Howard Barclay & Associates Limited ("HBA") is dedicated to protecting your privacy and the confidentiality of your personal information. This Privacy Policy tells you the ways in which HBA ensures that your privacy and the confidentiality of your personal information are protected.

HBA will obtain your consent to collect, use or disclose personal information. You have the right to access personal information held by HBA. Your personal information can only be used for the purposes for which it is collected. HBA will also protect your personal information by appropriate safeguards.

HBA collects and uses personal information to serve you. The type of information depends on the investment services we provide to you. HBA also collects information as part of our legal requirements, including “know your client” requirements. HBA may use information to offer you additional related services. Personal information may include your address and telephone number, social insurance number, birth date, account holdings, credit and other financially related information and similar information on your spouse and beneficiary. Depending on the investment or service we provide to you, additional personal information may be included in your client record, for example, your financial institution account information and contact information of your professional advisers or financial consultants.

Our Privacy Principles

As part of our privacy policy and in accordance with the federal Personal Information Protection and Electronic Documents Act (Canada), HBA has adopted the following ten principles:

1. Accountability: HBA is responsible for maintaining and protecting the personal information we collect about you.

2. Identifying Purposes: HBA will identify the purposes for which information is collected before or at the time the information is collected.

3. Consent: HBA will obtain your consent to collect and hold your personal information. HBA may rely on your actions as indications of your consent to our existing and future information practices including information given through your authorized representatives. Subject to certain legal restrictions and reasonable notice, you may withdraw your consent at any time. If you wish to withdraw your consent or discuss the implications of such withdrawal, please contact us.

4. Limiting Collection: HBA will limit the collection of personal information to what is necessary for the purposes identified. HBA may collect information from third parties such as your custodian, adviser or dealer.

5. Limiting Use, Disclosure and Retention: HBA will use and disclose information only for the purposes identified, except with the consent of the individual or as required or permitted by law. There are times when we may disclose information to an agent, service provider or other organization. This information will be used only for the identified purposes and HBA will ensure by contractual means that such information is used only for the purposes required. Personal information is retained for only as long as necessary.

6. Accuracy: HBA will use reasonable efforts to ensure your personal information is accurate, complete and up-to-date.

7. Safeguards: HBA will protect your personal information with appropriate safeguards and security measures in a manner appropriate to the sensitivity of the information.

8. Openness: HBA will make readily available to our clients, specific information about our policies and practices relating to the management of personal information.

9. Access: You are entitled to access your personal information. Through a written request, HBA will inform you of the existence, use and disclosure of your information and provide access to that information. You are entitled to challenge the accuracy and completeness of the information and have it amended, as appropriate. HBA may not be able to provide you with full access to your information if it contains references to other persons, it would reveal information commercially confidential to HBA, it is protected by solicitor/client privilege, or it cannot be disclosed for legal reasons.

10. Compliance: HBA will ensure that an individual will be able to address concerns regarding your information and our adherence to these principles.

If you have any questions about our privacy policy please feel free to contact us:

Howard Barclay & Associates Ltd.
277 Lakeshore Road East, Suite 302
Oakville, Ontario L6J 1H9
Telephone: 905-337-2401
Fax: 905-337-2186

March 2006