Our company imposes a trading blackout as soon as material information becomes available to the insiders. For example, if we are drafting a news release based on material information, a trading blackout is imposed for insiders until the news is disseminated. There are times when the blackout has been in place for several weeks because several material releases were made or material information was being discussed that we felt should require a blackout. As soon as the news is released we lift the blackout. We communicate to our insiders regarding the blackout via e-mail primarily and advise people in the office personally. On occasion we have contacted people via telephone as well.

There will be four trading windows each year, one each fiscal quarter, during which Insiders who have not been exempted from the application of this Rule will be permitted to trade in securities. Each period for permissible trading will usually start on the third business day (Toronto time) after the release of company's financial quarterly or annual financial results and continue for 20 business days, unless the window is closed earlier or extended (see below). Insiders may not trade in securities even if they do not possess confidential material information unless (i) formal notification that a trading window is open has been given, or (ii) they have been exempted from the application of this Rule. Notification that a trading window is open or closed will be made by facsimile transmission or e-mail or both.

Under no circumstances are Insiders permitted to buy or sell securities if they have knowledge of confidential material information, regardless of whether a trading window is open.

Trustees of the Fund, members of the Board of Directors and all officers of the Company, as well as those employees listed in Schedule A, and such other employees that may be added thereto from time to time as determined by the Vice President, General Counsel and Secretary of the Company, can only trade in securities of the Fund or of the Company (including but not limited to purchase or sell units or trade options) during the period commencing after two full trading days following the release of the quarterly or annual results of the Fund and ending 10 business days before the end of every quarter.