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Anti-spam Commitment

Anti-spam Commitment

All WSP Canadian entities (hereinafter “WSP”) are committed to providing transparency to outside parties with respect to compliance with Canada’ Anti-Spam Legislation, in effect as of July 1st, 2014, and its relevant rules and regulations (hereinafter “CASL”). CASL regulates commercial electronic messages (“CEMs”), which are messages sent from Canada or accessed in Canada that have as a purpose to encourage participation in a commercial activity.

WSP complies with the rules established by CASL and enforced by the Canadian Radio-television and Telecommunications Commission, the Competition Bureau and the Privacy Commissioner of Canada.

PURPOSE

The WSP Anti-Spam Commitment is a formal statement of rights and obligations which is made available to outside parties who may receive WSP electronic communications. It is intended to inform outside parties of the type of responsible and transparent practices adopted by WSP when sending electronic communications, of who they may contact at WSP for any concern pertaining to electronic communications, and of where/how they may unsubscribe from CEMs received from WSP.

APPLICATION AND SCOPE

This Anti-Spam Commitment applies to CEMs sent by WSP from Canada or accessed in Canada by outside parties.

WSP’S COMPLIANCE WITH CASL

WSP undertook various initiatives to comply with CASL, including the implementation of business procedures, processes and guidelines. In addition to the adoption of this Anti-Spam Commitment, WSP notably undertook the following initiatives:

WSP IMPLEMENTED CASL COMPLIANT CONSENT COLLECTION PROCESSES

The consent of outside parties is necessary in order for WSP to send a CEM. This consent must be “express” or “implied”, unless the electronic communication is exempt from CASL or its consent requirements. WSP modified consent collection processes to ensure that consent obtained from recipients is in compliance with CASL.

WSP MODIFIED ITS EMAIL FOOTERS

WSP modified its email footers to manage CASL’s requirements. In particular, CEMs sent from WSP identify WSP as the party sending the CEM, provide a method whereby the recipient can readily contact WSP, such as a mailing address and one of (i) a telephone number with active response voicemail, (ii) an email address, or (iii) a web address; and provide a working unsubscribe mechanism.

WSP INCORPORATED UNSUBSCRIBE MECHANISMS

CEMs sent from WSP provide a working unsubscribe mechanism (functional for 60 days), which is processed within a maximum of 10 business days after receiving the unsubscribe request. To this effect, WSP incorporated compliant unsubscribe mechanisms into CEM email footers. Recipients may at any time unsubscribe from receiving CEMs from WSP by following the process laid out in the CEM, or by contacting unsubscribecanada@wsp.com.

WSP IMPLEMENTED INTERNAL GUIDELINES AND TRAINING FOR EMPLOYEES

WSP implemented internal guidelines as well as a training program on CASL awareness for all its employees. WSP employees are further required to confirm their awareness of CASL requirements and their agreement to abide by WSP’s Anti-Spam Commitment and associated business procedures, processes and policies.

WHY ARE YOU RECEIVING AN ELECTRONIC MESSAGE FROM WSP?

The types of electronic messages WSP may send from time to time include the following:

If you received a CEM or other electronic communication from WSP, you may be in a business relationship with WSP, you may have provided express or implied consent to receive CEMs from WSP, or the electronic communication may be exempt from CASL or its consent requirements.

WHEN IS AN ELECTRONIC MESSAGE EXEMPT FROM CASL REQUIREMENTS?

If you are receiving an electronic communication from WSP, it may be a message that does not qualify as a CEM or is otherwise exempt under CASL. For instance, a message is not considered a CEM where it does not have as one of its purposes to encourage the participation in a commercial activity. The electronic message is also exempt if it is one the following:

WHEN IS A CEM SENT WITH YOUR EXPRESS OR IMPLIED CONSENT?

Express Consent: You may have provided your express consent to WSP upon subscribing to receiving our Newsletter or other CEMs.

Implied Consent: WSP may infer your implied consent if:

Situations where no consent is required: WSP does not need your consent when sending the following types of CEMs:

WHEN IS A CEM REGARDED AS BEING SENT IN CONNECTION WITH YOUR BUSINESS ROLE AND FUNCTION?

A CEM would be regarded as being sent in connection with your business role and function in the following circumstances:

WHEN CAN A CEM BE RECEIVED THROUGH SOCIAL MEDIA?

You may be contacted by WSP via social media, such as LinkedIn, if you are connected on the social network with a WSP employee, or if you have indicated through your preference settings that you are open to receiving messages about commercial activities, business opportunities or ventures. You may also be contacted if you have conspicuously published your electronic address (for e.g., on a social media website), have not indicated that you do not wish to receive CEMs, and the CEM is sent in connection with your business role and function.

WHAT TO DO IF YOU DO NOT WISH TO RECEIVE CEMS FROM WSP

You may unsubscribe at any time from receiving CEMs by clicking on the unsubscribe link contained in the footer of the CEM. You may also request to be unsubscribed by notifying the WSP CASL Compliance Office at unsubscribecanada@wsp.com, and we will remove you from the CEM distribution list(s) within ten (10) business days.
If you have received a CEM from WSP that you do not believe you should have received, please contact us immediately at unsubscribecanada@wsp.com and we will promptly remove your email address from the CEM distribution list(s).

Once unsubscribed, you will no longer receive CEMs from WSP, although you may still receive electronic messages which relate to an ongoing business relationship and/or which are exempt under CASL.

AMENDMENTS OF THIS ANTI-SPAM COMMITMENT

From time to time, WSP will review and update this Anti-Spam Commitment as required to keep current with rules and regulations, new technologies, standards, business practices and outside parties’ concerns. We will post changes to the Anti-Spam Commitment on this page and, if the changes are significant, we will provide a more prominent notice.

QUESTIONS OR CONCERNS ABOUT THIS ANTI-SPAM COMMITMENT?

WSP has a designated CASL Compliance Office to answer any question or concern. You may contact the WSP CASL Compliance Office by emailing caslcompliance@wsp.com.
Revised June, 2017
Both the English and French versions of this Anti-Spam Commitment have equal legal value.