Companion Policy to NI 55-104 Insider Reporting Requirements and Exemptions
Part 5 Automatic Securities Purchase Plans
Section 5.4

Exemption from the Alternative Reporting Requirement

The rationale underlying the alternative reporting requirement is the need for reporting insiders to periodically update their publicly disclosed holdings to ensure that their publicly disclosed holdings convey an accurate picture of their holdings. If an individual has ceased to be subject to the insider reporting requirements at the time the alternative report becomes due, the market generally would not benefit from the information in the alternative report. Accordingly, we provided an exemption in subsection 5.4(3) of the Instrument in these circumstances.