Whistle-Blower Policy

Western Financial Group’s whistle-blower policy covers the following concerns related to financial or operational matters. For certainty, whistle-blower incidents are intended to include, but are not limited to, 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 or non-compliance with the Company’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 the Company;
Deliberate violation of any Applicable Law or Regulations relating to the operations of the Company;
Violation of an applicable professional code of conduct;
Violation of the Business Code of Conduct or any other Business Practice or Procedure by any Personnel or Agent.

Procedure for handling complaints

How to Report a Complaint

Whistleblower Hotline: 1-844-406-8159
Speaking Up Portal: http://www.westernfinancialgroup.ethicspoint.com
Regular mail:
Western Financial Group
Attention: Vice President, Ethics and Enterprise Compliance & Privacy Officer
1010 24th Street SE
High River, AB T1V 2A7

Receipt of a Complaint

Upon receipt of a complaint we will verify that the complaint actually pertains to a matter covered by these procedures and will direct the Chief Compliance Officer (CCO) of Western to develop a recommended strategy for the investigation of the complaint.

Confidentiality