"Does your company a) generally impose a trading blackout only near each quarter end and if so for how long is the trading black out in effect, or b) restrict all trading by insiders and only lift the trading restriction for certain periods during the year. In addition, how is the commencement and termination of a blackout period communicated to the outside directors"

Generally companies impose a trading blackout near the end of the quarter and lift it after 2 clear days following the earnings release. This is generally set out in the Company's insider trading policy which is disseminated to all employees when approved. An annual reminder notice can also be sent by email. I also set out the blackout periods in the schedule of meeting dates provided to directors

Trading “blackout periods” during which trading in securities of the Company is prohibited will apply to those officers, directors and employees and other insiders or persons in a special relationship with the Company, who have access to material undisclosed information during periods when financial statements are being prepared but the results of which have not yet been publicly disclosed and disseminated. The trading blackout period may, accordingly, vary from individual to individual. However, for all directors, senior officers and employees with access to drafts of financial statements before those statements are finalized, publicly disclosed and disseminated, the minimum blackout period commences on the 1st day following the end of a fiscal quarter or the 1st day following the end of a fiscal year, as the case may be, and ends at the close of business on the second trading day following the release of the financial statements publicly or of a news release disclosing the material financial results or an estimate thereof.

Other blackout periods may also be prescribed from time to time by the Committee as a result of special circumstances relating to the Company pursuant to which directors of the Company and those officers and employees with access to material undisclosed information would be precluded from trading in securities of the Company. All persons with knowledge of such special circumstances will be covered by the blackout. Such persons may include external advisors such as legal counsel, investment bankers and counter-parties in negotiations of material potential transactions.

The Corporate Secretary reminds insiders by e-mail and/or telephone of an upcoming blackout period.

My clients do not have restrictions quarterly. The Blackout periods are depending on news coming out or material activities. The restriction is put on all officers, directors and employees of the company. Notification is sent by myself (corporate secretary) which states the date of the blackout commencing and ending. It is usually 24 hours prior to the news until 4 hrs. after the news has hit the public.

Our trading blackout commences 5 days after quarter end and continues until two full trading days post release of the financials.

The blackout involves all directors and employees and an email is sent from me announcing the blackout period a couple of days prior to blackout and a reminder is sent once the release has been issued stating they will be free to trade on XXXXX. The blackout includes both the exercise and granting of stock options.