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The Policy is consistent with the ORLEN Group’s position on ethics, compliance and correctness while conducting business, “THE CORE VALUES
AND STANDARDS OF CONDUCT OF ORLEN Group”.
ORLEN UPSTREAM CANADA LTD. (“ORLEN UPSTREAM CANADA”)
WHISTLEBLOWER POLICY & PROCEDURES
(THE "POLICY")
I.
Introduction
We, at ORLEN Upstream Canada, are dedicated to the highest standards of honesty and integrity in all matters in
which we conduct our business. The integrity of the financial and other information of ORLEN Upstream Canada
Ltd., together with its direct and indirect subsidiaries, (collectively, the "
Corporation
") is vital. The Corporation's
financial and other information guides the decisions of the Board of Directors of the Corporation (the "
Board of
Directors
"), and is relied upon by our shareholder.
For these reasons, the Corporation must maintain a workplace where the Corporation can receive, retain and address
all reports and complaints received by the Corporation concerning:
i.
accounting, internal accounting controls, or auditing matters, and the confidential, anonymous
submission by employees and consultants as well as suppliers, contractors and customers
(collectively known as “non-employees”) of the Corporation of concerns regarding questionable
accounting or auditing matters (collectively "
Accounting/Audit Matters Concerns
");
ii.
the potential violation of any law relating to fraud, including without limitation the reporting of
fraudulent financial or other information to our shareholder, governments or regulatory bodies or
our lenders (a "
Potential Violation
"); and
iii.
any concerns respecting a breach or potential breach of the Corporation's Code of Business
Conduct and Ethics or any manner of harassment (each, a "
Breach of Conduct
"). The purpose of
this Policy is to provide the Corporation’s employees, consultants and non-employees with a
mechanism by which they can raise these concerns free of any discrimination, retaliation or
harassment.
The Corporation recognizes the value of transparency and accountability in its administrative and management
practices, and therefore also supports the making of disclosures to the Corporation, or, if applicable, to law
enforcement agencies that reveal "
Grave Misconduct
", i.e., conduct which constitutes or could result in a violation
of law by the Corporation or in a substantial mismanagement of Corporation resources and if proven constitutes a
criminal offence or reasonable grounds for dismissal of the person engaging in such conduct.
Therefore, it is the policy of the Corporation to encourage employees, consultants and 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, to report those concerns to the Corporation's
management (on an anonymous basis, if employees, consultants or non-employees so desire) or to raise those
concerns by e-mailing, sending a letter, calling directly or otherwise informing their immediate supervisor or the
Corporation's Senior Vice President, Finance, on an anonymous basis, as described below. All reports will be taken
seriously and will be promptly investigated. The specific action taken in any particular case depends on the nature
and gravity of the conduct or circumstances reported, and the quality of the information provided. Where the
reported Accounting/Audit Matters Concerns are found to be accurate, and where a Breach of Conduct, Potential
Violation or Grave Misconduct has been found to have occurred or be occurring, those matters will be corrected
and, if appropriate, the persons responsible will be disciplined.
In addition, the Corporation is committed to providing a work environment in which employees, consultants and
