Whistleblower Policy

General

Accord Financial Corp. and its subsidiaries (“Accord”) require directors, officers and employees to observe the highest standards of business and personal ethics in the conduct of their duties and responsibilities.  As employees and representatives of Accord, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations. 

Accord’s internal controls, operating procedures and policies are intended to detect and to prevent or deter improper activities.  Improper activities include any activity by an employee that is undertaken in the performance of the employee’s official duties, whether or not that action is within the scope of his or her employment, and that:

1. is in violation of any applicable law or regulation, including, but not limited to, corruption, malfeasance, bribery, theft of property, fraudulent claims, fraud, coercion, conversion, malicious prosecution, misuse of property, or willful omission to perform a duty, or,
2. is economically wasteful, or involves gross misconduct, incompetence, or inefficiency.

 
Even the best systems of control cannot provide absolute safeguards against irregularities.  Intentional and unintentional violations of laws, regulations, policies and procedures may occur and may constitute improper activities. This Policy governs the reporting and investigation of allegations of suspected improper activities.

Whistleblower

A person or entity making a disclosure of improper activities is commonly referred to as a whistleblower.  Whistleblowers may be employees, vendors, clients, customers or the general public.  A whistleblower is not an investigator or finder of fact.  A whistleblower does not determine the appropriate corrective or remedial action that may be warranted.  The purpose of this Policy is to establish procedures whereby a person may report improper activities, as defined below.

Reporting Responsibility

It is the responsibility of all directors, officers and employees to report violations, suspected violations or unlawful conduct in accordance with this Whistleblower Policy.

Improper Activities

Improper activities include instances of corporate fraud, unethical business conduct, violations of laws, and practices or procedures related to accounting, internal accounting controls, or auditing matters.

Particular areas of concern include equal employment opportunity, harassment, conflicts of interests, confidential or proprietary information, accounting controls and procedures, fraud, protection of shareholder interests and competition.

Improper activities related to accounting controls and procedures may include:

• Fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement of Accord
• Fraud or deliberate error in the recording and maintaining of financial records of Accord
• Deficiencies in or non-compliance with Accord’s internal accounting controls
• Misrepresentation or false statement to or by a senior officer or accountant regarding a matter contained in the financial records, financial reports or audit reports of Accord, or
• Deviation from full and fair reporting of Accord’s financial condition.

No Retaliation

No director, officer or employee who in good faith reports a violation shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within Accord rather than seeking resolution outside Accord.

Reporting Violations

Accord has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an employee’s supervisor is in the best position to address an area of concern. However, if you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with someone in management whom you are comfortable in approaching. Supervisors and managers are required to report suspected violations to the Chairman of the Audit Committee of the Board of Directors, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud or securities law violations, or when you are not satisfied or not comfortable with following Accord’s open door policy, individuals should contact the Chairman of the Audit Committee directly.

The Chairman of the Audit Committee is responsible for investigating and resolving all reported complaints and allegations concerning violations and, at his discretion, may advise the President, the Chief Financial Officer and/or the Audit Committee.

Accounting and Auditing Matters

The Audit Committee shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation.  Any allegations that prove not to be substantiated and which prove to have been made frivolously will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The Chairman of the Audit Committee will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Contact Person

The Chairman of the Audit Committee of the Board of Directors is Mr. Austin Beutel, who can be contacted at 416-932-6304 or by email at austin@oakwest.ca.