As employees of a publicly traded corporation, Ezenet staff having access to material information must abide by the regulations of the Ontario Securities Commission and the Toronto Stock Exchange regarding the distribution of this information. The TSE’s policy is that all persons investing in securities listed on the Exchange have equal access to information that may affect their investment decisions: “At any time when material information is being withheld from the public, the issuer is under a duty to take precautions to keep such information completely confidential. Such information should not be disclosed to any of the issuer’s officers, employees or advisors except in the necessary course of business.” Employees must keep any material information they have acquired confidential.

Below are a few examples of material information that an issuer can only disclose to those employees, customers, consultants or other vendors who require the information to perform their functions for Ezenet.

• Financial result
• Firm evidence of significant changes in earnings prospects
• Development of new products and developments affecting the company’s resources, technology, products or market
• Entering into or loss of significant contracts
• Changes in ownership that may affect control of the company
• Significant changes in management
• Major corporate acquisitions or dispositions

An announcement to all employees can only be made at the same time in which a general press release is disseminated to the public.

If it is deemed that a consultant or other vendor requires access to material information to provide service to Ezenet, these individuals must sign a confidentiality agreement with Ezenet. A confidentiality clause should also be included in all customer contracts and agreements. Please contact either Gary Guthro or myself if you need a confidentiality agreement.

In addition, all employees with access to material information are prohibited from trading until all the information has been fully disclosed and a reasonable period of time has passed for the information to be disseminated. A reasonable period of time can be taken to be 24 hours after a general press release has been issued.

Insider Trading:

Insider reporting obligations apply to every person who is directly or indirectly the beneficial owner of more than 10 percent of any class of stock and any director or officer of the company.

Insiders are prohibited from trading securities of Ezenet 2 weeks prior and 24 hours after the release of the quarterly financial statements. Other events may trigger a blackout period. An insiders report must also be filed with various securities’ commissions after each trade. Insiders are therefore advised to notify either Gary Guthro or myself before trading in the company’s securities or exercising the company’s stock options.

It is unlawful for anyone to trade in the company's securities on the basis of insider information. This applies equally to those directly privy to the insider information (e.g., directors, officers, employees) and to anyone whom they "tip off" regarding such information before it is made public. Both the insider (whether or not he or she benefits personally) and the "tippee" may be subject to liability for damages to everyone who traded in the security during the period of such illegal insider trading.

To learn more about TSE regulations, click here.