Pre-announcement Trading Blackout

(a) Scheduled material announcements

The Chief Financial Officer and all directors, officers, employees and other

persons subject to this Policy and involved in the preparation or review of the

Corporation’s financial statements are prohibited from trading for a minimum of

30 days before the release of financial statements, which minimum period is

subject to increase at the discretion of the Board from time to time.

All other directors, officers, employees and other persons subject to this Policy are

prohibited from trading for a minimum of five trading days before the release of

financial statements, which minimum period is subject to increase at the discretion

of the Board from time to time.

The Chief Executive Officer will designate an individual who will disseminate an

e-mail to all of the directors, officers and employees of the Corporation and other

persons subject to this Policy confirming the scheduled release date for financial

statements, and the date preceding such scheduled release upon which date the

blackout period will commence, and any amendments thereto.

(b) Unscheduled material announcements

The Corporation will impose a blackout period if there is a pending undisclosed

material development on all directors, officers, employees and other persons

subject to this Policy where they are prohibited from trading. The blackout period

will commence at the time that an individual designated by the Chief Executive

Officer disseminates an e-mail to all of the directors, officers, employees and

other persons subject to this Policy confirming same.

http://www.allanapotash.com/i/pdf/Disclosure_Policy_November_2011.pdf