1. Purpose

The Whistleblower policy is designed to encourage board members, leadership, staff (paid and volunteer), and others to report suspected or actual occurrences of illegal, unethical, or inappropriate events without fear of retribution. This policy aims to uphold integrity, transparency, and accountability within the organization while ensuring a safe environment for all stakeholders.

2. Scope

This policy applies to all employees, contractors, vendors, and stakeholders of the organization.

3. Abbreviations & Definitions

  • Investigators: Individuals or groups authorized or consulted by the Group CISO, which may include Quinte’s auditors and law enforcement.
  • Protected Disclosure: Any report made in good faith by an employee or director revealing unethical, illegal, or improper behavior that violates Quinte’s Code of Conduct.
  • Subject: The individual against whom a Protected Disclosure has been made.
  • Whistleblower: Personnel who make a report under this policy.

4. Roles and Responsibilities

Employee/Whistleblower
  • Report unethical or unlawful practices witnessed at Quinte as whistleblowers.
  • Submit written complaints through the policy’s defined email address.
  • Refrain from engaging in investigative activities or acting as finders of facts.
Audit Committee of the Company
  • Receive written complaints and review the performance of investigating agencies.
  • Determine the need for investigation and select investigating agencies.
  • Monitor investigation progress and receive investigation findings.
  • Review and monitor corrective actions initiated to prevent/minimize the recurrence of events.
  • Keep the identity of whistleblowers confidential.
  • Recommend corrective actions against protected disclosures.
  • Decide on disciplinary action based on the final investigation report.
Investigator or Investigating Agency/Committee
  • Conduct investigations as per the defined terms of reference.
  • Keep the identity of whistleblowers confidential.

5. Roles and Responsibilities

General Guidelines
  • This policy sets out the process for reporting and investigating unethical and unlawful practices.
  • Whistleblowers should report reliable information and refrain from conducting investigative activities.
  • HR shall handle all Protected Disclosures by employees.
  • This policy does not apply to personal grievances or complaints dealt with under existing Quinte policies.
  • Quinte encourages all employees and directors to disclose any information or suspicion of fraud or illegal acts.
  • Reportable activities or behaviors under this policy include, but are not limited to:
  • Decide on disciplinary action based on the final investigation report.
  • Other criminal or illegal actions.
  • Serious negligence, misconduct, or omissions.
  • Misappropriation of funds, securities, supplies, or other assets through fraudulent means.
  • Falsifying records, such as payrolls, by removing or replacing documents with fraudulent ones.
  • Intentionally withholding facts or deceiving in matters like appointments, placements, or report submissions leads to unfair gains or losses.
  • Engaging in any anti-competitive behavior.
  • Committing criminal offenses.
  • Any other behavior that may be considered unlawful or fraudulent towards stakeholders.
Disqualifications from Making Protected Disclosures
  • Employees making false, fraudulent, or malicious Protected Disclosures may face disciplinary action, including termination.
  • Whistleblowers making repeated false or malicious disclosures may be disqualified from reporting further disclosures.
  • Whistleblowers found complicit may not be protected from disciplinary proceedings.
Process for Making Protected Disclosures
  • Protected disclosures should be addressed to the Group CISO.
  • Employees should submit written complaints to  whistleblower@quinteft.com
  • Anonymous disclosures will not be entertained.
  • Disclosures should be factual, containing adequate details and evidence.
Protection from Retaliation
  • Whistleblowers shall be protected from unfair treatment, discrimination, or retribution.
  • Quinte condemns any unfair employment practices against whistleblowers.
  • Whistleblowers reporting retaliation shall inform HR of the investigation.
  • The identity of whistleblowers shall be kept confidential.
Investigations and Reporting
  • Investigators shall be recommended by the Group CISO, depending on the seriousness and complexity of the issues.
  • Investigators must conduct fair, objective, and thorough investigations.
  • Investigations will be initiated based on a preliminary review of disclosed information.
  • If an investigation concludes that an improper or unethical act has been committed, the Group CISO shall recommend corrective actions to the senior management.
  • Disciplinary or corrective actions shall adhere to applicable personnel or staff conduct procedures.
  • The Audit Committee shall submit annual reports to management on all Protected Disclosures, along with investigation results.

Last update on August 20, 2025