Our Approach To Corporate Governance

CT REIT is committed to sound and effective corporate governance. The majority of our board is made up of independent trustees who chair all our committees and all trustees strive to uphold the tenets of good corporate governance.

Further details on the REIT’s approach to corporate governance is described on pages 18 to 31 of its Management Information Circular. Click here to access the REIT’s 2024 Management Information Circular.

Declaration of Trust

The REIT’s Declaration of Trust governs our operations and includes such topics as investment guidelines and operating policies, units and distributions, unitholders and the responsibilities and obligations of the Trustees.

Declaration of Trust

Code Of Conduct

CT Real Estate Investment Trust (the “REIT”) is committed to upholding the values of honesty, integrity and respect in everything that we do. To ensure a clear understanding and consistent level of commitment to ethical business practices, the REIT has a Code of Conduct (the “Code”) to appropriately direct the actions of all employees and those individuals who act on behalf of the REIT. If you have any complaints or concerns regarding potential breaches, please advise us by contacting one of the reporting options listed below.

Business Conduct Compliance

Integrity, honesty and respect are core values at the REIT and we expect that each of our employees and trustees will abide by the principles and expectations set out in our Code when conducting business on behalf of the REIT.

Ethical business conduct is an important component of our reputation and the Code sets out our minimum expectations and accountabilities for managing the risks associated with unethical business conduct.

The Canadian Tire Triangle Ethics Office (TEO) provides several channels through which individuals can report breaches of the Code related to CT REIT (confidentially and anonymously) for investigation and follow-up. The TEO also provides assistance in interpreting the application of the Code. Employees and trustee are required to formally acknowledge and confirm their commitment to abide by the Code’s standards and expectations.

Code of Conduct

Triangle Ethics Office

Email: TEO@cantire.com

Direct line: 416-480-8202

Mail:
Triangle Ethics Office – CT REIT
2180 Yonge Street
Box 770, Station K
Toronto, ON
M4P 2V8
Mark the envelope: Personal and Confidential - To Be Opened Only by Addressee

CT REIT Privacy Policy

We have updated our Privacy Policy, effective September 2023

CT Real Estate Investment Trust (hereinafter “CT REIT”) is committed to protecting the privacy and security of all personal information obtained in connection with the operation of CT REIT’s business. Personal Information is information that can be used to identify an individual. We may collect personal information for administrative purposes, marketing and advertising purposes, research purposes and to achieve other purposes as may, from time to time, be permitted by law and/or necessary for CT REIT’s business activities.

CT REIT’s privacy policy and practices have been designed to ensure that all personal information is handled appropriately and in accordance with federal and applicable provincial privacy legislation.

CT REIT’s commitment to ensuring the safety and security of all personal information obtained is governed by the following privacy principles:

1. Accountability

CT REIT is responsible for all personal information under its control including any personal information that is transferred to third parties for processing, storage or other purposes.

2. Identifying Purposes

CT REIT may collect, use and disclose your personal information in order to provide you with the services offered by CT REIT, including but not limited to, leasing, property management, making available this Web Site and investment information, communicating with you, and to achieve other purposes as may, from time to time, be permitted by law and/or necessary for CT REIT’s business activities.

CT REIT may use “cookies” or other unique identifiers and technologies such as “tracer tags”, “pixels”, or “web beacons” to collect information automatically when you visit our website to track and analyze website use. The information collected through these technologies may include Internet Protocol (IP) addresses, components of the website you have clicked on or engaged with and website settings. Cookie preferences can be controlled through your browser to notify you when you receive a cookie or to not accept certain cookies.

CT REIT may also use automated decision-making practices to support our projects and initiatives. For more information about the automated decision-making practices that we use you can contact us (see “CT REIT Privacy Office Contact Information” below).

3. Consent

CT REIT will obtain consent to collect, use or disclose personal information either by directly requesting it, or consent may be implied by conduct in providing the information to CT REIT. The method of obtaining consent will be appropriate to the type of personal information being collected, used or disclosed:

  • Express consent (either oral or written) will be obtained for sensitive personal information. 
  • Implied consent may be taken for less sensitive information, where one or more of the following apply: 
    • A relationship already exists; 
    • Express consent has previously been given; 
    • The purpose of using the personal information is reasonably apparent. 

CT REIT will not disclose personal information to any third party without your written consent, unless it is required by law to do so or as otherwise required for the agreed upon purpose.

Consent for minors

CT REIT does not knowingly collect, use, or disclose the personal information of minors under the age of 13 without the prior express consent of a parent or guardian. If a minor under the age of 13 and under your guardianship has provided us with their personal information without your express consent, you may contact us to request that the personal information be removed (see “CT REIT Privacy Office Contact Information” below).

4. Limiting Collection

CT REIT collects only the personal information necessary for the identified purposes. CT REIT will collect personal information only by clear, fair and lawful means.

5. Limiting Use, Disclosure and Retention

CT REIT uses and discloses personal information only for the identified purposes, except with your consent or as otherwise required or permitted by applicable law. We do not sell or rent personal information. If any personal information is shared with third parties, these third parties are bound by appropriate agreements with CT REIT to secure and protect the confidentiality of this personal information.

CT REIT retains personal information only as long as it is required for the identified purposes or as required by applicable federal and provincial laws. Personal information that is no longer required to be retained is destroyed in a safe and secure manner in accordance with our policies.

CT REIT may use service providers located outside of Canada, and, if applicable, your personal information may be processed and stored in other countries and therefore may be subject to disclosure under the laws of those countries.

Residents of Quebec

In accordance with Quebec private sector privacy legislation, CT REIT assesses personal information that is being transferred outside of Quebec to ensure that the information receives adequate protection. We may transfer your information outside of Quebec in order to facilitate the operation of CT REIT and/or as a part of our regular business activities.

6. Accuracy

CT REIT is committed to maintaining the accuracy of personal information for as long as it is being used. CT REIT will make best efforts to ensure that all personal information in its possession is kept up to date, accurate and relevant for its intended use. An individual may request access to their personal information that CT REIT has on record in order to review and correct the information, as appropriate. If you would like to update your personal information, you can do so by contacting us (see “CT REIT Privacy Office Contact Information” below).

7. Security

CT REIT takes steps to safeguard your personal information, regardless of the format in which it is held, including:

  • Physical security measures such as restricted access facilities and locked filing cabinets; 
  • Electronic security measures for computerized personal information such as password protection, database encryption and personal identification numbers; 
  • Limiting individual access to personal information to only those persons with a need for this information in the performance of their duties; contractual obligations obtained from third parties who require access to personal information.

We review our procedures and security measures regularly to ensure that they are properly administered and remain effective and appropriate for the sensitivity of the information.

8. Openness

CT REIT is committed to providing information about our policy and practices related to the management of personal information. This policy is available at all times on the CT REIT Web Site, www.ctreit.com.

9. Individual Access

Individuals can request to review and verify the accuracy and completeness of their personal information retained by CT REIT, or request to make changes to their personal information by contacting the Canadian Tire Corporation Privacy Office (see “CT REIT Privacy Office Contact Information” below).

10. CT REIT responds to questions, concerns and complaints about privacy

CT REIT will respond in a timely manner to questions, concerns and complaints regarding the privacy of personal information in its control and its privacy policies and procedures. Please refer to the contact information outlined below.

CT REIT Privacy Office Contact Information:

Phone:
1-866-846-5841

Email:
PrivacyOffice@cantire.com

Mail:
CT Real Estate Investment Trust Privacy Office
c/o Canadian Tire Privacy Office
2180 Yonge Street
P.O. Box 770 Stn. K
Toronto, Ontario
M4P 2V8