Diversity and Inclusion Program

This program applies to all individuals who work for Petrano in whatever capacity: the Operational Director, employees, and any contractor or consultant engaged to perform work on Petrano’s behalf; to all applicants and candidates; and to Petrano’s business dealings generally, including its dealings with contracting authorities and public bodies in Quebec and any personnel or representatives Petrano sends to customer sites in connection with delivery, installation support or after-sales service.

It does not extend Petrano’s own employment terms to the employees of OEMs or third-party logistics providers, who remain governed by their own employer’s policies and the law of their own jurisdiction. Where those parties act on Petrano’s behalf at a customer site, Petrano expects them to conduct themselves consistently with the respectful-workplace standard in this program.

Petrano provides equal opportunity in recruitment, hiring, compensation, training, advancement and every other condition of engagement, without discrimination on any ground protected by applicable human rights law. Decisions about who Petrano hires, promotes or engages are based on qualifications, competence and the genuine needs of the role. Petrano does not tolerate harassment or discrimination by anyone acting on its behalf, and it commits to accommodating employees, applicants and, where reasonably within its control, customers and site visitors, to the point of undue hardship.

This commitment is made honestly. Petrano does not operate a diversity committee, a dedicated human resources department or formal quota programs, and this document does not pretend otherwise. What it commits to is a set of practical, verifiable behaviours: writing job postings that do not exclude qualified candidates, sourcing candidates from more than one network, applying the same interview questions to every candidate for a role, responding promptly and seriously to any accommodation request, and giving every person who raises a concern a fair and documented process. As Petrano grows, it commits to formalizing these practices further.

The Operational Director is personally accountable for this program. Where Petrano engages outside recruiters, staffing agencies or contractors to perform work connected to hiring, those parties are expected to comply with this program’s non-discrimination standard as a condition of engagement.

Petrano operates from Winnipeg, Manitoba, as a small, privately held, provincially regulated company. The Human Rights Code (Manitoba), CCSM c. H175, is Petrano’s primary human rights obligation and applies fully to every aspect of its employment practices. The Accessibility for Manitobans Act, CCSM c. A1.7, is Petrano’s primary accessibility obligation, including the Accessible Information and Communication Standard that applies to organizations of any size.

The Charter of Human Rights and Freedoms (Quebec) applies to Petrano’s Quebec-directed conduct: its internal employment relationship is governed by Manitoba law, but where Petrano supplies or supports equipment for a Quebec public body, its conduct in that business relationship, including its dealings with the contracting authority, site personnel and any representatives present in Quebec, is expected to meet the Quebec Charter’s non-discrimination and respect-for-the-person standards, and Petrano commits to conducting all Quebec-directed business in a manner consistent with the Charter.

The federal instruments most often associated with large-employer diversity programs, the Canadian Human Rights Act, the Employment Equity Act and the Federal Contractors Program, and the federal Pay Equity Act, do not bind Petrano directly, because Petrano is neither federally regulated nor large enough to meet their thresholds. Petrano states this plainly rather than imply an obligation it does not have, and instead voluntarily aligns with the principles behind those instruments, in particular the focus on removing recruitment and advancement barriers, where they are relevant to good practice at its size.

Petrano prohibits discrimination in every aspect of employment and engagement, including recruitment and advertising, screening and interviewing, hiring, compensation and benefits, scheduling, training, performance evaluation, promotion, discipline and termination. This prohibition covers every ground protected under the Human Rights Code (Manitoba), including ancestry, colour and perceived race, nationality or national origin, ethnic background, religion or creed, age, sex including pregnancy and gender identity, sexual orientation, marital or family status, source of income, political belief, physical or mental disability, social disadvantage, and any other ground later added to the Code.

Job requirements are set based on the genuine and reasonable needs of the role. Where a limitation connected to a protected characteristic appears necessary, for example a physical requirement tied to safe handling of laboratory or capital equipment, Petrano confirms it is a bona fide occupational requirement before applying it, and considers whether accommodation could remove the need for the limitation at all.

Petrano extends the same equal-opportunity standard to its dealings with customers, tender evaluators, contracting authorities and members of the public who interact with the Company.

Petrano’s hiring needs are modest and infrequent, but every hire matters and is an opportunity to reach a wider pool of qualified candidates. Petrano does not use quotas or preferential hiring based on a protected characteristic, which would itself risk being discriminatory; instead, it commits to practices that remove unnecessary barriers so the widest possible range of qualified people can compete on merit.

Job postings are plain-language and requirement-based, describing the actual skills the role needs, such as technical sourcing experience or bilingual capability for Quebec-facing work, and avoiding criteria without a genuine link to the job.

Roles are posted in more than one channel, beyond management’s immediate personal network, so the pool is not limited to people already known to the Company.

Candidates for the same role are asked substantially the same core questions, so decisions are based on comparable information.

Every posting and interview invitation states that accommodation is available on request during the recruitment process.

The reason a candidate was selected or not selected is briefly documented, so hiring decisions can be explained by reference to qualifications.

Petrano does not currently operate structured outreach partnerships with organizations serving underrepresented groups, given its size and hiring volume. As the Company grows and hiring becomes more frequent, it commits to building at least one such relationship, for example with a local employment service for persons with disabilities or newcomers to Canada.

Petrano accommodates employees, applicants and site visitors who require an adjustment related to a disability, religious observance, family status or another protected ground, up to the point of undue hardship. In practice this most often means flexible scheduling, adjusted work arrangements, accessible meeting locations, or information in an alternate format. Requests are made to the Operational Director directly and are handled promptly, respectfully and, where the person prefers, confidentially.

Petrano is subject to the Accessibility for Manitobans Act and meets the standards that apply to organizations of its size, including the Accessible Information and Communication Standard: Petrano informs employees, customers and members of the public that information about its services is available in accessible formats and through communication supports on request. Petrano also aligns voluntarily with the barrier-identification approach of the federal Accessible Canada Act, because systematically checking for and removing accessibility barriers is useful regardless of legal threshold.

Where Petrano personnel attend customer sites, including sites in Quebec, Petrano accommodates any disclosed accessibility need to the extent reasonably within its control and coordinates with the customer where a site-specific accommodation is needed.

Anyone covered by this program, an employee, a contractor, an applicant, or a person Petrano deals with in the course of business, may raise a concern about discrimination, harassment or a failure to accommodate. There is no separate human resources department, so this section states plainly who to contact and what happens next.

Raise the concern with the Operational Director directly, in writing or verbally, or through info@petrano.ca. If the concern involves the Operational Director, or the complainant does not feel comfortable raising it internally, the complainant may go directly to the external avenue below.

The concern is acknowledged within 5 business days, and the complainant is told, in general terms, how it will be looked into. The facts are reviewed, the people involved are spoken with as appropriate, and a resolution is decided, which may include a change in practice, a corrective conversation or another appropriate step. The complainant is told the outcome and the reasoning, subject to privacy considerations for other individuals. Petrano aims to resolve most concerns within 15 business days of receipt.

A complainant is never limited to Petrano’s own process. A person may at any time contact the Manitoba Human Rights Commission (manitobahumanrights.ca) for a matter connected to Petrano’s Manitoba employment practices, or the Commission des droits de la personne et des droits de la jeunesse (cdpdj.qc.ca) for a matter connected to Petrano’s conduct in Quebec. These bodies are independent of Petrano and can investigate a complaint regardless of what Petrano itself decides.

Petrano will not retaliate against anyone for raising a concern in good faith, participating in a review, or contacting an external body. Retaliation is itself treated as a serious violation of this program.