Whistleblower

Whistleblower

The purpose of this policy is to establish procedures for (a) the receipt, retention, and treatment of complaints received by Alexis Minerals Corporation. (the “Company”) regarding accounting, internal accounting controls, auditing matters or violations to the Company’s Code of Business Conduct and Ethics and other corporate governance policies; and (b) the submission by employees of the Company, on a confidential and anonymous basis, of concerns regarding questionable accounting, auditing matters or violations to the Company’s Code of Business Conduct and Ethics.

The purpose of this policy is also to state clearly and unequivocally that the Company prohibits discrimination, harassment and/or retaliation against any employee, director or officer who (i) reports complaints to the Corporate Secretary and/or the Audit Committee regarding accounting, internal controls, auditing matters or violations of the Code of Business Conduct and Ethics or (ii) provides information or otherwise assists in an investigation or proceeding regarding any conduct that he or she reasonably believes to be a violation of employment or labour laws, securities laws (including the rules or regulations of the Ontario Securities Commission (the “OSC”), securities regulatory authorities in other provinces of Canada or the Toronto Stock Exchange), or laws regarding fraud or the commission or possible commission of a criminal offence. Everyone at the Company is responsible for ensuring that the workplace is free from all forms of discrimination, harassment and retaliation. No employee, director or officer of the Company has the authority to engage in any conduct prohibited by this policy.

This policy protects:

any employee, director or officer who legitimately and in good faith discloses an alleged violation of employment or labour laws, securities laws, laws regarding fraud or the commission or possible commission of a criminal offense, by any person with supervisory authority over the employee, director or officer, or any other person working for the Company who has the authority to investigate, discover or terminate conduct prohibited by this policy;

any employee, director or officer who legitimately and in good faith files, causes to be filed, testifies, participates in, or otherwise assists in a proceeding filed under employment or labour laws, securities laws or laws regarding fraud;

any employee who legitimately and in good faith provides information, causes information to be provided, or otherwise assists in an investigation regarding any conduct which the employee reasonably believes constitutes fraud when the information or assistance is provided to or the investigation is conducted.