Whistleblower Policy
Effective October 15, 2006
- General
This policy addresses Leader Energy Services Ltd.'s continuing commitment to integrity and ethical behaviour. The Policy establishes procedures that allow employees of the Company to confidentially and anonymously submit their concerns to the Chair of the Audit Committee of the Company's Board of Directors regarding questionable ethical, moral, accounting, internal accounting controls, or auditing matters, without fear of retaliation. - Whistleblower Protection
The Company shall not take adverse employment action against an employee in retaliation for:- Any reports of wrongdoing made in good faith; or
- Providing information or causing information to be provided in an investigation conducted by any regulatory agency or authority, or person at the Company with supervisory or similar authority over the employee, regarding any conduct the employee in good faith believes constitutes a violation of applicable securities laws, any rule or regulation of any applicable securities commission or any provision of law relating to fraud against the Company's shareholders; or
- Participating in an investigation, hearing, court proceeding or other administrative inquiry in connection with a report of wrongdoing.
This policy is intended to encourage reporting of wrongdoing by the Company’s employees and presumes that employees will act in good faith and will not make false accusations. An employee who knowingly or recklessly makes statements or disclosures that are not in good faith may be subject to discipline, which may include termination. Employees who report acts of wrongdoing pursuant to this policy can, and will continue to be, held to the Company’s general job performance standards. Therefore, an employee against whom legitimate adverse employment actions have been taken or are proposed to be taken for reasons other than prohibited retaliatory actions, such as poor job performance or misconduct by the employee, is prohibited from using this policy as a defence against the Company’s lawful actions. - Reporting of Wrongdoing
Any employee who becomes aware of any wrongdoing or suspected wrongdoing regarding questionable ethical, moral, accounting, internal accounting controls and/or auditing matters is encouraged to make a report as soon as possible to the Chair of the Audit Committee of the Company’s Board of Directors via email or letter. The contact information for the current Chair of the Audit Committee is as follows:
Steve Austin
Chair of the Audit and Compensation Committee
Leader Energy Services Ltd.
c/o Energy Accounting Services Inc.
Suite 207, 525 – 11th Ave S.W.
Calgary, Alberta T2P 0C9
Phone: 403-294-0151
Email: steve@energyaccountingservices.com
To the extent practical, the identity of any employee who makes reports pursuant to this policy shall not be revealed to persons in the employee’s department, division, or work location. The Company will make good faith efforts to protect the confidentiality employees making reports provided, however, the Company or its employees and agents shall be permitted to reveal the reporting employee’s identity and confidential information to the extent necessary to permit a thorough and effective investigation. - Claims of Retaliation
Claims of acts of retaliation should be submitted via email or letter to the Chair of the Audit Committee of the Company’s Board of Directors. See contact information in section 3 above.