Policies

Whistleblower Hotline


Pembrook has a Whistleblower Policy whereby employees have direct and anonymous access to the Chairman of the Audit Committee of the Board of Directors to report any wrongdoing or violation of the Company's Code of Conduct. Pembrook is committed to maintaining and fostering a work environment where employees can conduct themselves with integrity in accordance with the Code of Conduct and where violations can be reported without fear of retaliation. Pembrook has a strict policy of no reprisals against individuals submitting a complaint in good faith.

You are welcome to discuss any issue or violation directly with your supervisor, however; if you believe that the issue has not been adequately addressed by your supervisor or if you feel that the nature of the issue involves your supervisor or if you are not comfortable having the discussion with your supervisor, then you can submit a whistleblower complaint or violation using any of the following three options:
  • Contact Steve Kurtz, the Chairman of the Audit Committee of the Board of Directors directly on his mobile phone (303) 888-5650 or via e-mail:

  • The Whistleblower Hotline phone-based system where you can submit an anonymous report or complaint to Mr. David Allman of the law firm Edwards Kenny & Bray LLP. The telephone number is based in Canada: +1-604-661-1071. Mr. Allman is external to Pembrook and will keep any report anonymous unless the reporting person consents to the disclosure of his or her name to Pembrook;

  • The Whistleblower Hotline email-based system where you can email an anonymous report or complaint to Mr. David Allman of the law firm Edwards Kenny & Bray LLP:
  • Mr. Allman is external to Pembrook and will keep any report anonymous unless the reporting person consents to the disclosure of his or her name to Pembrook.

When registering a complaint or reporting a violation to the Whistleblower Hotline, you have the option of making the report anonymously, or you can provide permission for your name to be disclosed to Pembrook so that Pembrook can follow up directly with you in its investigation. Pembrook has entered into a binding agreement with Edwards Kenny & Bray LLP whereby the Pembrook will not receive any information regarding the identity of anyone submitting an anonymous whistleblower report. All reports submitted through the Whistleblower Hotline will be forwarded directly to Steve Kurtz as Chairman of the Audit Committee for further action. Senior management, including the CEO and CFO, will not receive a copy of the report if they are involved in the violation, pending the outcome of any investigation.

All reported violations and complaints will be evaluated to determine any further action. Each quarter, a report will be submitted to the Board of Directors, detailing any complaints received in the prior quarter.

If you have any questions or would like to know more about the Whistleblower Hotline or the Company's Code of Conduct, you may contact any of the individuals below, regardless of your home country:
  • In Peru: Mauro Quintana
  • In Canada: Steve Kurtz, Brian Booth or April Hashimoto