We are committed to conducting all aspects of our business in accordance with the principles of sustainable development. Based on our values of protecting the environment, operating safely and fiscally responsible and creating authentic relationships, we will:

Governance

Evaluate and manage risk on a continuing basis, including those that impact the environment, employees, contractors, local communities, customers and shareholders.
Ensure adequate resources are available and systems are in place to implement risk-based management systems, including defined standards and objectives for continuous improvement.
Measure and review performance with respect to our environmental, safety, health, socio-economic commitments and continuous improvement goals.
Employ independent audits to monitor compliance with legal requirements and internal standards.
Conduct all activities in compliance with applicable legal requirements.
Implement employee performance review processes to ensure accountability at all levels.

Workplace and People

Strive to achieve a workplace for our employees and contractors free from occupational injury and illness.
Respect human rights, and the traditional culture, values and customs of the Inuit people.
Report, manage and learn from injuries, illnesses and high potential incidents to foster a workplace culture focused on safety and the prevention of incidents.
Foster and maintain a positive culture of shared responsibility based on participation, behavior and awareness.

Social and Economic

Contribute to the social, cultural and economic development of sustainable communities associated with our operations.
Engage with governments, employees, local communities and the public to create a shared understanding of relevant social, economic and environmental issues, and take their views into consideration in making decisions.
Employ our shareholder’s capital effectively and efficiently.
Demonstrate honesty and integrity by applying the highest standards of ethical conduct.

Environment

Employ a balance of scientific and traditional Inuit knowledge to safeguard the environment.
Apply the principles of pollution prevention and continuous improvement to minimize ecosystem impacts, and facilitate biodiversity conservation.
Use energy, raw materials and natural resources efficiently and effectively.
Ensure closure plans are in place and progressive restoration is undertaken to reduce potential long-term environmental and community impacts.

Every employee, contractor, and visitor is expected to demonstrate through their actions a personal commitment to this policy.

Gord McCreary

President and Chief Executive Officer

February 2009