As of January 1, 2004 the federal government's Personal Information Protection and Electronic Document Act (PIPEDA), a new privacy law, applied to T olstoy R esources ' operations as an executive search and recruitment consulting firm. In addition, the provinces of Quebec , British Columbia and Alberta have enacted or intend to enact a private sector privacy law. These acts regulate the collection, use and handling of personal information about an individual (PII) regardless of how the information exists.

Organizations covered by the Act must obtain an individual's consent when they collect, use or disclose the individual's personal information. The individual has a right to access personal information held by an organization and to challenge its accuracy, if need be. Personal information can only be used for the purpose for which it was collected. If an organization is going to use it for another purpose, consent must be obtained again. Individuals should also be assured that specific safeguards will protect their information, including measures such as locked cabinets, computer passwords and encryption.

This policy explains how Tolstoy Resources protects your privacy and summarizes how and why we collect, use and disclose personal information that you may provide to us.

Under the law, personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

• Age, ID numbers, income, ethnic origin, or blood type
• Opinions, evaluations, comments, social status or disciplinary actions
• Employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions, (for example, to acquire goods or services), or job changes.

The following is not considered personal information:

• the name, title, company name, business address, office telephone/fax telephone numbers or email addresses of an employee of an organization, or
• the name, address, telephone number or similar information of a person that is publicly available (e.g. public telephone directories, association or membership lists, company directories, newspapers and other media that is public domain).

In this policy we also explain how you can contact us if you have a question about, or want to make a change to or delete any personal information that Tolstoy Resources may be holding about you. We strongly recommend that you take the time to read this privacy policy and retain it for future reference.

1. What personal information does Tolstoy Resources collect about me and how does it collect it?

When you interview with, and/or submit your résumé to a T olstoy R esources Consultant, we need to collect certain information about you in order to provide our executive search and recruitment services to our clients. The information we require is necessary to identify whether your skillsets, work experience and salary expectations will be a good match with that of our clients.

The information we need to collect will include most of the following about you:

a. Candidate Contact Information;

Name, home and business address, phone numbers and email addresses at which we may contact you.

b. Current Employment Profile:

Title, description of position, specific responsibilities, length of time in current position/company, description of work culture and your likes and dislikes regarding your current position.

c. Current Compensation & Incentives:

Base salary, bonus/commission structure, benefits, annual vacation, conditions and other benefits such as a training allowance, employee discounts, vehicle and equipment leases, parking, daycare facilities, flexible working hours, etc.

d. Current Reporting Relationships

Reporting structure or org chart

e. Previous Employment:

Employer's name, position, start & finish date and description of responsibilities

f. Career Objectives:

Anticipated career growth projection in 6 months, 1 year, 3 years, and 5 years.

Work/home lifestyle characteristics (what is most/least important to you)

g. Your Specific Qualifications:

• Product/service/industry background or expertise
• Years of industry experience
• Memberships in Associations, Unions or Guilds
• Technical skills & specific computer applications
• Academic Background
• Management or supervisory skills
• Personal qualities
• Misc. related background information

h. Company Research Criteria:

List 3 companies you would like to work for and why

List companies you have discussed opportunities with or applied to recently.

List companies that should be avoided in the search and why.

i. Objective Employment Profile:

The ideal position you are looking to move into; position title, description of position, specific responsibilities, work culture, etc.

j. Objective Compensation & Incentives Expectations:

Base salary, bonus/commission structure, benefits, annual vacation and other benefits such as a training allowance, employee discounts, equipment and/or vehicle leases, parking, daycare facilities, flexible working hours, etc.

k. Personal Achievements:

Identify, relate and define the qualities that you bring to a new employer such as individual recognition, education, cost savings, revenue generation, productivity improvement, problem identification, etc.

l. Hiring Conditions:

Availability to start new position. Upon a job offer consent to the following: credit checks, security checks, reference checks and personality assessments (as required by the client).

m. References:

Include up to 4 professional references (a minimum of 2 from previous supervisors). References are not contacted until after client interviews and when a letter of offer is eminent.

Portions of personal information we collect about you may also be extracted and used in the creation of salary surveys, market research and other industry studies. For these purposes your identity is not disclosed in the resulting reports.

You may choose not to provide some or all of your personal information to us but this may prevent us from providing our services to you, or limit our ability to provide you with the level of service that you would otherwise expect from us.

2. How is my personal information used or disclosed by T olstoy R esources ?

 We strive to ensure a stress-free and ethical recruitment experience and are dedicated to building a rewarding and lasting relationship with every candidate. In order to provide the level of service we believe you expect from us, we may use and disclose your personal information for the following purposes:

•  To conduct executive searches requested by our client corporations.

•  To introduce you directly to our client corporations.

•  To administer personality assessments.

•  To carry out reference checks.

•  To conduct salary surveys, market research and other industry studies.

•  To comply with any law, rule, court order, or subpoena as required or authorized by law enforcement agencies.

•  To enforce our legal rights or to protect our business, property and operations.

3. Use or disclosure for marketing purposes.

 Tolstoy Resources provides job search notification, quarterly newsletters and special notices to its candidate database by mail and/or email on a regular basis. We do not disclose candidate information to any of our suppliers or to other recruitment organizations. The service providers we have retained to perform services on our behalf, are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.

Tolstoy Resources does not sell, rent, license, trade or otherwise disclose the contents of its candidate database to mailing list companies or any other organization that would use that information for their own marketing purposes.

4. How does T olstoy R esources protect your personal information?

 We take reasonable steps to protect all of the personal information we hold from misuse, loss, unauthorized access and modification or disclosure in violation of this policy. This protection applies in relation to information stored in both electronic and hard copy form.

When you provide us with your personal information in the form of a résumé, candidate profile or email/phone contact, we enter your information into a stand-alone database system that is not linked to the Internet. The candidate database is located and maintained in Bolton , Ontario . Once your information is in the Tolstoy R esources database system, your personal information will not be used for any purpose not set forth in this policy.

Access to the Tolstoy Resources candidate database is restricted to authorized personnel and is fire walled and password protected. Other security safeguards are locked rooms and alarm systems. As a disaster and recovery precaution duplicate electronic and hard copy information is also stored in a secure offsite location.

5. Can I access the personal information that Tolstoy Resources has about me?

You may access any personal information that we have collected about you subject to certain exceptions. We will normally provide access to your Career Summary, without charge. If you request access to a large volume of information, or we have to access archived records to obtain the information, in these circumstances, we may impose a reasonable fee. We will however, advise you of that fee in advance. You may challenge the reasonableness of the cost. Details of how to contact us are set out below. There may be instances where we may not be able to provide you access to your personal information for certain reasons. Among these are: it has been destroyed or deleted after expiry of applicable retention periods (10 years), it contains personal information of other persons or it contains commercially sensitive or proprietary information owned by us. If we are unable to provide you access, we will explain why and document that for our records.

6. Tell us if we need to update your personal information or preferences.

 You play an active role in assisting Tolstoy Resources in maintaining the accuracy of your personal information for as long as it is used for the purposes set out in this policy. Over the past 6 months Tolstoy Resources has endeavoured to contact its entire candidate database by mail and/or email to ensure that public and personal information contained in our database in up to date. Your prompt notification to us of any changes to your personal information will assist you for qualification in potential job searches.

7. What you consent and agree to.

Consent can be either expressed or implied. Expressed consent is either verbal or in writing. Expressed consent is unequivocal and does not require an inference on the part of the organization seeking consent. Implied consent arises where consent may be reasonably inferred from the action or inaction of the individual, i.e. candidates submitting their résumés, candidate profiles and other information to
Tolstoy R esources by email, mail, fax or in person.

When you provide us with your personal information, you consent and agree to our use and disclosure of your personal information in accordance with this policy.

8. Your options.

 You can ?opt-out? of use and disclosure of your personal information for executive searches, client introductions, salary surveys, market research and other industry studies by contacting Tolstoy Resources ' Privacy Officer in writing (email, fax or letter) indicating your withdrawal of consent. You may also request that both your electronic and physical files be destroyed. Your name and contact number would be retained in the Tolstoy Resources database with the notation ?NO FURTHER CONTACT REQUESTED'.

By withdrawing your consent, you cease being a potential candidate with Tolstoy Resources . You will no longer be contacted for future employment opportunities and no longer receive Tolstoy Resources newsletters .

9. Changes to this Policy

 This is our current privacy policy outlining our personal information management practices. It replaces any other privacy policy published by us prior to the date below. We may change this policy from time to time. If you have any questions, need to modify, or delete your personal information or to obtain an up to date copy of our privacy policy, contact us. This Policy was updated on January 1, 2005.

10. Whom can I contact for further information?

 If you wish to contact us to:

•  inquire about our privacy practices;

•  provide feedback and comments;

•  access or correct your personal information;

•  opt out of further communications,

please contact the Tolstoy Resources Privacy Officer:

Mail: 15535 Mount Pleasant Road , Bolton , Ontario L7E 5R7

Phone: 905-880-0804

Fax: 905-880-2671

Email: contact@tolstoy-resources.com

11. Dispute Resolution

If you are not satisfied with the way in which we handle your inquiry, you can contact:

The Privacy Commissioner of Canada

Mail: 112 Kent Street , Ottawa , Ontario K1A 1H3

Phone: 1-800-282-1376

Fax: 613-967-6850

Links to provincial information and privacy commissioners can be found on the Privacy Commissioner of Canada Website at http://www.privcom.gc.ca

12. About the Tolstoy Resources

Tolstoy Resources is a privately owned retainer-based executive search and recruitment consulting firm founded in 1990 and is based in Bolton , Ontario . Information about our services can be obtained from our website at http://www.tolstoy-resources.com or in promotional material in the form a brochure that can be obtained by contacting our office at 905-880-0804.