HUDBAY MINERALS INC.
(the "Company") WHISTLEBLOWER POLICY PURPOSE
The purpose of this Policy is to establish procedures for:
the receipt, retention, and treatment of complaints received by the Company and its subsidiaries (the "HB Group") regarding accounting, internal accounting controls, auditing matters or violations of the Company's Code of Business Conduct and Ethics, Supplier Code of Conduct and Ethics and Customer Code of Conduct and Ethics (collectively, "Codes of Conduct"), and
the submission by employees, officers and directors ("HB Personnel") of the HB Group on a confidential and anonymous basis, of concerns regarding questionable accounting, auditing matters or violations of the Company's Codes of Conduct.
The purpose of this Policy is also to state clearly and unequivocally that the Company prohibits discrimination, harassment and/or retaliation against any HB Personnel who:
reports complaints regarding accounting, internal accounting controls, auditing matters, or violations of the Company's Codes of Conduct, and/or
provides information or otherwise assists in an investigation or proceeding regarding any conduct which they reasonably believe to be a violation of employment or labour laws; securities laws; laws regarding fraud; anti-bribery and anti-corruption laws; the rules or regulations of applicable securities regulatory authorities (the "Securities Regulators") and the rules of any stock exchange (the "Exchange") on which securities of the...
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