WHISTLE BLOWER POLICY
At Citadel we are committed to operating our business with integrity and high ethical standards. Each of us is responsible for demonstrating these principles in our daily work activities. In addition, we all share the responsibility to act when we observe or gain knowledge of behaviour that falls short of these standards. The Whistle Blower policy sets out the process in which employees are able to report concerns of wrong doing that they believe conflict with Citadel’s Code of Conduct and Business Ethics policy.
Taking action to resolve a code of conduct or business ethics concern can be a complex matter. Such incidents may take many forms and are not always straight forward. Citadel recognizes this reality and provides employees with several options they can turn to for assistance.
Talk to Your Supervisor or Human Resources
Citadel promotes an open door approach to communication. The immediate supervisor is often in the best position to provide assistance and help the employee work through the issue. There may be times, however, where the supervisor is unable to provide the necessary support, or the employee is not comfortable bringing their concern forward at this level. In these instances, employees are encouraged to speak with the next level of leadership or if they prefer, contact the Human Resources department at 1-855-651-3023.
Code of Conduct and Business Ethics Hotline
Rather than speak with a supervisor, or Human Resources, employees may elect to report their concerns using Citadel’s confidential Code of Conduct and Business Ethics Hotline. The hotline is operated by an independent company outside of Citadel and is available 24 hours a day, seven days a week. Concerns reported through the hotline are sent directly to the attention of the Chair of the Audit Committee, who has the responsibility to review each submission and respond or investigate as required.
When reporting a concern using the Code of Conduct and Business Ethics Hotline, employees have two options. Concerns may be submitted in writing at www.ethcomp.com/citadel, or by telephone at 1-800-798-0467. There is no requirement for employees to provide their identity when reporting a concern.
Having first tried the above steps, if employees still have concerns, they should contact any of the following additional resources for assistance: The Chairman of Citadel’s Board of Directors, or a senior officer of Citadel including the Chief Executive Officer or Chief Financial Officer.
Chairman of The Board of Directors
4300, 400 – 3 Avenue SW
Calgary, AB T2P 4H2
Phone: (403) 292-0794
Chief Executive Officer
#610, 736 - 8 Avenue SW
Calgary, AB T2P 1H4
Phone: (587) 350-7205
Chief Financial Officer
#610, 736 - 8 Avenue SW
Calgary, AB T2P 1H4
Phone: (587) 350-7206
The Audit Committee of the Board of Directors is responsible for ensuring all complaints submitted through the Code of Conduct and Business Ethics Hotline are reviewed, and where required investigated. To properly review and investigate claims brought forward under this policy, employees are responsible for providing as much detail as possible including sharing the identity of those involved if known, providing relevant dates in question and any documentation that may be considered helpful to the investigative process. Reports based on second hand information or vague accounts of events, may be considered insufficient for investigation and dismissed by the Audit Committee.
For purposes of assisting with the review and investigative process, the Audit Committee may enlist employees of Citadel, legal counsel and/or any other experts deemed appropriate to the circumstance. Where the Audit Committee considers corrective and/or disciplinary action to be appropriate, it will take such action as may be within its authority, or make recommendations to the senior officers or the Board of Directors of the Company (as applicable), where the implementation of corrective and/or disciplinary action falls outside its scope of authority.
There will be no adverse action taken in regards to the reporting under this policy, against employees who in good faith come forward to report concerns of misconduct or unethical behaviour. Any employee who provides information to a supervisor, agency, or legal authority as part of an investigation into an alleged violation of securities law, any rule or regulation of the Alberta Securities Commission, any provision of law relating to fraud against Citadel shareholders, hearing, court proceeding or other administrative inquiry in connection with a report of wrongdoing, will not be retaliated against for providing such information.
This policy is intended to encourage reporting of wrongdoing and presumes that employees will act in good faith and not make trivial or false accusations. In the event that a reported violation is found to be frivolous, slanderous, or otherwise made in bad faith, Citadel reserves the right to discipline the employee up to and including termination of employment.