Whistleblower Policy (FY25)

Date of Last Review: October 2024. | Effective Date of this Version: January 2025.

The purpose of this policy is to codify Denver Gold Group’s compliance with all applicable insider whistleblower laws and expectations for superior governance.

This policy applies globally to all employees and directors of Denver Gold Group (“DGG” or “Organization”). It also applies to other individuals and entities that Denver Gold Group may require to adhere to this policy.

Directors, officers and employees of the Denver Gold Group (“DGG”) are expected to safeguard and avoid misuse of the funds, records, tangible assets, intellectual property and other property of DGG, and to avoid conduct that violates applicable law or DGG’s ethical standards. Directors, officers, and employees are prohibited from engaging in any activity that may involve theft, misappropriation, or other misuse of DGG property, including use of credit cards, checks and other financial instruments to purchase personal items or divert DGG funds to personal use or the use of third parties; misappropriation of DGG data or proprietary material; or falsification of time records, expense reports, or other DGG records, reports or statements. Directors, officers, and employees are expected to report immediately any known or suspected violation of this policy, of applicable local, state or federal law, or of DGG’s ethical standards. Such persons are also expected to report activities by others, including vendors, business partners, and other third parties, that place at risk or involve misuse of DGG assets. DGG expects that persons who make reports under this policy will make such reports truthfully, to the best of their knowledge of the facts. Such reporting provides DGG with the opportunity to evaluate the known or suspected violation and to take action to protect DGG’s property, funds, staff, or business interests. Employees wishing to raise questions about or report unlawful employment discrimination or harassment should consult and make reports under the Non-discrimination and Harassment policy of the DGG personnel manual.

Reports under this policy may be made to any of the following persons: the Executive Director, the Chairman of the Board of Directors, or the Treasurer of the Board of Directors. Reports may be made orally or in writing. Reports may be made anonymously. Reports should include as complete a description as possible of all known facts and circumstances. DGG will strive to maintain the confidentiality of reports made under this policy to the extent it can in the circumstances, although complete confidentiality cannot be guaranteed; disclosures may be necessary, for example, to address and evaluate the report, provide corrective action, or report to law enforcement or other government authorities.

DGG prohibits any DGG director, officer or employee from knowingly, and with intent to retaliate, causing harm to any other DGG director, officer or employee for providing truthful information to DGG concerning a violation or possible violation of this policy or local, state, or federal law in accordance with this policy. Further, DGG prohibits any DGG director, officer or employee from knowingly, and with the intent to retaliate, causing harm to any DGG director, officer or employee for providing truthful information to a law enforcement officer concerning the commission or possible commission of a local, state or federal criminal offense (felony or misdemeanor). Any person who feels that he or she, or another person affiliated with DGG, has been subjected to retaliation in violation of this policy should report the matter immediately to one of the persons designated above.

Any DGG director, officer or employee, or other person affiliated with DGG, who fails to comply with the expectations of this policy or otherwise violates this policy may be subject to disciplinary action, immediate termination of such person’s relationship with DGG, or such other corrective or remedial action as DGG determines is appropriate in the circumstances.

DGG may modify this policy at any time, in its discretion. This policy does not constitute an express or implied contract or a legally enforceable promise or representation, benefitting any person. My signature below indicates that I have received, reviewed and understand this policy. I also confirm that I have been provided with an opportunity to ask questions about this policy.