Whistleblower Policy

This policy applies to all employees, independent insurance agents, contractors, vendors, clients, and other stakeholders who interact with the Company.  It provides a mechanism for reporting concerns while ensuring protection against retaliation. It also extends protections to members of the general public who report unethical or illegal insurance practices that could cause harm to policyholders or the public interest.

Whistleblower:  An individual who reports misconduct, unethical behavior, or illegal activity within the Company, including clients or members of the public.  It is a person who provides first-hand knowledge or evidence of actual or potential misconduct or any illegal activity occurring within the organization. 

Retaliation:  Any adverse action taken against a Whistleblower, including but not limited to dismissal, demotion, harassment, discrimination, or intimidation.

Good Faith Report:  A report made with reasonable belief that wrongdoing has occurred, even if it is later found to be unsubstantiated.

False Report:  A report made in bad faith and/or without substantiated evidence or cause; based on mere hearsay or intended to cause unnecessary disruption or defamation.

Misconduct: Includes fraud, financial misrepresentation, conflicts of interest, regulatory non-compliance, workplace harassment, breaches of client confidentiality, deceptive insurance practices, or failure to act in accordance with the Insurance Act or applicable law.

Confidentiality:  Protection of the Whistleblower’s identity to the extent possible, subject to legal requirements.

 Reportable conduct includes, but is not limited to:

• Fraud, embezzlement, or financial misconduct

• Misrepresentation of insurance policies or claims

• Violations of industry regulatory requirements (e.g., non-compliance with the Insurance Companies Act S.C. 1991, c. 47)

• Unethical business practices or conflicts of interest

• Breach of privacy laws (e.g., PIPEDA, CASL)

• Harassment, discrimination, or workplace violence

• Retaliation against whistleblowers

Whistleblowers may report concerns through the following channels:

• Confidential Email: whistleblower@greatwayfinancial.com

• Anonymous Reporting Hotline: (587) 443-6700

• Online Submission: Whistleblower Form

• Direct Mail: 
  The Compliance Officer: 
  Greatway Financial Inc.
  1223 31 Ave NE, Calgary, AB T2E 7W1

• Direct Reporting to the Compliance Office

Reports should include sufficient details to facilitate an investigation, such as dates, individuals involved, and supporting evidence, if available. Members of the public may also report concerns anonymously.

Whistleblowers may choose to report anonymously.  However, providing contact information can facilitate a more thorough investigation.  The Company will make all reasonable efforts to protect the identity of Whistleblowers, subject to legal and regulatory obligations.

Confidentiality will be maintained throughout the investigation process to the fullest extent possible.  However, Greatway cannot guarantee complete anonymity, as the whistle-blower’s identity or submitted documents may become known during an investigation or legal proceedings if disclosure is legally required.

A whistleblower’s identity shall only be disclosed where:

• Greatway is required to do so by a court or tribunal.

• The whistleblower consents to the disclosure.

• The whistleblower has committed an offense under the Criminal Code of Canada or related statute.

The Company strictly prohibits retaliation against any individual who reports concerns in good faith.  Retaliation may result in disciplinary action, including termination. 

Whistleblowers who experience retaliation should report it immediately to the Compliance Officer or an executive officer.  Clients and members of the public who experience intimidation or retaliation due to a report may be provided with legal recourse information.

The Compliance Officer or an appointed investigator will assess and determine the credibility of the report.  Investigations will be conducted in a timely, impartial, and confidential manner. 

If misconduct is substantiated, appropriate corrective and disciplinary actions will be taken.

The Whistleblower may receive feedback on the status of their report, subject to confidentiality obligations.

 All reports will be taken seriously and investigated promptly:

1. Acknowledgement: The whistleblower will receive confirmation of their report (unless anonymity is requested).

2. Preliminary Review: The Compliance Officer will assess the validity and determine the need for an investigation.

3. Investigation: A thorough and impartial investigation will be conducted.

4. Resolution: Findings and necessary corrective actions will be documented and implemented.

5. Follow-Up: The whistleblower (if known) will be informed of the outcome, subject to confidentiality constraints.

Whistleblowers must act in good faith.  Deliberately false or malicious reports may result in administrative or disciplinary action.  A report made in good faith, even if unsubstantiated, shall not be met with disciplinary action.

This policy aligns with relevant Canadian laws, including the Criminal Code of Canada, the Whistleblower Protection Act, and the Insurance Act.  The Company will cooperate with legal and regulatory authorities as required.  Clients and members of the public who report insurance misconduct will be afforded protection under applicable consumer protection laws.  Whistleblowers will not be held liable for reporting concerns in good faith.

This policy will be reviewed annually to ensure compliance with evolving legal requirements and best practices.

Any changes will be communicated to all employees, agents, and the public as necessary.