Policy Statement on Timely Disclosure

The Exchange also suggests that a company: ● circulate some basic do’s and don’ts about employee trading to all their staff; ● designate a contact person who is familiar with the disclosure rules and who can help employees determine whether or not they may trade in a given circumstance; ● set expiry dates for the exercise of stock options and other such compensation plans so that the expiry dates normally would fall after the release of fnancial statements; ● educate employees about any additional specifc trading restrictions that may apply to them (for example, Section 130 of the Canada Business Corporations Act generally prohibits insiders of CBCA companies from selling that company’s shares short, or from buying or selling put or call options on the shares. Insiders of companies which have to report under the U.S. Securities Exchange Act of 1934 may be subject to other restrictions, such as liability to account for short swing profts.); ● decide whether employees who are subject to more stringent trading restrictions, and who are not required by law to fle insider trading reports, should have to report details of their trading to the company; ● decide whether the company should review insider trading reports to make sure that employees have complied with company policy and disclosure rules. 22