The Whistleblower Policy was created to provide direction to Ducks Unlimited Canada’s stakeholders in the communication of concerns regarding questionable financial or operational matters. Whistleblower incidents can be reported, in confidence, using the online, third party Whistleblower Form, after reviewing the Whistleblower Policy.

A "whistleblower incident" is when any stakeholder has reported a financial or operational incident of concern.

Examples of whistleblower incidents may include, but are not limited to, the following:

• Misrepresenting program budgets
• "Side deals" or "under the table" dealings with contractors for personal benefit
• Receiving personal kickbacks or significant gifts (over $100) from contractors or vendors which could create bias in the tendering process

We believe in the value of responsible, sound governance practices and supports that belief through action and policy. Along with other governance innovations, the Whistleblower Policy will ensure that we continue to demonstrate due diligence in its operations.

Reporting Process

Whistleblower incidents are sent to an independent third party. The third party will direct the incident to the General Counsel or the National Director of Human Resources of Ducks Unlimited Canada. Where there would be a conflict of interest with those individuals, the report will be directed to a member of the Executive Committee of the Board of Directors or the CEO as appropriate.

Once received, the submission is assessed and a recommendation on investigation protocol is reviewed by a Complaint Review Committee. Consensus is reached and then the appropriate action and investigation commences, involving various levels of management and the Board dependent on the severity of the incident reported.

Confidentiality and Protection

All whistleblower incidents shall be communicated and resolved using the Company's prescribed procedures. Each whistleblower incident will be treated with confidentiality and due care. It is our policy that the whistleblower will not be negatively affected in any way. We recognize the significance of this policy, and as such will not protect whistleblowers who undermine the policy by reporting intentionally false accusations.

How to Report

A Whistleblower Form is used to communicate appropriate whistleblower incidents. The whistleblower's identity will be protected by an independent third party, and they can choose to remain anonymous. If a name is provided, the Whistleblower will be contacted within two weeks. Please read the complete Whistleblower Policy before submitting.

Following an investigation, each whistleblower incident will be rated according to policy to determine their validity, significance, ability to be proven. Appropriate action will be taken and all reported incidents will be documented and logged.