Insider Trading Policy

Luminor Medical Technologies Inc. employee and insider trading guidelines


Under Canadian securities and corporate legislation as well as the policies of the TSX Venture Exchange (the “TSX-V”) the purchase or sale of securities of a public company by persons who use information which has not been generally disclosed to the public may result in such persons, as well as the Company, incurring substantial liability. The purpose of the following guidelines is to ensure that the Company avoids any activity (or the appearance of any activity) based on an improper use of confidential information.

The guidelines apply to persons in a “special relationship” with the Company. These include:

(a) insiders of the Company (“Insiders”) as defined as officers and directors of the Company, the five highest paid employees of the Company (subject to a minimum annual salary of $50,000) and holders of 10% or more of the voting securities of the Company;

(b) any insiders of an Insider;

(c) employees of the Company;

(d) an “associate” of any of (a), (b) or (c) (see Schedule “A” for definition of “associate”); and

(e) a person who receives specific material information from (a), (b), (c) or (d).

This policy is provided to all persons in a special relationship with the Company and such persons are reminded of the provisions of this policy on a regular basis. This policy is updated on a regular basis and such updates are brought to the attention of all persons in a special relationship with the Company.