Electronic Communications Disclosure Guidelines

6 B) ALL SUPPLEMENTAL INFORMATION PROVIDED TO ANALYSTS AND OTHER MARKET OBSERVERS BUT NOT OTHERWISE DISTRIBUTED PUBLICLY TSX recommends that an issuer that distributes non-material investor relations information to analysts and institutional clients make such supplemental information available to all investors. Supplemental information includes such materials as fact sheets, fact books, slides of investor presentations and transcripts of management investor relations speeches and other materials distributed at investor presentations. Posting supplemental information on a web site is a very useful means of making it generally available. Keeping in mind that an issuer should design its web site to meet its business needs, TSX recommends that an issuer post all supplemental information on its web site, unless the volume or format makes it impractical. If this is the case, the issuer should describe the information on the web site and provide a contact for the information so that an investor may contact the issuer directly either to obtain a copy of the information or to view the information at the issuer’s offices. In addition to any supplemental information provided by the issuer to analysts, TSX recommends that whenever an issuer is making a planned disclosure of material corporate information in compliance with TSX Timely Disclosure Policy and related guidelines, it should also consider providing dial-in and/or web replay or make transcripts of the related conference call available for a reasonable period of time after the call. C) INVESTOR RELATIONS CONTACT INFORMATION TSX suggests that an issuer provide an e-mail link on its web site for investors to communicate directly with an investor relations representative of the issuer. The issuer policy should specify who may respond to investor inquiries and should provide guidance as to the type of information that may be transmitted electronically. When distributing information electronically the issuer must adhere to TSX and legislative disclosure requirements in order to minimize the potential of selective disclosure of information. To assure rapid distribution of material information to Internet users who follow the issuer, an issuer may consider establishing an e-mail distribution list, permitting users who access its web site to subscribe to receive electronic delivery of news directly from the issuer. Alternatively, an issuer may consider using software that notifies subscribers automatically when the issuer’s web site is updated. The issuer must note, however, that any electronic distribution of material information must be made after the information has been disseminated on a news wire service. D) ONLINE CONFERENCES TSX recommends that issuers hold analyst conference calls and industry conferences in a manner that enables any interested party to listen either by telephone and/ or through a web cast, in accordance with s. 6.7(1) of National Policy 51-201 Disclosure Standards . If an issuer chooses to participate in an online news or investor conference, TSX suggests that participation by the issuer in such online conferences should be governed by the same policy that the issuer has established in respect of its participation in other conferences such as analyst conference calls. 3. WHAT SHOULD NOT BE DISTRIBUTED VIA ELECTRONIC COMMUNICATIONS A) EMPLOYEE MISUSE OF ELECTRONIC COMMUNICATIONS Access to e-mail and the Internet can be valuable tools for employees to perform their jobs, however, TSX recommends that clear guidelines should be established as to how employees may use these media. These guidelines should be incorporated into the issuer’s disclosure, confidentiality and employee trading policy. Employees should be reminded that their corporate e-mail address is an issuer address and that all correspondence received and sent via e-mail is to be considered corporate correspondence. Appropriate guidelines should be established about the type of information that may be circulated by e-mail. An issuer should prohibit its employees from participating in Internet chat rooms  2 , newsgroups  3A or social media  3B in discussions relating to the issuer or its securities. As stated in s. 6.13 of National Policy 51-201 Disclosure Standards , an issuer should also consider requiring employees to report to a designated issuer official any discussion pertaining to the issuer which they find on the Internet. Moreover, communications over the Internet via e-mail may not be secure unless the issuer has appropriate encryption technology. Employees should be warned of the danger of transmitting confidential information externally via unencrypted e-mail. 2 A chat room is a live electronic forum for discussion among Internet participants. 3A A newsgroup is an electronic bulletin board on which Internet participants may post information. 3B Social media includes electronic communication through which users create or participate in online communities to share information, ideas and other content, or to participate in social networking.