Whistleblower Policy

The whistleblowing policy intends to encourage and enable employees, board and committee members, and other third parties that do business with the corporation to report events that are suspected to be illegal, unethical, or inappropriate in nature, without fear of negative consequences. All employees, board members and committee members have a responsibility to report these matters and have a right to be protected when they do.

The policy does not apply to problems or grievances relating to job performance, terms of employment, or other job-related matters. Any individual or outside party who is reporting a suspected violation must be acting in good faith, and have reasonable grounds to believe that another employee, board member or committee member has committed such an act.

Provident10 has an open-door communication policy, and employees should feel comfortable bringing suspected whistleblowing events to their immediate supervisor, and/or Human Resources for guidance. All formal reports are to be made in writing, and submitted to the appropriate person as outlined below:

1. If the activity is committed by an employee, or a third party that does business with the corporation, the statement must be submitted to the Chief Executive Officer.
2. If the activity is committed by the Chief Executive Officer, a member of the board or a member of a committee, the statement must be submitted to the chair of the board of directors.
3. If the activity is committed by the chair of the board of directors, the statement must be submitted to the vice-chair of the board of directors.

The written statement of the event should include the following information:

• • The name and contact information of the person that the allegations are against
  • Brief description of the activity, including when and where it occurred
  • Any evidence that can support the claim

If the whistleblower does not have evidence, he/she should not go looking for it. The sole responsibility of the whistleblower is to report the violation – not to investigate it.

All reports of wrongdoing will be treated confidentially. The identity of an individual alleging wrongdoing and the identity of an individual alleged to have committed wrongdoing will be protected to the extent permissible by law, and feasible to allow a proper investigation.

However, the corporation cannot guarantee that the identity of other individuals involved in an investigation, will not become disclosed or apparent through an investigation, depending on the nature of the wrongdoing reported. Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know.

Should a whistleblower prefer to remain anonymous when reporting an incident, Provident10 has secured the services of a third-party provider, NAVEX Global, to accept confidential, anonymous reports. Employees can access the system via the internet or by telephone at:

URL: provident10.ethicspoint.com
Hotline: 844-678-6263

All incidents reported through NAVEX Global will be forwarded to the appropriate person as outlined by the earlier formal reporting process.

Anyone who uses this anonymous system to report a whistleblowing event should return to the source within five business days to review the response to his or her report, and to respond to any follow up questions.

Employees and outside parties that report anonymously should take extra care to ensure their report of wrongdoing is comprehensive and detailed, as this facilitates the investigation process. It is important to note that reporting events anonymously or maintaining anonymity may limit the ability to investigate thoroughly.

The default position will be to engage an external investigator/team in situations of alleged serious misconduct, breach of a legal requirement (i.e. occupation health and safety or human rights), or alleged material breach of internal policy. A designated individual/team will begin an investigation into the matter and will take all necessary steps to determine the facts surrounding the matter complained of and shall provide a recommendation as to the outcome of the complaint by Provident10.

If wrongdoing is found, appropriate remedial and disciplinary actions will be taken. Once the investigation has concluded, there will be follow up with the complainant to ensure that no details were missed.

Provident10 will not, in any way, retaliate against a whistleblower who has acted in good faith. This includes demotion, harassment, or any kind of discrimination. Any employee, board or committee member, or outside party having dealt with the corporation who does retaliate against the whistleblower will be subject to discipline, up to and including termination.

If a whistleblower feels that he/she is being retaliated against, they must contact Human Resources immediately.