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2.
Treatment of Complaints
i.
All reports and Complaints under this Policy will be promptly investigated, and all information
disclosed during the course of the investigation will remain Confidential, except as necessary to
conduct the investigation and take any remedial action, in accordance with applicable law.
ii.
All employees, consultants and non-employees are required to cooperate in the investigation of
reports of Accounting/Audit Matters, Concerns, Breaches of Conduct, Potential Violations or
Grave Misconduct, or of discrimination, retaliation, threats or harassment resulting from the
reporting or investigation of such matters.
iii.
In addition, an employee, consultant or non-employee may be subject to disciplinary action,
including the possible termination of their employment or contract, if the employee, consultant or
non-employee fails to cooperate in an investigation, or deliberately provides false information
during an investigation. If, at the conclusion of its investigation, the Corporation determines that a
violation of this Policy has occurred, the Corporation may take remedial action commensurate
with the severity of the offense. This action may include disciplinary action against the accused
party, including termination. Reasonable and necessary steps may also be taken to prevent any
further violations of this Policy.
iv.
Treatment of Complaints may include taking reasonable and necessary actions in order to prevent
similar violations in the future.
v.
Whistleblower Hotline – Chair – email
3.
Retention
All documents related to reporting, investigation and enforcement of and under this Policy, or of the
discrimination, retaliation or harassment of an employee, consultant or non-employee that made a report or
complaint hereunder, shall be kept:
i.
in accordance with the Corporation’s record retention policy and applicable law;
ii.
subject to safeguards that ensure their confidentiality and, when applicable, the anonymity of the
complainant; and
iii.
in such a manner as to maximize their effectiveness to Corporation’s overall compliance and
governance programs.
This Policy is intended to encourage reporting of wrongdoing by the Corporation’s employees, consultants and non-
employees and presumes that such persons will act in good faith and will not make false accusations. An employee,
consultant or non-employee who knowingly or recklessly makes statements or disclosures that are not in good faith
may be subject to discipline, which may include termination. Employees who report acts of wrongdoing pursuant to
this Policy can, and will continue to be held to the Corporation’s general job performance standards. Therefore, an
employee against whom legitimate adverse employment actions have been taken or are proposed to be taken for
reasons other than prohibited retaliatory actions, such as poor job performance or misconduct by the employee, is
prohibited from using this Policy as a defense against the Corporation’s lawful actions.
IV.
Modification
The Board of Directors can modify this Policy unilaterally at any time without notice. Modification may be
necessary, among other reasons, to maintain compliance with federal, provincial or local regulations and/or
accommodate organizational changes within the Corporation.
