This memorandum sets forth the Corporation’s policy on insider trading and trading blackouts in order to ensure the strict compliance by all insiders with the prohibition against insider trading.

All those with access to material confidential information are prohibited from using such information in trading in the Corporation’s securities until the information has been fully disclosed and a reasonable period of time has passed for the information to be disseminated. In general, the Corporation has stipulated that a minimum of two clear trading days be allowed after the release of all such disclosures, including after the release of financial statements as well as certain blackout periods noted below.

This prohibition applies not only to trading in the Corporation’s securities, but also to trading in other securities whose value may be affected by changes in the price of the Corporation’s securities.

If an employee becomes aware of undisclosed material information about another public Corporation, the employee may not trade in securities of that other Corporation. Insider trading is strictly regulated by the corporate and securities laws in Canada, as well as The Toronto Stock Exchange.

All directors, seniors officers and major shareholders (over 10%) of the Corporation are insiders and must file an initial report with the applicable securities commissions and with all other securities regulatory authorities in Canada upon acquiring any securities in the Corporation or upon becoming an insider (whichever last occurs) and to report all trades made in the securities of the Corporation within ten days of the day any trade is made. Trades include a change in nature of the ownership of the securities (e.g. a disposition to a company controlled by the insider or a determination that the securities are to be held in trust for another person). A “senior officer” is defined as: (a) a chair or vicechair of the board of directors, the president, a vicepresident, the secretary, the treasurer or the general manager of a company or any other individual who performs functions for an issuer similar to those normally performed by an individual occupying such office; and (b) each of the five highest paid employees of an issuer, including any individual referred to in clause (a). each person that is obligated to file a report is responsible for filing his or her own report. 2 Legal*2710998.1

Any person or company that is in a “special relationship” with the Corporation is prohibited from trading on the basis of undisclosed material information concerning the affairs of the Corporation. A person or company considered to be in a “special relationship” includes the following:

(a) insiders;

In order to ensure that perceptions of improper insider trading do not arise, insiders should not “speculate” in securities of the Corporation. For the purpose of this Policy, the word “speculate” means the purchase or sale of securities with the intention of reselling or buying back in a relatively short period of time in the expectation of a rise or fall in the market price of such

securities. Speculating in such securities for a short term profit is distinguished from purchasing and selling securities as part of a long term investment program. Insiders should not at any time sell securities of the Corporation short or buy or sell a call or put option in respect of securities of the Corporation or any of its affiliates.

Liability is imposed by the Securities Act

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The definition of “security” includes shares, options, subscriptions or other interests in or to a security and includes puts, calls, or other rights or obligations to purchase or sell securities, the market price of which varies materially with the market price of the securities of the Corporation.

4. Postannouncement