Policy Statement on Timely Disclosure

Material Information Defnition Material information is any information relating to the business and affairs of a company that results in or would reasonably be expected to result in a signifcant change in the market price or value of any of the company’s listed securities. Material information consists of both material facts and material changes relating to the business and affairs of a listed company. In addition to material information, trading on the Exchange is sometimes affected by the existence of rumours and speculation. Where this is the case, IIROC may require that an announcement be made by the company whether such rumours and speculation are factual or not. The policy of the Exchange with regard to rumours is set out more fully on page fve. The timely disclosure policy of the Exchange is designed to supplement the provisions of the OSA which requires disclosure of any “material change” as defned therein. A report must be fled with the Ontario Securities Commission concerning any “material change” as soon as practicable and in any event within ten days of the date on which the change occurs. The Exchange considers that “material information” is a broader term than “material change” since it encompasses material facts that may not entail a “material change” as defned in the OSA. It has long been the practice of most listed companies to disclose a broader range of information to the public pursuant to the Exchange’s timely disclosure policy than a strict interpretation of the OSA might require. Companies subject to securities legislation outside of Ontario should be aware of their disclosure obligations in other jurisdictions. It is the responsibility of each listed company to determine what information is material according to the above defnition in the context of the company’s own affairs. The materiality of information varies from one company to another according to the size of its profts, assets and capitalization, the nature of its operations and many other factors. An event that is “signifcant” or “major” in the context of a smaller company’s business and affairs is often not material to a large company. The company itself is in the best position to apply the defnition of material information to its own unique circumstances. The Exchange recognizes that decisions on disclosure require careful subjective judgments, and encourages listed companies to consult IIROC when in doubt as to whether disclosure should be made. 4