Conflicts of Interest Policy

These practices have been created to enable TMX Group staff to manage conflicts of interest that may arise by virtue of the fact that TSX Inc. owns and operates both an information processor and equity marketplaces.

Confidentiality of Information

The IP will gain access to valuable information of a confidential nature proprietary to the data contributors. The term Confidential Information is defined in the TMX Information Processor Data Contributor Agreement (Agreement). The IP will use the Confidential Information solely for the purpose of its role as the IP. Confidential Information will not be disclosed except to those employees, officers, directors, agents and consultants of TSX Inc. or its affiliates who need to know the information for purposes of the IP's operations. These individuals will be bound by confidentiality obligations.

Notwithstanding the above paragraph, Confidential Information can be disclosed to the governance committee of the IP or to the Canadian Securities Administrators or any of its members in the event that the IP determines that the Confidential Information may impact the operations of the IP or the Consolidated Data Products (as defined in the Agreement).

The IP Confidentiality Procedures, attached as Exhibit A, must be followed by all TMX Group staff who are involved in IP operations and have access to Confidential Information.

Fair Treatment of Data Contributors and the IP

Data from Toronto Stock Exchange and TSX Venture Exchange will not receive preferential treatment over data received from other contributors. The IP systems have been designed to treat each contributor agnostically and without prejudice or preference. The IP shall not discriminate in favour of any particular contributor when collecting, processing, disseminating or publishing data. The IP management team will ensure that the needs of the IP will be advocated in a timely manner to any third-party provider.