Supporting a culture of transparency and accountability.

Introduction

ConfidenceLine has been selected by Graham as its authorized external service provider for the purpose of reporting or questioning unethical or improper conduct. This service is open to all employees of Graham as well as those of its strategic labour partners.

The ConfidenceLine E-Web reporting system offers a secure, state of the art, web reporting communications process that allows for direct and confidential communication between you and Graham.

ConfidenceLine allows for complaints or inquiries to be raised, either by the ConfidenceLine E-Web application or telephone, instructions for which are below.

Instructions for the ConfidenceLine E-Web application

To create a report, simply press the "Continue" button on the log-in screen. The system will provide you with a User Name and you will be asked to create a Password for the purpose of receiving communications from your employer and/or to update information to your file. Once you have entered the ConfidenceLine E-Web application some preliminary instructions will be provided. Please read these carefully. You will find a series of screens that include questions and information particular to your concern. You may skip over questions that do not apply, and at the end of the process you will be given an opportunity to edit the final report before it is sent by you and received by the Chief Compliance Officer at Graham. The submitted report will contain a system-generated file number, but will not include your user-name.

For security purposes, there is a sixty minute inactivity time limit built in to this web application. If there is a period of inactivity for more than sixty minutes, the system will cancel your access to the program. Should this occur, please start the process from the beginning.

Once you are completely satisfied with your report, you will be asked to press a "Send Report" button that will send your confidential electronic report to the Chief Compliance Officer at Graham.

Upon receipt of a report, the Chief Compliance Officer will refer the report to an Investigation Manager with responsibility for the subject matter of the report. For a list of Investigation Managers, please see the Investigation Manager Listing maintained on Graham’s Legal Intranet Site. Should any of the Investigation Manager or the Chief Compliance Officer be listed or involved in your issue or concern, please contact our 1-800 services (1-800-661-9675) to file your report. Our call centre processes will ensure that the report is not forwarded to any individuals who may be implicated.

Remember to write down the User Name and Password provided so you can log back in to obtain an update or reply to your submission.

If you would like to see Graham’s response to your submission, simply log back into the website and enter your User Name and Password. You will be given an opportunity to update the file by entering communications directly over the internet that will be reviewed by the Investigation Manager. Type your message in the Communications Message Field and press the "Send Communications" button. An email alert will be sent by the program to the Graham Investigation Manager who will log in and see your comments.

Contact ConfidenceLine

An alternate way to submit a report is to call our ConfidenceLine 1-800 service at 1-800-661-9675. Our Call Agents are available 24 hours a day to assist you. You may also call us at 1-800-661-9675 if you have any questions regarding our service.

The program includes a mechanism for you to upload any documentation or evidence that you would like to forward with regard to this report. You may also forward documentation to ConfidenceLine Administration who will manage the upload for you. You may do so in a confidential manner as follows:

Documents, memos, pictures, emails, or any other supporting material in hard copy can be forwarded:

• By Fax: 1-800-515-1706
• By Mail: #202 – 8333 Eastlake Drive, Burnaby, BC V5A 4W2
• By email: confidenceline@xpera.ca

Please ensure your documents are marked "Confidential" and include your User Name that is provided by this program on the documentation. We will be unable to upload your documents to the file unless your User Name is included. ConfidenceLine will remove any identifiers that may jeopardize your anonymity prior to uploading your submitted materials for the company designate to review.