BIOASIS TECHNOLOGIES INC.
WHISTLEBLOWER POLICY
Procedures For The. Submission of Complaints or Concerns Regarding
Accounting, Internal Accounting Controls, or Auditing Matters
GENERAL
As a public company, the integrity of the financial and other information of the Company is vital. The Company's financial and other information guides the decisions of the Board of Directors of the Company (the Board), and is relied upon by our shareholders and the financial markets. For these reasons, the Company must maintain a workplace where the Company can receive, retain and address all reports and complaints received by the Company. In accordance with Canadian securities regulatory requirements, the Audit Committee (the "Committee") has established the following procedures for:
- complaints or concerns regarding accounting, internal accounting controls, or auditing matters, and the confidential submission by employees and consultants of the Company of concerns regarding questionable accounting or auditing matters (collectively "Accounting/Audit Matters"); and
- complaints or concerns regarding the potential violation of any law relating to fraud against shareholders, including without limitation the reporting of fraudulent, financial or other information to our shareholders, the government or the financial markets (a "Potential Violation").
The purpose of this Whistleblower policy is to provide the Company's employees and consultants with a mechanism by which they can raise these concerns free of any discrimination, retaliation or harassment.
SUBMISSION OF COMPLAINTS
Any person, including employees, may submit a concern or complaint regarding Accounting/Audit Matters to the management of the Company without fear of dismissal or retaliation of any kind.
The Company will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee (or take equivalent action against any consultant) in the terms and conditions of employment based upon any lawful actions of an Employee with respect to good faith reporting of concerns or complaints regarding Accounting/Audit Matters.
Any person, including Employees, may forward concerns or complaints regarding Accounting/Audit Matters on a confidential or anonymous basis as follows:
In Writing - the person submitting a complaint or a concern should include a telephone number in the submission at which he or she may be contacted if the person requests contact or if the Audit Committee determines that contact is appropriate. Where the person submitting a concern or complaint wishes to remain anonymous, then a telephone number is not required. However, it may be difficult to adequately investigate the concern or complaint if additional information is required.
SCOPE OF MATTERS COVERED BY THESE PROCEDURES
These procedures relate to concerns or complaints relating to any questionable Accounting matters including, without limitation, the following:
- fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement of the Company;
- fraud or deliberate error in the recording and maintaining of financial records of the Company;
- deficiencies in or noncompliance with the Company's internal controls over financial reporting;
- misrepresentation or false statement to or by a senior officer, accountant or external auditor regarding a matter contained in the financial records, financial reports or audit reports of the Company; or
- deviation from full and fair reporting of the Company's financial condition.
TREATMENT OF COMPLAINTS
Upon receipt of a concern or complaint, the Chair of the Audit Committee will:
- determine whether the concern or complaint actually pertains to Accounting Matters; and
- when and /or where possible, acknowledge receipt of the concern or complaint to the submitter.
Concerns or complaints relating to Accounting/Audit Matters will be reviewed under Audit Committee direction and oversight by such persons as the Audit Committee determines to be appropriate. Confidentiality will be maintained to the fullest extent possible, consistent with the need to conduct an adequate review.
Prompt and appropriate corrective action will be taken when and as warranted in the judgment of the Audit Committee. When possible and when determined appropriate by the Audit Committee, notice of any corrective action taken will be given to the person who submitted the concern or complaint.
REPORTING AND RETENTION OF COMPLAINTS AND INVESTIGATIONS
The Chair of the Audit Committee will maintain a log of all concerns or complaints, tracking their receipt and treatment and shall prepare a periodic summary report thereof for the Audit Committee.
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