Polydex Pharmaceuticals Limited
Shareholder Services / Investor Information

POLYDEX PHARMACEUTICALS LTD. will investigate any possible fraudulent or dishonest use or misuse of POLYDEX PHARMACEUTICALS LTD. resources or property by management, staff, volunteers, or members. 

Anyone found to have engaged in a fraudulent or dishonest conduct is subject to disciplinary action by POLYDEX PHARMACEUTICALS LTD. up to and including civil or criminal prosecution when warranted.
All members of the POLYDEX PHARMACEUTICALS LTD. community are encouraged to report possible fraudulent or dishonest conduct (i.e., a whistleblower). An employee should report his or her concerns to a supervisor or manager. If for any reason an employee finds it difficult to report his or her concern to a manager or supervisor, the employee can report it directly to the Director and Chairman, Audit Committee, Derek Lederer at dlederer@istar.ca.
Managers or supervisors are required to report suspected fraudulent or dishonest conduct to the Director and Chairman, Audit Committee, Derek Lederer at dlederer@istar.ca.
For more information about definitions, rights and responsibilities, procedures, and contacts read the following.
Definitions
Baseless Allegations: allegations made with reckless disregard for their truth or falsity. People making such allegations may be subject to institutional disciplinary action and /or legal claims by individuals accused of such conduct. Fraudulent or Dishonest Conduct: a deliberate act or failure to act with the intention of obtaining an unauthorized benefit. Examples of such conduct include, but are not limited to:

• forgery or alteration of documents
• unauthorized alteration or manipulation of computer files
• fraudulent financial reporting
• pursuit of a benefit or advantage in violation of the
  POLYDEX PHARMACEUTICALS LTD ’s conflict of interest policy
• misappropriation or misuse of POLYDEX PHARMACEUTICALS LTD. resources, such as funds, supplies, or other assets
• authorizing or receiving compensation for goods not received or services not performed
• authorizing or receiving compensation for hours not worked

• baseless allegations
• premature notice to persons suspected of misconduct and/or disclosure of suspected misconduct to others not involved with the investigation
• violations of a person's rights under law

• Should not contact the person suspected to further investigate the matter or demand restitution
• should not discuss the case with anyone other than the Director and Chairman, Audit Committee, the Office of General Counsel, or a duly authorized law enforcement officer
• should direct all inquiries from any attorney retained by the suspected individual to the General Counsel
• should direct all inquiries from the media to POLYDEX PHARMACEUTICALS LTD ’s Public Relations Office, or in the event that Public Relations cannot be contacted, to the Office of General Counsel.

• POLYDEX PHARMACEUTICALS LTD will use best efforts to protect whistleblowers against retaliation, as described below. It cannot guarantee confidentiality, however, and there is no such thing as an "unofficial" or "off the record" report. POLYDEX PHARMACEUTICALS LTD will keep the whistleblower's identity confidential, unless (1) the person agrees to be identified; (2) identification is necessary to allow POLYDEX PHARMACEUTICALS LTD or law enforcement officials to investigate or respond effectively to the report; (3) identification is required by law; or (4) the person accused of Fraud Policy violations is entitled to the information as a matter of legal right in disciplinary proceedings.
• POLYDEX PHARMACEUTICALS LTD employees may not retaliate against a whistleblower with the intent or effect of adversely affecting the terms or conditions of employment (including but not limited to, threats of physical harm, loss of job, punitive work assignments, or impact on salary or wages). Whistleblowers who believe that they have been retaliated against may file a written complaint with the Director and Chairman, Audit Committee. A proven complaint of retaliation shall result in a proper remedy for the person harmed and the initiation of disciplinary action, up to and including dismissal, against the retaliating person. This protection from retaliation is not intended to prohibit managers or supervisors from taking action, including disciplinary action, in the usual scope of their duties and based on valid performance-related factors.
• Whistleblowers must be cautious to avoid baseless allegations (as described earlier in the definitions section of this policy).

Contacts:

Questions related to the interpretation of this policy should be directed to: Director and Chairman, Audit Committee, Derek Lederer at (dlederer@istar.ca)

Effective Date
Original: April 23, 2008