WHISTLEBLOWER POLICY

1. Scope of Policy

This Policy is designed to enable employees and officers of the TransForce Inc. and its divisions (“TransForce”), including temporary staff, to raise concerns internally and at a high level and to disclose information which they believe shows financial malpractice, impropriety, fraud, theft, criminal activity and corruption.

Any event that could have a significant consequence on TransForce’s results and that, to the knowledge or belief of one employee, is neither adequately stated nor accounted for, could be reported under this Policy.

The Canadian Securities Administrators have recently issued a number of rules which give legal protection to employees against being dismissed or penalized by their employers as a result of disclosing certain serious concerns. TransForce has endorsed the provisions set out below so as to ensure that no staff members ever fear dismissal or reprisal in raising legitimate concerns.

It should be emphasized that this Policy is intended to assist individuals who believe they have discovered financial malpractice, fraud, theft, criminal activities or impropriety. It is not designed to question financial or business decisions taken by TransForce. TransForce Inc.’s Audit Committee is responsible for overseeing the receipt, investigation, resolution and retention of all credible, serious complaints submitted pursuant to this Policy.

2. Safeguards

A. Protection

This Policy is designed to offer protection to those employees of TransForce who disclose such concerns, provided the disclosure is made in good faith.

B. Confidentiality

TransForce will treat all such disclosures in a confidential and sensitive manner.  The investigation process may reveal the source of the information, but the employees would be protected against any dismissal or reprisal.

 
C. Untrue Allegations

If an individual makes an allegation in good faith, which is not confirmed by subsequent investigations, no action will be taken against the individual.  In making a disclosure, the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes frivolous allegations, disciplinary action may be taken against the individual.

3. Procedure for making a disclosure

Concerns should be raised with the employee’s line manager who will then notify one of the people listed below. However, if for some reason the employee does not feel comfortable to report through his/her line manager, then he has the right to bypass the line management structure and take his/her concerns directly to one of the following people:

Concerns are best raised in writing. The employee is invited to set out the background and history of the concern, giving name(s), date(s) and place(s) where possible, and the reasons why they are concerned about the situation.  If the employee does not feel able to put his/her concerns in writing, he/she can telephone, email or meet one of the people listed above. The employee’s concerns could also be expressed anonymously, and this choice would be respected.

The complainant will be kept informed of the final outcome of TransForce’s investigation. All responses to the complainant will be in writing and sent to his/her home address where the employee has provided his/her identification.