Integrity and commitment are among Domtar's core values. These values imply that each employee acts in the best interest of Domtar and refrains from any conduct or activity that is actually or potentially detrimental to the well being of Domtar, or that may be so perceived.
A conflict of interest arises when an employee is faced with a choice of acting in some matter where the interests of Domtar conflict with the interests of the employee or any other person to whom the employee owes a duty.
Examples of conflict of interest situations include:
- Borrowing money from a supplier, customer or competitor;
- Receiving gifts or favours of more than nominal value ($75 or less), particularly in situations in which business judgment may be influenced;
- ransacting with a supplier, customer or competitor out of the ordinary course of business;
- Direct or beneficial ownership of an interest in the securities of a supplier, customer or competitor, except in the case of an investment representing less than 1% of the outstanding securities of a publicly traded corporation;
- Supplying goods and services to Domtar via a business controlled by the employee or an immediate family member;
- Engaging during working hours in activities, which are not directly related to and required in the performance of his duties, on behalf of individuals, associations or other companies, with or without remuneration, that deprive Domtar of the employee's services. Exceptions may be made on a specific and irregular basis, with the express approval of the immediate supervisor;
- For employees and members of their immediate family, accepting from or being a party to giving gifts or favours to anyone with whom Domtar is doing or negotiating business. However, this is not intended to prohibit normal and widely accepted ethical business practices such as business meals and receptions, including mementos or gifts of nominal value ($75 or less) from or to individuals or firms with which Domtar does business.
Domtar recognizes that an employee may be asked to serve as a director on the board of a company or of a trade, business or professional association or society. Domtar is, in principle, in favour of an employee becoming a director of such an organization provided that it does not create any conflict with or prejudice to the interests of Domtar, and provided that such activity does not unduly restrict the time that the employee should be devoting to his employment with Domtar. Prior to accepting any such position, an employee must obtain approval from the Senior Vice-President responsible for his group and the Senior Vice-President, Corporate Affairs, General Counsel and Secretary.
Domtar acknowledges that an employee may wish to become involved in political activities at the local/municipal, state/provincial or federal level, and that this involvement may result in a request for an adjustment to his normal work schedule, occasional unremunerated time off or a leave of absence. Domtar encourages such activities provided they do not create a conflict of interest for either the employee or Domtar, and provided the activities are carried out within the democratic traditions of our society.
Inquiries about this policy should be addressed to the Senior Vice-President, Corporate Affairs, General Counsel and Secretary.

