Share Trading Policy

Purpose

The Share Trading Policy (the "Policy") describes the responsibilities, principles and practices for buying and selling ("trading") shares or other securities ("shares") of Carmanah Technologies Corporation (the "Company" or "Carmanah") by directors, officers, and employees ("employees"). This Policy ensures the Company complies with best practices in the trading of its securities.

Application of Policy

This Policy applies to all employees and is posted on the Company's website. Substantive changes will be communicated to all employees when they occur via the company portal and by email. New employees will be provided with a copy of this Policy and educated about its importance.

Any questions with respect to the interpretation of this Policy should be referred to the Chief Financial Officer or the Vice President, Administration.

Consequences of Non-Compliance

A violation of this Policy may carry severe consequences both for the Company and the employees involved. Compliance with this Policy is a condition of office or employment with the Company. A violation of this Policy may be grounds for discipline, up to and including immediate dismissal.

The violation of this Policy may also violate certain securities laws. If it appears that an employee may have violated such securities laws, the Company may refer the matter to the appropriate regulatory authorities.

Material Information

In general, any information concerning the Company's business and affairs is considered "material information" if it results in or would reasonably be expected to result in a significant change in the market price or value of the Company's shares or, stated another way, if a reasonable investor would consider the information important in making a decision to buy or sell the Company's shares.

Material information is fully defined in the Corporate Communications & Disclosure Policy.

Material information which has not yet been disclosed to the public is considered "confidential material information".

Responsibilities and Rules

Employees who have knowledge of confidential material information are personally responsible for complying with securities regulations when trading Carmanah shares. To clarify these regulations, the Company has adopted the following rules for employees who wish to trade Carmanah shares.

No Insider Trading:

An employee who has knowledge of confidential material information may not trade in shares of the Company or make use of such information to achieve any other benefit either for himself or herself or for another person. Trading shares of the Company with knowledge of confidential material information constitutes "insider trading" and is expressly forbidden.

Quarterly Blackout Period:

Since senior employees of the Company can be expected to know material information about quarterly results before they are released to the public, Carmanah has instituted a Blackout Period in the trading of Carmanah securities for Carmanah Board Members, Corporate Directors, Chief Executive Officer, Chief Operating Officer, Chief Financial Officer, Vice Presidents and Directors. This Blackout Period commences on the day that is 15 days prior to the end of the quarter, and continues until the end of the second trading day after Carmanah has publicly released its financial statements for that quarter.

Any individual employed by Carmanah that does not hold one of the above titles will be allowed unrestricted trading of Carmanah shares during the course of the year, subject to the "No Insider Trading" restrictions noted above.

Quarter	Blackout Commencement Date	Blackout Expiry Date
Q1 - (Jan. 1 – Mar. 31)	March 17	2 Days after release of quarterly financials
Q2 - (Apr. 1 – June 30)	June 16	2 Days after release of quarterly financials
Q3 - (July 1 – Sept. 30)	September 16	2 Days after release of quarterly financials
Q4 - (Oct. 1 - Dec. 31)	December 17	2 Days after release of quarterly financials

Additional Blackout Periods:

In the event of pending undisclosed material information the Company's Board of Directors or its Chief Financial Officer may notify specific employees of additional blackout periods during which they are prohibited from trading the Company's shares.

If at any time, an employee is approved for a grant of more than 25,000 stock options, the employee is prohibited from trading Carmanah shares during the 14 day period between approval and grant date of the stock options. (see Dating and Pricing of Stock Options Policy).

Short Sales and Derivatives:

Employees are prohibited from selling, directly or indirectly, the Company shares if the employee does not own or has not fully paid for the Company's shares to be sold; or directly or indirectly selling a call or buying a put, or similar derivative instrument, in respect of Company shares.

Insider Trader Reporting Requirements:

Responsibility for accurate, clear and timely insider trading filings with the appropriate regulatory authority (currently "System for Electronic Disclosure by Insiders" or "SEDI") rests with the employee and not with the Company.