Disclosure Controls and Procedures
Policies, Procedures & Narrative

• Statement of Policy - Winpak continues to be committed to full and prompt disclosure of material information to investors. No material information shall be disclosed in any way by any employee, officer or director of Winpak unless authorized by Company Policy. This Policy governs the conduct of directors, officers and all other employees of Winpak, and the methods the Company may employ to communicate to the public. Communications include not only written and filed documents such as the annual and interim financial statements, news and earnings releases and the AIF, but also communications to employees, speeches by senior management, information on Winpak's website and meetings with investors and analysts.
• Spokespersons - The Company's Board of Directors authorized only the following persons to be Spokespersons: The CEO is designated to speak for the Company on all matters of public interest; the CEO or the CFO are designated to speak for the Company on financial matters; the CEO may delegate in writing other person(s) to speak for the Company on specific matters.
• Material Information - Material information is any information that represents a "material change" as defined by the Securities Regulators. This means that any information that could materially impact the price of Winpak shares, either up or down, is deemed to be material. When a dollar value is required to facilitate the consideration of whether information is material, the value of materiality for Winpak has been defined as four percent of normalized annual operating earnings. Specific information directly related to the performance of employment duties such as sales or procurement, which may accordingly be provided to third parties such as customers or suppliers, is not material information for the purposes of this paragraph.
• Timing of and Procedure for Disclosure - Any material information will be publicly disclosed within three hours of the information being deemed material. Material disclosures will be published in writing as a press release, or verbally, providing a press release is issued simultaneously. Press releases will be balanced and not promotional. Releases will be disseminated through a wire service, and faxed or e-mailed as requested, according to the Company's authorized Procedure. The Procedure may only be completed by the Company Secretary or his/her designate, or a Spokesperson or his/her designate. Disclosures are authorized prior to release by the Audit Committee in the case of financial filings, and by the CEO, or the CFO if authorized by the CEO, regarding any other report.
• Responding to Market Rumors - The Company does not respond to market rumors.
• Conference Calls - Currently, the Company does not host quarterly or other multi-party conference calls for analysts and investors. However, the Company's authorized Spokespersons may conduct discussions by telephone or in person with individual analysts and/or investors regarding quarterly results or other matters at any time except during the period three weeks preceding a release of quarterly results, as envisaged by the following section, Communications with Financial Analysts and Investors.
• Communications with Financial Analysts and Investors - Periodically, as deemed appropriate or as requested by financial analysts and investors, either or both Spokespersons, and/or a designated Spokesperson, may make presentations to or conduct discussions with limited groups of financial analysts and investors. Management encourages additional active coverage of the Company by qualified financial analysts and welcomes contact by new or potential investors. The Spokespersons will provide the same information to new enquirers as provided to any other investor. If material information not previously publicly disclosed is inadvertently disclosed to a limited audience, the Company will take immediate action to publicly disseminate such information. Should questions arise through discussions with financial analysts and investors that lead the Company to believe explanation is required regarding prior disclosure, then such explanation will be published. Presentations and discussions will be prepared and conducted so that the content is consistent with previous public disclosures and does not constitute additional material disclosure. When Spokespersons conducting meetings or discussions are presented with questions for which answers would include information not previously disclosed, the Spokespersons will decline to provide the information and will advise participants that presentations and discussions cannot provide more than explanation of material information that has already been publicly disclosed. Communication of prepared presentations to, and discussions with, limited groups will be conducted on a basis consistent with each other. The Company will retain records of meetings and communications with financial analysts and investors, if situations arise that are, in the view of the Spokespersons, unusual or could require reference at a later date.
• Forward-Looking Information - Winpak may disclose forward-looking information when considered appropriate. Forward-looking information may constitute estimates of sales, earnings, capital expenditures, borrowings or other data considered relevant to investors or analysts in the context of Winpak's operations. Such information will relate to a future time period not exceeding five years. Any forward-looking information will be accompanied by a general disclaimer such as that preceding the Company's MD&A and/or by a specific disclaimer such as, "assuming no unforeseen events".
• Website - Certain information may be posted to the Company's website when authorized by a Spokesperson. Information previously made public by a press release may be repeated or supplemented with explanation in a posting to the website, but will not include previously undisclosed material information. The Winpak website contains a direct link to SEDAR, which includes press releases such as annual and interim reports, and therefore such SEDAR filings may not be posted to the Company website.
• Document Retention - The Company maintains documentary evidence of the source of data released to the public.
• Restrictions on Employee Trading - Winpak restricts Insider Trading in accordance with securities laws. The Company has implemented a separate written Policy regarding Insider Trading that is available upon request and has been provided to all employees.
• Disclosure Committee - Due to the limited size of Winpak compared to other larger issuers and the structure of the Company's operations, a Disclosure Committee has not been named. The Company has alternate processes in place and has named the CEO and CFO to fulfill the responsibilities that otherwise would be performed by a Disclosure Committee.