Code of Business Conduct and Conflict of Interest Policy

Freehold Royalty Trust and its controlled entities (Freehold or the Trust) are committed to the highest possible standards of openness, honesty and accountability. The business and affairs of Freehold will be conducted in strict observance of both the spirit and letter of the applicable laws of Canada and of each Province where the Trust conducts business. Where the situation is not governed by statute or explicit regulation or where the law is unclear or conflicting, the Trust's business and affairs will be conducted in accordance with the highest ethical standards of business conduct.

Whistleblower Policy

Freehold Royalty Trust (Freehold or the Trust) is committed to the highest possible standards of openness, honesty and accountability. In line with that commitment, we expect employees and others that we deal with who have serious concerns about any aspect of Freehold's work to come forward and voice those concerns.

Employees are usually the first to know when something is going seriously wrong. A culture of turning a blind eye to such problems means that the alarm is not sounded and those in charge do not get the chance to take action before real damage is done. This Policy aims to ensure that serious concerns are properly raised and addressed within Freehold, and it is a key tool in enabling the delivery of good governance practices.