Policy Statement on Timely Disclosure

Listed companies must comply with the provisions of Section 75 of the OSA requiring confdential disclosure to the Ontario Securities Commission of any “material change” that is not immediately being disclosed to the public. Insider Trading Law Every listed company should have a frm rule prohibiting those who have access to confdential information from making use of such information in trading in the company’s securities before the information has been fully disclosed to the public and a reasonable period of time for dissemination of the information has passed. Insider trading is strictly regulated by Part XXI and Sections 76 and 134 of the OSA and the Regulation under the OSA. The securities laws of other provinces also regulate insider trading in their respective jurisdictions. Insider trading in the securities of companies incorporated under the Canada Business Corporations Act is also regulated by Part XI of that Act. The defnition of an “insider” will vary from statute to statute, but in any case will include directors and senior ofcers of the company and large shareholders. In Ontario, directors and senior ofcers of any company that is itself an insider of a second company are considered insiders of that second company. It is recommended that directors and ofcers of listed companies be fully conversant with all applicable legislation concerning insider trading. The OSA requires insiders who own securities of a listed company to fle an initial report with the OSC upon becoming insiders and to report all trades made in the securities of the company of which they are insiders within ten days after a trade is made. In addition, Section 76 of the OSA prohibits any person or company in a “special relationship” with a listed company from trading on the basis of undisclosed material information on the affairs of that company. Those considered to be in a “special relationship” with a listed company include those who are insiders, afliates or associates of the listed company, a person or company proposing to make a take-over bid of the listed company, and a person or company proposing to become a party to a reorganization, amalgamation, merger or similar business arrangement with the listed company. A person or company in a “special relationship” also includes those involved, or which were involved, in the provision of business or professional services for the listed company, including employees. An indefnite chain of “tippees” is created by including in the “special relationship” category persons or 14