Effective 2007

Protecting the privacy of personal information is an important principle to J.D. Irving, Limited and its divisions and related operating companies (the “Companies”).

Responsible and Limited Collection, Use and Disclosure

Companies which collect, use and disclose personal information are committed to doing so responsibly and only to the extent necessary for the services they provide.

Policies and Procedures to Ensure Compliance with PIPEDA

Companies that are required to comply with the Personal Information Protection and Electronics Documents Act (“PIPEDA”) and which collect, use and disclose personal information will implement policies and procedures to ensure compliance with PIPEDA.

Accuracy

Companies which gather personal information will ensure that the information collected is as accurate, complete and up-to-date as is necessary for the purposes for which it is used.

Safeguards

Companies which gather personal information have safeguards to protect such personal information from unauthorized access, disclosure, copying, use or modification.

Education/Training

Companies that are required to comply with PIPEDA are committed to providing all necessary training and education to their employees to ensure a proper understanding of and compliance with PIPEDA.

Inquiries

J.D. Irving, Limited has appointed a Privacy Officer who is responsible for overseeing compliance with PIPEDA. The Privacy Officer can be contacted by email at privacyofficer@jdirving.com or by telephone at 506-632-7777.

Each of the Companies required to comply with PIPEDA have appointed a Privacy Administrator and the name of the applicable Privacy Administrator is available upon request from the Privacy Officer. Inquiries about privacy matters that relate to a specific company will be referred to the applicable Privacy Administrator. A copy of the Privacy Policy implemented by a specific company may be obtained from the Privacy Administrator.

If you are unable to satisfactorily resolve any privacy matter directly with the applicable Privacy Administrator, the matter can then be referred to the Privacy Officer.