Internal Control over Financial Reporting

Management is responsible for establishing and maintaining adequate internal control over financial reporting, as defined in NI 52-109. Internal control over financial reporting means a process designed by or under the supervision of the CEO and CFO, and effected by the Board of Directors, management and other personnel to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with GAAP, and includes those policies and procedures that: (1) pertain to the maintenance of records that in reasonable detail accurately and fairly reflect the transactions and dispositions of the assets of the Company; (2) are designed to provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of the Company are being made only in accordance with authorizations of management and directors of the Company; and (3) are designed to provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the Company’s assets that could have a material effect on the financial statements.

All internal control systems have inherent limitations and therefore internal control over financial reporting can only provide reasonable assurance and may not prevent or detect misstatements due to error or fraud.

The Company’s management, including the CEO and CFO, conducted an evaluation of the effectiveness of internal control over financial reporting as of December 31, 2008 using the Committee of Sponsoring Organizations of the Treadway Commission (COSO) framework. Based on this evaluation, the CEO and CFO have concluded that the Company’s internal control over financial reporting was effective as of December 31, 2008.

Changes in Internal Control over Financial Reporting

During 2008, the Company implemented a number of initiatives that served to strengthen its system of internal control over financial reporting (“ICFR”) including implementation of a formal testing program of key controls in conjunction with the Company’s 52-109 certification program, increased staffing in key financial roles that served to improve the level of financial expertise in the Company and strengthen segregation of duties, updating policies related to disclosure and insider trading and developing a policy on costing of inventory for new inventory items arising from the Company’s solar grade silicon product line. Additionally, a change in the scope of ICFR occurred with the closing of the Company’s manufacturing site in Haley, Ontario which had been an accounting centre. The evaluation of the effectiveness of ICFR was conducted following a reassessment of key internal controls incorporating these changes. There have been no other changes in the Company’s ICFR during the year ended December 31, 2008, that have materially affected, or are reasonably likely to materially affect, the Company’s ICFR.