Policy Statement on Timely Disclosure

companies who acquire information from a source known to them to have a “special relationship” with the listed company. In any situation where material information is being kept confdential because disclosure would be unduly detrimental to the best interests of the company, management is under a duty to take every possible precaution to ensure that no trading whatsoever takes place by any insiders or persons in a “special relationship” with the company, such as lawyers, engineers and accountants, in which use is made of such information before it is generally disclosed to the public. Similarly, undisclosed material information cannot be passed on or “tipped” to others who may beneft by trading on the information. In the event that IIROC is of the opinion that insider or improper trading may have occurred before material information has been disclosed and disseminated, the Exchange requires an immediate announcement to be made disclosing the material information of which use is being made. 15