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The privacy of individuals connected with our business, including our customers, contractors, employees, franchisees and website visitors has always been of great importance to Loblaw Companies Limited ("Loblaw"). Keeping personal information in strict confidence is a cornerstone of our business. Regardless of how the range of products and services we offer our customers expands, and the technology we use changes, we will always strive to protect the privacy of personal information, subject to any consent an individual has provided for its use. This policy describes the principles on which Loblaw Companies Limited and its subsidiaries and divisions, including President's Choice Bank ("PC Bank"), will protect the privacy of personal information. The policy is based on the Canadian Standards Association Model Code for the Protection of Personal Information. While this document sets out the principles on which Loblaw's privacy practices are based, privacy laws will vary from province to province and those laws may also govern Loblaw's privacy practices in such province. This policy is part of Loblaw's commitment to ensure that all personal information of individuals in its possession is protected and used in accordance with the law. Privacy laws across Canada are evolving, and therefore this policy is subject to change. Personal Information is any information about an identifiable person, other than the name, title, business address and business telephone number of a person. It includes such things as a person's home address, date of birth, social insurance number, medical and financial information. With respect to customers, such information is collected primarily in connection with services and products provided by Loblaw. Employees may be asked to provide such information to Loblaw in connection with matters relating to their employment. In all cases, Loblaw is committed to protecting the privacy of individuals and the integrity of their personal information. 1. Accountability Loblaw is responsible for personal information under its control, including any personal information disclosed to third parties for handling or administrative purposes. Loblaw has designated a Privacy Officer who is accountable for Loblaw's compliance with this Policy and with privacy legislation. 1.1 While ultimate accountability for Loblaw's compliance with the Policy rests with the Privacy Officer and Senior Management of Loblaw, day-to-day compliance with the Policy is delegated to individuals throughout Loblaw's business. 1.2 With respect to personal information that has been transferred to a third party for processing, Loblaw will use contractual or other means, which may include the examination of such third party's practices with respect to personal information, to safeguard personal information while it is being handled by a third party. 1.3 Loblaw has implemented internal guidelines and practices to give effect to this Policy, including: 1.

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