Whistleblower Protection and Investigation Policy
January 2026
Whistleblower Protection and Investigation Policy
The Code of Business Conduct and Ethics (the "Code") of Hemlo Mining Corp. (the "Company") requires all employees, officers and directors of the Company and its subsidiaries (collectively, "Employees"), as well as contractors, agents, consultants and other representatives of the Company and its subsidiaries (collectively, "Other Representatives") to observe high standards of business and personal ethics as they carry out their duties and responsibilities.
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COMPLAINT PROCEDURES
- Scope of Matters Covered by Procedures
Any Employee may submit a good faith complaint to the Company (a "Report"), without fear of dismissal or retaliation, of any actual or potential or suspected violation of the Company's Code of Business Conduct and Ethics; any applicable laws, rules or regulations; any applicable accounting, auditing or securities regulatory requirements; employment related matters; or other matters of ethical concern (the "Matters"). The Audit Committee of the Company (the "Audit Committee") has approved this Whistleblower Protection and Investigation Policy (the "Policy") and the reporting mechanisms contained in this Policy in order to fulfill its responsibilities.
Reports on Matters may include, without limitation, topics such as the following:
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questionable accounting, internal accounting controls and auditing matters, including the circumvention or...
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