Companion Policy to NI 55-104 Insider Reporting Requirements and Exemptions
Part 7 Exemptions For Normal Course Issuer Bids and Publicly Disclosed Transactions
Section 7.2

General exemption for transactions that have been generally disclosed

Section 7.3 of the Instrument provides that the insider reporting requirement does not apply to an issuer in connection with a transaction, other than a normal course issuer bid, involving securities of its own issue if the existence and material terms of the transaction have been generally disclosed in a public filing made on SEDAR. Because of this exemption and the exemption for normal course issuer bids in section 7.1, a reporting issuer that is an insider of itself will not generally need to file insider reports under Part 3 or Part 4 provided the issuer complies with the alternative reporting requirement in section 7.2 of the Instrument.