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FAIR COMPETITION + WAIVERS + REPORTING VIOLATIONS | 19

Employees may also report violations on a confidential basis to the EXP Ethics Line at 1-866-489-5803 or www.reportlineweb.com/exp. Any information reported will be reviewed by an independent member of the Board of Directors and General Counsel and where appropriate, the Vice-President of Human Resources. All information received will be treated as “confidential” and will be only handled by those of the Company’s employees tasked with dealing with the matter on a “need-to-know” basis.

Officers should report any violation of this Code to EXP’s Chairman or a member of the Board of Directors.

b. Protection for Whistle-Blowers

Regardless of reporting method, EXP has a non-retaliation policy with respect to good faith reports of compliance and ethics concerns or violations. This means employees who report violations will not suffer any adverse employment action as a result of making such a report. However, the Company reserves the right to discipline an employee who makes an accusation without reasonable good faith in the truth or accuracy of the information you provide or if you knowingly provide or make false information or accusations. “Good faith” does not mean that you have to be right – but it does mean you must reasonably believe you are providing truthful information.