Companion Policy to National Instrument 52-109 Certification of Disclosure in Issuers' Annual and Interim Filings
Part 15 Venture Issuer Basic Certificates
Section 15.3

Voluntary Disclosure Regarding DC&P and ICFR

If a venture issuer files Form 52-109FV1 or 52-109FV2, it is not required to discuss in its annual or interim MD&A the design or operating effectiveness of DC&P or ICFR. If a venture issuer files Form 52-109FV1 or 52-109FV2 and chooses to discuss in its annual or interim MD&A or other regulatory filings the design or operation of one or more components of its DC&P or ICFR, it should also consider disclosing in the same document that:

(a) the venture issuer is not required to certify the design and evaluation of the issuer’s DC&P and ICFR and has not completed such an evaluation; and

(b) inherent limitations on the ability of the certifying officers to design and implement on a cost effective basis DC&P and ICFR for the issuer may result in additional risks to the quality, reliability, transparency and timeliness of interim and annual filings and other reports provided under securities legislation. A selective discussion in a venture issuer’s MD&A about one or more components of a venture issuer’s DC&P or ICFR without these accompanying statements will not provide transparent disclosure of the state of the venture issuer’s DC&P or ICFR.