Violations of Western Energy Services Corp. (“Western”)’s Code of Business Conduct and Ethics or applicable laws, rules and regulations can result in serious damage to Western, its reputation and the reputations of its Employees. Accordingly, if an Employee has knowledge of any possible violation of the Code of Business Conduct and Ethics or any possible breach of applicable laws, rules or regulations or any possible wrongdoing or questionable practices regarding accounting or auditing matters or internal accounting controls (collectively called an “Alleged wrongdoing”), that Employee is encouraged to report such.
The report should be made to the Employee’s immediate supervisor, if appropriate. If the Employee is of the view that it would be more appropriate under the circumstances to take the alleged wrongdoing to higher levels, due to either the nature of the alleged wrongdoing or, if earlier reports through normal channels have not been acted upon, then that Employee has the right to directly contact CanaGlobe Compliance Solutions (“CanaGlobe”), an independent third-party service provider retained to receive anonymous reports on behalf of Western via its Incident Reporting System (the “Incident Reporting System”). All submissions made through the Incident Reporting System will remain anonymous.
All reports submitted using the Incident Reporting System are handled confidentially by CanaGlobe and will be forwarded to Western’s designates for review and investigation as follows:
(i) the Chairman of the Audit Committee, through the Incident Reporting System, will receive reports of Alleged wrongdoing relating to any theft, fraud, questionable accounting (including internal accounting controls) or auditing matters or any other financial matters; and
(ii) the Chief Executive Officer of Western, through the Incident Reporting System, will receive reports of Alleged wrongdoing relating to any matter other than those financial matters described in subparagraph (i) above.
All communication will be between yourself and CanaGlobe only and at no time will you be communicating directly with a representative from Western unless you choose to do so. Your contact information, if included in your report, is never shared with Western unless you provide CanaGlobe written authorization to do so or you choose to share it with Western directly. Unless required by law, Western shall not make, nor shall it tolerate, any effort to ascertain the identity of the Employee making an anonymous report.
Each complaint will be thoroughly investigated to ensure there are sufficient grounds and evidence supporting it. Upon confirmation of the alleged wrongdoing, the matter will be resolved by appropriate action.
Western and its directors, officers and Employees shall not retaliate against any Employee who reports, in good faith, an Alleged wrongdoing or a retaliatory act or who assists in the investigation of the Alleged wrongdoing. The term “in good faith” means that the reporting Employee should have evidence or reasonable grounds for believing that an Alleged wrongdoing or retaliatory act has occurred and must act without malicious intent or personal agenda. Reports of Alleged wrongdoings or retaliatory acts that were not made in good faith will be viewed as a serious disciplinary offence and may be subject to sanctions, including termination of employment for cause without notice or payment in lieu of notice.
To access the Incident Reporting System Employees and stakeholders can use any of the methods outlined below.
- Toll free telephone and fax number:
1-888-650-7768 (Canada and USA)