Canada’s Anti-Spam Legislation (CASL)

Anti-Spam Policy (CASL)

Dissemination of Commercial Electronic Messages (CEMs) to and from computer systems in Canada. Last Reviewed: September 2026.

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Policy Statement This document sets forth the policy of axtechdiaries and is designed to provide reasonable assurance that:
  • (i) A consistent process is followed with respect to the dissemination of commercial electronic messages by axtechdiaries and prospective clients in Canada; and
  • (ii) axtechdiaries sending commercial electronic messages from and/or to a computer system(s) in Canada comply with the requirements of CASL.
The axtechdiaries Anti-Spam Policy (“Anti-Spam Policy”) and related procedures (the “CASL Procedures”) require that all electronic messages sent by or on behalf of axtechdiaries, or using an axtechdiaries email address or device, comply with CASL.
Scope & Application

Policy Details & Application

The Anti-Spam Policy describes axtechdiaries commitments relating to the provisions of CASL and electronic messages of a commercial nature sent to clients, prospective clients, and others, as applicable. From time to time, axtechdiaries may implement additional policies, procedures and/or practices as it relates to anti-spam measures.

This Policy applies to axtechdiaries operations sending Commercial Electronic Messages (CEMs) from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada. All internal procedures are interpreted in a manner that is consistent with the Anti-Spam Policy and that promotes compliance with CASL to deter damaging and deceptive forms of spam from occurring in Canada.

Consent Architecture

Express and Implied Consent Requirements

axtechdiaries obtains express, opt-in consent, unless a verifiable basis for implied consent or an exception to consent exists, before sending a CEM to anyone who has not had an existing business relationship with axtechdiaries within two years before the date on which the CEM is sent. Unless a valid documented basis for implied consent or an exception to consent exists, axtechdiaries also obtains express, opt-in consent for the sending of CEMs to prospects.

Mandatory Consent Conditions:
  • The request for consent cannot be within an electronic message unless there exists a verifiable basis for implied consent.
  • Consent must be sought separately within a communication (e.g., through a separate affirmative action such as checking an unbundled checkbox) and cannot be bundled as a term of acceptance of an agreement.
  • Verbal consent is acceptable where a record of the details of the consent is maintained in a verifiable database.
Message Specification

Form and Content of CEMs

All CEMs are required to strictly comply with the form and content requirements of CASL, including:

• Identifies sender clearly
• Valid sender postal mailing address
• Telephone number or email address
• Working link to contact webpage
• Direct 1-click unsubscribe mechanism

axtechdiaries takes explicit steps to require that any third-party service provider who sends CEMs on behalf of axtechdiaries complies with CASL.

Data Governance

Storage of Relationship Details & CRM Tracking

A key component of complying with CASL involves maintaining records of axtechdiaries relationships with clients and prospective clients.

Each business unit of axtechdiaries is required to create and maintain in the business unit’s Client Relationship Management (CRM) system (including, but not limited to, Benchmark, Salesforce), verifiable records documenting the relationships giving rise to implied consent, and verifiable records of express, opt-in consents obtained from clients and prospective clients.

Definition of "Clients": Organizations or individuals who have at least one open account or a contractual relationship with axtechdiaries at the relevant time. Organizations or individuals who have closed their last remaining account or terminated their contract are not considered clients for the purposes of this Policy.

Retention Mandate: Records of express, opt-in consent and records documenting the relationships giving rise to implied consent are retained for a minimum of three (3) years after axtechdiaries ceases sending CEMs to the client or prospect.
CEM Scope

Commercial Electronic Messages Defined & Exemptions

A “CEM” is defined as an electronic message that includes content (for instance, text, hyperlinks, images or attachments) that:

  • Promotes, offers or advertises axtechdiaries products, services, or contacts;
  • Solicits business for axtechdiaries employees or contacts; or
  • Encourages participation in any commercial activity (e.g. promotional event invitations, webcasts, marketing newsletters).

Exempt Messages

The following messages do not have to comply with the requirements applicable to CEMs:

  • Messages sent to clients about their existing ongoing business;
  • Internal communications about axtechdiaries business (including communications with offices outside Canada);
  • Legally required notices (regulatory requirement, material changes, account activity); and
  • Responses to direct incoming requests or inquiries.
Unsubscribe & Third Parties

Unsubscribe Mechanism & Third-Party Contracts

All third-party contracts with service providers who may send CEMs on behalf of axtechdiaries must contain contractual clauses obligating the service provider to comply with CASL including the form and content requirements of CEMs.

CEMs that are not exempt must include a functional unsubscribe mechanism. axtechdiaries processes all withdrawals of consent or do-not-contact requests within a maximum period of 10 business days.

How to Unsubscribe from axtechdiaries CEMs:

You can unsubscribe from our Commercial Electronic Messages at any time by:

Governance & Audit

Policy Administration, Review and Enforcement

The Anti-Spam Policy is maintained by the Compliance department of each legal entity and will be reviewed and updated, where necessary, and approved on an annual basis. Any changes to, or exceptions from this Policy require formal Board approval.

Compliance with this Policy, and any related procedure, may be reviewed at any time. Failure to comply with this Policy, as well as any associated procedures, may result in disciplinary action in accordance with applicable Global Human Resources Disciplinary policy or procedure.