Bonterra – whistle blower policy c gastronomie plateaux repas

Bonterra Oil & Gas Ltd. is instituting the attached Whistle Blower Policy as a result of recent requirements made to securities and civil legislation. Bonterra has always had an informal open door policy for all employees, contractors and other stakeholders to discuss all matters pertaining to the operation and reporting of activities of Bonterra and its affiliated organizations.

Employees of entities are often the first to realize that there may be something seriously wrong with an organization. However, they may decide not to express their concerns because they feel that speaking up would be disloyal to their colleagues or to the organization. They may also fear harassment or victimization. In these circumstances, they may feel it would be easier to ignore the concern rather than report what may just be a suspicion of malpractice.

This policy document for Bonterra makes it clear that employees can do so without fear of victimization, subsequent discrimination or disadvantage. This Whistle Blowing Policy is intended to encourage and enable employees to raise serious concerns within Bonterra rather than overlooking a problem or seeking a resolution for the problem outside Bonterra.

This Policy applies to all employees and those contractors working for Bonterra. It is also intended to provide a method for other stakeholders (suppliers, customers, unitholders etc.) to voice their concerns regarding Bonterra’s business conduct.

The Policy is also intended as a clear statement that if any wrongdoing by Bonterra or any of its employees or by any of its contractors or suppliers is identified and reported to Bonterra, it will be dealt with expeditiously and thoroughly investigated and remedied. Bonterra will further examine the means of ensuring that such wrongdoing can be prevented in the future. Policy

This Policy is set in the context of the statutory provisions of the Canadian Securities Association (CSA) Multilateral Instrument 52-109. Any employee who makes a disclosure or raises a concern under this Policy will be protected if the employee:

1. Any one with a complaint or concern about Bonterra should try to contact their supervisor, manager or Vice President responsible for the area which provides the relevant service. This depends however, on the seriousness and sensitivity of the issues involved and who is suspected of malpractice and therefore contact directly to the President and CEO may be warranted.

contact between the persons considering the issues and you will depend on the nature of the matters raised, the potential difficulties involved and the clarity of the information provided. If necessary, Bonterra will seek further information from you.

Bonterra will take steps to minimize any difficulties which you may experience as a result of raising a concern. For instance, if you are required to give evidence in criminal or disciplinary proceedings, Bonterra will arrange for you to receive advice about the procedure.

Concerns will be investigated as quickly as possible. It should also be borne in mind that it may be necessary to refer a matter to an external agency and this may result in an extension of the investigative process. It should also be noted that the seriousness and complexity of any complaint may have an impact upon the time taken to investigate a matter. A designated person will attempt to indicate at the outset the anticipated time scale for investigating the complaint. Prevention of recriminations, victimization or harassment

Bonterra will not tolerate an attempt on the part of anyone to apply any sanction or detriment to any person who has reported to Bonterra a serious and genuine concern that they may have concerning an apparent wrong doing. Confidentiality and anonymity

Bonterra will respect the confidentiality of any whistle-blowing complaint received by Bonterra when the complainant requests confidentiality. However, it must be appreciated that it will be easier to follow up and to verify complaints if the complainant is prepared to give his or her name. In addition, confidentiality cannot be maintained if such confidentiality is incompatible with a fair investigation or if there is an overriding reason for identifying or otherwise disclosing the identity of the person making the complaint, or if disclosure of the identity of the complainant is required by law. In the event that anonymity is requested the person should contact one of the above mentioned audit committee members by phone who will give a case number and a time or times when he or she can call back for updates on the investigation of his or her complaint. False and malicious allegations

Bonterra is proud of its reputation of adhering to high standards of honesty. It will therefore ensure that resources are put into investigating any complaint which it receives. However, it is important to realize that Bonterra will view very seriously any allegations which prove not to be substantiated (unless made in good faith pursuant to this Policy) or which prove to have been made maliciously or knowing them to be false.

Bonterra will regard the making of any deliberately false or malicious allegations by any employee of Bonterra as a serious disciplinary offence which may result in disciplinary action including dismissal for cause and pursuing civil remedies.