Building an Ethical Workplace Together

WHISTLEBLOWER POLICY

SCOPE:

This Policy applies to all current and former employees, officers and directors of Shawcor and its subsidiaries

(Shawcor) worldwide, as well as to consultants, contractors, suppliers, customers and service providers (collectively Responsible Persons).

PURPOSE:

Shawcor is committed to the highest standards of ethical, moral and legal business conduct as evidenced by its Global Code of Conduct which establishes expectations as to the legal and ethical nature of the conduct of Responsible Persons. This Policy aims to enhance Shawcor's transparency and system for combatting practices that might damage its reputation and its long-term viability by providing an avenue for Responsible Persons to raise genuine concerns anonymously through a Whistleblower Hotline. Importantly, it also aims to provide reassurance of protection from reprisals or retaliation for whistleblowing in good faith.

This Policy is intended to cover serious concerns that could have a significant impact on Shawcor. The following are just a few examples of serious concerns:

• actual or suspected criminal activities;
• unlawful or unethical acts or omissions;
• fraud;
• violations of the Global Code of Conduct or other Shawcor policies or procedures;
• danger to health, safety or the environment;
• improprieties in the workplace, including relative to matters of financial reporting, internal control or auditing;

Regular business or employment...

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