2. Greater Vancouver Board of Trade's Whistleblower Policy

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The Greater Vancouver Board of Trade ("GVBOT” or the "Organization") is committed to the highest possible standards of openness, honesty and accountability. In line with that commitment, we expect employees and others that we deal with who have serious concerns about any aspect of the Organization’s work to come forward and voice those concerns.

What is Whistleblowing?

Employees are usually the first to know when something is going seriously wrong. A culture of turning a "blind eye" to such problems means that the alarm is not sounded and those in charge do not get the chance to take action before real damage is done. Whistleblowing can, therefore, be described as giving information about potentially illegal and/or underhanded practices i.e. wrongdoing.

What is wrongdoing?

Wrongdoing involves any unlawful or illegal behaviour and can include:

  • An unlawful act whether civil or criminal
  • Breach of GVBOT’s Code of Business Conduct and Ethics
  • Breach of or failure to implement or comply with any approved GVBOT policy
  • Knowingly breaching federal, state or provincial laws or regulations
  • Unprofessional conduct or below recognized, established standards of practice
  • Questionable accounting or auditing practices
  • Dangerous practice likely to cause physical harm/damage to any person/property
  • Abuse of power or authority for any unauthorized or ulterior purpose
  • Unfair discrimination in the course of the employment or provision of services.
  • Failure to rectify or take reasonable steps to report a matter likely to give rise to a

significant and avoidable cost or loss to the Organization

This list is not definitive, but is intended to give an indication of the kind of conduct which might be considered as "wrongdoing.”

This Policy applies to all employees and those contractors working for GVBOT. It is also intended to provide a method for other stakeholders (volunteers, suppliers, customers, shareholders etc.) to voice their concerns regarding the Organization’s business conduct.

The Policy is also intended as a clear statement that if any wrongdoing by the Organization or any of its employees or by any of its contractors or suppliers is identified and reported to the Organization, it will be dealt with quickly and thoroughly investigated and remedied. The Organization will further examine the means of ensuring that such wrongdoing can be prevented in future.

A Whistleblowing or reporting mechanism invites all employees and other stakeholders to act responsibly to uphold the reputation of their organization and maintain public confidence. Encouraging a culture of openness within the organization will also help this process. This Policy aims to ensure that serious concerns are properly raised and addressed within the Organization and are recognized as a key tool in enabling the delivery of good governance practices.

Who is protected?

This Policy is set in the context of the statutory provisions of the Canadian Securities Association (CSA) Multilateral Instrument 52-110 and the U.S. Sarbanes-Oxley Act Section 806. Any employee/stakeholder who makes a disclosure or raises a concern under this Policy will be protected if the employee/stakeholder:

  • Discloses the information in good faith
  • Believes it to be substantially true
  • Does not act maliciously or make false allegations, and
  • Does not seek any personal or financial gain

Confidentiality and Anonymity

GVBOT will respect the confidentiality of any whistleblowing complaint received by the Organization where the complainant requests that confidentiality. However, it must be appreciated that it will be easier to follow up and to verify complaints if the complainant is prepared to give his or her name. In the event that anonymity is requested and the information is given through the ethics hotline, the person will be given a case number and a time or times when he or she can call back or login for updates on the investigation of his or her complaint.

False and Malicious Allegations

GVBOT is proud of its reputation for the highest standards of honesty. It will, therefore, ensure that substantial and adequate resources are put into investigating any complaint which it receives. However, it is important to realize that the Organization will view very seriously any allegations which prove not to be substantiated or which prove to have been made maliciously or knowing them to be false.

GVBOT will regard the making of any deliberately false or malicious allegations by any employee/stakeholder of the Organization as a serious disciplinary offence that may result in disciplinary action, up to and including dismissal for cause.

To File a Report, follow one of the three methods below: