Whistleblower Policy

The purpose of this Policy is to encourage the reporting of breaches of the Corporate Governance Policy, or any other Westhaven Gold policy, any violation of law or other corporate misconduct or any accounting, internal accounting controls or auditing matters.

While reporting would generally occur through the normal channels within Management of the Company, there may be instances where an individual believes it is inappropriate or it is difficult for such matters to be reported through these channels.

In these cases, Westhaven Gold believes it is important that employees or others have an avenue through which to express concerns in a way that protects them from retaliation by the Company and protects their identity.

This Policy applies to directors, officers, full time and part time staff of Westhaven Gold. Any third party, however, may use the complaint procedures outlined in this Policy to make the Company aware of a reportable matter.

Any person reporting a concern under this Policy is referred to as a whistleblower. The Company encourages the reporting of breaches of the Code, any other Westhaven Gold policy, any violation of law or other corporate misconduct or any accounting, internal accounting controls or auditing matters that involve the Company or its employees in any way.

Information a Whistleblower Needs to Report

To assist the Company in the response to or investigation of a concern, the report should contain as much specific, factual information as possible to allow for proper assessment of the nature, extent and urgency of the matter.

If possible, you should include the following information:

• details of the event, matter or issue that is the subject of the report
• the name of each person involved;
• if the complaint involves a specific event or events, the approximate date and location of each event; and
• any additional information, documentation or other evidence available to support the complaint.

The Chair of Audit Committee will ensure that all reports are investigated promptly and appropriately. Depending on the outcome of the investigation, the Chair of the Audit Committee will ensure that appropriate corrective and disciplinary actions are taken.

The Company will maintain the confidentiality or anonymity of the whistleblower to the fullest extent possible, as permitted by law and by the investigation. In some cases, however, it may not be possible to proceed with or properly conduct a complete investigation unless the whistleblower identifies himself or herself. Whistleblowers should be cautioned that their identity might become known for reasons outside of the control of the Company as a result of the investigation.

We ask that you provide your contact information as it will be treated as confidential. Should you not wish to provide your information, and remain anonymous, that’s your prerogative.

The identity of other persons subject to or participating in any inquiry or investigation relating to a report will be maintained in confidence subject to the same limitations.

The Chair of the Audit Committee will maintain a log of all complaints, tracking their receipt, investigation and resolution and will prepare a summary to be presented to the Audit Committee of the Board of Directors on a quarterly basis. Copies of complaints and the log will be maintained by the Chair of the Audit Committee in a confidential manner.

Records of any complaints will be maintained by the Audit Committee or its designee for a period of at least seven years.