Whistleblower Policy

Whistleblower Policy

Wiseday Financial is dedicated to conducting its business in a manner that adheres to the utmost standards of honesty, integrity, ethics, and professionalism. We are committed not only to the success of our enterprise but, more importantly, to the well-being and support of the individuals who are at its core. The Whistleblower Policy is designed to provide all directors, officers, and employees with a confidential avenue to report any misconduct related to financial matters, ensuring that their voices are heard and acted upon responsibly.

Section 1. General

Wiseday Financial Corporation, encompassing its subsidiaries and affiliates ("the Corporation"), is dedicated to upholding the utmost standards of integrity and honesty in its business conduct and financial reporting. This commitment includes responsible financial accounting, robust internal controls, and thorough auditing processes ("financial matters"). The Corporation also ensures compliance with all relevant legal and regulatory requirements. The Whistleblower Policy and Procedures ("the Policy") enhance the principles in the Corporation's Code of Business Ethics and Conduct ("the Code"). All directors, officers, and employees are expected to actively contribute to maintaining these standards.

Section 2. Purpose

The Policy aims to provide a confidential process for directors, officers, and employees to report concerns or complaints about significant financial matters and adherence to legal and regulatory obligations. It safeguards against retaliation for reports made in good faith and protects the Corporation's reputation. This Policy outlines the procedures for submitting, handling, and documenting complaints, applicable to both internal and external sources.

Section 3. How to Report Violations

The Corporation encourages employees to report actual or suspected misconduct, including violations of our Code, in a timely manner. Normally, your immediate supervisor is the first point of contact for addressing concerns. However, you can also report misconduct directly to the Head of Human Resources through email or other communication methods.

For issues related to financial matters or compliance with legal and regulatory requirements, reports should be directed to the Head of Risk Management and Internal Audit. Anonymous reporting is an option in these cases.

In certain situations, you may prefer to report perceived or suspected misconduct to an external party. For such cases, you can contact the Chair of the Audit Committee through the following means:

• By calling a confidential, toll-free whistleblower hotline at +1 866-311-0756 and leaving a message detailing your concerns.
• By submitting a written report marked "Private and Confidential" to:
  
  Address: Wiseday Financial Corporation
  800-1 Westmount Square
  Westmount, Quebec
  H3Z 2P9
  Attention: Chair of the Audit Committee Private and Confidential
  Both of these reporting options can be exercised anonymously.
  

Section 4. Confidentiality

The Corporation treats all reports under this Policy as confidential, respecting legal boundaries and investigative needs. Identifying the complainant is encouraged for a thorough investigation, though anonymity is respected.

Section 5. Acting in Good Faith

Complaints must be made in good faith, based on a reasonable belief and evidence. Frivolous or malicious complaints are considered serious offenses.

Section 6. Handling of Reported Violations

Upon receiving a report, the designated Recipient should acknowledge receipt, maintain a confidential log, and conduct an independent investigation. The Corporation adheres to legal standards and maintains confidentiality throughout the process. Findings are reported to the Audit Committee and, where necessary, external authorities.

Section 7. Complaints from Third Parties

The Corporation has protocols for handling third-party complaints about financial matters, which are reviewed by the Audit Committee.

Section 8. Protection from Retaliation

The Corporation prohibits retaliation against anyone reporting misconduct in good faith. Retaliatory actions are subject to disciplinary measures, including termination.

Section 9. Records Retention

The Audit Committee is responsible for retaining all records related to allegations and investigations for seven years. The Policy may be amended or varied by the Directors.

Section 10. Monitoring and Review

The Policy is reviewed annually and may be modified or amended at the Corporation's discretion.

Approval and Amendments

This Whistleblower Policy for Wiseday Financial Corporation was approved on October 31, 2023, and is subject to amendment.