As a member of the Canadian Investor Relations Institute, I will:

1. Practice investor relations within the highest legal, regulatory and ethical standards.
2. Exercise independent professional judgment in the conduct of my duties and responsibilities.
3. Attempt to avoid even the appearance of professional impropriety in the conduct of my investor relations responsibilities.
4. Keep up to date regarding the affairs of my company/clients, as well as the laws, regulations and principles affecting the practice of investor relations.
5. Maintain the confidentiality of information acquired in the normal course of business.
6. Not use confidential information acquired in the normal course of business for my personal advantage, nor for the advantage of others, except in the legitimate performance of my duties on behalf of my company/clients.
7. Report to company authorities, the board of directors, or appropriate securities regulators, if I suspect or recognize fraudulent or illegal acts.
8. Recognize that the integrity and credibility of the capital markets is based on complete, timely and non-selective disclosure of financial and non-financial corporate information and, to the best of my ability and knowledge, work to ensure that my company or client communicates such information on a timely basis.

Enforcement and Communication of CIRI'S Code of Ethics

CIRI urges compliance with its code of ethics through broad dissemination of this document and others that enhance the understanding of investor relations. CIRI members who are sanctioned by regulatory or judicial bodies for violating laws or regulations in conjunction with their IR responsibilities may, upon recommendation of the CIRI Membership Committee, have their memberships terminated by the CIRI Board of Directors, in keeping with the provisions of CIRI's Bylaw.

CIRI Bylaw 5.6 states: "The Board shall have the power to suspend or withdraw the membership of a Member or take any other disciplinary action with regard to a Member, provided that such action must be approved by at least 67 percent of the Directors entitled to vote. The Board may establish conditions precedent or subsequent to reinstatement of the membership of any person or Member."

Approved by CIRI Board of Directors - July 2003