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Whistleblower Policy

Plurilock Policies and Procedures

December 1, 2018

September 18, 2020

Statement of Policy

Plurilock Security Inc. (“Plurilock” or the “Company”) including its subsidiaries and affiliates are committed to providing a workplace conducive to open discussion of the Company’s business practices and is committed to complying with the laws and regulations to which the Company is subject, as well as the Code of Business Conduct for Directors, Officers and Employees and all policies referenced therein (the “Code”). Accordingly, Plurilock will not tolerate conduct that is in violation of such laws, regulations or the Code. Each director, officer and employee have a responsibility to promptly report any suspected misconduct, illegal activities or fraud, including any questionable accounting, internal accounting controls or auditing matters, or other violations of federal, provincial and state laws, rules or regulations, or the Code (collectively “Misconduct”) in accordance with the provisions of this policy. Any other third party, such as partners, collaborators, vendors, consumers, shareholders or competitors may also submit in good faith a report of Misconduct pursuant to the procedures provided in this policy. To facilitate the reporting of Misconduct, the Company has established procedures for: (i) the confidential, anonymous submission of reports of Misconduct by directors, officers and employees; and (ii) the receipt, investigation and retention of such reports.

Any individual who has reasonable cause to suspect Misconduct is encouraged to report such acts. He or she may file a complaint with the Board of Directors (“Board”) of the Company.

The Board members (“Whistleblower Committee”) overseeing any reported complaints will include (1) the Chairman of the Board and (2) an Independent Member of the Board.

Information obtained by the Whistleblower Committee about the identity of a person reporting Misconduct will be held in strict confidence until such person agrees otherwise, and the Whistleblower Committee will only disclose such information on a need to know basis. No repercussions will be forthcoming upon a person reporting Misconduct as a result of contacting the Whistleblower Committee and that anonymity is maintained where possible.

2. Policy of Non-Retaliation

It is the Company’s policy to comply with all applicable laws that protect directors, officers and employees against unlawful discrimination or retaliation as a result of lawfully reporting information regarding, or participation in investigations involving, Misconduct by the Company or its directors, officers, employees or other agents. Specifically, this policy is designed to prevent directors, officers or employees from being subject to disciplinary or retaliatory action by the Company or any of its directors, officers, employees or other agents as a result of such director, officer or employee:

  • disclosing information to a government or law enforcement agency or a representative of the Company, where the director, officer or employee has a good faith, reasonable belief that the information demonstrates a violation or possible violation of a federal, provincial or state law, rule or regulation, or the Code; or
  • disclosing information, testifying or participating in a proceeding filed or about to be filed, or otherwise assisting in an investigation or proceeding, regarding any conduct that the director, officer or employee reasonably and in good faith believes involves a violation or possible violation of a federal, provincial or state law, rule or regulation, or the Code.

If any director, officer or employee believes he or she has been subjected to any discrimination or retaliation or other action by the Company or by any of its directors, officers, employees or other agents for reporting Misconduct in accordance with this policy, he or she may file a complaint with the Whistleblower Committee.

3. Procedure

  1. A person reporting Misconduct contacts the Whistleblower Committee.
  2. The Whistleblower Committee will then contact the person reporting the Misconduct.
  3. The Whistleblower Committee will advise the Board as to the nature of the report of Misconduct.
  4. The Board in conjunction with the Whistleblower Committee will then determine the nature of investigation required.
  5. The Whistleblower Committee report back to the person making the report of Misconduct.

Contact particulars (as consented) for the person reporting the Misconduct:

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