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Whistleblower Policy

Pursuant to Section 301(m)(4) of the Sarbanes-Oxley Act of 2002 (“SOX”), the SGF Energy Ltd (SGF) Audit Committee has adopted a Policy for Whistleblower Procedures. This policy establishes procedures for (i) the receipt, retention and treatment of complaints received by the company regarding accounting, internal accounting controls or auditing matters, and (ii) the confidential, anonymous submission by employees of the company of concerns regarding questionable accounting or auditing matters.

Concerns about these accounting related issues may be reported through the Integrity Helpline, electronic or regular mail, or a personal visit with Business Integrity and Compliance. Business Integrity and Compliance will record and categorize all calls to ensure appropriate retention according to the company’s Records Retention Policy and the provisions of Section 301(m)(4) of SOX.

SGF is committed to protecting the employee making the good faith report. As stated in the Code of Business Conduct, the company will not tolerate any retaliation against the employee.

Policy for Whistleblower Procedures