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Whistle Blower Policy

Whistle Blower

Non-employees may submit complaints by email to, or by regular mail or other means of delivery to 1867 Ashburnham Drive, PO Box 4125, Peterborough, Ontario, K9J 6Z5 marked “Private and Strictly Confidential" and "Attention: Chair of the Audit Committee of PUG“. Such envelopes shall be forwarded unopened to the Chair of the Audit Committee. These procedures shall be posted on the Peterborough Utilities Group (PUG) website.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suggested violation of the Code must be acting in good faith and have reasonable grounds for believing information disclosed indicates a violation of the Code and is real, legitimate, and significant enough to warrant an investigation. Handling of Reported Violations The Ethics Officer or the Chair of the Audit Committee (when sent directly to the Chair) will notify the sender and acknowledge receipt of the reported violation or suspected violation within five business days, unless it is received anonymously. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Treatment of Complaints

  1. All complaints will be treated as confidential, whether received anonymously or otherwise.
  2. Although a person making an anonymous complaint may be advised that to maintain anonymity could hinder an effective investigation, the anonymity of the person making the complaint shall be maintained until he/she no longer wishes to remain anonymous. Any system established for exchanging information with a complainant shall be designed to maintain anonymity.
  3. The Ethics Officer will inform the Audit Committee, in summary form or otherwise, of all complaints received, with an initial assessment as to the appropriate treatment of each complaint. Assessment, investigation, and evaluation of complaints shall be conducted by the Ethics Officer at the direction of the Audit Committee. If the Audit Committee deems it appropriate, the committee may engage, at PUG’s expense, independent advisors, such as outside legal counsel or auditors who are not affiliated with the PUG auditor for the purpose of undertaking an investigation and/or recommending appropriate action.
  4. PUG will regard the making of any deliberately false or malicious allegations by an employee as a serious offence that may result in disciplinary action up to and including termination for cause.
  5. Following investigation and evaluation of a complaint, the Ethics Officer will report to the Audit committee the recommended disciplinary or remedial action, if any is required.
  6. The recommended remedial actions will be reviewed by the Audit Committee and shall be brought to the Board for authorization who will then inform the appropriate Executive for implementation. If the action taken to resolve a complaint is deemed by the Audit Committee to be material or otherwise appropriate for inclusion in the minutes of the Audit Committee it shall be so noted.
  7. Reasonable and necessary steps will also be taken to prevent any further violations of the Code.
  8. To the extent that the policy allows, the complainant will be informed when the assessment is complete. Retention of Records of Complaints Records pertaining to complaints are the property of the PUG and will be retained:
    • Upon receiving a written declaration/complaint, a confidential file shall be created and maintained in compliance with applicable laws and document retention policies.
    • Subject to safeguards that ensure their confidentiality, and when applicable, the anonymity of the complainant.
    • In such a manner as to maximize their usefulness to PUG’s overall compliance program.