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Trident Whistleblower Policy

The purpose of this Whistleblower Policy ("policy") is to provide a mechanism for all staff members, vendors, partners and various other stakeholders (the "users") to raise concerns free of discrimination, retaliation or harassment.

Trident is committed to social and environmental responsibility. Our operations are conducted with integrity and in accordance with all applicable laws, rules, and regulations. This policy seeks to provide an avenue for users to raise any concerns they may have and to be assured that in making complaints they will be protected from discrimination, retaliation or harassment for raising their concerns in good faith.

All Trident staff members and other stakeholders, including suppliers, creditors and shareholders are bound by the requirements and standards set forth in this policy . Any violator of this policy will be subject to appropriate disciplinary action as necessary.

Trident encourages users of the hotline to report any concerns or issues they have pertaining to:

  1. Accounting, auditing and any other financial reporting irregularities.
  2. Unethical business conduct including, but not limited to, safety, environment, conflicts of interest, theft and fraud.
  3. Violations of Trident's staff member handbook (for Trident staff members only).

To protect your anonymity, Trident has outsourced all Whistleblower services to a third party provider. The provider is a leading hotline company that has more than twenty years of experience in handling confidential information.

To access the third party Whistleblower Hotline you may use either of the following methods;

  1. Telephone – Toll free 1-877-888-0002 anywhere in North America. An experienced interviewer will be available to take you call twenty-four hours a day, seven days a week. Your call is completely anonymous and cannot be traced.
  2. Internet – A report can be submitted anonymously online through the provider's online web service at www.tnwinc.com/webreport

If the third party provider determines that your concern is within the scope of Trident's policy, a report will be generated and forwarded to all of the following designated reviewers;

  1. Chairman of the Audit Committee
  2. President & Chief Executive Officer

Your concern will be reviewed and appropriate investigative procedures will commence as deemed necessary.

Users of the hotline may remain anonymous if so they desire. However, to facilitate a better review of your concerns or issues, users may want to consider providing their contact information (name, telephone number, etc.) to the provider. Trident will maintain your contact information in complete confidentiality except to the minimum extent necessary to conduct a complete and fair investigation.

When submitting a concern or issues please provide as much information as possible to help facilitate the designated reviewers' investigation.

All reports made in accordance with this policy shall be kept in accordance with Trident's document retention policy and applicable law.

Trident will not permit discrimination, retaliation or harassment against anyone who in good faith submits a report in accordance with this policy. Any staff member who retaliates against someone who has submitted a report in good faith is subject to disciplinary action up to and including termination of employment with Trident.

In accordance with this policy, any Trident staff members who submit a report are obligated to act in good faith. Any reports that cannot be substantiated and have been made with malicious intent will be viewed as a serious disciplinary offence.


 
 
 
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