Confidential Reporting Policy

Encorp Pacific (Canada) (“The Company”) is committed to the highest standards of trust, transparency and accountability, as defined in the Corporate Code of Conduct Policy presented in Appendix B.

An important aspect of accountability and transparency is a mechanism to enable staff, contractors, suppliers and other stakeholders of the Company to voice concerns in a responsible and effective manner. Where an individual discovers information, which they believe demonstrates inappropriateness or wrongdoing within the organization, then this information should be disclosed without fear of reprisal in any way to the individual making the disclosure (“The Discloser”). To this end, the Company has developed this Policy to ensure Employees and other stakeholders have a secure, confidential and expedited process for reporting and to raise concerns.

It should be emphasized that this Policy is intended to assist individuals who believe they may have discovered impropriety (the “Improper Act”). It is not designed to question the proper financial or business decisions taken by the Company.

Scope of Policy

This Policy is designed to enable employees, contractors, suppliers and other stakeholders of the Company to raise concerns internally to the “Privacy Officer” or other senior managers and to disclose information which the individual believes may show the Improper Act. These concerns could include but are not limited to the following:

Procedures for Making a Disclosure

All internal complaints or concerns should be referred directly to the Employees’ supervisor. If this is not feasible, it may be referred to an appropriate member of management. Individuals also have the right to submit a complaint confidentially and/or anonymously to management via email at

It should be noted that the concern will be reviewed by the Privacy Officer and addressed immediately or referred internally to the appropriate member of management for further investigation.

The Discloser also has the right to bypass reporting to management and take the Improper Act directly to the Chairman of the Board or to the Chair of the Audit Committee via email at The Chairman of the Board and/or Chair of the Audit Committee may review the matter and refer the matter back to management for further investigation if they deem it appropriate.


This policy is designed to offer protection and confidentiality to those employees, contractors, external suppliers and other stakeholders of the Company who disclose such concerns provided the disclosure is made:

The identity of the Discloser will be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may require the Company to reveal the source of the information to certain authorities and the Discloser may need to provide a statement as part of the evidence required. This policy in the first instance, encourages Disclosers to put their name to any disclosure they make to assist in further investigation and follow-up.

It is expected that an individual will only raise a bona fide complaint or concern in good faith.

Due to the varied nature of complaints, which may involve internal investigators and/or law enforcement authorities, it is not possible to lay down precise timescales for such investigations. The Company should ensure that the investigations are undertaken as quickly and practically possible without affecting the quality and depth of those investigations.

The investigating officer should as soon as practically possible send a written acknowledgement, if appropriate, of the concern to the Discloser, if known, and thereafter, if appropriate, report to them the outcome of the investigation.

All responses to the Discloser should be in writing and sent to their home address.

The investigating officer is appointed by the Privacy Officer or Board and should follow the below steps: