ARC Whistleblower Policy
As a public reporting issuer, the integrity of the financial and other information and the integrity of the officers of ARC Resources Ltd. and its subsidiaries (together, "ARC") is vital. Our financial and other information guides the decisions of the Board of Directors of ARC (the "Board"), and is relied upon by our shareholders, financial markets, and other stakeholders. The fair and accurate reporting of all material financial and other facts regarding ARC and its affairs is of paramount importance and we will not tolerate fraud or misrepresentation of any kind.
As part of our efforts to ensure the integrity of ARC and our financial and other information, we encourage employees who have concerns regarding any suspected violations of our disclosure standards and Code of Business Conduct and Ethics or our disclosure policies or our financial reporting to raise them with the appropriate people.
The purpose of this Whistleblower Policy is to provide ARC employees, consultants, and external stakeholders with a mechanism by which they can raise these concerns through their supervisors or in a confidential anonymous process.
At ARC we promote an open door policy where members of our organization should feel comfortable discussing matters with individuals at all levels. If you are:
- Aware of any violations of ARC's code of business conduct and ethics, which covers a broad spectrum of matters including the health, safety and workplace environment of our employees and consultants, disclosure of conflicts of interest, the confidentiality of our information and use of our assets, compliance with insider trading and compliance with environmental and other laws; or
- Aware of any violations of ARC's disclosure policy, which requires that the communications of ARC with the public are timely, factual and accurate, and broadly disseminated; or
- Have complaints regarding accounting, internal accounting controls or auditing matters or any questionable accounting or auditing matters,
it is your duty to report such occurrences.
Reporting and Investigating
As a first step, we encourage you to report any known violations or complaints to your immediate supervisor. If you do not feel comfortable reporting the information to your immediate supervisor we recommend reporting violations or complaints to the senior officers of the organization (Chief Executive Officer, the President and Chief Operating Officer, the CFO, or other Vice Presidents).
Violations or complaints can be reported directly in person, via phone, regular mail or email.
In order to adequately investigate any claims brought forth we require that you provide a detailed explanation of any violation or complaint along with information that will enable us to contact you to follow up on the ongoing investigation. Your identity will remain confidential.
All reports and complaints under this policy will be promptly and thoroughly investigated, and all information disclosed during the course of the investigation will remain confidential, except as necessary to conduct the investigation and take any remedial action, in accordance with applicable laws. We will retain all reports or complaints for a minimum of two years.
In the event you do not feel comfortable informing your supervisor or ARC's officers of the violation, we have set up a confidential Whistleblower hotline with an independent third party that you can access. Complaints and concerns can be left on either the toll free telephone number or e-mail which is accessed only by the Chair of the Audit Committee and the Chair of the Policy and Board Governance Committee. Please visit ARC's Whistleblower Hotline for more information.
All concerns and complaints received will be promptly investigated by the appropriate senior officers or by the appropriate independent directors. Appropriate corrective action will be taken by us if warranted by the investigation. All reports will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Any member of ARC that reports a violation in good faith and with absence of malice will not be the subject of retaliatory actions against them by ARC. If later you believe that you have been subject to any discrimination, retaliation, threats, or harassment as a result of reporting a violation or making a complaint you must immediately report it, as these actions will not be tolerated by ARC.