WHISTLEBLOWER POLICY AND PROCEDURES 2016 - page 2

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non-employees, when based on their reasonable belief they have Accounting/Audit Matters Concerns, or believe
that a Breach of Conduct, Potential Violation or Grave Misconduct has occurred or is occurring, can raise those
concerns free of discrimination, retaliation, threats or harassment. Accordingly, the Corporation strictly prohibits
discrimination, retaliation, threats or harassment of any kind against any employees, consultants or non-employees
who, based on the employees, consultants or non-employees reasonable belief that such conduct or practices have
occurred or are occurring, reports that information to the Corporation in accordance with this Whistleblower Policy.
II.
Definitions
"Anonymous" means unknown authorship, and without designation that might lead to information about the
authorship. Anonymity is not compromised by assignment of a code or other designation with which a person can
communicate without revealing their identity.
"Complaint" means any adverse information provided to ORLEN Upstream Canada, whether in the form of a
concern, a demand for remedial action, or a report of a suspected violation of law or on Accounting/Audit Matters
Concerns, Potential Violations or a Breach of Conduct.
"Confidential" means authorized for access by only those persons who have a need to know. A need to know
normally arises from an obligation to investigate or to take remedial or disciplinary action.
"Whistleblower Hotline" means an e-mail address for the Chair of the Board of Directors (the "
Chair
") made
available for receiving Anonymous Complaints from any source. The Whistleblower Hotline or e-mail address is
posted on ORLEN Upstream Canada’s website as well as listed below (Treatment of Complaints).
III.
Procedures
1.
Submission and Receipt of Complaints
i.
Employees, consultants and non-employees are encouraged that if you have Accounting/Audit
Matters Concerns, believe that a Breach of Conduct, Potential Violation or Grave Misconduct has
occurred or is occurring, and/or a breach or violation of the Corporation’s Code of Business
Conduct to immediately report those facts to your immediate supervisor or to the Senior Vice
President, Finance, either identifying yourself or on an Anonymous basis. If you identify yourself,
you may then be requested to document your report in writing. You may also report your concerns
Anonymously by sending an Anonymous letter (marked "Private & Confidential") to your
immediate supervisor or the Senior Vice President, Finance. Upon receiving such reports or
Complaints, immediate supervisors or the Senior Vice President, Finance shall promptly forward
the same to the Chair who will oversee and endeavour to provide direction on the investigation
and resolution of the matter. If you have reason to believe that your immediate supervisor and/or
the Senior Vice President, Finance are involved in these matters, you should report those facts
directly to the Chair.
ii.
If you later believe that you have been subject to discrimination, retaliation, threats or harassment
for having made a report under this Policy, you must immediately report those facts in the same
manner as detailed immediately above in (i.). It is imperative that you bring the matter to the
Corporation's attention promptly so that any concern of discrimination, retaliation, threats or
harassment can be investigated and addressed promptly and appropriately.
iii.
Any complaints so received shall be handled as Confidential and promptly forwarded to the Chair.
iv.
Employees, consultants and non-employees may submit Anonymous Complaints to the Chair.
v.
Non-employees may also submit Complaints by mail (or other means of delivery) to the head
office of ORLEN Upstream Canada marked "Private and Confidential – Attention: Chair of the
Board of Directors". Envelopes so marked shall be forwarded unopened to the Chair.
vi.
The Chair shall report to the Board of Directors periodically about the process for receiving
Complaints so that the Board of Directors can ensure that the process is satisfactory in its
efficiency, accuracy, timeliness, protection of confidentiality or anonymity, and effectiveness.
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