Whistleblower Policy

The purpose of this policy is to establish procedures for (a) the receipt, retention and treatment of complaints received by the Company regarding financial statement disclosure issues, accounting, internal accounting controls, auditing matters or violations of the Company's Code of Business Conduct and Ethics; and (b) the submission by employees, officers and directors of the Company, on a confidential and anonymous basis, of concerns regarding questionable financial statement disclosure, accounting, auditing matters or violations to the Company's Code of Business Conduct and Ethics.

The purpose of this Policy is also to state clearly and unequivocally that the Company prohibits discrimination, harassment and/or retaliation against any employee, officer or director who:

• reports complaints regarding financial statement disclosure issues, accounting, internal accounting controls, auditing matters or
• violations of the Company's Code of Business Conduct and Ethics; or
• provides information or otherwise assists in an investigation or proceeding regarding any conduct which he or she reasonably believes to be a violation of employment or labour laws; securities laws (including the rules and regulations of the Ontario Securities Commission, the securities regulatory authorities in the other provinces and territories of Canada and the TSX Venture Exchange), laws regarding fraud or the commission or possible commission of a criminal offence.

Everyone at the Company is responsible for ensuring that the workplace is free from all forms of discrimination, harassment and retaliation prohibited by this policy. No employee, officer or director of the Company has the authority to engage in any conduct prohibited by this policy.

Any questions or communication regarding this policy should be addressed to the Company's counsel at 220 Bay Street, Suite 700, Toronto, Ontario, M5J 2W4.