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REPORTING ILLEGAL OR UNETHICAL BEHAVIOUR POLICY ("Whistleblower Policy") 1. GENERAL This Policy addresses Wellco Energy Services' ("Wellco" or the "Company") commitment to integrity, ethical behavior and compliance with all applicable financial reporting and accounting regulations. The Policy establishes a procedure that allows employees of Wellco and other interested persons to anonymously and confidentially, or otherwise, submit their concerns to the Chair of the Company's Audit Committee regarding illegal or unethical behavior, including questionable accounting practices, internal accounting controls or auditing matters, without fear of retaliation. Employees are encouraged to speak with their supervisor, manager or other appropriate Company personnel regarding observed illegal, unethical or other behavior which compromises the Company's policies or reputation. Employees who not comfortable approaching their superiors with their concerns, or believe that their concerns are not being appropriately addressed by senior management, or other interested persons who have no direct access to Company management, may, depending on the circumstances, contact the Chief Executive Officer of Wellco or use the process outlined on this web-site to contact the Chair of the Company's Audit Committee. The effectiveness of an investigation and follow-up to any submitted report may be improved if the investigator can seek clarification and further information from the person submitting a report. For those who are unwilling or unable to provide their name when submitting a report, this procedure permits complete anonymity. 2. WHISTLEBLOWER PROTECTION Wellco will not take adverse employment action against an employee in retaliation for: (a) Reports of any act or acts the employee believes constitutes a violation of securities law, any rule or regulation of the Alberta Securities Commission or any provision of law relating to fraud against the Company's unit holders, or breach of any Corporate policy relating to ethical practice, conflicts of interest, or similar policy breach, if made in good faith; or (b) Providing information or causing information to be provided in an investigation conducted by any regulatory agency or authority, or by any person at Wellco, arising from any such report; or (c) Participating in an investigation, hearing, court proceeding or other administrative inquiry in connection with any such report. This Policy is intended to encourage reporting of wrongdoing by Wellco's employees and other stakeholders and presumes that all will act in good faith and will not make false accusations. An employee who knowingly or recklessly makes statements or disclosures that are not in good faith may be subject to discipline, which may include termination. 3. REPORTING OF WRONGDOING Any person who becomes aware of any wrongdoing or suspected wrongdoing regarding accounting practices, internal accounting controls, auditing matters or unethical business practice, may submit a confidential and anonymous report through the process available on this web-site. The report will be received by an independent third party and forwarded immediately to the Chair of the Company's Audit Committee for follow-up. The person reporting may retrieve information relating to such follow-up using the procedures outlined on the Website. Should a "whistleblower" reveal his or her identity hereunder, to the extent reasonable and practical, the identity of such person shall not be revealed, in the case of an employee, to any person in the employee's department, division or work location, and in the case of a third party, to anybody but the Chair of the Company's Audit Committee and any person who he deems requires the information. Wellco will make good faith efforts to protect the confidentiality of any person making reports; provided, however, Wellco or its employees and agents shall be permitted to reveal the reporting person's identity and confidential information to the extent necessary to permit a thorough and effective investigation. Persons filing complaints should ensure that any complaint includes sufficient detail to allow substantiation and investigation. Related documents, dates and identity of parties involved should also be provided. 4. CLAIMS OF RETALIATION Wellco and its officers, employees and agents will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee based upon lawful actions of such employee in relation to a good faith reports of the nature contemplated by this Policy or the investigation of issues or concerns regarding Wellco's accounting, auditing or business practices. If the individual filing a report is an employee, and if the identity of the employee making the report or assisting in investigation of the report is known by any other person within Wellco, the Audit Committee will monitor any disciplinary action taken against the employee to determine whether such disciplinary action is the result of or related to the report or its investigation.
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