EMPLOYMENT OF RELATIVES / PERSONAL RELATIONSHIPS POLICY

Every Waséyabek Federal Services (WFS) employee has a responsibility to preserve a

professional environment and to avoid situations that may create a possible conflict of
interest or an uncomfortable working environment.

In any case where employees, both management and non-management, are or become
involved in a personal relationship as defined in this policy, the general presumption will
be that the employees will not be permitted to work together and will be separated.
WFS reserves the right to deviate from the presumption where it determines, in its sole
discretion, that:

• The relationship does not involve a supervisor/subordinate relationship;

• No conflict of interest exists;
• The relationship does not have any negative effect on the working environment.

WFS further reserves the right to take whatever action is necessary to separate the
employees, either by reassignment or, where reassignment is not feasible, by
termination of one or both of the employees.

To be sensitive to the issues of favoritism that these special relationships may imply and
to avoid any conflict of interest, no employee may initiate or participate in, directly or
indirectly, decisions involving a direct benefit (e.g. initial employment, retention, job
classification, salary, work assignments, performance appraisals, etc.) to an employee
with whom such a relationship exists.

DISCLOSURE REQUIRED

As a necessary corollary to these policies, any employee who is or becomes involved in

a personal relationship with another employee is responsible to promptly disclose the
existence of the personal relationship to the CFO. The purpose of this disclosure is to
allow the Company to determine whether the relationship implicates this policy or any
other policy, and whether any action by the Company is necessary under the
circumstances. Any such disclosures will be kept confidential consistent with the
Company’s obligations under its policies or under applicable law. Failure to disclose a
personal relationship may be grounds for discipline, up to and including termination.

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DEFINITIONS
For purposes of this policy, a relative is defined as any person who is related to
the third degree of kindred by blood or marriage, or who is a member of the
employee’s household other than in a landlord-tenant relationship. Third degree
of kindred includes parents, grandparents, children, grandchildren, brother/sister,
aunt/uncle; and nephew/niece whether by blood or marriage.

For purposes of this policy, a Personal Relationship is defined to include any kind of
romantic relationship, including casual dating, or relatives working together.

EMPLOYMENT OF RELATIVES

WFS’s policy is to avoid hiring relatives of employees or those in close personal

relationships with employees where one of the relatives would supervise the other, or
where there are bona fide business reasons not to hire the relative. The purpose of
this policy is to prevent conflicts of interest that may occur in those situations.

If relationships develop during the course of employment, neither employee should be

in a position to participate in making recommendations or decisions specifically
affecting the appointment, retention, work assignments, promotions, demotion,
salary, or working conditions of the other. In the event a conflict of interest is
determined, an attempt will be made to relocate one of the employees within the
organization. If that cannot be arranged, the employees will be asked to choose which
of them should leave WFS employment. That employee will have three (3) months to
find other employment. Exceptions to this Employment of Relatives policy must be
reviewed and approved by the CEO.

BOARD OF DIRECTORS AND OFFICER FAMILY RELATIONSHIP

In conforming with WFS’s employment policy to promote Native American candidates
and to have the best candidate for any vacant position, it is WFS’s intent when
appointing managers, executives and officers to select the best qualified candidates
and to consider candidates regardless of family relationships with other officers or the
Board of Directors. The Board of Directors sets policy and, in some instances, works
directly with the executive and officer employees of WFS and/or its affiliates. The
policy is established to address when family relationships exist between and among
board members and WFS’s officer and management level employees to ensure
prudent corporation governance and avoid conflicts of interest. This policy applies to
all Board members and elected officers. It also applies to non-officer executive or
management level employees, except that where such employees are not officers,
the requirement of an independent third-party recruiting firm may be waived,
provided the other requirements of this policy are met.

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• A relative of a member of the Board of Directors of WFS or any of its affiliates, or
an officer thereof, is allowed to be hired, appointed or transferred into a position
within WFS. The relative may serve in such position as long as there is no direct
and exclusive reporting relationship with the director and related officer or
manager.

• Recruitment and hire of relative for officer positions elected by the Board that have
direct reporting relationship to other WFS executives, the board and/or
committees of the board can be hired consistent with the policy of shareholder
employment and hiring the best qualified candidate. When considering hiring an
officer who is a relative to 1) another officer of 2) a board member where the new
hire could have a direct reporting relationship, management or the board shall
require that an independent executive recruiting firm be used to interview and
recommend the best qualified candidates(s) for those positions where nepotism or
the appearance of nepotism or conflict of interest may exist. Reporting
relationship is defined as a supervisory relationship or similar arrangement, where
one person reports to and accepts direction from another.

• The Board, in its role of corporate oversight and governance, will review the
relationship and take appropriate action such as reassignment, change in line of
authority, Board member abstention or other action to mitigate the effect of the
family relationship, if it deems such action is necessary. The Executive
Committee of the Board shall have oversight authority and shall be advised in
advance of any intended action to which this policy applies.

• No board member or officer shall take part in the deliberation upon or in the
determination of any matter that directly affects a relative. In the event that a
matter before the board directly affects such a relative, the board member or
officer shall withdraw or abstain from participation in the meeting during the
deliberation or determination of the matter. The meeting minutes shall reflect
the board member’s or officer’s withdrawal or abstention.