Antitrust Compliance Statement

Antitrust Compliance Statement

1. It is a policy of the International Energy Credit Association, Inc. (“IECA”) that all members conduct themselves so as to be in strict compliance with all Antitrust Regulations while participating in IECA activities.

2. IECA shall have an Officer/Director/Educational Chair or President’s designee present during all IECA business sessions to assist our membership in identifying areas of discussion, which while not intended, could potentially lead to violations.

3. While the following guidelines are presented for your convenience, the IECA strongly encourages each member to review in detail, with company or outside counsel, anti-trust compliance as it relates to your conduct while participating in IECA activities.

A. You may discuss general trends or conditions in the industry or the economy, as well as general credit related issues, if the purpose or effect of such discussion is not to elicit or encourage uniform action or policy with respect to future transactions by members of the group.

B. You may exchange current, factual information relevant to the credit of accounts based on actual experience or present knowledge. You should not share recommendations, opinions, or information received from a third party without substantiation.

C. There is to be no discussion of pricing - past, present or future.

D. Do not participate in or give consideration to any activity that would restrict or interfere with the exercise of free and independent judgment by the members in the management or operation of their respective credit functions.

E. Do not act in concert or agree in any respect to a specific credit policy towards a particular company or group of companies. Adherence to and compliance with Antitrust Regulations is not only a matter of concern for the group, but also for self-protection. Although membership by itself in an association found guilty of violation of the anti-trust statutes is usually not sufficient to establish the liability of any member, the courts have held that if a member knows of or should have known that his/her associates in the group engage in unlawful activities, and he/she continues his/her membership without protesting, he/she and the company he/she represents may become liable; and the consequences of an antitrust violation is a felony, carrying up to a $10,000,000 fine plus treble damages.

Competition Act Compliance Statement

Competition laws seek to maintain a free competitive economy in Canada and provide consumers with competitive prices and product choices. Generally, competitors may not restrain competition among themselves through agreements or understandings that unduly restrict competition. Specifically, under section 45 of the Canada Competition Act (the “Act”) “every one who conspires, combines, agrees or arranges with another person to limit, prevent or lessen . . . or otherwise restrain or injure competition unduly is guilty of an indictable offence” and “liable to imprisonment for a term not exceeding five years or to a fine not exceeding ten million dollars or to both”. With this provision of the Act in mind, the Canadian Competition Bureau looks at meetings of trade associations with suspicion. This Competition Act Compliance Statement is designed to avoid even the appearance of questionable activity at IECA meetings.

Statement of Policy

The policy of the IECA dictates that all members residing in Canada conduct themselves so as to be in strict compliance with the Act and all related regulations while participating in IECA activities.

Monitoring Responsibility

IECA shall have an officer, director, educational chair or a person so designated by the president present during all IECA business sessions to assist membership in identifying areas of discussion, which while not intended, could potentially lead to violations.

Competition Law Guidelines

While the following guidelines are presented for your convenience, the IECA strongly encourages each member to review in detail, with company or outside counsel, Competition Act compliance as it relates to your conduct while participating in IECA activities.

1. You may discuss general terms or conditions in the industry or the economy, as well as general credit related issues, if the purpose or effect of such discussion is not to elicit or encourage uniform action or policy with respect to future transactions by members of the association.

2. You may exchange current, factual information relevant to credit standing of accounts based on actual experience or present knowledge. You may not share recommendations, opinions or information received from a third party. 3. You may not discuss pricing – past, present or future.

4. You may not participate in or give consideration to any activity that would restrict or interfere with the exercise of free and independent judgment by the members in the management of or operation of their respective credit functions.

5. You may not act in concert or agree in any respect to a specific credit policy towards a particular company or group of companies.

Conclusion and Acknowledgement

Each IECA member has an equivalent responsibility for competition law compliance. Each member and IECA depends upon good judgment by all to avoid discussions and activities which could involve improper subject matter, improper procedures or even an appearance of improper activity. Adherence to and compliance with the Act is not only a matter of concern for the members of the IECA and the companies that employ those members, but also for individuals present at IECA meetings. Although membership in an association found guilty of violation of the Competition Act may not be sufficient by itself to establish the liability of any particular member, the courts have held that if a member knows of or should have known that his or her associates within the meeting of the group are engaging in unlawful activities and he or she continues his or her attendance or membership without protesting, he or she and the company he or she represents may become liable to penalties under the Act. In order to demonstrate the commitment of the individual members of IECA to compliance with the Competition Act and related regulations, the participants in meetings of IECA hereby acknowledge that no issue will be discussed that will violate this Competition Act Compliance Statement or Canadian competition laws and that this Competition Act Compliance Statement will be respected under all circumstances.

Issued January, 2006.