Material Disclosure

Pender Financial Group Corporation intends to disclose its acquisition, disposition and holdings of securities in investee companies in accordance with the following principles:

• Pender will disclose the acquisition of securities of a value of $200,000 or more at the time that it acquires such securities;
• Pender will not disclose the partial sale of securities made from time to time unless such disposition is considered by management to be material to Pender. It will disclose when the sale of the security position has been concluded if the acquisition was disclosed at the time of acquisition;
• Pender will set out in its quarterly report a list of the securities held at the end of such quarter together with an internal calculation of the net asset value.
• Pender will also disclose other material facts and changes in accordance with the general requirements of the law.

Data Protection

Pender Financial Group Corportion ("Pender") respects your privacy and values its relationship with you.

Your personal information will be protected, will never be sold and will be used only by Pender Capital Management, Pender Financial Group Corporation and the affiliates, business partners and investee companies of both organizations in order to:

• provide you with general marketing, product, service and business partner information and offers;
• conduct market and sales analysis;
• maintain the accuracy of our records to communicate and respond to your inquiries, and otherwise manage its relationship with you; and
• satisfy other reasonable, legitimate business interests

Pender does not intend to share your information. Pender will not collect, use or disclose your personal information for any other purpose than those disclosed above.

Pender is committed to protecting your personal information in full compliance with this Privacy Policy and applicable laws. Pender understands your concerns about online security and about the security of your information and we take reasonable precautions to prevent the loss, misuse or alteration of information under Pender's control.

Opting out

If you do not want to be contacted, or if you would like to be removed from any direct marketing initiatives, corporate surveys, telemarketing or direct mail or e-mail lists, or if you would otherwise like to limit Pender's use or disclosure of your personal information, please "unsubscribe" by clicking here.

Except as required or permitted by applicable law, Pender will respect your wishes relating to the use of your personal information and Pender will ensure that your file reflects the limitations that you have requested.

Correcting Errors

You can correct errors in your personally identifiable information by contacting the Webmaster at webmaster@penderfund.com. Note: you may be asked for your name, address and additional contact information.

Links to Outside Sites

Pender's website, http://www.penderfinancial.com, does contain links to sites outside of and not controlled by Pender. Pender is not responsible for these sites, their omissions or for the policies or content of their websites. Pender recommends that you read the privacy policies of these sites before making a decision to provide your personal information to the site operators.

While Pender uses reasonable efforts to ensure that the information we hold about you is accurate, complete and current, we rely in part on you to inform us about changes to your contact or other relevant information.