INTRODUCTION

HARD Marketing is committed to ethical business practices and compliance with all applicable laws, including the prevention of tax evasion and its facilitation under Canadian law and other jurisdictions where we operate.

The policy is in line with the principles established by Canada’s Income Tax Act and relevant provincial tax regulations. This policy outlines our zero-tolerance approach to tax evasion or its facilitation, ensuring that all individuals and organizations associated with HARD Marketing adhere to the highest standards of integrity and compliance.

This policy applies to all employees, contractors, and associated persons acting on behalf of HARDMarketing, collectively referred to as “associated persons.”

BACKGROUND

The facilitation of tax evasion is a serious offense under Canadian law. Businesses can be held accountable if they fail to prevent their associated persons from facilitating tax evasion,whether intentional or due to negligence.

Tax evasion undermines public trust, carries severe penalties, and can result in reputational damage.Facilitating or turning a blind eye to such practices can lead to criminal prosecution, unlimited fines, and other legal consequences for both individuals and organizations.

HARD Marketing recognizes these risks and takes a proactive stance to ensure that reasonable measures are inplace to prevent the facilitation of tax evasion in any form.

SCOPE: WHO IS COVERED BY THIS POLICY?

This policy applies to:

•  Employees: All staff members, whether permanent, fixed-term, or temporary.

•  Leadership and Management: Senior managers, directors, and officers.

•  Contractors and Consultants: External advisors and independent contractors working with HARD Marketing.

•  Suppliers and Agents: Third-party service providers, vendors, and agents acting on behalf of HARD Marketing.

•  Business Partners: Joint ventures, affiliates, and any other entities working with or representing HARD Marketing.

This policy is binding for all associated persons regardless of their location, including Canada and any international operations.

WHAT IS TAX EVASION ANDFACILITATION OF TAX EVASION?

1.   Tax Evasion

Tax evasion refers to the deliberate and dishonest use of illegal methods to avoid paying taxes owed to the Canada Revenue Agency (CRA) or other tax authorities. Examples include:

     •   Misreporting or underreporting income.

     •   Falsifying tax records.

     •   Hiding assets or income in offshore accounts.

     •   Claiming false expenses or deductions.

2.   Facilitation of Tax Evasion

Facilitation occurs when an individual or entity knowingly assists or enables another party to evade taxes. Examples include:

     •   Altering invoices to reduce tax liabilities.

     •   Advising clients or suppliers on evasion strategies.

     •   Processing payments in ways designed to conceal taxable income.

HARD MARKETING’S ZERO-TOLERANCE POLICY

HARD Marketing strictly prohibits:

•  Engaging in any form of tax evasion.

•  Assisting,facilitating, or enabling others to evade taxes.

•  Turning a blind eye to suspicious activities that may indicate tax evasion.

Third-Party Compliance:

HARD Marketing expects all third parties, including suppliers and partners, to adhere to the same standards of compliance. Contracts with such parties will include clauses that enforce adherence to this policy.

IDENTIFYING RED FLAGS

Employees and associated persons must remain vigilant and report any of the following red flags:

•  Unusual Payment Requests: Requests for payments to accounts not specified in official documentation.

•  Altered Documentation: Suspicious changes to invoices, contracts, or financial records.

•  Non-Standard Business Practices: Discounts or deals offered without legitimate explanation, such as avoiding taxes.

•  Conflicting Information: Discrepancies between what is reported and what is observed during business operations.

•  Requests for Concealment: Instructions to hide or misreport information to tax authorities.

EMPLOYEE RESPONSIBILITIES

All employees must:

•  Familiarize themselves with this policy and the relevant laws.

•  Complete mandatory training on the prevention of tax evasion.

•  Report any suspicions or concerns regarding tax evasion or facilitation to their manager or a designated compliance officer.

Failure to adhere to this policy may result in disciplinary action, including termination of employment.

REPORTING PROCEDURES

1.   Raising Concerns:

If you suspect tax evasion or facilitation, immediately report your concerns to:

     •   Your manager or supervisor.

     •   The compliance officer.

     •   The confidential reporting hotline (if available).

2.   Confidentiality and Support:

Reports will be treated confidentially, and HARD Marketing will ensure that individuals raising concerns in good faith are protected from retaliation.

3.   What to Do If Asked to Facilitate Tax Evasion:

If you are asked to take part in activities that may facilitate tax evasion, you must decline and report the incident to your manager or compliance officer.

ONGOING MONITORING AND TRAINING

HARD Marketing is committed to maintaining an effective compliance program that includes:

•  Regular training for employees and contractors.

•  Periodic reviews and updates of this policy.

•  Ongoing monitoring of business practices to identify and mitigate risks.

POTENTIAL CONSEQUENCES

Violations of this policy may result in:

•  Criminal prosecution of individuals and the organization.

•  Fines,penalties, and legal costs.

•  Reputational damage to HARD Marketing.