Whistleblower Protection Policy

This policy outlines how Impossible Metals protects persons who identify and call out misconduct or harm.

Position on Whistleblowing

Impossible Metals is committed to the highest standards of conduct and ethical behavior, and to promoting and supporting a culture that values honest, transparent and ethical practices.

Impossible Metals encourages the reporting (by any person, internal or external to the organization) of any instances of suspected unethical, illegal, fraudulent or undesirable conduct involving Impossible Metals, and provides protections and measures so that those persons who make a report may do so confidentially and without fear of intimidation, disadvantage or reprisal.

Reportable Conduct

The reporting of wrongdoing that is of legitimate concern may include (but is not limited to) conduct that:

  • Breaches legislation or is an offence against any law;
  • Is corrupt, dishonest or fraudulent;
  • Is discriminatory, oppressive or grossly negligent;
  • Unreasonably endangers a person’s health and safety, or the environment;
  • Perverts the course of justice;
  • Represents gross mismanagement or unethical use of Impossible Metals resources; or
  • Causes loss of the financial resources of Impossible Metals or otherwise damages Impossible Metals’s reputation or interests.

Process for Disclosure

Reports of conduct referred to above must be made in the first instance to the Chief Executive Officer at ceo@impossiblemetals.com. In the event that the incident relates to the Chief Executive Officer, the incident may be reported to the Chair of the Board (chair@impossiblemetals.com ). Reports may also be made in person or via telephone. The person reporting (the Whistleblower) must indicate to the recipient of the report (the Receiver) that they wish to make a report under this Policy.

Impossible Metals will connect the Whistleblower with internal and external support providers as necessary, or as requested by the Whistleblower.

All reasonable steps will be taken to protect a Whistleblower’s identity following a report of any matter that is considered Reportable Conduct. Where a Whistleblower wishes to remain anonymous, the Whistleblower’s identity will not be disclosed to the investigator or to any other person. Information about a Whistleblower’s identity and information that may lead to the identification of the Whistleblower may be disclosed in the following circumstances:

  • where the information is disclosed to a regulatory body;
  • where the information is disclosed to a legal practitioner for the purpose of obtaining legal advice in relation to the operation of applicable whistleblowing protection laws; or
  • where the Whistleblower consents.

Protection for Whistleblowers

A Whistleblower will not be subject to any civil, criminal or disciplinary action for making a report that is covered by this Policy, or for participating in any subsequent investigation by Impossible Metals. Further, Impossible Metals will not tolerate any form of detrimental treatment towards, or retaliation (including threats) against a Whistleblower, for the reporting of conduct under this Policy. Detrimental treatment that is expressly prohibited includes, but is not limited to dismissal or demotion of a Whistleblower, harassment, intimidation or vilification of a Whistleblower or damage to a Whistleblower’s property, financial position or reputation.

Detrimental treatment by any employee towards a Whistleblower will be deemed a serious breach of this Policy and may result in disciplinary action up to and including termination of employment.

Exclusions

Protection of Whistleblowers does not extend to disclosures that are:

  • Trivial or vexatious in nature, with no substance; or
  • Unsubstantiated in nature and/or found to have been made maliciously.

Disclosures that are found to be false or vexatious may be the subject of disciplinary action, up to and including termination of employment.

Changes to this Policy

This policy is reviewed under Impossible Metals’s mandatory annual policy review schedule and is next due for formal review in October 2022.

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