Real Estate "Keystone of Wealth"

It is important that the Company respect all international and local anti-bribery and anti-corruption laws, even where the perception is such that standards are loosely enforced by local authorities. Corrupt acts could expose the Company and its directors, officers and employees to the risk of prosecution, fines and imprisonment in Canada and in other countries where the Company does business. In addition, non-compliance threatens the Company's reputation, which plays a critical role in our success as a business. 

IThis Policy applies to the worldwide conduct of all directors, officers and employees of the Company, wherever situated (collectively the "Employees"). This Policy also reflects the standard to which the Company expects Covered Third Parties, meaning all of the Company's partners, agents, consultants and other contractual counterparties, wherever situated, who interact with public officials on the Company's behalf, to adhere when acting on the Company's behalf. This Policy applies to Covered Third Parties. In addition to any other obligation, Covered Third Parties have all of the obligations set out in this Policy that apply to Employees.   

Employees and Covered Third Parties must report, in person or in writing, any known or suspected violations of laws, governmental regulations, the Code of Business Conduct or this Policy to the Chair of the Audit Committee. Any questions or violation reports will be addressed immediately and seriously, and can be made anonymously. If you feel uncomfortable reporting suspected violations to this individual, you may report matters to the Company's legal counsel, DuMoulin Black LLP. The addresses and telephone numbers of these reporting contacts are listed in Schedule "A" to this Policy.