Rosehill,

I agree .... Confidentiality agreements are generally useful but only work well for the professional staff. For the rest of the gang it’s best to set an example if the opportunity exists. They are however not that hard to action and they do work for all levels of staff. They are but one part of shifting the behaviour of the people working on the project.

Most leaks are pretty blatent, can be tracked to a source and can be plugged. Firing for cause, not renewing contracts, telling a contractor that one of their employees is not welcome on your project etc happens all the time. Almost all staff on the project are new and are on short term renewable contracts or work for a contrator. Most of the employees have worked for the company for a shorter period of time then most of us have held the stock. Clearly, if you were going to feed them to the wolves you better have some pretty solid proof. Getting rid of someone is pretty easy.

One of the challenges is that as a junior the culture was to feed the rumour mill. Everyone had a source that skirted the edges of the TSE rules and it was no big deal as we were dealing with a couple of million dollar cap. To keep the company alive RN and the guys (as does every junior) had to work the system. Now we are approaching a billion dollar cap and the rules and oversight are different.

In my experience the meaningful leaks come from three sources: The office staff, the drillers and the geologists on site. Everyone else tends to be relating something they have heard from one of the above so if you shut off the tap the rumours dry up fairly quickly.

A large part of compliance is changing culture and cutting off the flow of non-authorized information. The first step is telling people what is and is not acceptable and the confidentiality agreements stress this. The second is to tighten up who sees information before it is released. The first step by itself will cut out most of the internal leaks. For example geologists are told not to discuss the project or results outside of the core shack/field office with anyone including the rest of the geologists. The core shack and office is out of bounds to everyone but the geologists. No chatting with the drillers or cooks or pilots, or bar tenders about what they aree doing. Let them guess all they want but don't be involved. In the corpoarte office sectretaries and IR staff are given new rules on what the can tell investors or outsiders, results are only accessed by the 'authorized person' and released only to those with a need to know. ROF project staff don't see WF results etc.

A big challenge is the drillers and pilots. These guys see first hand what is coming out of the ground, what the geologists get excited about, what the zone looks like etc and they have seen it on other properties as well. Most of them have more experience then the drill geologists they are working with (I've had drillers call back to camp for mr to come and check the drill because they have "drilled through the zone" and want to know when to shut down). Its almost impossible to prevent them from calling home and telling the 'wife' to give the kids an extra 'hug' tonight (after something exciting is hit) or telling the 'wife' they don't think it's a good time to 'buy' the new car yet (when the results aren't looking very good). However the drillers know that their job is toast if word gets out that they are trading in the company that they are drilling for. Most drilling contracts expressly forbid anyone in the drill company including the drillers from doing so (it may not stop them but it keeps the rumours contained to the drillers immediate family ... or else). Pilots are the same way. They get to see the drill locations, sample volume etc week or months before we know. It doesn't take a geologist to know that when a drill stops moving around the property and starts pounding a series of holes it one area its a pretty good indicator that something is going on (or when a geologist charters a flight to Toronto with a bunch of core to show the 'boss').

However the the biggest source of leaks was probably RN and the other CEOs. After decades of begging anyalsts, the press and the money men to pay attention to them they now have to radically shift their behaviour. Similarly with investors. No more casual coversations about what is coming down, no more hints about great things to happen etc. Heck, we now have hundreds of posters that analyse each word to see if there is a secondary implied meaning in them.

So at the end of the day, as you rightfully stated, you lead by example, lay out the rules, make clear the penalties and rely on the fact that you have hired good people to work for you. However, if someone crosses the line they pay because as we evolve into a major company we will be sued by those that lose because someone else has inside information (good or bad) that they should not have. I don't now for a fact but I believe that the TSE has told NOT that they are responsible for making sure that they are compliant with the rules. This is probably also the reason why we are not seeing pictures of core or 'visual' descriptions before we get assays back but that is a topic for another night.

.... Been There