If disclosure of material information is delayed, complete
confidentiality must be maintained. In the event that such
confidential information, or rumours respecting the same, is
divulged in any manner (other than in the necessary course
of business), the company is required to make an immediate
announcement on the matter. Market Surveillance must be
notified of the announcement in advance in the usual manner.
During the period before material information is disclosed,
market activity in the company’s securities should be closely
monitored. Any unusual market activity probably means that
news of the matter is being disclosed and that certain persons
are taking advantage of it. In such case, Market Surveillance
should be advised immediately, and a halt in trading will be
imposed until the company has made disclosure on the matter.
At any time when material information is being withheld from
the public, the company is under a duty to take precautions to
keep such information completely confidential. Such information
should not be disclosed to any officers or employees of the
company, or to the company’s advisors, except in the necessary
course of business. The directors, officers and employees of a
listed company should be reminded on a regular basis that
confidential information obtained in the course of their duties
must not be disclosed. It is contrary to law under the Ontario