Personal Information Protection Policy

Purpose

The Oppenheimer Group maintains the principles of integrity and trust with respect to the privacy of personal information. As part of this commitment, Oppenheimer will protect the privacy of personal information by applicants for employment with the company, employees of the company and personal information received by the company from other sources at all times during and after employment with the company. To ensure this commitment, the company will comply in all material respects with all applicable privacy laws.

Definition of terms used in this policy

"Contact information" is information that enables an individual to be contacted at a place of business, including their name, position, business telephone number, business address, business e-mail or business fax number.

"Employee personal information" is personal information about an individual that is collected, used or disclosed solely for the purposes reasonably required to establish, manage or terminate an employment relationship, but does not include information that is not about an individual's employment.

"Personal information" is information about an identifiable individual, but does not include contact information or work product information.

"Work product information" is information related to an individual's employment or business, which is prepared or collected, by an individual or group of individuals as part of their employment or business responsibilities.

Privacy Officer

The company's Privacy Officer is Marjorie Calibaba, Director Human Resources. Any questions related to the Privacy Policy should be directed to the Privacy Officer.

Purpose for Collection of Personal Information

The Company collects, uses and discloses employee personal information for reasonable purposes related to the employment relationship, including:

• To administer compensation, benefits, pension and payment of wages. Your name, birth date, salary, social security number and address is disclosed to third party carriers so they can process and maintain your benefits and pay.
• To meet statutory, common law and other Federal, state and provincial regulatory requirements such as employment Insurance, pension plans and workers' compensation legislation.
• To manage the workforce, e.g. to make staffing and succession decisions for employment development, performance evaluations, 360o reviews, assessing ability to meet business objectives, etc.
• To manage our business operations, surveys, applications for immigration visas and permits, etc.
• To provide information to Anderson Air for customs clearance purposes. This information is also required from customers whenever they travel aboard Anderson Air.

Security

The company maintains reasonable safeguards that comply in all material respects with industry standards to guard personal information against loss, destruction or modification.

Accuracy of Information

The company makes all efforts to ensure that personal information collected, used and disclosed for its intended use is accurate and as complete as possible.

Access to Employee Personal Information

An employee may request access to his or her employee personal information, or request correction of an error or omission in his or her employee personal information, by making a request in writing to the Privacy Officer and specifying the information for which access is requested or for which the correction is being sought.

In some circumstances, the company would not be required to provide information requested by an employee or contractor (for example, when an investigation is being conducted and disclosure of the requested information would harm the investigation process). If all or part of the requested information is refused, the Privacy Officer will provide the applicant with a response that includes: reasons and the provision of the Act on which the refusal is based; the name or title and contact information of someone who can answer the applicant's questions about the refusal; and information on how to request a review by the Information and Privacy Commissioner.

If an employee asks to review documents in his or her personnel file, the employee shall review the requested documents in the presence of an appropriate company representative at a mutually convenient time. An explanation will be given as to how this personal information has been used and a list will be provided of any individuals or organizations to whom their personal information has been disclosed.

Correction

In the case of a request to correct personal information, the Privacy Officer will first of all verify that the information is inaccurate or incomplete. If a correction is made, a copy of the corrected personal information will be sent to each organization to which the incorrect or incomplete information was disclosed in the past year. If no correction is made in response to an individual's request, the Privacy Officer will annotate the personal information to indicate that a correction was requested but not made.

Training

The company will make every effort to train all employees with respect to their rights and obligations relating to protection of personal information.

Retention

The company retains employee personal information in a manner consistent with statutory and legal requirements and will retain employee personal information as long as is reasonably necessary within those requirements.

Complaints

If you have a complaint about how your personal information is being collected, used, maintained or disclosed, or about the Privacy Policy, you must submit your complaint in writing, specifying your concerns. The complaint should be delivered to the Privacy Officer.

Once in receipt of a complaint, the Privacy Officer will acknowledge the correspondence and provide an estimate date as to when the complaint can be dealt with. The Privacy Officer will investigate the claim and if necessary consult with the Privacy Committee to determine the correct course of action. Once a decision has been reached, the Privacy Officer will inform the complainant of the final decision.

Enforcement

The Privacy Officer will promptly and independently review and investigate every allegation that the Privacy Policy has been violated, by reviewing any practices and procedures which have occurred and determine whether any appropriate disciplinary measures should be taken.

Please contact our Human Resources department if you have any additional questions.