Online Policy and Cautionary Notes

Online Policy

In accordance with Toronto Stock Exchange (“TSX”) recommendations, North American Palladium Ltd. (“NAP” or the “Company”) does not comment or respond to online posts or 'forums'. Investors or potential investors should not rely on the content of such unregulated media for accurate Company information or investment decisions, and they should contact the Company with questions.

As you may be aware, TSX guidelines (which are consistent with National Policy 51-201 - Disclosure Standards) advise public company representatives to refrain from posting messages on internet bulletin boards, blogs etc. We invite shareholders and investors to please call our investor relations officer at +1 (416) 360-8782 should they have any questions.

Cautionary Notes

General Disclaimer

NAP has taken all reasonable care in producing and publishing information contained on this website and will endeavor to do so regularly. Material on this website may still contain technical or other inaccuracies, omissions, or typographical errors, for which NAP assumes no responsibility. Unless otherwise indicated, all information posted on this website is current only as of the date of the document that contains the information, if indicated, or the date on which the document is posted, whichever is earlier. NAP may at any time make changes to the information on this website without prior notice. You should always ensure that you are referring to the most current information available on this website.

NAP does not warrant or make any representations regarding the use, validity, accuracy, completeness or reliability of any claims, statements or information on this website. Under no circumstances, including, but not limited to, negligence, shall NAP be liable for any direct, indirect, special, incidental, consequential, or other damages, including but not limited to, loss of programs, loss of data, loss of use of computer or other systems, or loss of profits, whether or not advised of the possibility of damage, arising from your use, or inability to use, the material on this website. The information on this website is not a substitute for independent professional advice before making any investment decisions. Furthermore, you may not modify or reproduce in any form, electronic or otherwise, any information on this website, except for personal use, unless you have obtained our express permission.

Within this website, we have or may provide links and references to several other websites. NAP has no control over information at sites hyperlinked or referred to in this website. These links and references are being provided for your convenience only, and NAP does not endorse and is not responsible or liable for the content, nature or reliability of any linked or referenced website or any link contained in a linked or referenced website. NAP takes no responsibility for monitoring, updating, supplementing, or correcting any information on any linked or referenced website and makes no representation or warranties regarding such information. Please be aware that in linking or accessing these third-party websites, you are leaving this website and that NAP is not responsible for the content of any other site.

The TSX has not reviewed the information on this website and does not accept responsibility for the adequacy or accuracy of it.

Cautionary Statement regarding Forward-Looking Statements and other Cautionary Notes

Certain information contained in this website constitutes 'forward-looking statements' and ‘forward-looking information’ (collectively, “forward-looking statements”) within the meaning of applicable Canadian securities laws. All statements other than statements of historical fact are forward-looking statements. The words 'target,' 'plan,' 'should,' 'could,' 'estimate,' 'guidance,' and similar expressions identify forward-looking statements. Forward-looking statements on this website include, without limitation: information pertaining to the Company’s future dividend payments; information pertaining to the Company's strategy, strategic process, plans or future financial or operating performance, such as statements with respect to, long term fundamentals for the business, operating performance expectations, project timelines, tailings management plan, mining method change, production forecasts, operating and capital cost estimates, expected mining and milling rates, cash balances, projected grades, mill recoveries, metal price and foreign exchange rates and other statements that express management's expectations or estimates of future performance. Forward-looking statements involve known and unknown risk factors that may cause the actual results to be materially different from those expressed or implied by the forward-looking statements. Such risks include, but are not limited to: the possibility that metal prices and foreign exchange rates may fluctuate, the risk that Lac des Iles Mine may not perform as planned, that the Company may not be able to meet production forecasts, the possibility that the Company may not be able to generate sufficient cash to pay a dividend and/or to service its indebtedness and may be forced to take other actions, inherent risks associated with development, exploration, mining and processing including environmental risks and risks to tailings capacity, employment disruptions, including in connection with collective agreements between the Company and unions and the risks associated with obtaining necessary licenses and permits. For more details on these and other risk factors, see the Company's most recent management’s discussion and analysis and the Company’s annual information form on file with Canadian securities regulatory authorities on SEDAR at www.sedar.com under the heading “Risk Factors.”

Forward-looking statements are necessarily based upon a number of factors and assumptions that, while considered reasonable by management, are inherently subject to significant business, economic and competitive uncertainties and contingencies. The factors and assumptions contained on this website, which may prove to be incorrect, include, but are not limited to: that the Company will be able to continue normal business operations at the Lac des Iles Mine, that metal prices and exchange rates between the Canadian and United States dollar will be consistent with the Company's expectations, that there will be no significant disruptions affecting operations, and that prices for key mining and construction supplies, including labour, will remain consistent with the Company's expectations. The forward-looking statements are not guarantees of future performance. The Company disclaims any obligation to update or revise any forward-looking statements, whether as a result of new information, events or otherwise, except as expressly required by law. Readers are cautioned not to put undue reliance on these forward-looking statements.

Qualified Person

The content of this website relating to geology and exploration has been read and approved by the Company’s Vice-President, Exploration, Dr. Dave Peck. Dr. Peck is a Qualified Person under the meaning of National Instrument 43–101 and a registered Professional Geoscientist with the Association of Professional Geoscientists of Ontario, the Association of Professional Engineers and Geoscientists of British Columbia, and the Association of Professional Engineers and Geoscientists of Manitoba.

Privacy Statement

NAP is committed to ensuring that the privacy of your personal information is protected. NAP’s commitment to you has been developed in accordance with the Personal Information Protection and Electronic Documents Act and ensures that your personal information will only be collected, used, and disclosed in compliance with the law. NAP does not collect any personal information about visitors to this website other than information as you may specifically and knowingly provide to NAP or other such personal information as is indicated below. Personal information collected by NAP will not be transferred to any party outside of NAP unless otherwise stated at the time of collection.

NAP may collect and maintain statistics relating to the number of visits to the website, the types of browsers used and the internet protocol address of the originator. This information is used only for internal purposes. Any material, information or other communication including, but not limited to, questions, comments or suggestions you transmit to NAP through this website will be considered non-confidential and non-proprietary. In making any such transmission, you agree that NAP will have no obligations of any kind with respect to those communications. Where it is necessary, in order to respond to your enquiry, the communications you provide may be passed on within the NAP organization. By sending any communications to us, you are consenting to the personal information contained therein being transferred within NAP and being processed by NAP for these purposes. You are prohibited from posting or transmitting to or from NAP any unlawful, threatening, libelous, defamatory, obscene, pornographic or other such materials in addition to materials or communications that may violate any law.

Your Consent

By using this website, you consent to the collection and use of information as outlined in the above statement. If NAP decides to change its privacy policy, NAP will post those changes on this page so that you are always aware of what information NAP collects, how it will be used, and under what circumstances it will be disclosed.

Jurisdiction

Your use of this website shall be governed by the laws of the Province of Ontario and any applicable federal laws of Canada. You hereby attorn to the exclusive jurisdiction of the courts of the Province of Ontario in respect of all matters arising out of your use of this website, and the courts of the Province of Ontario shall have exclusive jurisdiction over any dispute arising out of your use of this website.

Contacting Us

NAP welcomes any queries, comments or requests you may have regarding its Privacy Policy. Please do not hesitate to contact investor relations at ir@nap.com.