DICKIE WALKER MARINE, INC.
Financial and Code of Ethics Complaint Procedures Policy
The Board of Directors of Dickie Walker Marine, Inc. hereby adopts the following resolution by unanimous vote on
November 17, 2003:
RESOLVED, that the following procedures shall apply to financial complaints and known or suspected violations of the
Code of Ethics affecting Dickie Walker Marine, Inc. (the “Company”) effective immediately:
1. All complaints and concerns received by the Company regarding accounting, internal accounting controls or auditing
matters (each a “Financial Complaint”) and known or suspected violations of the Company’s Code of Ethics (each a “Code of
Ethics Complaint”) shall be dealt with expeditiously, thoroughly and in writing by management. Each of the Chief Financial
Officer of the Company (“CFO”) and the Chief Executive Officer of the Company (“CEO”) shall be provided a copy of each
Financial Complaint and Code of Ethics Complaint (each, a “Complaint”).
2. The CFO shall retain in filing for a period of not less than five (5) years copies of all Complaints regarding the Company,
whether received from employees of the Company or third parties, and management’s written responses.
3. The CFO or CEO shall notify the Audit Committee of the Board of the Company (the “Committee”) of each Complaint
received from any person who is not an employee of the Company (an “External Complaint”) and the disposition of such
External Complaint in accordance with paragraph 10 below.
4. Each employee of the Company is directed to notify his or her direct supervisor of any Financial Complaints regarding
questionable accounting or auditing matters of the Company or any Code of Ethics Complaint (each an “Internal Complaint”),
unless such employee believes that his or her direct supervisor (i) is the source of or a knowing participant in the questionable
matter, or (ii) is otherwise compromised in addressing the Internal Complaint objectively (a “Compromised Su