**Exhibit 99.6**

 

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** **

** **

**TELUSETHICS POLICY**

** **

** **

**February 2008**

 

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**TELUS Ethics Policy**

 

**Table of Contents**

 
| Introduction                                                                                                   |   | 4  |
|----------------------------------------------------------------------------------------------------------------|--------|----|
| Responsibilities                                                                                               |   | 5  |
| Team TELUS                                                                                                     |   | 5  |
| Compliance/Exceptions                                                                                          |   | 5  |
| Managers                                                                                                       |   | 6  |
| Senior Managers  (directors and above)                                                                         |   | 6  |
| TELUS Board of  Directors Members and Employees who represent TELUS as Directors on other  organization boards |   | 6  |
| Ethics Office                                                                                                  |   | 6  |
| Ethics Work Group                                                                                              |   | 6  |
| Ethical Decision Making                                                                                        |   | 7  |
| 1. Questions to Ask  Yourself                                                                                  |   | 7  |
| 2. Review Guidelines and Policies                                                                              |   | 7  |
| 3. Talk to Your Manager                                                                                        |   | 8  |
| 4. Expert Assistance                                                                                           |   | 8  |
| 5. TELUS EthicsLine                                                                                            |   | 8  |
| 6. Last Resort Resolution                                                                                      |   | 9  |
| Ethical Guidelines                                                                                             |   | 11 |
| Customer and Team TELUS Information                                                                            |   | 11 |
| Privacy of Communications                                                                                      |   | 11 |
| Confidentiality of Information                                                                                 |   | 11 |
| Integrity                                                                                                      |   | 14 |
| Personal and Corporate Integrity                                                                               |   | 14 |
| Human Rights                                                                                                   |   | 14 |
| Proprietary Rights of Others                                                                                   |   | 14 |
| Compliance with Laws                                                                                           |   | 14 |
| International Operations                                                                                       |   | 15 |
| Public Safety                                                                                                  |   | 15 |
| Environment                                                                                                    |   | 15 |
| Political Activities                                                                                           |   | 15 |
| Company Assets                                                                                                 |   | 18 |
| Company Information                                                                                            |   | 18 |
| Public Disclosure                                                                                              |   | 18 |
| Business Records                                                                                               |   | 19 |
| Financial Transactions                                                                                         |   | 19 |
| Property                                                                                                       |   | 19 |
| Personal Use of  Communication Devices                                                                         |   | 20 |
| Conflict of  Interest                                                                                          |   | 23 |
| Relationships                                                                                                  |   | 23 |
| Competition                                                                                                    |   | 24 |
| Future Business                                                                                                |   | 24 |
| Outside Demands                                                                                                |   | 24 |
| Information                                                                                                    |   | 24 |
| Insider Trading                                                                                                |   | 25 |
| Gifts and Benefits                                                                                             |   | 25 |
| Dealing with  Suppliers, Contractors, Consultants and Agents                                                   |   | 30 |
| Selecting Suppliers, Contractors, Consultants and Agents                                                       |   | 30 |
| Adherence to applicable TELUS policies                                                                         |   | 30 |

 

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**AllTELUS team members:**

 

Centralto TELUS’ purpose is to make the future friendly for our stakeholders.  One of the critical elements in realizingthis ambition is to ensure our individual and collective reputation is abovereproach.  *How*wework is just as important as *what*we do.  Our goal is to demonstrate the highest levelof ethics and integrity in our business dealings with all stakeholders(customers, shareholders, suppliers, colleagues and our communities).  This is a corporate priority and a sharedresponsibility for all TELUS team members as each one of our actions anddecisions affect our company and its reputation.

 

ThisEthics Policy outlines the responsibilities and guidelines that describe the *ethical standard expected of all team members.* In addition,it provides a decision making process supporting the resolution of ethicalissues and identifies members of the TELUS team who are available for help andadvice.  Real life case studies areprovided to illustrate how ethical responsibilities and guidelines apply in everydaysituations.

 

Pleaseread this document carefully and make it an integral part of the way youconduct business at TELUS. You play an important role in representing ourorganization.  Guided by these ethicalstandards, we build trusted relationships with our customers, shareholders,suppliers, fellow team members and the communities in which we live, work andserve.

 

DarrenEntwistle

President and Chief Executive Officer

 

Robert McFarlane

Executive Vice-President and Chief Financial Officer

 

Josh Blair

Executive Vice-President, Human Resources

 

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***Introduction***

 

This Policyapplies to all of TELUS, including members of the Board of Directors, officersand employees of TELUS Corporation and its subsidiaries (referred to as TeamTELUS or team members).

 

It is notintended that there be any waivers to this Policy. In the unlikely eventthat a waiver is considered and granted it must receive prior approval by theBoard of Directors or their delegate. The delegate must be a Board committee for any waivers granted tomembers of the Board of Directors or executive officers.  In such circumstances, any waivers granted tomembers of the Board of Directors or executive officers will be disclosedsubject to the TELUS Policy on Corporate Disclosure and Confidentiality ofInformation.

 

Inreviewing this Policy, team members are reminded that TELUS reserves the rightto vary, revoke or amend any terms of the Policy as is required by the needs ofthe business.  TELUS will notify teammembers of any amendments to the Ethics Policy prior to the changes becomingbinding. Nevertheless, team members are encouraged to periodically review thisPolicy (at least annually) in order to remain familiar with its terms.  To assist this review, team members arerequired to complete the ethics training module each year.  The Ethics Policy constitutes a term of theemployment contract.

 

This Policy is available on theCompany’s intranet and is publicly available on the Company’s website, at www.telus.com,www.telusinternational.com and www.telusmobility.com.

 

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***Responsibilities***

 

### **TeamTELUS**

### ** **

All members of the TELUS team are expected to act honestly in alldealings, comply with the laws and regulations governing our businesses, andmaintain an ethical work environment**.***This standard requires that each member of our teamunderstand and apply the guidelines in this policy to everyday actions anddecisions.*

 

At TELUS, wenot only do things right, but we should strive to *do the right things*. Each member of our team takes responsibility for their actionsincluding:

·                  Observance of the guidelines outlinedin this and other company policies wherever in the world we are working

·                  Compliance with applicable local lawsand regulations

 

All business activities should be able to stand up topossible public scrutiny and further investigation if required.

 

Theguidelines in this policy are based upon generally accepted standards ofethical business conduct and applicable civil and criminal laws. The absence ofa guideline covering a particular situation does not relieve any of us from theresponsibility for acting ethically.

 

Team TELUS members, or any person acting under the directionthereof, are prohibited from directly or indirectly taking any action toimproperly influence, coerce, manipulate or mislead the Company’s external orinternal auditors or their representatives.

 

### **Compliance/Exceptions**

### ** **

In situationswhere the right ethical behaviour is unclear, or where there may be theappearance of a contravention of these guidelines, we support each other inseeking advice and clarification.  If youare unsure as to the ethical course of action, you should first discuss the situationwith your manager or the applicable department identified in this policy.

 

If you becomeaware of a possible violation of the Ethics Policy you are required to reportthis to the Director- Ethics and Controls Compliance.  For more details please refer to the TELUSEthicsLine section.  Members of the TELUSBoard of Directors may also advise the Chair of the Board of potentialviolations. The Chair will refer the matter to the Director — Ethics andControls Compliance for investigation, resolution and reporting.

 

Failureto act in accordance with the guidelines outlined in this policy may haveconsequences for the individual, may create potential harm to TELUS’ reputationand brand, and may put TELUS at risk for legal penalty. Individual consequencesmay include disciplinary action, up to and including dismissal as well as civiland criminal penalties.  Corporateconsequences may include civil and criminal penalties. Therefore, please regardthe requirement to understand and to act in accordance with the TELUS EthicsPolicy as a most serious matter.

 

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### **Managers**

### ** **

In addition tothe aforementioned responsibilities, TELUS managers have the additionalresponsibility to:

·                  Be familiar with the TELUS EthicsPolicy and resolution procedures

·                  Promote and maintain a climate inwhich honest, ethical and legal business conduct is the norm

·                  Encourage open discussion andresolution of all business concerns

·                  Accept and investigate reports ofpossible business misconduct

·                  Maintain,without compromise, our ethical standards in achieving goals and objectives, nomatter how important the goal or objective may be

·                  Review the Ethics Policy with teamsand colleagues on a regular basis (at least annually)

 

### **Senior Managers (directorsand above)**

### ** **

In addition tothe aforementioned responsibilities, TELUS team members who have rolesregarding internal controls and financial reporting and disclosure controlshave, as outlined in the Policy on Corporate Disclosure and Confidentiality ofInformation, the responsibility to make full, fair, accurate, timely andunderstandable disclosure in reports and documents that TELUS files with, orsubmits to, securities commissions and in other public communications made byTELUS.

 

### **TELUS Board of DirectorsMembers and Employees who represent TELUS as Directors on other organizationboards**

### ** **

In addition tothe aforementioned responsibilities, but subject to the requirement that suchindividuals comply with their fiduciary obligations as a director of anotherorganization, TELUS Board members have the responsibility to notify the Chairof the Board of TELUS or, in case of TELUS employees who represent TELUS on theBoards of other organizations, the TELUS Ethics Work Group of any potentialperceived conflict of interest or other Ethics Policy issues which arise duringthe course of their Board service.

 

### **EthicsOffice**

### ** **

The EthicsOffice is established to provide Team TELUS with a resource regarding ethicalmatters.  This Office conductsinvestigations, provides advice on ethical dilemmas, develops ethics training,establishes and updates appropriate policies, guidelines and processes forTELUS’ expected standards of business conduct, and reports on EthicsLinecomplaints to the Audit Committee of the Board of Directors on a quarterlybasis.

 

### **EthicsWork Group**

### ** **

An Ethics WorkGroup oversees the Ethics Policy and annual reporting to senior management andthe Audit Committee of the TELUS Board of Directors. If an ethical issue isunresolved, as a body of last resort, the Ethics Work Group is available todiscuss and guide issue resolution and provide input on any ethical situationsbrought forward. Members of the Ethics Work Group include representatives fromRisk Management, Human Resources, Corporate Affairs, Corporate Security and theChief Financial Officer.

 

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***Ethical Decision Making***

 

This policy reflects our commitment to high standards of ethicalbehaviour in our professional and business dealings. The TELUS Ethics Policy isintended as a living document that supports open and frank discussion and thesatisfactory resolution of ethical dilemmas.

 

Each of us is responsible for striving to ensure our behaviour isethical and for taking steps to resolve ethical dilemmas. The guidelines inthis policy are provided to assist with ethical decision-making. As businessbecomes increasingly complex, the policy cannot provide guidance about everypossible situation.  In thesecircumstances, discuss your situation with your manager or with colleagues todetermine the appropriate, ethical course of action.

 

If you would like to discuss ethics further or have a dilemma withwhich you would like help, follow the process below, stopping at the point atwhich your situation has been resolved.

 

#### ***1.  Questions to Ask Yourself***

#### ** **

Gather information and then determine if the situation you face is anethical dilemma. The questions below may help to clarify your situation andethical action.

·                  What is my immediate feeling aboutthis?

·                  Does this comply with companypolicies and procedures?

·                  Is this legal?

·                  Is this an expected part of my job?

·                  How would others perceive thisaction?

·                  Would I or TELUS be embarrassed ifthis situation were discussed in the media?

·                  Would I be putting TELUS or myself atunnecessary risk?

·                  What impact would this have on my orthe company’s reputation?

·                  Is this taking revenue or customersaway from TELUS?

 

#### ***2.  Review Guidelines and Policies***

#### ** **

Review the guidelines in this policy and the case studies.  If you need further assistance, consider thefollowing related policies as they may apply to your situation.

Signing Authority Policy

Corporate Security Policies and Corporate Security Manual

Respectful Workplace Policy

Alcohol and Drug Corporate Policy

TELUS Health and Safety Policy

Environmental Policy

TELUS Privacy Code

Corporate Credit Card Policy

CorporateDisclosure and Confidentiality of Information

Insider Trading Policy

Records Retention Policy

 

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#### ***3.  Talk to Your Manager***

#### ** **

Often your manager is in the best position to help you workthrough the dilemma. Your manager is responsible for supporting opendiscussion, working through the ethical questions you have, and guiding youraccess to further assistance as required. In situations where you areuncomfortable talking with your manager, or your manager is unable to help, youshould refer to the next level of management or seek expert assistance asdetailed in the next section.

 

#### ***4.  Expert Assistance***

#### ** **

If you have tried the above sources but still have questions,assistance is available through designated subject matter experts in HumanResources, Legal, Privacy, Corporate Security, Regulatory Affairs andAccounting Policies. Names and contact telephone numbers are listed on thecompany’s internal website, under Ethics. TELUS Québec team members should seekadvice from the TELUS Québec Director-Labour Relations and TELUS InternationalPhilippines team members should contact their Vice President for HumanResources.

 

#### ***5. TELUSEthicsLine***

#### ** **

You may also contact the TELUS EthicsLine to request guidance or make agood-faith report about misconduct or a perceived violation of this Policy,another company policy or procedure or a government law or regulation,questionable business practices, potential fraud or accounting or auditingmatters that may not be in compliance with this Policy.  Reports may be made anonymously.

 

EthicsLine is staffed by a live operator from an independent companywho reports the call or web contact to TELUS to enable it to respond to yourconcerns.  It operates 24 hours a day and7 days a week in many languages.

 

Phone toll free: 1-888-265-4112 in North America. See website for otherinternational dialing instructions

Web: link from www.telus.com or company intranet

 

****Handling of the Report****

 

**For Inquiries:**

 

The Ethics Office will assistteam members in ethical decision-making by providing guidance concerning thisPolicy.  The Ethics Office may also referteam members to or involve subject matter experts within TELUS forassistance.  Inquiries regarding labourrelations and employment matters or customer service complaints will bere-directed as indicated in the section below.

 

**For Complaints****:**

 

**a)****             ****Assessment ofcomplaint**

 

The Ethics Office will assessthe nature of the complaint under the direction of Legal Services whereappropriate.  The following matters forwhich other remedies exist will not be investigated by the Ethics Officeand will be redirected as follows:

·                  **Labour relationsissues** — Immediatemanager or other members of management

·                  **Employment matters** such as promotions, remuneration,reprimands, suspensions, dismissals, harassment, discrimination  — Human Resources

 

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·                  **Customer servicecomplaints** —Customer Care or Client Care

 

With the exception of issuesrelating to union collective agreements, the Ethics Office will track allcomplaints, including those that are redirected to other areas of expertassistance, until they are resolved.

 

**b)****             ****Investigation**

 

All reports are taken seriously.Each allegation will be promptly investigated by the Ethics Office inconjunction with subject matter experts within TELUS if necessary. The EthicsOffice may request the assistance of TELUS Corporate Security or otherdepartments for investigation of the allegation or other related issues.  If substantiated, the allegation will beresolved through appropriate corrective action and/or discipline. If you chooseto identify yourself, you will be provided with feedback when the Ethics Officehas completed its review. Every effort will be made to maintain confidentialityfor those who contact the Ethics Office or who are accused of a breach of thisPolicy (although disclosure may be necessary in some cases to effectivelyconduct an investigation or support legal proceedings). It is expected that allreports to the Ethics Office will be made in good faith. Deliberately makingfalse claims will result in disciplinary action.

 

**c)****             ****Protectionfor Reporting**

 

Retaliation or retribution againsta team member for contacting the Ethics Office or for assisting orparticipating in an investigation of a complaint violates our ethicalprinciples****and will not betolerated. If you feel you have been retaliated against, you should contactHuman Resources or the Director-Ethics & Controls Complianceimmediately.

 

**d)****             ****Opportunity toRespond**

 

If it has been found that a team member has breached ormay likely have breached the Policy, this team member will be informed of theallegations in due course and be provided the opportunity 1) to respond tothem, and 2) where appropriate, to contribute to the correction of the breach.

 

**e)****             ****Reporting ofBreaches**

 

Any breach of the Policy will bereported to senior management with recommendations for action.  Ethical issues reported to the Ethics Officewill be summarized quarterly and reported to the Audit Committee of the Boardof Directors, together with results of investigations, recommendations andmanagement action.

 

****f)********               ******File Documentation**

 

Records ofthe report and investigation, including contents of meetings, interviews,results of investigations and other relevant material, will be maintained bythe Ethics Office in a separate file, and managed in accordance with the TELUSPrivacy Code and Record Retention Policy. Disclosure of information will bestrictly limited on a need-to-know basis only.

 

#### *** 6. ****LastResort Resolution*

#### ** **

If an ethical issue remainsunresolved, the Ethics Work Group is available as the body of last resort todiscuss the issue and guide the resolution of any conflict of interest or otherethical situation brought forward. Members of the Ethics Work Group are drawn from 

 

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Risk Management, CorporateAffairs, Corporate Security, Chief Financial Officer and Human Resources.  Their names and contact telephone numbers arelisted on the company’s internal website, under Ethics.

 

The Ethics Work Group has a reporting relationship with theAudit Committee of the Board of Directors to ensure compliance with thisPolicy, and a process for reporting potential breaches of the Policy throughthe Director — Ethics & Controls Compliance without fear ofretribution.

 

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***Ethical Guidelines***

 

### **Customerand Team TELUS Information**

### ** **

#### ***Privacy ofCommunications***

#### ** **

As atelecommunications service provider we may have access to content ofcommunications transmitted on our facilities. We protect the privacy of customer communications, ensuring notampering, intrusion or disclosure except as authorized by law. This includesensuring the content, nature and existence of telephone calls and datatransmissions are not released to third parties.

 

Ateam member may intercept a private communication only when such interceptionis necessary for the purpose of providing the service, for the purpose ofquality control checks, to protect the company’s facilities from fraudulentabuse, or when authorized by law.

 

Ifa team member comes across a suspected illegal activity (e.g. childpornography) in the course of their work, they should report it to CorporateSecurity who will determine the appropriate course of action such as reportingto the appropriate authority.

 

#### ***Confidentialityof Information***

#### ** **

We respectcustomer and team member related information and protect its security,confidentiality and integrity. The definition of ‘customer’ includes our directcustomers, customers who are our competitors, third party customers (customersof our clients), and team members. All customer and team member personalinformation is confidential and may not be disclosed except as outlined in theTELUS Privacy Code and permitted by law or by applicable regulations.

 

Access tocustomer and team member personal information is strictly controlled on a “needto know” basis and is used for legitimate business purposes only.

 

The TELUS Privacy Code and related practices set out guidelines formanaging customer and team member personal information. Various areas of thecompany may have additional supporting management practices in place. Refer toyour manager for more information.

 

***Case Studies***

 

Problem

 

I sell TELUSproducts and services in the business market and, in meeting with a customer ina specific industry, I learn that this customer has plans to aggressivelyexpand their business to another city; however this information is not publiclyknown. The next day, I meet with a competitor to this previous day’s customer.The competitor indirectly asks several questions about the first customer’sbusiness strategy. I know if I subtly mention the first customer’s businessplans, I can sell more TELUS products and services.

 

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Action

 

My job is to sell TELUS products and services; however, I must notdisclose this confidential information to my second customer.

 

Problem

 

We recently hired someone who held an executive position with one ofour competitors. This person was deeply involved in planning the competitor’sexpansion strategy, and has information that would be very valuable to us. Canwe ask him to disclose this information?

 

Action

 

Absolutely not. The new team member has an obligation to protect hisformer company’s confidential or proprietary information, just as you would beobliged to protect the confidential or proprietary information of TELUS if youwere to leave the company. You must respect the team member’s personalintegrity as well as his obligation to his former employer.

 

Problem

 

I am a customer service representative for the residential market. Acompetitor informed me that a customer authorized him to obtain informationabout the customer’s service record from TELUS. Should I provide theinformation?

 

Action

 

As a general rule, TELUS does not disclose any customer informationother than what is listed in published directories: name, address and telephonenumber. Since only the customer can authorize the release of furtherinformation, you should check that the customer did indeed authorize thecompetitor’s representative to obtain the information. If you do not findwritten authorization, ask the competitor’s representative to obtain thecustomer’s consent in writing and send it to TELUS.

 

Problem

 

My friend calls me at work in the Call Centre to talk about the TVpersonality who has just moved to the city. She asks me to look up his address and phone number since thisinformation is not listed in the public directory.  Should I look this up and provide theinformation?

 

Action

 

Absolutely not.  Unless you havea business reason to look up the information, you should not even access thiscustomer’s account and should certainly not provide the requested informationto your friend.

 

Problem

 

Mynext-door neighbour is a good friend of the family of one of my former teammembers who now works for a different manager. My neighbour and I are having a casual conversation one day in my backyard, and my neighbour asks me how my team member is doing.  I explain that he no longer works on my teamand is away from the 

 

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officeon stress leave.  Should I have discussedmy former team member’s status with a close family friend?

 

Action

 

No. It is not appropriate for you to discuss the status of your former team membereven though you know your neighbour is a close family friend.  Team members are reminded that, as a generalrule, it is inappropriate to disclose personal information of our employees fornon-work related purposes.  Of particularconcern is sensitive personal information such as health or financialinformation and information about disciplinary action.  This is contrary to our Privacy Code.

 

Problem

 

TodayI had a challenging experience with a customer and I could not make themhappy.  I have my own blog on ourintranet and would like to post my experience so that I can get suggestionsfrom my team members on how to handle similar situations.  Should I post this?

 

Action

 

Soliciting feedback from your team members is anexcellent idea; however you should act cautiously.  Even though you are posting this internally,you must protect the privacy of your customer. Review what you intend to post to ensure you are not identifying yourcustomer and if in doubt discuss with your manager before posting.

 

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### **Integrity**

### ** **

#### ***Personaland Corporate Integrity***

#### ** **

Individually and collectively, our personal integritysupports the honest use of time, funds and property in ethical dealings withco-workers and others. Business needs must take priority in the allocation ofour time at work. Use of company time and property is for business purposesonly unless otherwise authorized by management.

 

We consciouslyapply high standards of courtesy, professionalism, and honesty in our interactionswith customers, shareholders, suppliers, co-workers and the community. We donot support any form of corruption, including extortion and bribery. We arefair in representing others’ products and services and do not improperly seekcorporate trade secrets or confidential information belonging to others.  This does not preclude gathering informationwith the owner’s consent or from the public domain.

 

We arecommitted to free competition based upon the merits of our products andservices and do not support any agreements, actions or concerted actions thatrestrict or impede fair competition in contravention of applicable law.  Under certain circumstances, we may, forstrategic marketing reasons, develop and contract services exclusively with agiven partner.  Legal Services must beconsulted before all such arrangements are established.

 

#### ***HumanRights***

#### ** **

We establish and maintain an ethical work place. We treatpeople fairly and respect human rights. We recognize that there are differencesamong individuals that go beyond race and gender, and value the contributionour differences bring to the business. We provide team members with thetraining, tools, and coaching necessary for the job, including the RespectfulWorkplace Policy to which team members are referred for further information.

 

#### ***ProprietaryRights of Others***

#### ** **

We honour theproprietary rights of others as expressed in patents, copyrights, trademarksand industrial designs. Examples of intellectual and real property that may beprotected include, but are not limited to, written materials, logos, creativesuggestions, pictures, audio and video products and computer software.  We respect conditions of use. Copyrightmaterials are not copied in whole or in part, or used in violation of any lawor agreement with vendors, licensors or other similar parties. Software licenseconditions may be included in instruction manuals, in separate documents, or onthe disk itself, and breaking the seal on a disk package may constituteacceptance of the stated agreement.

 

#### ***Compliancewith Laws***

#### ** **

We comply withall applicable laws and regulations wherever we conduct business.  Team members should be familiar with the lawsand regulations that relate to their work and to comply with them. It is theresponsibility of managers to ensure that members of their team are aware oftheir responsibilities in this regard and to seek advice from Legal Services orRegulatory Affairs if they are unsure.

 

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#### ***InternationalOperations***

#### ** **

Many countries have laws that regulate the import and export of goods,services, software and technology for a variety of reasons, including nationalsecurity and foreign policy. We will comply with all the laws of Canada andthose of other countries that may apply, concerning the import and export ofgoods, services, software and technology.

 

In countries outside of Canada, customs vary regarding exchangingbusiness courtesies, particularly when dealing with government employees.  We understand that government officials areoften prohibited from accepting any gift or entertainment, regardless of value,and that special care needs to be taken in this highly regulated area.  Team members should exercise care to avoidhaving their actions or the actions of their agents being construed as anattempted bribe or kickback.  Teammembers considering making payments, or gifts outside the limits of responsibleand generally accepted business practices, to government officials outside ofCanada must seek advice from TELUS EthicsLine or Legal Services in advance.

 

#### ***PublicSafety***

#### ** **

Whenworking on customer premises and public thoroughfares, we safeguard the rightsand safety of the customer, the public and ourselves as outlined in the Healthand Safety Policy.  We are expected to reportfit for work; such that our ability to work safely is not impaired by alcohol,drugs, medications or any other substance. Our actions in these instances notonly reflect on us as individuals, but on TELUS as a whole.  Team members are referred to the Alcohol andDrug Corporate Policy for further details.

 

#### ***Environment***

#### ** **

TELUSis committed to being an environmental leader by meeting or surpassing ourregulatory requirements.  We embrace thisresponsibility to all of our stakeholders by integrating environmentalconsiderations into our business.  Wesupport sustainable development and offer innovative telecommunicationssolutions that include environmental benefits and we look to minimize wastegeneration and energy consumption in all of our activities.  Striving for continuous improvement guidesour approach.

 

Detailedinformation on our commitment to the environment can be found in our on-lineEnvironmental Policy.

 

#### ***PoliticalActivities***

#### ** **

As private citizens, we are free to make contributions to causes, candidatesor political parties of our choice. Unless expressly approved by TELUS, we willnot associate TELUS with our personal political activities. TELUS will complywith all relevant laws regulating its participation in political affairs,including political contributions.

 

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***Case Studies***

 

Problem

 

As aninstaller, I am called to an out of town, visibly neglected acreage in an areawhere TELUS is the only service provider. The customer, an elderly woman, tells me several times that she is neververy comfortable when the phone does not work. It is important to her, being out in the country, to have reliableservice.  I discover her repair is veryminor, consisting of a simple adjustment, and I am hesitant to inform her ofthe service charge.  I look around hermodest home and feel she cannot afford the service charge.

 

Action

 

Yourcompassion is understandable. However, you should inform your customer of theservice charge. TELUS is legally required to apply tariff charges to everycustomer in areas where there is no local service competition and rates arestill regulated. Also, you are presuming the elderly woman’s financial status.In fact, she may be very able to pay the service charge. If she says she has aproblem paying, you can suggest some of TELUS’ payment options or identifyareas of the company where she can get more information.

 

Problem

 

My managerfrequently makes racist comments about one of my co-workers. This personallyoffends me but, because my manager is involved, I don’t feel I can speak up.What should I do?

 

Action

 

Racistcomments are unacceptable. You have a right to express your disapproval of suchcomments — without fear of reprisal. If you are uncomfortable approaching yourmanager, you should speak to the Respectful Workplace Office in Human Resourcesor your manager’s manager.

 

Problem

 

TELUS, inpartnership with a supplier, is offering Canadian-based team members an on-linediscount program on the purchase of books, CD’s, and magazines. We would liketo place orders, but do not have a PC at home from which to access the website. A co-worker suggests we use our work PC’s to place our personal orders.We are very busy at present dealing with a backlog of ADSL service requests. Isthis an appropriate use of company equipment and time?

 

Action

 

Beinga member of the TELUS team has privileges. From time to time, TELUS offersprograms and incentives specifically for team members. Personal use of companyproperty such as PC’s is permitted, when approved by a team member’s manager orcorporately authorized, to enable team members to take advantage of theseopportunities. You may use company PC’s to place your orders *since the discount program has been authorized bymanagement.*  Team members arereminded that authorized personal use should not interfere with businesspriorities and should be conducted on personal time.

 

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Problem

 

We use a contractor todispose of hazardous materials such as lead. I know the contractor’s crew chief and I get the feeling that they maynot be disposing of the materials correctly, at least not according to thelaw.  Should I care about this?  After all, it is not my company and they areprobably saving us money.

 

Action

 

Yes,you should care.  What the contractor isdoing may expose the company to liability. But even if there would be no liability, we still care.  Improper waste disposal is inconsistent withour commitment to reduce the environmental impact of our activities.  Doing things the right way means not lookingthe other way if you have any reason to think someone we work with is doingsomething wrong.  Not all substances areequally harmful, but all must be properly disposed of.  And we should never “second guess” thelaw.  Do the right thing.  Talk with your supervisor, environmentdepartment or call the EthicsLine.

 

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### **Company Assets**

### ** **

Companyassets are both physical (people, equipment, real estate, supplies, tools,non-public information, funds) and logical (communication networks, informationsystems, intellectual property, brand, goodwill, reputation).  We take appropriate care to protect teammembers and assets against undue risks, exposures and liabilities.

 

#### ***CompanyInformation***

#### ** **

As members ofteam TELUS, we have access to information about our company that belongs toTELUS and is used by the company for its business. Unless specificallypublished for external use, and public dissemination has occurred, all companyrecords, information, reports, data, plans, processes and methods areconsidered company information and are prohibited from disclosure withoutproper authorization. Access should be limited to those team members with alegitimate business reason to seek the information.  Team members are referred to the CorporateSecurity Policies for further details on the classification and safeguarding ofTELUS’ information assets.

 

Team members,including members who have left the employ of TELUS, must not use or disclosecorporate trade secrets, competitive information or other confidential,proprietary information to benefit themselves or others. In situations where wewould be willing to share information, our Legal Services Department can drawup a confidentiality agreement or license agreement to protect TELUS.

 

No team membershould knowingly invoke a software program or code that could damage TELUS’information assets. All team members are responsible for taking reasonablemeasures to ensure that software and data is clear of malicious code and safefor use in TELUS’ electronic data processing environment. It is also importantthat you not share your computer access password.

 

***Public Disclosure***

 

TELUS issubject to strict securities rules regarding disclosure of financial andother material information to the public. Selective disclosure of confidentialinformation by any team member can create liabilities for TELUS and for thatteam member. All discussions about TELUS in a public environment should complywith the TELUS Policy on Corporate Disclosure and Confidentiality ofInformation, to which team members are referred for further details.

 

Examples ofsituations that may lead to inappropriate public disclosure include:

·                  Participating in aninvestment-related discussion forum, chat room, blog or bulletin board on theInternet.  The team member must notdisclose any confidential or material information about TELUS.

·                  Contact with a member of theinvestment community or the media.  Allinquiries from these groups must be referred to those team members authorizedto communicate on behalf of TELUS.  Forfurther information, contact Investor Relations or Public & CommunityAffairs.

·                  Presentations to business,educational, community groups or large internal TELUS audiences.  Team members invited to make suchpresentations should receive approval from the VP Investor Relations prior toaccepting the invitation.  

 

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In addition, all such public speeches and presentations must beprovided in advance to Investor Relations for review where requested by them.

 

#### ***BusinessRecords***

#### ** **

Accurate,reliable records are essential for effective company management to enable us tomeet our business, legal and financial obligations. We strive to ensure allreports (whether for external or internal use), records, and other data arefactual, fair, complete, timely and understandable. Information of significantconfidentiality should be properly identified, and respected as such. Toprotect the accuracy of our records, only legal and approved software is to beused on TELUS equipment.

 

Every businessneeds an orderly process for retaining and disposing of records and documentsin order to comply with legal and regulatory requirements.  Team members are referred to the RecordsRetention Policy for guidance on minimum and maximum retention periods, storageof records, suspension of disposal by reason of a potential or on-goinglitigation or investigation, and where to obtain further information.

 

#### ***FinancialTransactions***

#### ** **

It is expectedall team members understand their role and responsibility for the company’sfinancial transactions and records and follow approved procedures to protect,report, control, and accurately reflect these transactions.  Team members are referred to the SigningAuthority Policy for further details.

 

Itis a violation to falsify company records or documents (including, for example,contracts, orders, time sheets, adjustments and expense statements) and tomisuse company-issued credit cards.

 

Teammembers whose duties involve authentication are responsible for the closescrutiny and timely verification of all documents upon which monies are paidout or received.

 

#### ***Property***

#### ** **

We displaypride of ownership on behalf of the TELUS team as we protect companyfacilities, equipment, tools, supplies, vehicles, funds, communication networksand information systems against loss, theft, damage, vandalism, gross neglect,unauthorized use and unauthorized disposal.

 

Team membersare expected to take reasonable measures to safeguard access controls such aspasswords, identification cards, keys, cards and hand-held user authenticationdevices. We are careful not to compromise access security to sites by leavingaccess doors open and unattended, we do not tamper with the network to bypassbilling and we do not make unauthorized charges or credits to customeraccounts. Team members are the first line of defense in protecting TELUSassets.

 

Team membersmust not make adjustments to their own accounts or services, or to those offamily members, friends, co-workers or acquaintances.  Customer facing business units may exercisetheir discretion to establish procedures for the adjustment 

 

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of team memberaccounts.  Team members in NetworkOperations may only do so if specifically authorized by trouble ticket orcustomer order.

 

#### ***Personal Use of CommunicationDevices***

#### ** **

Inour future friendly world, communication devices (whether the company’s or ourown) are used for both business and personal purposes.  Electronic communication may occur via a widerange of technologies including, but not limited to computers, telephones,personal digital assistants (PDA), fax machines and Internet connections.   This can take the form of emails, texting,research, blogs, social networking, peer to peer file transfers and physicalexchange of media (e.g. CD’s, USB storage devices and devices such asiPods).  As we communicate in any of theseways, we may identify ourselves as TELUS team members either by naming thecompany or by our email or IP addresses.

 

While wepermit team members to use TELUS-provided communications devices for personalpurposes, such use should be limited, should not interfere with our duties ornegatively impact TELUS in any way.  Weexpect any such personal use to take place before or after the normal workingday, or during reasonable permitted breaks from business work subject to localmanagement approval and the needs of the business.

 

Team membersmust comply with all TELUS policies when using TELUS-provided communicationsdevices for personal use.  We areresponsible for all of our actions while using TELUS-provided communicationdevices.  TELUS routinely monitors theuse of its systems and equipment, including emails and Internet access.  Abuse may result in disciplinary action.  Team members are referred to the CorporateSecurity Policies for further details on the acceptable use of companyequipment (including email and Internet use).

 

In ourpersonal electronic communications using either TELUS-provided devices orpersonal devices where we are identified as a TELUS team member, we should:

·                  Remember that these communicationsprovide a permanent record and we may be operating in a public space.

·                  Use common sense when offering ourpersonal opinions to avoid subjecting either TELUS or ourselves to legalaction.  To help avoid confusion, add thefollowing notice: “the views expressed on this website/weblog/email are minealone and do not necessarily reflect the views of my employer”.

·                  Not disclose information that isconfidential to TELUS or to any third party that has disclosed information tous.

·                  Show respect towards other personsand organizations and avoid defamatory or discriminatory messages.

·                  Avoid offensive content of any kind,including pornography and materials promoting violence, discrimination orhatred.

·                  Not display the TELUS logo or brandimages in personal communications without written permission from a seniormanager or the Brand Office.

·                  Not disclose personal informationabout ourselves that we do not want the public to be aware of, nor disclosepersonal information about others.

 

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***Case Studies***

 

Problem

 

How do I tellif a document (paper or electronic) is proprietary if it is not marked as such?

 

Action

 

You shouldbegin by asking the person who issued the document. If you cannot find thesource of the information, consider the nature of the information itself. Forexample, does the information deal with highly sensitive company strategy,sales and marketing initiatives, or important human resources issues? If youare still uncertain, speak to your manager.

 

Problem

 

I am attendingan important sales meeting next week and I have to prepare a presentation usingslides and fairly complicated charts. My co-worker has the software I need toput the presentation together, and he has offered to lend it to me so I caninstall the program on my computer. Can I go ahead?

 

Action

 

No. Theuse of software on unlicensed computers is strictly prohibited by law. You mustverify and respect the manufacturer’s conditions of license or the agreementunder which the software was acquired. By copying your colleague’s softwareinto your computer, you may be breaking the software company’s agreement aswell as copyright laws and placing the company at risk of prosecution forcopyright infringement. You should speak to your group’s computer administratorto discuss your software needs.

 

Problem

 

I am part of ateam working on a piece of the quarterly financial results. In the course of mywork, I regularly see the draft package of all the results before they areapproved for release. One evening, my neighbor asks me, “How is TELUS doingthese days?” In this casual conversation, is it acceptable if I answer, “Well,I can tell you one thing; the results are really good this quarter.

 

Action

 

No, it isnot.  This information is not yet publicand therefore it should be regarded as confidential proprietary companyinformation. In addition, if this information is material (i.e. wouldreasonably be expected to have a significant effect on the value or price ofTELUS shares), you may also have engaged in “tipping” in violation ofsecurities law.

 

Problem

 

I am travelingon business and have brought my corporate credit card for these businessrelated expenses.  When I am shopping oneevening, I spot the perfect gift for my parents’ 40th wedding anniversary.  Without thinking, I pull out my corporatecredit card and buy it right away.  WhenI return to the office, I realize I have made a mistake.  What should I do?

 

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Action

 

Corporatecredit cards are for business use only, and should not be used for personalpurchases of any kind.  Intent to repaydoes not negate the fact that the credit card has been used inappropriately.Since you have misused the credit card you should inform your manager, codeyour expense statement so that this expense is deducted from your next paycheque and ensure this does not happen again. Otherwise, you may face discipline as a result of your actions.

 

Problem

 

I would liketo search for a new car on the Internet and compare notes with friends on asocial networking site.  Is this allowedfrom my workstation?

 

Action

 

Reasonablepersonal use of your TELUS-provided communication device (e.g. computer, cellphone, PDA) to access the Internet is allowed provided it complies with ourpolicies, is carried out on personal time, does not interfere with your work ornegatively impact TELUS in any way. Remember that business needs must take priority in the allocation of ourtime at work and that TELUS monitors such traffic and logs of this activity maybe used in an investigation of a breach of our policies.

 

Problem

 

While surfingthe web, I came across a forum where people discuss TELUS products andservices.  I saw questions, praise andsome criticism of TELUS.  What should Ido?

 

Action

 

We encourageyou not to participate in discussions about TELUS on the Internet. You may openyourself and TELUS to unacceptable risk since you may inadvertently discloseconfidential information about TELUS as you defend the company or be viewed asspeaking on behalf of TELUS when you have not been authorized to do so.  If you do participate in such discussions ina personal capacity, you may not discuss confidential information about TELUS.

 

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### **Conflict of Interest**

### ** **

As teammembers, our first business loyalty must be to TELUS. We must avoid situationsor relationships that may be harmful or detrimental to the best interests ofthe Company and result in a conflict of interest.  A conflict arises whenever we face a choicebetween what is in our personal interest (financial or otherwise) and theinterests of TELUS. We must not only avoid any actual or potential conflict ofinterest, but also situations where there is an appearance of conflict ofinterest.  In such circumstances, teammembers must take action to eliminate the conflict of interest or theperception of conflict of interest.

 

**We must disclose actual orpotential conflicts of interest to our manager.** Eachsituation must be considered individually and the potential for conflict ofinterest determined based on the parties involved, level of access to businessinformation, decision-making authority, job duties / responsibilities, positionwithin the organization, and potential impact on others.

 

Thissection is intended as a guide in those areas in which conflicts of interestmost often arise. It is not intended to be definitive or all-inclusive, asguidelines cannot cover every situation that could give rise to a conflict ofinterest.

 

#### ***Relationships***

#### ** **

Conflict of interestmay occur when a team or family member gains personal benefit from a businessrelationship with TELUS, or from an outside business with which TELUS has arelationship such as a customer, supplier, contractor, consultant, agent,vendor, channel partner or dealer. This personal benefit may take the form ofan ownership interest in or a role as a director, officer or employee of anentity that is engaged in a business relationship with TELUS.

 

This guidelinedoes not prohibit team members from holding publicly traded shares of anentity with which TELUS has a business relationship or a competitor providedthat the team member does not have a significant investment in the entity anddoes not acquire the shares based on material undisclosed confidential informationobtained as a result of employment with TELUS or by being a member of the Boardof Directors of a TELUS company.

 

Team membersmay not participate in a decision to hire, transfer or promote a family member,or be in a position of direct or indirect position of influence over a familymember.  Team members may not supervise afamily member nor have direct or indirect authority over employment-relateddecisions that impact a family member such as pay, performance ratings, workassignments, discipline, training or termination. Team members whohave authority over decisions that impact former team members should becognizant that real or perceived conflicts of interest may continue to arisewhen they make decisions that affect a family member who is also a former TELUSteam member.

 

Family memberis defined as a spouse (including common-law spouse and same sex partner),child, stepchild, parent, sibling, niece, nephew, aunt, uncle, cousin,grandparent, grandchild, in-law (including mother-in-law, father-in-law,son-in-law, 

 

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daughter-in-law,sister-in-law, brother-in-law) or any person (other than domestic employees)residing in the same household as the TELUS team member.

 

TELUS Boardmembers must disclose any family or personal relationship with TELUS teammembers or with TELUS job applicants to the Chair of the Corporate GovernanceCommittee in order that the Committee may determine whether the relationshipimpacts the Director’s independent status.

 

Situations mayarise where broader familial relationships and other close personalassociations cause real or perceived conflicts of interest or the possibilityof real or perceived improper influence. Team members should be sensitive to these concerns and demonstrate goodbusiness judgment in the best interest of TELUS and in keeping with the spiritand intent of this policy.  Anyuncertainty should be discussed with the appropriate HR business partner.

 

Team membersmust not be involved in any negotiations or transactions with customers,suppliers, contractors, consultants, agents, vendors, or outside parties wherethe team member has a personal, commercial or financial interest in the outcomeof the negotiations.

 

Board Members,Executives and Senior Finance Managers have a duty to disclose whether theyhave a relationship with the Company’s External Auditor.

 

#### ***Competition***

#### ** **

Conflict ofinterest may occur when a team member or family member gains personal benefitfrom an outside business in competition with TELUS.

 

#### ***Future****Business*

#### ** **

Over time,TELUS may expand into new businesses or change its product lines or services.Team members are responsible for re-examining their individual situations on aregular basis to avoid becoming involved in a conflict of interest situationwhere no such conflict previously existed.

 

#### ***OutsideDemands***

#### ** **

It is a conflict of interest to have an outside interest that demandsso much time and energy that it interferes with the team member’s ability to doTELUS work. This could include any charitable activities that require time andeffort during normal working hours, except for situations where the individualis acting in a representative capacity at the request of TELUS with theexplicit and written permission of his or her manager.

 

#### ***Information***

#### ** **

Team membersmay not disclose or use for any personal reason, including personal gain, anyconfidential information (including competitive intelligence) obtained throughemployment with TELUS or by being a member of the Board of Directors of a TELUScompany.

 

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#### ***InsiderTrading***

#### ** **

As detailed inthe TELUS Insider Trading Policy and summarized here, team members may nottrade in shares or other securities of TELUS or any other company while in possessionof undisclosed material information relative to the company whose securitiesare being traded.  Nor may team membersinform or tip any other person, including their immediate family, of anyundisclosed material information, other than in the “necessary course ofbusiness”. The “necessary course of business” exception is a limited one andexists so as not to unduly interfere with a company’s ordinary businessactivities.  Please see the TELUS InsiderTrading Policy for more information.

 

Material informationin respect of a company is information that could reasonably be expected tohave a significant effect on the market price or value of any securities ofthat company.

 

#### ***Gifts andBenefits***

#### ** **

TELUS teammembers shall not offer or accept, directly or indirectly, gifts, gratuities,rewards, favours or benefits from any organization or person having businessdealings with TELUS other than as described below.  These guidelines apply at all times and donot change during traditional gift-giving seasons.

 

It is not aconflict of interest to accept hospitality or entertainment, provided it isreasonable, and is within the limits of responsible and generally acceptedbusiness practices.  However, teammembers should not accept gifts or receive benefits that are intended toinfluence, or appear to influence, a particular business decision.  Acceptable benefits in the normal course ofbusiness for TELUS employees typically are less than $250 Canadian or the close equivalent in other currenciesand include

·                  Transportation to or from thecustomer’s or supplier’s place of business

·                  Hospitality suites

·                  Attendance at sporting or culturalevents

·                  Business lunches or dinners

·                  Small seasonal holiday gifts orprizes to be used in office draws and raffles

 

Thirdparty-paid seminars or conferences may be appropriate if there is a clearbenefit to TELUS for attending and the attendance is approved in advance by themanager.  In order to avoid a real orperceived conflict of interest, team members should consider TELUS fundingincremental expenses (e.g. airfare and hotel).

 

Team memberswith supplier selection, negotiation, purchasing or contract management roleswithin TELUS are subject to more stringent professional purchasing requirementsregarding gifts and benefits and maintaining appropriate relationships withsuppliers**and should therefore not accept anygifts or benefits from suppliers or potential suppliers without the explicitand written permission of his or her manager.**

 

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***Case Studies***

 

Problem

 

My wife and Ihave been looking for a way to make some extra money. Our neighbor introducesus to a multi-level marketing firm that distributes hundreds of products atwholesale prices to individuals. The individuals, in turn, sell the items toothers at higher-than-wholesale prices. My wife is confident she can sell theproducts and we would benefit from the extra income. However, as I flip throughthe company catalogue, I see the company sells products from a TELUS competitor.Our neighbor insists my wife can and should sell everything in the catalogue.When I point out the products in competition with products offered by TELUS,our neighbor tells me that since my wife is not a team TELUS member it is okayfor her to give her customers what they want.

 

Action

 

Although yourwife is selling a competitor’s product, this does not automatically create aconflict of interest position. A conflict of interest will exist if yourability to act in the best interests of TELUS is compromised. You and your wifeneed to carefully consider whether one or both of you have access toconfidential or proprietary information such as, but not limited to, productspecifications, marketing plans, or confidential team member, supplier, contractor,or customer information. Obtaining from, or disclosing to, one another suchinformation will create a conflict of interest. Assuming no such situationexists, it is possible that you would not be in a conflict of interestposition. If you are in any doubt, you should disclose and discuss thesituation with your manager.

 

Problem

 

I work in asenior marketing position at TELUS and operate my own business after hours.Though I use my marketing skills, the business in no way competes with TELUSbusiness. I started small - out of my basement. But my business is graduallygenerating more and more revenue. I am considering hiring a part-time manager,as I am not ready to leave my full time employment. Once my own business canpay me as much as my salary does, I will devote my full attention to it. I havethe best of both worlds - a salary and a blossoming business for futuresecurity.  Is this a conflict ofinterest?

 

Action

 

No. If,however, TELUS decides in the future to enter the same line of business thatyour company is in, you will be in a conflict of interest position, even thoughyou were in that business first.  Youmust then decide which of your two interests, your own company or your employer’s,will receive your full attention. Since TELUS is not currently in the same lineof business as your company, you are operating ethically, as long as it remainsan after-hours pursuit.

 

Problem

 

I recentlymarried someone who runs their own business: they own a local franchise sellinga competitor’s cellular phone service. We have agreed not to talk about ourbusiness days. Instead our private conversations are filled with hopes anddreams for our future, discussion of hobbies and mutual family events. One day,my manager advises me that I could be in a conflict of interest position.  What should I do?

 

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Action

 

You are in asituation that may leave the impression of a conflict of interest. Even thoughyou and your new spouse have decided not to talk about your business lives,people outside the marriage—including your employer—may perceive you are in aconflict of interest position. You should discuss your situation with yourmanager and identify the extent to which your access to TELUS’ informationcould benefit your spouse’s company and develop alternatives to avoid anyappearance of a conflict of interest.

 

Problem

 

I installtelecommunications inside wiring for small-and medium-sized business customers.With the growth of the Internet and other communications services, demand formy expertise is booming. Can I take advantage of this opportunity and start upan installation business on my own time?

 

Action

 

No. Youcannot engage in any outside activity that might take business away from TELUSor any of its subsidiaries. Furthermore, as a team member, you are expected tocontribute your energy and ideas to your job at TELUS. To avoid a conflict ofinterest, or even the appearance of such a conflict, you should discuss yourplanned outside business activities with your manager.

 

Problem

 

My spouse hasjust become an executive sales manager for a company that services thecomputers in my department. Do I need to tell anyone about this?

 

Action

 

Yes. One ofyour spouse’s competitors or a fellow TELUS team member could claim that yourspouse gets TELUS’ business because you are a TELUS team member. You shouldnotify your manager and make sure you are not involved in any decisionsregarding your spouse’s company.

 

Problem

 

I am acontract administrator with TELUS and love the mountains. I have mentioned myfondness for mountain parks a few times in general conversations with aparticular company supplier.  Whileseeking bids for a major order, I receive a phone call from that supplier. Heoffers me and my family free use of his luxury vacation condominium. He says heis not using it and says it would be a shame to have it sit empty when he knowshow much I enjoy the mountains.

 

Action

 

The supplierhas made a generous offer.  Too generous.Your use of the condominium appears offered in exchange for future specialtreatment from you in your position with TELUS. You should decline the offer.

 

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Problem

 

While atlunch, I overheard a conversation between two other TELUS team membersregarding company plans to make a minority investment in a business thatdevelops communications software. Can I buy shares in the software company orsuggest to my spouse that she do so?

 

Action

 

No. Althoughyou found out about TELUS’ planned investment by accident, you are prohibitedfrom buying shares by virtue of the fact that you are a member of the TELUSteam. Your spouse is also prohibited, because she obtained information aboutthe proposed investment from you, a TELUS team member. However, you and yourspouse will be able to buy shares when TELUS’ investment in the softwarecompany becomes publicly disclosed.

 

Problem

 

As a networkengineer with TELUS, I have significant influence over the selection of thecompany’s suppliers.  I have known theowner of one of TELUS’ suppliers since we were kids and have always maintaineda close personal relationship.  I have nopersonal, commercial or financial interest in the supplier.  Is there still an appearance of conflict?

 

Action

 

Yes.  Although you may not have a personal,commercial or financial interest in the outcome of the business relationshipwith this person, there may still be an appearance of bias or preferentialtreatment towards their company.  You musttake action to eliminate the perception of conflict of interest.  Examples of such actions include removingyour involvement from the selection of the company’s preferred suppliers orhaving a second person (a superior or a peer) co-approve the supplier selectiondecision.

 

Problem

 

I am a customerservice manager with TELUS and my nephew is seeking employment as an engineerwith TELUS. Am I able to recommend him for employment?

 

Action

 

Toavoid a conflict of interest, you should have no involvement in the selectiondecision.  However, you may provide awritten personal reference to the appropriate HR recruitment manager.

 

Problem

 

One of myvendors offered to send me to a conference at no cost to TELUS.  Can I accept the invitation?

 

Action

 

Notwithout considering if there is a real or perceived conflict of interest andobtaining the approval of your manager.  One way to avoid this conflict is for 

 

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TELUSto fund the incremental costs associated with your attendance at the conference(e.g. travel and hotel).

 

Problem

 

As a senior memberof team TELUS, I have been asked to approve the expansion of high speed serviceto a rural area where my family has recreation property. Should I be concernedabout a possible conflict of interest?

 

Action

 

Yes. Although you are approving the expansionof service in the interests of TELUS and its rural customers, the fact thatyour family will also benefit could lead to perceptions of a conflict ofinterest. In order to eliminate this perception, you should inform your managerof the relationship.  Actions that couldbe taken to eliminate this perception include removing your involvement fromthe approval process or have a second person (a superior or peer) co-approve theexpansion decision.

 

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### ** **

### **Dealing with Suppliers,Contractors, Consultants and Agents**

### ** **

Wevalue our relationship with suppliers, contractors, consultants and agents andthose acting on behalf of TELUS because they contribute to our overall success.  We strive to ensure our business dealingswith them are ethical and that they understand our expectations of them forcompliance with applicable TELUS policies.

 

#### ***SelectingSuppliers, Contractors, Consultants and Agents***

#### ** **

·                  Westrive to award business to suppliers, contractors, consultants and agents whoare in compliance with applicable laws and regulations in their businessrelationships, including those with their employees, their communities andTELUS.

 

·                  Westrive to select our suppliers, contractors, consultants and agents based uponobjective and fair criteria including but not necessarily limited to businessneed, price, service, quality, reputation for ethical conduct and health,safety and environmental business considerations.

 

#### ***Adherenceto applicable TELUS policies***

#### ** **

·                  Weexpect the suppliers, contractors, consultants and agents with whom we dobusiness to demonstrate similar values and standards as the applicable TELUSpolicies.

 

·                  We strive to ensure that our suppliers,contractors, consultants and agents are made aware of applicable TELUS policiesspecific to the work for which they are being engaged.

 

***Case Study***

 

Problem

 

Ourteam was tasked to construct a specialized telephone network for a customer ina very restricted timeline. We chose a locally reputable contractor that wasnot on TELUS’ preferred list of contractors because none of these contractorshad the resources or skills to complete this project by the deadline. In ourcontractor selection we ensured it was not done at the expense of objectivefair criteria such as quality service and price. What else should we do?

 

Action

 

Weshould also ensure our contractor is made aware of applicable TELUS policiesspecific to the work for which they are being engaged.

 

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