In order to provide comfort to our clients with respect to the personal information that KBSH Capital Management Inc. (“KBSH”) is either required to gather or which accumulates in the course of doing business with a client, KBSH has implemented the following policy with respect to the collection and disclosure of its clients personal and non-public information.

Collection of Information

Collection of information is based on the Know Your Client (“KYC”) rules mandated by the CFA Institute and Provincial regulators. In complying with the KYC rules KBSH collects the following information from its clients, which provides not only client contact information, but also allows KBSH to consider the appropriateness and suitability of investment recommendations or actions for each client:

1. Information including but not limited to, client’s full legal name, social insurance/security number, date of birth, citizenship, home address and phone number, type of business client is employed in, employers name, business address, business phone and fax number, position held, name of lawyer/accountant, approximate net worth of client, investment experience, investment objectives, income needs, risk attitude, consultant information, and various information about a client’s spouse and immediate family; and
    
2. Information obtained through client’s transactions with KBSH, its affiliates, or others, including but not limited to, account balances, transaction reports, and parties to transactions.

A client profile is also prepared which primarily summarizes the client’s investment guidelines, their investment knowledge and their investment return expectations.

A designated administrator enters information collected by KBSH from its clients into a limited access database. Access to such information for those employees who require it in order to provide products or services to the client is the responsibility of the President, or the Vice-President, regarding private client or managed account clients, respectively.

Disclosure of Information

No confidential or non-public information will be disclosed to any external parties without either the client’s consent, or unless such information is required, by legal process, statutory authority or in the normal course of providing KBSH services and products to the client.

Privacy on the Internet

KBSH has taken the following measures in order to protect the privacy of all individuals who visit our website:

1. KBSH does not sell, share or exchange personal information of clients with any other organization over the internet;
    
2. KBSH does not require personal information from you prior to accessing our website;
    
3. KBSH requires that clients identify themselves via password on the Client Access Login section before being granted internet access to their accounts;
    
4. KBSH protects all client account and login information behind highly secure firewalls;
    
5. KBSH sends and receives your account information in “encrypted” form to ensure maximum security.

Application of Privacy Policy

KBSH applies its Privacy Policy as follows:

1. The KBSH Privacy Policy applies to personal information about clients and employees, which is collected, used, or disclosed by KBSH.
    
2. The KBSH Privacy Policy applies to personal information in oral, written or electronic form.
    
3. The application of the KBSH Privacy Policy is pursuant to Part 1 of The Personal Information Protection and Electronic Documents Act and regulations thereof.

A client may withdraw their consent for the use of all or any part of personal information collected by KBSH at any time, subject to legal or contractual restrictions and reasonable notice. The client should be aware that once consent is withdrawn KBSH might not be able to provide the client with the services and/or products chosen by them.

KBSH has appointed a Privacy Officer to oversee all aspects of this policy and the handling of any client or employee complaints. The Privacy Officer will deliver a report to the Management Committee of the company annually, or more frequently as needed, with respect to all privacy issues that have arisen.

Questions or concerns regarding this policy or the non-compliance of same should be directed to the Privacy Officer at:

KBSH Capital Management Inc.
One Toronto Street, Suite 700
Toronto, ON M5C 2V6

Oct 2006