Nevsun Resources Ltd. (the ‘Company’) has adopted certain policies, including its Operating Business Principles and Code of Ethics (“Principles and Ethics”), which require the observation of high standards of business and personal ethics in the conduct of all employees and management of the Company, its subsidiaries and affiliates.  In addition, regulators in Canada and the US. have established or proposed rules requiring the audit committees of public companies to develop procedures for a confidential and/or anonymous complaint procedure for employees who have concerns about questionable accounting, internal controls or auditing matters. To meet these needs, the Company’s audit committee has developed this Whistleblowing Policy.

Reporting Responsibility

It is the responsibility of all directors, officers and employees to comply with the Company’s Operating Business Principles and to report violations or suspected violations, including those relating to accounting, internal controls or auditing matters, in accordance with this Whistleblower Policy.

No Retaliation

No director, officer or employee who in good faith reports a violation of such nature shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistlblower Policy is intended to encourage and enable employees and others to raise serious concerns within the Corporation rather than seeking resolution outside the Corporation.

Acting in Good Faith

Anyone filing a complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of Operating Business Principles, including accounting matters. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

 
Handling of Reported Violations

A hotline service which is unrelated to the Company has been contracted to handle any complaint on a confidential and anonymous basis, details of which are outlined in Schedule A: Reporting Violations.  The Audit Committee of the board of directors shall address all reported concerns or complaints, including those regarding corporate accounting practices, internal controls or auditing. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

SCHEDULE A

Reporting Violations

Any employee or other person with a concern or complaint regarding a violation of the Company’s Operating Business Principles or Code of Ethics may submit their concern or complaint by either of the following methods:

1.   By telephone or email on a confidential and anonymous basis through WhistleBlowerSecurity, a hotline service which is unrelated to the Company and reports directly to the Chair of the Audit Committee

VoiceMail

Call 1-866-921-6714 to talk to an experienced professional or leave a message.

Email

Messages may be sent to: nevsun@whistleblowersecurity.com

The Whistleblower service will maintain your anonymity if you so request.  However, use of a non-identifiable or third party email address may also be used to maintain anonymity.

2.   In writing to the Chair of the Audit Committee of the board of directors as follows:

Mr. Robert Gayton, Confidential
Chair, Audit Committee
Nevsun Resources Ltd.
800-1075 West Georgia Street
Vancouver, BC V6E 3C9