Whistleblower

WHISTLEBLOWER POLICY AND PROCEDURES 1. Purpose. • The purpose of this policy is to encourage all Associates of West Marine, Inc. (the “Company”) to disclose any wrongdoing that may adversely impact our Company, our Customers, Stockholders, Associates, and/ or the public at large. This policy also details an investigative process of reported acts of wrongdoing and/or retaliation received from our Associates or from other interested third parties. • The Company’s internal controls and reporting and disclosure procedures are intended to prevent, deter and remedy any violation of the applicable laws and regulations that relate to financial reporting and disclosure, accounting and auditing controls and procedures, securities compliance and other matters pertaining to fraud against Stockholders. Even the best systems of controls and procedures, however, cannot provide absolute safeguards against such violations. • The Company has a responsibility to investigate and report to our Board of Directors (“Board”), any appropriate standing committee of the Board, and/or any appropriate governmental authorities, as required, any violations of applicable legal and regulatory requirements relating to corporate reporting and disclosure, accounting and auditing controls and procedures, securities compliance and other matters pertaining to fraud against Stockholders, and the actions taken by the Company to remedy such violations. • This policy governs the process through which we, as Associates, and others acting on behalf of the Company, either directly or anonymously, can notify Company representatives, outside agencies (such as the Securities and Exchange Commission [“SEC”]) and/or our Board’s Audit Committee of potential violations or concerns. • This policy complies with the Sarbanes-Oxley Act of 2002 - Section 301.4 concerning procedures for the receipt, retention, and treatment of complaints received by the Company regarding accounting, internal accounting controls, or...