that a fraudulent transaction has occurred or is about to occur should report their concern to their manager or the Executive member responsible for Human Resources and/or Legal. Bribery A bribe occurs when someone gives or promises another person something of value to obtain a benefit or favourable treatment. Bribes do not always come in the form of cash, bank transfers or even gifts. They can take the form of anything with value, such as job offers, contracts or favours for family and friends. Offering or accepting bribes and/or kickbacks is illegal, unethical and a violation of the Code. Report any suspicious activities, transactions or alleged violations to the Executive member responsible for Human Resources and/or Legal. What to Remember Honesty with time means a fair day’s work for a fair day’s pay, keeping absences to a minimum, reporting to work on time and generally abiding by work rules in place.

Our Goal SaskEnergy employees are to act with integrity, transparency and accountability in all of their business affairs. Duty to Report Criminal Charges and Convictions If an employee is charged with, or convicted of, an offence that: (i) could impact the ability of the individual to perform their duties; (ii) could negatively impact the reputation of SaskEnergy; (iii) could affect the willingness of other employees to work with the individual; (iv) could pose a threat to the Company’s ability to carry on its business safely and efficiently; or (v) occurs on Company property or in Company equipment; the individual is required to report such charge or conviction as soon as reasonably possible to their manager and the Executive member responsible for Human Resources and/or Legal. Failure to report the charge or conviction as soon as reasonably possible may result in disciplinary action up to and including termination.

What You ShouldKnow

Fraud is defined as the theft, abuse or misuse of funds or resources where the act is made with the intention of obtaining an advantage, avoiding an obligation, or causing loss to another party. Falsifying business records such as time sheets, invoices, travel benefits and expense claims is fraud.

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3.3 Information Technology & Social Media

Guidelines

What to Remember Employees are to be careful when drafting electronic messages, including email and text messages, as these communications are permanent business records. Messages can be forward or altered without knowledge and can damage the Company’s reputation.

Employees are to use information technology systems and assets (such as computers, mobile phones, tablets and IT networks) responsibly and in accordance with company policies and practices. This includes using them for legitimate business purposes and requires that employees take adequate precautionary steps to protect against potential cyber risks. Employees are to never use these resources to perform illegal or unethical activities. Social Media Social media includes websites, networking and online tools that allow users to interact with each other in diverse ways — by instantly sharing information, opinions, knowledge and interests. Employees must maintain constant awareness that online activities may reflect on the Company. Employees should never engage in social media activities that could harm the reputation of the Company. Employees are to communicate with integrity and respect and ensure their comments are business appropriate. Employees are to let people know that their views are their own and not those of SaskEnergy.

What You ShouldKnow

Employees should have no expectation of privacy when using SaskEnergy’s information technology systems or assets. The Company reserves the right to monitor its system, including blocking access to inappropriate websites and intercepting any messages or files transmitted by or stored in their systems. While occasional personal use of SaskEnergy information technology systems and assets is permissible, use of the assets must not cause significant added cost to SaskEnergy and/or interfere with work-related duties and responsibilities.

For more information, refer to the Enterprise Security Policy , Social Media Policy and Acceptable Use of Technology Policy

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3.4 Handling Company Assets

Financial Assets Compliance with generally accepted accounting principles and internal controls is expected at all times and SaskEnergy's books of account reports (i.e., financial/operational), records (i.e., expense reports, job applications, time sheets) and other documents must accurately account for and report all assets, liabilities and transactions affecting SaskEnergy. Employees are accountable for any corporate funds over which they have control. If SaskEnergy’s money is spent, or personal money is spent on the understanding that it will be reimbursed, the spender should ensure that the Company receives good value. Claims for reimbursement must be for actual expenditures, and/or be in accordance with corporate policies. Employees responsible for handling SaskEnergy’s funds and associated records and materials are also accountable for the safe keeping of these matters. With the exception of business hosting and corporate-initiated events such as the Service Achievement Awards, alcohol shall not be purchased with corporate resources. In the case of the purchase of alcohol at corporate-initiated events, prior approval of the Division Executive Vice President or Chief Executive Officer is required.

Employee Responsibility Employees are responsible for the security of all SaskEnergy assets whether they are physical or intangible. This means employees are responsible for protecting them from theft, loss, damage, waste and improper use. Employees are to protect the confidentiality associated with intellectual property during their tenure and after their departure from the Company. Copyright SaskEnergy utilizes a variety of information, data, and computer software programs that are subject to certain conditions. Employees must only use computer software in accordance with these licensing agreements. Employees shall not make unauthorized copies of corporate software, as such action may be a breach of contractual obligations and may lead to potential criminal charges or litigation. Due to virus and licensing concerns, all software used must be approved and acquired by SaskEnergy. Use of external software is prohibited without the express written permission of the Company. Employees who are unclear about appropriate external software should consult the Digital Technology & Security Department, and access the application link on Innergy.

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3.4 Handling Company Assets

Corporate and Employee Security and Privacy SaskEnergy recognizes that on many occasions, it and its employees will receive information or requests that deal with matters that may be of a private or sensitive nature. SaskEnergy's customers, agents, employees and governing bodies have a right to expect that, as a responsible corporation, and as required by law, the Company and its employees will endeavor to conduct its business in a manner that respects corporate and individual security and privacy. SaskEnergy recognizes that in order to administer its employee programs it must collect personal information about its employees. Such information must be kept private and secure from inappropriate disclosure or use. SaskEnergy and its employees will only collect, use and disclose any personal information about its employees or customers for the purpose outlined, and in accordance with, Company privacy policies.

Confidentiality Subject to SaskEnergy’s obligations pursuant to The Freedom of Information and Protection of Privacy Act (Sask.), all data and information held by SaskEnergy, in whatever form, is confidential and the property of SaskEnergy, and may also be subject to The Public Interest Disclosure Act . Employees are not permitted to disclose information about SaskEnergy, its property, or its activities to any unauthorized employee or party, or discuss it outside of the workplace prior to its release to the public. This includes any information obtained by employees in the course of employment that is not generally available to the public. All customer information and employee information shall not be used by employees to derive any benefit to themselves, the employee’s relatives, friends or business associates. SaskEnergy employees who cease to be employed by SaskEnergy for any reason, agree that they will not disclose, show, demonstrate, reproduce, copy or use in any way, SaskEnergy confidential information and/or proprietary information or communicate it or any part of it to any third party, except as required by law. Employees regularly receive confidential information from those who do business with SaskEnergy. Prior to receiving such information, a written agreement should be entered into that sets forth our obligations for the use and protection of the information. These "non- disclosure" agreements should be referred to the Corporation's Legal Department. Employees must protect the confidentiality of any such information and limit their use of it to that which is authorized by the agreement. Employees are also responsible to see that those who are not authorized do not have access to the confidential information.

Intellectual Property All designs, ideas, inventions or

improvements made, conceived, written and/or designed during or after working hours and which fall within the scope of SaskEnergy’s business operations, belong to SaskEnergy. Employees are expected to disclose fully such designs, ideas, inventions, improvements and software and to assign all rights to SaskEnergy without charge. If the Company decides to develop or pursue an invention or software or apply for a patent or other intellectual property rights protection, the employee will provide complete cooperation.

For more information, refer to the Employee Privacy Policy and SaskEnergy Incorporated Privacy Policy

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3.4 Handling Company Assets

Physical Assets Employees have a responsibility to protect SaskEnergy’s physical property. Employees may not use (except as part of an employee’s normal duties), borrow, take, sell, lend, give away or intentionally damage any property, equipment, tools, materials and supplies, regardless of the condition or value, without specific authorization. SaskEnergy and its employees are responsible for assisting in preventing waste and theft of property. Insider and Other Trading An employee shall not, either directly or indirectly, personally profit from any information gained in the course of the employee’s employment. Employees shall not use inside information to trade securities of any organization with which SaskEnergy has dealings, except when done in compliance with laws governing insider trading. Insider information may include, but is not limited to, dividend changes, earnings estimates, significant business developments, expansion or curtailment of operations, sale or purchase of substantial assets or other activity of significance.

What You ShouldKnow

Corporate Property includes, but is not limited to, premises, equipment, supplies, furnishings, funds, reports, records, vehicles, trade secrets, security information, computer software and hardware and intangible items such as the details of business application systems whether these exist in print, electronic or other form.

Records Management SaskEnergy complies with legal and regulatory requirements related to the management of business records. The Company follows procedures that have been developed to ensure each department retains and discards business records appropriately. These procedures detail the length of time a record is to be retained and other relevant principles around business records management and storage. A business record includes information that evidences a business transaction, decision or action. The record can exist and be stored in either a paper or electronic format, and includes emails, text messages, digital data and other electronic data transmissions.

For more information, refer to the Records and Information Management Policy

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4.0 Stewardship

We are responsible in our use of all resources.

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4.1 Environment

Guidelines SaskEnergy is committed to the protection of the environment. Our commitment to environmental leadership is to reduce the impact of our daily operations on the environment, recognize the role we play in the stewardship of a non-renewable resource and protect the local environment including plant life, wildlife, wetlands, native prairie and species at risk. The Company expects its employees to build and consider sustainability into their operational decision making. Employees should strive to identify and implement emission reduction solutions wherever possible.

What to Remember

Report all environmental incidents and work processes that have the potential to adversely impact the environment, are not in compliance with environmental laws and regulations, or do not conform with internal environmental standards.

What You Should Know

Sustainability for SaskEnergy means providing reliable, affordable energy to our customers today and for years to come while acknowledging their desire for a cleaner energy future.

For more information, refer to the Environment and Sustainability Policy and Sustainability Report

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5.0 Spirit

We support a respectful, dynamic and a diverse work environment that encourages achievement.

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5.1Respectful Workplace

Our Guidelines SaskEnergy promotes and maintains a diverse workplace culture of inclusion and respect. The Company values employees’ individual differences, unique perspectives and backgrounds, and the variety of contributions each employee brings to work. Employees are to conduct themselves in accordance with applicable Human Rights legislation and corporate policies. SaskEnergy does not tolerate behaviour that interferes with employee well-being and work such as discrimination, harassment or violence. The Company is committed to eliminating exclusion, including those forms of exclusion prohibited by law. Conduct that does not align with the Company’s standard is taken seriously; it will be investigated and promptly acted upon. Behaviour that interferes with work or creates an offensive, intimidating, disruptive, abusive or hostile work environment is prohibited and can result in disciplinary action up to and including termination.

What You Should Know

To maintain an inclusive and respectful culture , the Company addresses behaviours that are inappropriate. Speak up if you observe conduct that does not align with our values or is disrespectful or non-inclusive. Employees will not be retaliated against for raising a concern in good faith .

What to Remember Employees must always be respectful to their co-workers and be sensitive to the way in which others may react to behaviours and comments. Employees must always try to resolve differences in a calm and respectful manner, without resorting to insults, threats or violence.

For more information, refer to the Harassment Policy and Respectful Workplace Policy

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6.0 Relationships

We succeed through strong internal and external collaboration, trust and open communication.

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6.1 Interactions with the Public

Guidelines Employees are expected to act ethically and to serve our customers effectively, either directly or by supporting the work of other individuals or departments. The Company expects employees to provide our customers with value and to deal with them fairly. Our customers deserve the highest quality service and high standards in all transactions. While working on customer premises, employee must act in professional and respectful manner. Employees must ensure they have the authority or permission to access customer property; respect customer property and privacy; not take or borrow anything without authorization or permission; and treat any information about the customer's affairs as confidential.

What You ShouldKnow

The conduct of SaskEnergy employees is always subject to intense public scrutiny. The public has a right to expect and to receive from SaskEnergy integrity, high ethical standards, and fair treatment. Such conduct is expected in all facets of SaskEnergy operations including the service of customers, procurement activities, or in the acquisition of property.

What to Remember

You are responsible for your behaviour and actions while you are at work and when you are out in the community.

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