Corporate Policies

Corporate Disclosure Policy

The Disclosure Policy confirms in writing the existing disclosure policies and practices of the Company. The goal of the policy is to promote appropriate and consistent disclosure practices aimed at accurate, informative, timely and broadly disseminated disclosure of material information to the market and to promote compliance among the directors, officers, employees and consultants of the Company.

The policy covers written disclosure in documents filed with the securities commissions and stock exchanges, written statements made in the Company’s annual and quarterly reports, news releases, letters to shareholders and other documents released to the public, the content of which would reasonably be expected to affect the market price or value of the Company’s securities, or a reasonable investor’s investment decision, including information contained on the Company’s website and other electronic communications. The policy also extends to public oral statements made in meetings and telephone conversations with analysts and investors, interviews with the media, press conferences, conference calls and in other circumstances in which it is reasonable to expect that the information will become generally disclosed.

Corporate Disclosure Policy

Code of Business Conduct

The Code of Business Conduct applies to all directors, officers, employees and consultants of the Company. The Board of Directors is responsible for monitoring compliance with the Code of Business Conduct and for approving waivers of such standards by any director or officer. Waivers in respect of employees or consultants may be given by the President and Chief Executive Officer who must report any such waiver to the Board.

The Code of Business Conduct addresses such matters as conflicts of interest, confidential information, and the protection and proper use of the Company’s assets. All directors, officers, employees and consultants are encouraged to report violations of the Code of Business Conduct in accordance with the procedures described in the Company’s whistleblower policy.

Code of Business Conduct Policy

Whistleblower Policy

The purpose of the Whistleblower Policy is to maintain a workplace where concerns regarding questionable business practices can be raised without fear of any discrimination, retaliation or harassment. The Whistleblower Policy encourages all directors, officers, employees and consultants to promptly report either orally or in writing any activity that may constitute questionable accounting or auditing practices; inadequate internal accounting controls; misleading or coercion of auditors; disclosure of fraudulent or misleading financial information; instances of corporate fraud; a material misrepresentation in any written or oral disclosure made by or on behalf of the Company; breaches of the Company’s policy on trading in securities; and other activities which may violate the Company’s Code of Business Conduct.

The Whistleblower Policy outlines several means by which concerns may be reported, including communication with an immediate supervisor, an officer or director of the Company, or contact with the Chairman of the Audit Committee. Contact by mail, telephone, fax or email is encouraged. All reports made to supervisors and senior officers in respect of matters specifically covered by the Whistleblower Policy are reported to the Audit Committee of the Board of Directors.

Policy on Trading in Securities by Directors, Officers, Employees and Consultants

The purpose of the Policy on Trading in Securities by Directors, Officers, Employees and Consultants is to ensure compliance with provincial securities laws governing trading while in possession of material non-public information concerning the Company. The Policy also prohibits tipping or disclosing material non-public information to outsiders.

The scope of the Policy is defined to include family and household members; shares directly or indirectly owned; and shares over which control or direction is exercised. The Policy defines "material non-public information", outlines prohibited activities, and provides information regarding blackout periods and reporting requirements for insiders. The Policy outlines some of the penalties of prohibited trading and/or tipping under securities laws, as well as the potential disciplinary actions by the Company.

Trading Policy