As a public reporting issuer, the integrity of the financial and other information and the integrity of the officers of Starfield Resources Inc. ("Starfield" or “the Corporation”) is vital. Our financial and other information guides the decisions of the Board of Directors of Starfield (the "Board of Directors"), 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 Starfield 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 Starfield and our financial and other information, we encourage employees who have concerns regarding any suspected violations of our disclosure standards and Code of Conduct or our disclosure policies or our financial reporting to raise them with the appropriate people.
The purpose of this Whistleblower Policy is to provide Starfield 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 Starfield, 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 Starfield's Code of Conduct, 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 disclosure violations. Starfield requires that its communications 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 (President, the CFO, or Chair of the Audit Committee).
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.
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 Starfield that reports a violation in good faith and with absence of malice will not be the subject of retaliatory actions against them by the Corporation. 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 Starfield.