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Acasti Pharma

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FY2017 Annual Report · Acasti Pharma
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

FORM 20-F

☐ REGISTRATION STATEMENT PURSUANT TO SECTION 12(b) or (g) OF THE SECURITIES EXCHANGE ACT OF 1934

☒ ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

OR

For the fiscal year ended March 31, 2017
OR

☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

OR

☐ SHELL COMPANY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

Commission file number: 001-35776

Acasti Pharma Inc.

(Exact name of Registrant as specified in its charter)

N/A
(Translation of Registrant’s name into English)
Québec, Canada
(Jurisdiction of incorporation or organization)
545, Promenade du Centropolis, Suite 100, Laval, Québec H7T 0A3
(Address of principal executive office)
Linda P. O’Keefe, Chief Financial Officer
Acasti Pharma Inc.
545, Promenade du Centropolis, Suite 100
Laval, Québec H7T 0A3
Tel: 450-687-2262
Fax: 450-687-2272
(Name, Telephone, Email and/or Facsimile number and Address of Company Contact Person)
Securities registered or to be registered pursuant to Section 12(b) of the Act.

Title of each class

Common Shares, no par value

Name of each exchange on which  registered

The NASDAQ Capital Market

Securities registered or to be registered pursuant to Section 12(g) of the Act.
Not applicable
Securities for which there is a reporting obligation pursuant to Section 15(d) of the Act.
None

Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as of the close of the period covered by the annual report.

14,702,556 Common Shares issued and outstanding as of March 31, 2017.

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.    Yes  ☐    No  ☒
If this report is an annual or transition report, indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or 15(d) of the Securities
Exchange Act of 1934.    Yes  ☐    No  ☒
Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the
preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past
90 days.    Yes  ☒    No  ☐
Indicate  by  check  mark  whether  the  registrant  has  submitted  electronically  and  posted  on  its  corporate  Web  site,  if  any,  every  Interactive  Data  File  required  to  be
submitted and posted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant
was required to submit and post such files).    Yes  ☐    No  ☐
Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, or a  non-accelerated filer. See definition of “accelerated filer and large
accelerated filer” in Rule 12b-2 of the Exchange Act. (Check one):
Large accelerated filer  ☐                Accelerated  filer  ☐                Non-accelerated filer  ☐            Emerging growth company  ☒
If an emerging growth company that prepares its financial statements in accordance with U.S. GAAP, indicate by check mark if the registrant has elected not to use the
extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act ☐.
Indicate by check mark which basis of accounting the registrant has used to prepare the financial statements included in this filing:

U.S. GAAP  ☐                      

International Financial Reporting Standards as
issued  by 
Board  ☒

the 

International  Accounting  Standards

Other  ☐

If “Other” has been checked in response to the previous question, indicate by check mark which financial statement item the registrant has elected to follow.    
Item 17  ☐     Item 18  ☐
If this is an annual report, indicate by check mark whether the registrant is a shell company (as defined in  Rule 12b-2 of the Exchange Act).    Yes  ☐    No  ☒

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
Table of Contents

TABLE OF CONTENTS

INTRODUCTION AND USE OF CERTAIN TERMS

SPECIAL NOTE REGARDING FORWARD-LOOKING STATEMENTS

PART I

  Item 1.
  Item 2.
  Item 3.
  Item 4.
  Item 4A.
  Item 5.
  Item 6.
  Item 7.
  Item 8.
  Item 9.
  Item 10.
  Item 11.
  Item 12.

    Identity of Directors, Senior Management and Advisers
    Offer Statistics and Expected Timetable
    Key Information
    Information on the Company
    Unresolved Staff Comments
    Operating and Financial Review and Prospects
    Directors, Senior Management and Employees
    Major Shareholders and Related Party Transactions
    Financial Statements
    The Offer and Listing
    Additional Information
    Quantitative and Qualitative Disclosure about Market Risk
    Description of Securities other than Equity Securities

PART II

    Defaults, Dividend Arrearages and Delinquencies
    Material Modification to the Rights of Security Holdings and Use of Proceeds
    Controls and Procedures
    Reserved

  Item 13.
  Item 14.
  Item 15.
  Item 16.
  Item 16A.    Audit Committee Financial Expert
  Item 16B.    Code of Ethics
  Item 16C.    Principal Accountant Fees and Services
  Item 16D.    Exemptions from the Listing Standards for Audit Committees
  Item 16E.     Purchases of Equity Securities by the Issuer and Affiliated Purchasers
  Item 16F.     Change in Registrant’s Certifying Accountant
  Item 16G.    Corporation Governance
  Item 16H.    Mining Safety Disclosure

PART III

  Item 17.
  Item 18.
  Item 19.

    Financial Statements
    Financial Statements
    Exhibits

EXHIBITS INDEX

SIGNATURES

    3 

    4 

    8 
    8 
    8 
    8 
   28 
   49 
   49 
   64 
   79 
   79 
   80 
   82 
   91 
   91 

   92 
   92 
   92 
   92 
   92 
   92 
   93 
   93 
   94 
   94 
   94 
   94 
   94 

   94 
   94 
   94 
   94 

   95 

   96 

 
Table of Contents

INTRODUCTION AND USE OF CERTAIN TERMS

As used in this annual report on Form 20-F, or this annual report, unless the context otherwise requires, references to “we”, “our”,

“us”, “Acasti”, “Acasti Pharma”, “Corporation”, “it”, “its” or similar terms refer to Acasti Pharma Inc.

Market data and certain industry data and forecasts included in this annual report were obtained from internal company surveys,
market research, publicly available information, reports of governmental agencies and industry publications and surveys. We have relied
upon industry publications as our primary sources for third-party industry data and forecasts. Industry surveys, publications and forecasts
generally  state  that  the  information  they  contain  has  been  obtained  from  sources  believed  to  be  reliable,  but  that  the  accuracy  and
completeness  of  that  information  is  not  guaranteed.  We  have  not  independently  verified  any  of  the  data  from  third-party  sources  or  the
underlying economic assumptions they made. Similarly, internal surveys, industry forecasts and market research, which we believe to be
reliable based upon our management’s knowledge of our industry, have not been independently verified. Our estimates involve risks and
uncertainties, including assumptions that may prove not to be accurate, and these estimates and certain industry data are subject to change
based  on  various  factors,  including  those  discussed  under  “Risk  Factors”  in  this  annual  report.  While  we  believe  our  internal  business
research is reliable and the market definitions we use in this annual report are appropriate, neither our business research nor the definitions
we use have been verified by any independent source. This annual report may only be used for the purpose for which it has been published.

We own or have rights to trademarks, service marks or trade names that we use in connection with the operation of our business. In
addition,  our  name,  logo  and  website  names  and  addresses  are  our  service  marks  or  trademarks.  CaPre®  and  the  phrase  “BREAKING
DOWN  THE  WALLS  OF  CHOLESTEROL”  are  our  registered  trademarks.  The  other  trademarks,  trade  names  and  service  marks
appearing  in  this  annual  report  are  the  property  of  their  respective  owners.  Solely  for  convenience,  the  trademarks,  service  marks,
tradenames and copyrights referred to in this annual report are listed without the ©, ® and TM symbols, but we will assert, to the fullest
extent under applicable law, our rights or the rights of the applicable licensors to these trademarks, service marks and tradenames.

Financial Information

All financial information in this annual report is presented in accordance with International Financial Reporting Standards, or IFRS,

as issued by the International Accounting Standards Board, or IASB.

We  use  multiple  financial  measures  for  the  review  of  our  operating  performance.  These  measures  are  generally  IFRS  financial
measures, but one adjusted financial measure, Non-IFRS operating loss (adding to net loss, finance expenses, depreciation and amortization
and impairment loss, change in fair value of derivative warrant liabilities, stock-based compensation and by subtracting finance income and
deferred  income  tax  recovery),  is  also  used  to  assess  our  operating  performance.  This non-IFRS  financial  measure  is  derived  from  our
financial  statements  and  is  presented  in  a  consistent  manner.  We  use  this  measure,  in  addition  to  the  IFRS  financial  measures,  for  the
purposes of evaluating our historical and prospective financial performance, as well as our performance relative to competitors. All of these
measures also help us to plan and forecast future periods as well as to make operational and strategic decisions. We believe that providing
this Non-IFRS information to investors, in addition to IFRS measures, allows them to see our results through the eyes of our management,
and  to  better  understand  our  historical  and  future  financial  performance.  See  “Item  5.  Operating  and  Financial  Review  and  Prospects”,
including for a reconciliation to net loss.

In this annual report, all references to “CA$” or “$” are to Canadian dollars, unless expressly otherwise stated. All amounts related

to our financial results are presented in thousands of Canadian dollars, except where noted and per share amounts.

Exchange Rate Information

The following table presents the average exchange rate for one Canadian dollar expressed as one U.S. dollar for each of our last

five fiscal years. The average rate is calculated using the average of the exchange rates on the last day of each month during the period.

3

 
Table of Contents

Fiscal Year Ended

February 28, 2013
February 28,2014
February 28, 2015
February 29, 2016
March 31, 2017

   Average  
(US$)   
0.9903   
0.9555   
0.8003   
0.7645   
0.7618   

The following table presents the high and low exchange rate for one Canadian dollar expressed as one U.S. dollar for each month

during the previous six months.

Month

November 2016
December 2016
January 2017
February 2017
March 2017
April 2017
May 2017

Low     

High

(US$)

   0.7359     
   0.7354     
   0.7431     
   0.7520     
   0.7388     
   0.7301     
   0.7276     

0.7520
0.7645
0.7711
0.7704
0.7539
0.7559
0.7437

The exchange rates are based upon the noon buying rate, as quoted by the Bank of Canada. As of May 1, 2017, the Bank of Canada
no  longer  publishes  updated  data  for  exchange  rates  published  under  previous  methodologies,  including  daily  noon  and  closing  rates  as
well  as  high  and  low  exchange  rates.  For  the  month  of  May  2017,  the  exchange  rate  presented  above  is  based  upon  the  daily  average
closing rate. As of June 26, 2017, the exchange rate for one Canadian dollar expressed as one U.S. dollar, as quoted by the Bank of Canada
was $1.00 = US$0.7554.

SPECIAL NOTE REGARDING FORWARD-LOOKING STATEMENTS

This annual report contains information that may be forward-looking information within the meaning of Canadian securities laws
and  forward-looking  statements  within  the  meaning  of  U.S.  federal  securities  laws,  both  of  which  we  refer  to  in  this  annual  report  as
forward-looking information. Forward-looking information can be identified by the use of terms such as “may”, “will”, “should”, “expect”,
“plan”, “anticipate”, “believe”, “intend”, “estimate”, “predict”, “potential”, “continue” or other similar expressions concerning matters that
are  not  statements  about  the  present  or  historical  facts.  Forward-looking  information  in  this  annual  report  includes,  among  other  things,
information or statements about:

•

•

•

•

•

•

•

•

•

  our ability to conduct all required clinical and nonclinical trials for CaPre, including the timing and results of those clinical
trials;

  our strategy, future operations, prospects and the plans of our management;

  the design, regulatory plan, timeline, costs and results of our clinical and nonclinical trials for CaPre;

  the timing and outcome of our meetings and discussions with the U.S. Food and Drug Administration, or FDA;

  our planned regulatory filings for CaPre, and their timing;

  our expectation that our Bridging Study (as defined below) results will support our plan to get authorization from the FDA to
use the its 505(b)(2) pathway with new chemical entity, or NCE, status towards a New Drug Application, or NDA, approval
in the United States;

  the timing and results from two competitor outcomes studies in mild to moderate hypertriglyceridemia, or HTG, patients;

  the potential benefits and risks of CaPre as compared to other products in the pharmaceutical, medical food and natural health
products markets;

  our  anticipated  marketing  advantages  and  product  differentiation  of  CaPre  and  its  potential  to  become  the best-in-class
omega-3, or OM3, compound for the treatment of severe HTG;

4

 
 
  
  
  
  
  
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

•

•

•

•

•

•

•

•

•

•

•

•

•

  our  estimates  of  the  size  of  the  potential  market  for  CaPre,  unmet  medical  needs  in  that  market,  the  potential  for  market
expansion, and the rate and degree of market acceptance of CaPre if it reaches commercialization, and our ability to serve that
market;

  the potential to expand CaPre’s indication for the treatment of mild to moderate HTG;

  the degree to which physicians would switch their patients to a product with CaPre’s target product profile;

  our strategy and ability to develop, commercialize and distribute CaPre in the United States and elsewhere;

  the manufacturing scale-up of CaPre and the related timing;

  our intention and ability to strengthen our patent portfolio and other means of protecting our intellectual property rights;

  the availability, consistency and sources of our raw materials, including krill oil;

  our expectation to be able to rely on third parties to manufacture CaPre whose manufacturing processes and facilities are in

compliance with current good manufacturing practices, or cGMP;

  the potential for OM3s in other cardiovascular medicine, or CVM, indications;

  our  intention  to  pursue  development  and/or  distribution  partnerships  to  support  the  development  and  commercialization  of

CaPre, and to pursue strategic opportunities to provide capital and market access;

  our need for additional financing and our estimates regarding our future financing and capital requirements;

  our expectation regarding our financial performance, including our revenues, profitability, research and development, costs

and expenses, gross margins, liquidity, capital resources and capital expenditures; and

  our projected capital requirements to fund our anticipated expenses, including our research and development and general and
administrative expenses.

Although  the  forward-looking  information  in  this  annual  report  is  based  upon  what  we  believe  are  reasonable  assumptions,  you
should  not  place  undue  reliance  on  that  forward-looking  information  since  actual  results  may  vary  materially  from  it.  Important
assumptions by us when making forward-looking statements include, among other things, assumptions by us that:

•

•

•

•

•

•

•

•

•

•

  we successfully and timely complete all required clinical and nonclinical trials necessary for regulatory approval of CaPre;

  we successfully enroll patients in our Phase 3 program;

  the timeline and costs for our clinical programs are not materially underestimated or affected by unforeseen circumstances;

  CaPre is safe and effective;

  the  FDA  confirms  our  505(b)(2)  regulatory  pathway  with  NCE  status  towards  NDA  approval  in  the  United  States  and  we
finalize the protocols for our Phase 3 program for CaPre within our anticipated timeframe;

  outcome study data from two of our competitors in mild to moderate HTG patients is positive;

  we obtain and maintain regulatory approval for CaPre on a timely basis;

  we are able to attract, hire and retain key management and skilled scientific personnel;

  third parties provide their services to us on a timely and effective basis;

  we are able to maintain our required supply of raw materials, including krill oil;

5

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

•

•

•

•

•

•

•

•

•

•

•

•

•

•

  we are able to find and retain a third-party to manufacture CaPre in compliance with cGMP;

  we are able to secure distribution arrangements for CaPre, if it reaches commercialization;

  we are able to manage our future growth effectively;

  we are able to gain acceptance of CaPre in its markets and we are able to serve those markets;

  our patent portfolio is sufficient and valid;

  we are able to secure and defend our intellectual property rights and to avoid infringing upon the intellectual property rights

of third parties;

  we are able to take advantage of business opportunities in the pharmaceutical industry and receive strategic partner support;

  we are able to continue as a going concern;

  we are able to obtain additional capital and financing, as needed, on favorable terms;

  there is no significant increase in competition for CaPre from other companies in the pharmaceutical, medical food and natural

health product industries;

  CaPre would be viewed favorably by payers at launch and receive appropriate healthcare reimbursement;

  market data and reports reviewed by us are accurate;

  there are no adverse changes in relevant laws or regulations; and

  we face no product liability lawsuits and other proceedings or any such matters, if they arise, are satisfactorily resolved.

In addition, the forward-looking information in this annual report is subject to a number of known and unknown risks, uncertainties
and other factors, including those described in this annual report under the heading “Item 3.D. Risk Factors”, many of which are beyond
our  control,  that  could  cause  our  actual  results  and  developments  to  differ  materially  from  those  that  are  disclosed  in  or  implied  by  the
forward-looking information, including, among others:

•

•

•

•

•

•

•

•

•

•

•

  risks related to timing and possible difficulties, delays or failures in our planned Phase 3 program for CaPre;

  pre-clinical and clinical trials may be more costly or take longer to complete than anticipated, and may never be initiated or
completed, or may not generate results that warrant future development of CaPre;

  CaPre may not prove to be as safe and effective or as potent as we currently believe;

  our planned Phase 3 program may not produce positive results;

  our anticipated studies and submissions to the FDA may not occur as currently anticipated, or at all;

  the FDA could reject our 505(b)(2) regulatory pathway;

  outcome  study  data  from  two  of  our  competitors  in  mild  to  moderate  HTG  patients  may  be  negative,  which  could  also
negatively affect the market perception of CaPre;

  we  may  encounter  difficulties,  delays  or  failures  in  obtaining  regulatory  approvals  for  the  initiation  of  clinical  trials  or  to
market CaPre;

  we may need to conduct additional future clinical trials for CaPre, the occurrence and success of which cannot be assured;

  CaPre may have unknown side effects;

  the FDA may refuse to approve CaPre, or place restrictions on our ability to commercialize CaPre;

6

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

•

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•

•

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•

•

  CaPre could be subject to extensive post-market obligations and continued regulatory review, which may result in significant

additional expense and affect sales, marketing and profitability;

  we may fail to achieve our publicly announced milestones on time;

  we may encounter difficulties in completing the development and commercialization of CaPre;

  third parties we will rely upon to conduct our Phase 3 program for CaPre may not effectively fulfill their obligations to us,

including complying with FDA requirements;

  there may be difficulties, delays, or failures in obtaining health care reimbursements for CaPre;

  recently  enacted  and  future  laws  may  increase  the  difficulty  and  cost  for  us  to  obtain  marketing  approval  of  and

commercialize CaPre and affect the prices we can charge;

  new laws, regulatory requirements, and the continuing efforts of governmental and third-party payors to contain or reduce the

costs of healthcare through various means could adversely affect our business;

  the market opportunity for, and demand and market acceptance of, CaPre may not be as strong as we anticipate;

  third parties that we will rely upon to manufacture, supply and distribute CaPre may not effectively fulfill their obligations to

us, including complying with FDA requirements;

  there may not be an adequate supply of raw materials, including krill oil, in sufficient quantities and quality and to produce

CaPre under cGMP standards;

  Neptune has significant influence with respect to matters submitted to our shareholders for approval;

  Neptune’s interest may not align with those of us or our other shareholders;

  we  may  not  be  able  to  meet  applicable  regulatory  standards  for  the  manufacture  of  CaPre  or scale-up  our  manufacturing
successfully;

  we may not be able to produce clinical batches of CaPre in a timely manner or at all;

  as a company, we have limited sales, marketing and distribution experience;

  our patent applications may not result in issued patents, our issued patents may be circumvented or challenged and ultimately
struck down, and we may not be able to successfully protect our trade secrets or other confidential proprietary information;

  we may face claims of infringement of third party intellectual property and other proprietary rights;

  we may face product liability claims and product recalls;

  we face intense competition from other companies in the pharmaceutical, medical food and natural health product industries;

  we have a history of negative operating cash flow and may never become profitable or be able to sustain profitability;

  we have significant additional future capital needs and may not be able to raise additional financing required to fund further
research  and  development,  clinical  studies,  obtain  regulatory  approvals,  and  meet  ongoing  capital  requirements  to  continue
our current operations on commercially acceptable terms or at all;

  we may acquire businesses or products or form strategic partnerships in the future that may not be successful;

  we may be unable to secure development and/or distribution partnerships to support the development and commercialization of
CaPre, provide development capital, or market access;

  we rely on key management and skilled scientific personnel; and

  general changes in economic and capital market conditions could adversely affect us.

7

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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All of the forward-looking information in this annual report is qualified by this cautionary statement. There can be no guarantee
that the results or developments that we anticipate will be realized or, even if substantially realized, that they will have the consequences or
effects on our business, financial condition or results of operations that we anticipate. As a result, you should not place undue reliance on
the  forward-looking  information.  Except  as  required  by  applicable  law,  we  do  not  undertake  to  update  or  amend  any  forward-looking
information, whether as a result of new information, future events or otherwise. All forward-looking information is made as of the date of
this annual report.

Item 1.

Identity of Directors, Senior Management and Advisers

Not applicable.

Item 2. Offer Statistics and Expected Timetable

PART I

Not applicable.

Item 3. Key Information

A.

Selected Financial Data

The following information should be read in conjunction with “Item 5. Operating and Financial Review and Prospects” and our
audited financial statements and the related notes for our fiscal year ended March 31, 2017, which are prepared in accordance with IFRS as
issued by the IASB and are included in this annual report. The selected financial information below includes financial information derived
from our audited financial statements. Our historical results from any prior period are not necessarily indicative of results to be expected for
any future period. The following table is a summary of our selected consolidated financial information in accordance with IFRS as issued
by the IASB for each of our five most recently completed fiscal years.

Revenue from sales
Loss from operating activities
Net loss and total comprehensive

loss

Basic and diluted loss per share
Total assets
Total liabilities
Share capital
Warrants and rights
Weighted average number of

shares outstanding

Dividends declared per share

       March 31, 2017   
  $
nil   
(11,210)  
  $

  February 29, 2016   
nil     
$
(9,612)  
$

For the fiscal year ended
  February 28, 2015   
nil     
$
(12,395)  
$

  February 28, 2014   
$
501   
(10,800)  
$

  February 28, 2013    
724    
$
(6,980)   
$

  $
  $
  $
  $
  $
  $

(11,247)  
(1.01)  
25,456   
3,753   
66,576   
453   

$
$
$
$
$
$

(6,317)  
(0.59)  
28,517   
1,297   
61,973   
—   

$
$
$
$
$
$

(1,655)  
(0.16)  
37,208   
3,980   
61,628   
—   

$
$
$
$
$
$

(11,612)  
(1.38)  
45,632   
12,352   
61,027   
407   

$
$
$
$
$
$

(6,892)   
(0.95)   
12,170    
2,446    
28,923    
407    

11,094,512   
—   

10,659,936   
—   

10,617,704   
—   

8,436,893   
—   

7,275,444    
—    

B.

Capitalization and Indebtedness

Not applicable.

C.

Reasons for the Offer and Use of Proceeds

Not applicable.

8

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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D. Risk Factors

Investing in our securities involves a high degree of risk due to, among other things, the nature of our business and the present
stage of our development. Prospective and current investors should carefully consider the following risks and uncertainties, together with
all other information in this annual report, as well as our financial statements included in this annual report and “Item 5. Operating and
Financial Review and Prospects.” If any of these risks actually occur, our business, financial condition, prospects, results of operations or
cash flow could be materially and adversely affected and you could lose all or a part of the value of your investment. Additional risks or
uncertainties not currently known to us, or that we currently deem immaterial, may also negatively affect our business operations.

Risks Facing Our Business and Industry

We may not be able to maintain our operations and advance our research and development of CaPre without additional funding.

We  have  incurred  operating  losses  and  negative  cash  flows  from  operations  since  our  inception.  To  date,  we  have  financed  our
operations through public offerings and private placements of securities, proceeds from exercises of warrants, rights and options, and receipt
of  research  tax  credits.  Our  cash  and  cash  equivalents  (including  restricted  investments)  were  $9.8  million  as  of  March  31,  2017  and
$12.6 million as of February 29, 2016. We will require substantial additional funds to conduct further research and development and our
planned Phase 3 program, obtain regulatory approvals and commercialize CaPre. In addition to completing nonclinical and clinical trials,
we expect that additional time and capital will be required by us to file an NDA to obtain FDA approval for CaPre in the United States and
to  complete  marketing  and  other pre-commercialization  activities.  We  will  also  most  likely  require  additional  capital  to  fund  our  daily
operating needs. To achieve our business plan, we will need to raise the necessary capital primarily through additional securities offerings
and  strategic  alliances.  We  have  no  committed  source  of  additional  capital  from  our  parent  company,  Neptune  Technologies  and
Bioressources Inc., or Neptune, which owns approximately 34% of our common shares, or any other party, and if we are unable to raise
additional  capital  in  sufficient  amounts  or  on  terms  acceptable  to  us,  we  may  have  to  significantly  delay,  scale  back  or  discontinue  our
development or commercialization of CaPre or our other research and development initiatives. Funding needs could also force us to seek
strategic partners for CaPre at an earlier stage than we desire or on terms that are less favorable to us or force us to relinquish or license our
rights  to  CaPre  on  unfavorable  terms  or  in  markets  where  we  would  prefer  to  pursue  development  or  commercialization  ourselves.
Additional funding from third parties may not be available on acceptable terms or at all to enable us to continue and complete our research
and development of CaPre.

Our  financial  statements  have  been  prepared  on  a  going-concern  basis,  which  assumes  we  will  continue  our  operations  in  the
foreseeable future and will be able to realize our assets and discharge our liabilities and commitments in the ordinary course of business. If
we are unable to continue as a going concern, material writedowns to the carrying value of our assets, including intangible assets, could be
required. If we fail to obtain additional financing, we may not be able to continue as a going concern.

We may never become profitable or be able to sustain profitability.

We are a clinical-stage biopharmaceutical company with a limited operating history. The likelihood of success of our business plan
must be considered in light of the problems, expenses, difficulties, complications and delays frequently encountered when developing and
expanding  early-stage  businesses  and  the  regulatory  and  competitive  environment  in  which  we  operate.  Biopharmaceutical  product
development is a highly speculative undertaking, involves a substantial degree of risk and is a capital-intensive business. We expect to incur
expenses  without  any  meaningful  corresponding  revenues  unless  and  until  we  are  able  to  obtain  regulatory  approval  and  sell  CaPre  in
significant quantities. We have been engaged in developing CaPre since 2008. To date, we have not generated any revenue from CaPre, and
we may never be able to obtain regulatory approval for marketing CaPre in any indication. Even we are able to commercialize CaPre, we
may  still  not  generate  significant  revenues  or  achieve  profitability.  We  have  incurred  net  losses  of  $11.2  million  for  the  thirteen  month
period ended March 31, 2017, and $6.3 million and $1.7 million for our fiscal years ended 2016 and 2015, respectively. As of March 31,
2017, we had an accumulated deficit of $50.9 million.

If we obtain FDA approval for CaPre, we expect that our expenses will increase as we prepare for the commercial launch of CaPre.
We  also  expect  that  our  research  and  development  expenses  will  continue  to  increase  if  we  pursue  FDA  approval  for  CaPre  for  other
indications. As a result, we expect to continue to incur substantial

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losses  for  the  foreseeable  future,  and  these  losses  may  be  increasing.  We  are  uncertain  about  when  or  if  we  will  be  able  to  achieve  or
sustain profitability. If we fail to become and remain profitable our ability to sustain our operations and to raise capital could be impaired
and the price of our common shares could decline.

We have no marketing and sales organization and, as a company, no experience in marketing products. If we are unable to establish
marketing  and  sales  capabilities  or  enter  into  agreements  with  a  strategic  partner  to  market  and  sell  CaPre,  we  may  not  be  able  to
generate revenue.

We have no sales, marketing or distribution capabilities and, as a company, we have no experience in marketing products. If CaPre
or  another  of  our  future  product  candidates  is  approved  for  commercialization,  unless  we  find  a  strategic  partner  to  assist  us  with  sales,
marketing and distribution, we will be required to develop in-house marketing and sales force capability, which would require significant
capital  expenditures,  management  resources  and  time. Also,  we  would  have  to  compete  with  other  biotechnology  and  pharmaceutical
companies to recruit, hire, train and retain marketing and sales personnel. We face competition in our search for strategic partners to assist
us with sales, marketing and distribution, and we may not be able to establish or maintain any such arrangements. If we do find a strategic
partner, any revenue we receive from CaPre would partly depend upon the efforts of that strategic partner, which may not be successful.
We may have little or no control over the marketing and sales efforts by any strategic partner we find for CaPre and our revenue may be
lower than if we had commercialized CaPre independently.

If  we  are  not  successful  in  attracting  and  retaining  highly  qualified  personnel,  we  may  not  be  able  to  successfully  implement  our
business strategy.

Our  ability  to  compete  in  the  highly  competitive  pharmaceuticals  industry  largely  depends  upon  our  ability  to  attract  and  retain
highly qualified managerial, scientific and medical personnel. Competition for skilled personnel in our market is intense and competition
for experienced scientists may limit our ability to hire and retain highly qualified personnel on acceptable terms. We are highly dependent
on  our  management,  scientific  and  medical  personnel.  Despite  our  efforts  to  retain  valuable  employees,  members  of  our  management,
scientific and medical teams may terminate their employment with us on short notice or, potentially, without any notice at all. The loss of
the  services  of  any  of  our  executive  officers  or  other  key  employees  could  potentially  harm  our  business,  operating  results  or  financial
condition. Our success may also depend on our ability to attract, retain and motivate highly skilled junior, mid-level, and senior managers
and scientific personnel. In addition, we do not maintain “key person” insurance policies on the lives of our executives or those of any of
our  other  employees.  Other  pharmaceutical  companies  with  which  we  compete  for  qualified  personnel  have  greater  financial  and  other
resources, different risk profiles, and a longer history in the industry than we do. They also may provide more diverse opportunities and
better chances for career advancement. Some of these characteristics may be more appealing to high-quality candidates than what we can
offer.  If  we  are  unable  to  continue  to  attract  and  retain  high-quality  personnel,  the  rate  and  success  at  which  we  can  develop  and
commercialize CaPre and any other future product candidates would be limited.

Neptune has significant influence over matters we put to a vote of our shareholders.

Neptune currently owns approximately 34% of our outstanding common shares and we are a subsidiary of Neptune. As a result,
Neptune has significant influence with respect to all matters submitted to our shareholders for approval, such as the election and removal of
directors, amendments to our articles of incorporation and by-laws and the approval of certain business combinations. This concentration of
holdings  may  cause  the  market  price  of  our  common  shares  to  decline,  delay  or  prevent  any  acquisition,  delay  or  discourage  take-over
attempts that shareholders may consider to be favourable, or make it more difficult or impossible for a third party to acquire control of us
or  effect  a  change  in  our  board  of  directors  and  management. Any  delay  or  prevention  of  a  change  of  control  transaction  could  deter
potential  acquirors  or  prevent  the  completion  of  a  transaction  in  which  our  shareholders  could  receive  a  premium  over  the  then  current
market price for our common shares.

Neptune’s interests may not align with those of us or our other shareholders.

Neptune’s interests may not in all cases be aligned with interests of us or our other shareholders. Neptune may have an interest in
pursuing acquisitions, divestitures and other transactions that may ultimately be detrimental to our business and negatively affect the market
price of our common shares.

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Business disruptions could seriously harm our future revenue and financial condition and increase our costs and expenses.

Our  operations,  and  those  of  our  suppliers,  third  party  manufacturers  and  other  contractors  and  consultants  could  be  subject  to
earthquakes,  power  shortages,  telecommunications  failures,  water  shortages,  floods,  hurricanes,  typhoons,  fires,  extreme  weather
conditions,  medical  epidemics  and  other  natural  or man-made  disasters  or  business  interruptions,  for  which  we  are  predominantly  self-
insured. The occurrence of any of these business disruptions could seriously harm our operations and financial condition and increase our
costs and expenses. We rely on third-party manufacturers to manufacture CaPre. Our ability to obtain supplies of CaPre could be disrupted
if the operations of our manufacturers and suppliers are affected by a man-made or natural disaster or other business interruption.

Our  prospects  currently  depend  entirely  on  the  success  of  CaPre,  which  is  still  in  clinical  development,  and  we  may  not  be  able  to
generate revenues from CaPre.

We have no prescription drug products that have been reviewed or approved by the FDA, Health Canada or any similar regulatory
authority. Our only prescription drug candidate is CaPre, for which we have not yet filed an NDA, and for which we must conduct a Phase 3
program, undergo further development activities and seek and receive regulatory approval prior to commercial launch, which we do not
anticipate will occur until 2021 at the earliest. We have invested significant effort and financial resources in researching and developing
CaPre.  Further  development  of  CaPre  will  require  substantial  investment,  access  to  sufficient  commercial  manufacturing  capacity  and
significant marketing efforts before we can generate any revenue from sales of CaPre, if it is ever approved for commercialization.

We do not have any other prescription drug candidates in development and so our business prospects currently depend entirely on
the  successful  development,  regulatory  approval  and  commercialization  of  CaPre,  which  may  never  occur.  Most  prescription  drug
candidates  never  reach  the  clinical  development  stage  and  even  those  that  do  reach  clinical  development  have  only  a  small  chance  of
successfully completing clinical development and gaining regulatory approval. If we are unable to successfully commercialize CaPre, we
may never generate meaningful revenues. In addition, if CaPre reaches commercialization and there is low market demand for CaPre or the
market  for  CaPre  develops  less  rapidly  than  we  anticipate,  we  may  not  have  the  ability  to  shift  our  resources  to  the  development  of
alternative products.

If we encounter difficulties enrolling patients in our planned Phase 3 program, our development activities for CaPre could be delayed or
otherwise adversely affected.

We may experience difficulties in patient enrollment in our clinical trials, including our planned Phase 3 program for CaPre, for a
variety of reasons. Timely completion of our clinical trials in accordance with their protocols depends, among other things, on our ability to
enroll  a  sufficient  number  of  patients  who  remain  in  the  trial  until  its  conclusion.  The  enrollment  of  patients  depends  on  many  factors,
including:

•

•

•

•

•

•

•

•

•

  the  number  of  clinical  trials  for  other  product  candidates  in  the  same  therapeutic  area  that  are  currently  in  clinical
development, and our ability to compete with those trials for patients and clinical trial sites;

  patient eligibility criteria defined in the protocol;

  the size of the patient population;

  the risk that disease progression will result in death before the patient can enroll in clinical trials or before the completion of
any clinical trials in which the patient is enrolled;

  the proximity and availability of clinical trial sites for prospective patients;

  the design of the trial;

  our ability to recruit clinical trial investigators with the appropriate competencies and experience;

  our ability to obtain and maintain patient consents; and

  the risk that patients enrolled in clinical trials will drop out of the trials before completion.

Our  planned  Phase  3  program  for  CaPre  may  compete  with  other  clinical  trials  for  product  candidates  that  are  in  the  same
therapeutic areas as CaPre. This competition could reduce the number and types of patients and qualified clinical investigators available to
us, because some patients who might have opted to enroll in our Phase 3 program may instead opt to enroll in a trial being conducted by
one of our competitors or a clinical trial site may not allow us to conduct our clinical program at that site if competing trials are already
being conducted there. We may

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also encounter difficulties finding adequate clinical trial sites at which to conduct our Phase 3 program. Delays in patient enrollment may
result in increased costs or may affect the timing or outcome of our planned Phase 3 program, which could impair or prevent its completion
and adversely affect our ability to advance the development of CaPre.

We may not be able to obtain required regulatory approvals for CaPre.

We  have  limited  experience  in  conducting  and  managing  the  clinical  trials  necessary  to  obtain  regulatory  approvals,  including
approval by the FDA and, as a company, we have no experience in obtaining approval of any product candidates. The research, testing,
manufacturing,  labeling,  packaging,  storage,  sale,  marketing,  pricing,  export,  import  and  distribution  of  prescription  drug  products  are
subject to extensive regulation by the FDA and other regulatory authorities in the United States and other countries and those regulations
differ from country to country. We are not permitted to market CaPre in the United States until we receive approval of an NDA from the
FDA and similar restrictions apply in other countries. In the United States, the FDA generally requires the completion of preclinical testing
and clinical trials of each drug to establish its safety and efficacy and extensive pharmaceutical development to ensure its quality before an
NDA is approved. Regulatory authorities in other jurisdictions impose similar requirements. Of the large number of drugs in development,
only a small percentage result in the submission of an NDA to the FDA and even fewer are approved for commercialization. To date, we
have not submitted an NDA for CaPre to the FDA or comparable applications to other regulatory authorities.

Our receipt of required regulatory approvals for CaPre is uncertain and subject to a number of risks, including:

•

•

•

•

•

•

•

•

•

  the FDA or comparable foreign regulatory authorities or independent institutional review boards, or IRBs, may disagree with

the design or implementation of our clinical trials;

  we may not be able to provide acceptable evidence of the safety and efficacy of CaPre;

  the  results  of  our  clinical  trials  may  not  meet  the  level  of  statistical  or  clinical  significance  required  by  the  FDA  or  other

regulatory agencies for marketing approval;

  the dosing of CaPre in a particular clinical trial may not be at an optimal level;

  patients in our clinical trials may suffer adverse effects for reasons that may or may not be related to CaPre;

  we may be unable to demonstrate that CaPre’s clinical and other benefits outweigh its safety risks;

  the data collected from our clinical trials may not be sufficient to support the submission of an NDA for CaPre or to obtain
regulatory approval for CaPre in the United States or elsewhere;

  the FDA or comparable foreign regulatory authorities may not approve the manufacturing processes or facilities of third party
manufacturers with which we contract for clinical and commercial supplies of CaPre; and

  the approval policies or regulations of the FDA or comparable foreign regulatory authorities  may  significantly  change  in  a
manner rendering our clinical data insufficient for approval.

The FDA and other similar regulators have substantial discretion in the approval process and may refuse to accept our application
or  may  decide  that  our  data  is  insufficient  for  approval  and  require  additional  clinical  trials,  or  preclinical  or  other  studies  for  CaPre.  If
regulatory approval for CaPre is obtained in one jurisdiction, that does not necessarily mean that CaPre will receive regulatory approval in
all  jurisdictions  in  which  we  seek  approval.  If  we  fail  to  obtain  approval  for  CaPre  in  one  or  more  jurisdictions,  our  ability  to  obtain
approval in a different jurisdiction may be negatively affected.

Even if we receive regulatory approval for CaPre, it may just be for a limited indication.

If we obtain regulatory approval for CaPre, we will only be permitted to market it for the indication approved by the FDA, and any
such  approval  may  put  limits  on  the  indicated  uses  or  promotional  claims  we  may  make  for  it,  or  otherwise  not  permit  labeling  that
sufficiently differentiates CaPre from competitive products with comparable therapeutic profiles. For example, while our initial objective is
to seek regulatory approval for the treatment of severe HTG, afterwards obtaining approval for CaPre to address mild to moderate HTG
could greatly expand our potential market for CaPre. However, even if CaPre is approved for severe HTG, it may never be

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approved  for  the  treatment  of  mild  to  moderate  HTG.  In  addition,  any  approval  we  receive  for  CaPre  could  contain  significant  use
restrictions for specified age groups, warnings, precautions or contraindications, or may be subject to burdensome post-approval study or
risk  management  requirements.  If  any  regulatory  approval  for  CaPre  contains  significant  limits,  we  may  not  be  able  to  obtain  sufficient
funding or generate meaningful revenue from CaPre or be able to continue developing, marketing or commercializing CaPre.

We may be unable to find successful strategic partnerships to develop and commercialize CaPre.

We  intend  to  seek co-development,  licensing  and/or  marketing  partnership  opportunities  with  third  parties  that  we  believe  will
complement or augment our development and commercialization efforts for CaPre. Entering into partnership relationships may require us to
incur non-recurring and other charges, increase our near and long-term expenditures, issue securities that dilute our existing shareholders or
disrupt  our  management  and  business.  Entering  into  partnership  relationships  could  also  delay  the  development  of  CaPre  and  our  other
future product candidates if we become dependent upon a strategic partner and that strategic partner does not prioritize the development of
CaPre  relative  to  its  other  development  activities.  In  addition,  we  face  significant  competition  in  seeking  strategic  partners  and  the
negotiation process is time-consuming and complex. We may not be successful in our efforts to establish a strategic partnership or other
alternative  arrangements  for  CaPre  on  our  anticipated  timeline,  or  at  all,  because  CaPre  may  be  deemed  to  be  at  too  early  of  a  stage  of
development  for  collaborative  effort  and  third  parties  may  not  view  CaPre  as  having  the  requisite  potential  to  demonstrate  safety  and
efficacy. Even if we do enter into strategic partnerships, those partnerships may not achieve our objectives.

We may be unable to develop alternative product candidates.

To date, we have not commercialized any prescription drug candidates and, other than CaPre, we do not have any compounds in
clinical trials, nonclinical testing, lead optimization or lead identification stages. If we fail to obtain regulatory approval for and successfully
commercialize CaPre as a treatment for severe HTG or any other indication, whether as a stand-alone therapy or in combination with other
treatments,  we  would  have  to  develop,  acquire  or  license  alternative  product  candidates  or  drug  compounds  to  expand  our  product
candidate pipeline beyond CaPre. In such a scenario, we may not be able to identify and develop or acquire product candidates that prove to
be successful products, or to develop or acquire them on terms that are acceptable to us.

We may not be able to compete effectively against our competitors’ pharmaceutical products.

The  biotechnology  and  pharmaceutical  industries  are  highly  competitive.  There  are  many  pharmaceutical  companies,
biotechnology companies, public and private universities and research organizations actively engaged in the research and development of
products that may be similar to CaPre. It is probable that the number of companies seeking to develop products and therapies similar to
CaPre  will  increase.  Many  of  these  and  other  existing  or  potential  competitors  have  substantially  greater  financial,  technical  and  human
resources  than  we  do  and  may  be  better  equipped  to  develop,  manufacture  and  market  products.  These  companies  may  develop  and
introduce products and processes competitive with or superior to CaPre. In addition, other technologies or products may be developed that
have  an  entirely  different  approach  or  means  of  accomplishing  the  intended  purposes  of  CaPre,  which  might  render  our  technology  and
CaPre non-competitive or obsolete.

Our  competitors  in  the  United  States  and  globally  include  large,  well-established  pharmaceutical  companies,  specialty
pharmaceutical sales and marketing companies, and specialized cardiovascular treatment companies. GlaxoSmithKline plc, which currently
sells LOVAZA, a prescription-only OM3 fatty acid indicated for patients with severe HTG, was approved by FDA in 2004 and has been on
the market in the United States since 2005. Multiple generic versions of LOVAZA are now available in the United States. Amarin launched
its prescription-only OM3 drug VASCEPA in 2013, and reached a market share of approximately 20% by the end of 2015. In addition,
EPANOVA (OM3-carboxylic acids) capsules, a free fatty acid form of OM3 (comprised of 55% EPA and 20% DHA), is  FDA-approved
for patients with severe HTG. Omtryg, another OM3 fatty acid composition developed by Trygg Pharma AS, received FDA approval for
severe HTG. Neither EPANOVA nor Omtryg have yet been commercially launched, but could launch at any time. Other large companies
with products competing indirectly with CaPre include AbbVie, Inc., which currently sells Tricor and Trilipix for the treatment of severe
HTG, and Niaspan, which is primarily used to raise HDL-C but is also used to lower TGs. Generic versions of Tricor, Trilipix and Niaspan
are also now available in the United States. In addition, we are aware of a number of other pharmaceutical companies that are developing
products that, if approved and marketed, would compete with CaPre.

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Even  if  it  receives  regulatory  approval,  CaPre  may  need  to  demonstrate  compelling  comparative  advantages  in  efficacy,
convenience,  tolerability  and  safety  to  be  commercially  successful.  Other  competitive  factors,  including  generic  drug  competition,  could
force  us  to  lower  prices  or  could  result  in  reduced  sales  of  CaPre.  In  addition,  new  products  developed  by  others  could  emerge  as
competitors to CaPre. If we are not able to compete effectively against our current and future competitors, our business will not grow and
our financial condition and operations will suffer.

CaPre could face competition from products for which no prescription is required.

If  it  receives  regulatory  approval,  CaPre  will  be  a  prescription-only  OM3.  Mixtures  of  OM3  fatty  acids  are  naturally  occurring
substances in various foods, including fatty fish. OM3 fatty acids are also marketed by other companies as dietary supplements or natural
health products. Dietary supplements may generally be marketed without a lengthy FDA premarket review and approval process and do not
require a prescription. However, unlike prescription drug products, manufacturers of dietary supplements may not make therapeutic claims
for  their  products;  dietary  supplements  may  be  marketed  with  claims  describing  how  the  product  affects  the  structure  or  function  of  the
body without premarket approval, but may not expressly or implicitly represent that the dietary supplement will diagnose, cure, mitigate,
treat,  or  prevent  disease.  We  cannot  be  certain  that  physicians  or  consumers  will  view  CaPre  as  superior  to  these  alternatives  or  that
physicians will be more likely to prescribe CaPre. If the price of CaPre is significantly higher than the prices of commercially available
OM3  fatty  acids  marketed  by  other  companies  as  dietary  supplements  or  natural  health  products,  physicians  may  recommend  these
commercial  alternatives  instead  of  CaPre  or  patients  may  elect  on  their  own  to  take  commercially  available non-prescription  OM3  fatty
acids. Either of these outcomes could limit how we price CaPre and negatively affect our revenues.

If outcome studies being conducted by two of our competitors testing the impact of OM3 on treating patients with mild to moderate HTG
are negative, there could also be an adverse impact for CaPre.

We are currently awaiting outcome study data from two of our competitors that are testing the effects of OM3 on patients with mild
to moderate HTG. If those studies show that OM3 effectively treats patients with mild to moderate HTG, we believe that the potential to
expand CaPre’s indication in the future to include the treatment of moderate to high HTG would be significantly advanced. Conversely, if
outcome study data from one or both of those competitors is negative, or if one or both clinical trials fail to be completed, our potential
target market for CaPre could be limited solely to  patients  with  severe  HTG  and  our  ability  to  realize  greater  market  potential  of  CaPre
could be harmed.

Recent  and  future  legal  developments  could  make  it  more  difficult  and  costly  for  us  to  obtain  regulatory  approvals  for  CaPre  and
negatively affect the prices we may charge.

In the United States and elsewhere, recent and proposed legal and regulatory changes to healthcare systems could prevent or delay
our receipt of regulatory approval for CaPre, restrict or regulate our post-approval marketing activities, and adversely affect our ability to
profitably sell CaPre. Proposals have also been made to expand post-approval requirements and to restrict sales and promotional activities
for pharmaceutical products. We do not know whether additional legislative changes will be enacted, or whether the FDA’s regulations,
guidance or interpretations will be changed, or what impact any such changes will have, if any, on our ability to obtain regulatory approvals
for CaPre. Further, the Centers for Medicare and Medicaid Services, or CMS, frequently changes product descriptors, coverage policies,
product and service codes, payment methodologies and reimbursement values. Also, increased scrutiny by the U.S. Congress of the FDA’s
approval process could significantly delay or prevent our receipt of regulatory approval for CaPre and subject us to more stringent product
labeling and post-marketing testing and other requirements.

In  the  United  States,  the  Medicare  Modernization  Act,  or  the  MMA,  changed  the  way  Medicare  covers  and  pays  for
pharmaceutical products. The MMA expanded Medicare coverage for drug purchases by the elderly and introduced a new reimbursement
methodology  based  on  average  sales  prices  for  drugs.  In  addition,  the  MMA  authorized  Medicare  Part  D  prescription  drug  plans  to  use
formularies  where  they  can  limit  the  number  of  drugs  that  will  be  covered  in  any  therapeutic  class. As  a  result  of  the  MMA  and  the
expansion of federal coverage of drug products, we expect there will be additional pressure to contain and reduce healthcare costs. These
healthcare  cost  reduction  initiatives  and  other  provisions  of  the  MMA  could  decrease  the  coverage  and  price  that  we  would  receive  for
CaPre. While the MMA applies only to drug benefits for Medicare beneficiaries, private health insurance companies often follow Medicare
coverage policy and payment limitations in setting their own reimbursement rates, and any reduction in reimbursement that results from the
MMA may result in a similar reduction in payments from private health insurance companies.

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The Patient Protection and Affordable Care Act, as amended by the Health Care and Education Affordability Reconciliation Act
(the  Health  Care  Reform  Law),  has  broadened  access  to  health  insurance,  reduced  or  constrained  the  growth  of  healthcare  spending,
enhanced  remedies  against  fraud  and  abuse,  added  new  transparency  requirements  for  the  healthcare  and  health  insurance  industries,
imposed new taxes and fees on the health industry and imposed additional health policy reforms. Provisions of the Health Care Reform
Law  affecting  pharmaceutical  companies  include  requirements  to  offer  discounts  on  brand-name  drugs  to  patients  who  fall  within  the
Medicare  Part  D  coverage  gap,  commonly  referred  to  as  the  “donut  hole”,  and  to  pay  an  annual non-tax  deductible  fee  to  the  federal
government based on each company’s market share of prior year total sales of branded products to certain federal healthcare programs, such
as Medicare, Medicaid, Department of Veterans Affairs and Department of Defense.

Despite  initiatives  to  invalidate  the  Health  Care  Reform  Law,  the  U.S.  Supreme  Court  has  upheld  key  aspects  of  it.  Due  to  the
results of the recent presidential election, the Health Care Reform Law may be significantly changed and we do not know whether any such
changes  could  have  significant  negative  financial  impact  on  the  development  or  potential  profitability  of  CaPre. At  this  time,  it  remains
unclear whether there will be any changes made to the Health Care Reform Law, whether to certain provisions or its entirety. The Health
Care  Reform  Law  or  any  replacement  of  it  could  continue  to  apply  downward  pressure  on  pharmaceutical  pricing,  especially  under  the
Medicare program, and may also increase our regulatory burdens and operating costs. Additional federal healthcare reform measures could
be adopted in the future limiting the amounts that federal and state governments will pay for healthcare products and services, which could
negatively affect the value of CaPre and our ability to achieve profitability.

In Canada, most new patented drug prices are limited so that the cost of therapy is in the range of the cost of therapy for existing

drugs sold in Canada used to treat the same disease. As a result:

•

•

•

  prices of moderate and substantial improvement drugs and breakthrough drugs are also restricted by a variety of tests;

  existing patented drug prices cannot increase by more than the Canadian Consumer Price Index; and

  the Canadian prices of patented medicines can never be the highest in the world.

If CaPre receives regulatory approval in Canada, restrictions on the price we can charge there for CaPre could reduce the value of CaPre
and our ability to generate revenue and achieve profitability.

In many jurisdictions outside the United States, a product candidate must be approved for health care reimbursement before it can
be approved for sale. In some cases, the price that we intend to charge for CaPre will also be subject to approval. If we fail to comply with
the regulatory requirements in our target international markets or to receive required marketing approvals, our potential market for CaPre
will be reduced and our ability to realize the full market potential for CaPre will be harmed.

Reimbursement decisions by third-party payors may have an adverse effect on pricing and market acceptance. If there is not sufficient
reimbursement for CaPre, it is less likely that it will be widely used.

Even if CaPre is approved for sale by the appropriate regulatory authorities, market acceptance and sales of CaPre will depend on
reimbursement policies and may be affected by future healthcare reform measures. Government authorities and third-party payors, such as
private  health  insurers  and  health  maintenance  organizations,  decide  which  drugs  they  will  reimburse  and  establish  payment  levels.  We
cannot be certain that reimbursement will be available for CaPre. If reimbursement is not available or is available on a limited basis, we
may not be able to successfully commercialize CaPre.

There may be significant delays in obtaining coverage and reimbursement for newly-approved drugs, and coverage may be more
limited than the purposes for which the drug is approved by the FDA or other regulatory authorities. Moreover, eligibility for coverage and
reimbursement does not imply that a drug will be paid for in all cases or at a rate that covers our costs, including research, development,
manufacture, sale and distribution expenses. Interim reimbursement levels for new drugs, if applicable, may also be insufficient to cover
our costs and may not be made permanent. Reimbursement rates may vary according to the use of a drug and the clinical setting in which it
is used, may be based on reimbursement levels already set for lower cost drugs and may be incorporated into existing payments for other
services. Net prices for drugs may be reduced by mandatory discounts or rebates required by government healthcare programs or private
payors and by any future relaxation of laws that presently restrict imports of drugs from countries where they may be sold at lower prices
than in the United States. Our inability to promptly obtain coverage and profitable payment rates from both government-funded and private
payors for CaPre could have a material adverse effect on our operating results and our overall financial condition.

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Even if we obtain FDA approval of CaPre, we may never obtain approval or commercialize it outside of the United States, which would
limit our ability to realize CaPre’s full market potential.

In  order  to  market  CaPre  outside  of  the  United  States,  we  must  establish  and  comply  with  numerous  and  varying  regulatory
requirements of other countries regarding safety and efficacy. Clinical trials conducted in one country may not be accepted by regulatory
authorities in other countries, and regulatory approval in one country does not mean that regulatory approval will be obtained in any other
country. Approval procedures vary among countries and can involve additional product testing and validation and additional administrative
review  periods.  Seeking  foreign  regulatory  approvals  could  result  in  significant  delays,  difficulties  and  costs  for  us  and  may  require
additional preclinical studies or clinical trials, which would be costly and time consuming. Regulatory requirements can vary widely from
country  to  country  and  could  delay  or  prevent  the  introduction  of  CaPre  in  those  countries.  In  addition,  our  failure  to  obtain  regulatory
approval in any country may delay or have negative effects on the process for regulatory approval in other countries. If we fail to comply
with regulatory requirements in international markets or to obtain and maintain required approvals, our target market will be reduced and
our ability to realize the full market potential of CaPre will be harmed.

If we or our third-party service providers fail to comply with healthcare laws and regulations or government price reporting laws, we
could be subject to civil or criminal penalties.

In addition to the FDA’s restrictions on marketing pharmaceutical products, several other types of federal and state healthcare fraud
and abuse laws restrict marketing practices in the pharmaceutical industry. These laws include the U.S. Anti-Kickback Statute, U.S. False
Claims Act and similar state laws. The U.S. Anti-Kickback Statute prohibits, among other things, offering, paying, soliciting or receiving
remuneration  to  induce,  or  in  return  for,  purchasing,  leasing,  or  ordering  any  healthcare  item  or  service  reimbursable  under  Medicare,
Medicaid  or  other  federally  financed  healthcare  programs. A  person  or  entity  does  not  need  to  have  actual  knowledge  of  the  U.S. Anti-
Kickback Statute or special intent to violate the law in order to have committed a violation. This statute has been interpreted broadly to
apply  to  arrangements  between  pharmaceutical  manufacturers  and  prescribers,  dispensers,  purchasers  and  formulary  managers.  The
exemptions and safe harbors from prosecution are drawn narrowly and we may fail to meet all of the criteria for safe harbor protection from
anti-kickback liability.

In addition, the Health Care Reform Law provides that the government may assert that a claim including items or services resulting
from a violation of the U.S. Anti-Kickback Statute constitutes a false or fraudulent claim for purposes of the U.S. False Claims Act. Federal
false  claims  laws  prohibit  any  person  from  knowingly  presenting,  or  causing  to  be  presented,  a  false  claim  for  payment  to  the  federal
government or knowingly making, or causing to be made, a false statement to get a false claim paid. The “qui tam” provisions of the False
Claims Act allow a private individual to bring civil actions on behalf of the federal government alleging that the defendant has submitted a
false claim to the federal government. These individuals, sometimes known as “relators” or,  more  commonly,  as  “whistleblowers”,  may
share in any amounts paid by the entity to the government in fines or settlement. The number of filings of qui tam actions has increased
significantly in recent years, causing more healthcare companies to have to defend a case brought under the federal False Claim Act. If an
entity is determined to have violated the federal False Claims Act, it may be required to pay up to three times the actual damages sustained
by  the  government,  plus  attorneys’  fees  and  costs,  and  civil  penalties  of  up  to  US$21,563  for  each  separate  false  claim.  Certain
administrative sanctions, up to and including exclusion of an entity from participation in the federal healthcare programs, may also ensue.

Additional laws and regulations include:

•

  the  U.S.  federal  Health  Insurance  Portability  and  Accountability  Act  (HIPAA),  as  amended  by  the  Health  Information
Technology for Economic and Clinical Health Act (HITECH), which created additional federal criminal statutes that prohibit,
among other things, schemes to defraud healthcare programs and imposes requirements on certain types of people and entities
relating to the privacy, security, and transmission of individually identifiable health information, and requires notification to
affected individuals and regulatory authorities of breaches of security of individually identifiable health information;

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•

•

  the federal Physician Payment Sunshine Act, which requires certain manufacturers of drugs, devices, biologics and medical
supplies  for  which  payment  is  available  under  Medicare,  Medicaid,  or  the  Children’s  Health  Insurance  Program,  to  report
annually to the CMS information related to payments and other transfers of value to physicians, other healthcare providers
and  teaching  hospitals,  and  ownership  and  investment  interests  held  by  physicians  and  other  healthcare  providers  and  their
immediate family members, which is published in a searchable form on an annual basis; and

  the U.S. Foreign Corrupt Practices Act and similar worldwide anti-bribery laws, which generally prohibit companies and their
intermediaries  from  making  improper  payments  to  government  officials  for  the  purpose  of  obtaining  or  retaining  business.
Violations of these laws, or allegations of such violations, could result in fines, penalties or prosecution and have a negative
impact on our business, results of operations and reputation.

Over the past few years, a number of pharmaceutical and other healthcare companies have been prosecuted under these laws for a
variety of alleged prohibited promotional and marketing activities, such as providing free trips, free goods, sham consulting fees and grants
and other monetary benefits to prescribers; reporting to pricing services inflated average wholesale prices that were then used by federal
programs  to  set  reimbursement  rates;  engaging  in off-label  promotion  that  caused  claims  to  be  submitted  to  Medicaid  for non-covered,
off-label uses; and submitting inflated best price information to the Medicaid Rebate Program to reduce liability for Medicaid rebates. Most
states also have statutes or regulations similar to the U.S. Anti-Kickback Statute and the U.S. False Claims Act, which apply to items and
services  reimbursed  under  Medicaid  and  other  state  programs,  or,  in  several  states,  apply  regardless  of  the  payor.  Sanctions  under  these
federal and state laws may include civil monetary penalties, exclusion of a manufacturer’s products from reimbursement under government
programs, criminal fines and imprisonment. Settlements of U.S. government litigation may include Corporate Integrity Agreements with
commitments for monitoring, training, and reporting designed to prevent future violations.

Any  action  against  us  for  an  alleged  or  suspected  violation  of  these  laws  could  cause  us  to  incur  significant  legal  expenses  and
could divert our management’s attention from the operation of our business, even if our defense is successful. In addition, achieving and
sustaining compliance with these laws and regulations may be costly to us in terms of money, time and resources. If we or any strategic
partners, manufacturers or service providers fail to comply with these laws, we could be subject to enforcement actions, including:

•

•

•

•

•

•

•

•

•

•

•

•

  adverse regulatory inspection findings;

  warning letters;

  voluntary or mandatory product recalls or public notification or medical product safety alerts to healthcare professionals;

  restrictions on, or prohibitions against, marketing our products;

  restrictions on, or prohibitions against, importation or exportation of our products;

  suspension of review or refusal to approve pending applications or supplements to approved applications;

  exclusion from participation in government-funded healthcare programs;

  exclusion from eligibility for the award of government contracts for our products;

  suspension or withdrawal of product approvals;

  product seizures;

  injunctions; and

  civil and criminal penalties and fines.

We rely on third parties to conduct our clinical trials for CaPre.

We rely heavily on contract research organizations, or CROs, to monitor and manage data for our preclinical studies and clinical
trials for CaPre. While we only control certain aspects of the CRO’s activities, we nevertheless are responsible for ensuring that our clinical
trials are conducted in accordance with applicable protocols, legal, regulatory and scientific standards, and our reliance on the CRO does
not  relieve  us  from  those  responsibilities.  We  and  the  CRO  are  required  to  comply  with  cGCPs,  which  are  regulations  and  guidelines
enforced by the FDA, Health Canada and comparable foreign regulatory authorities for any products in clinical development.

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The FDA enforces these cGCP regulations through periodic inspections of trial sponsors, principal investigators and trial sites. If we or the
CRO fail to comply with applicable cGCPs, the clinical data generated in our clinical trials may be deemed unreliable and the FDA, Health
Canada  or  comparable  foreign  regulatory  authorities  may  require  us  to  perform  additional  clinical  trials  before  approving  our  marketing
applications  for  CaPre.  Upon  inspection,  the  FDA  could  determine  that  our  clinical  trials  do  not  comply  with  cGCPs.  In  addition,  our
clinical trials must be conducted with products produced under cGMP regulations and require a large number of test subjects. If we or the
CRO fail to comply with these regulations, we may have to repeat preclinical studies or clinical trials for CaPre, which would delay the
regulatory approval process and could also subject us to enforcement action up to and including civil and criminal penalties.

If our relationship with a CRO terminates, we may not be able to enter into arrangements with alternative CROs. If the CRO does
not successfully carry out its duties or obligations or meet expected deadlines, if it needs to be replaced or if the quality or accuracy of the
clinical data it obtains is compromised due to the failure to adhere to our clinical protocols, regulatory requirements or for other reasons, we
may have to extend, delay or terminate our preclinical studies or clinical trials, and we may not be able to obtain regulatory approval for or
successfully commercialize CaPre.

The third parties conducting our preclinical studies and clinical trials at CROs will not be our employees and, except for remedies
available to us under our agreements with the CROs,  we  cannot  control  whether  or  not  they  devote  sufficient  time  and  resources  to  our
preclinical, clinical and nonclinical programs. These third parties may also have relationships with other commercial entities, including our
competitors,  for  whom  they  may  also  be  conducting  clinical  studies  or  other  drug  development  activities,  which  could  affect  their
performance on our behalf.

We rely on third parties to manufacture, produce and supply CaPre and we may be adversely affected if those third parties are unable or
unwilling to fulfill their obligations, including complying with FDA requirements.

Producing pharmaceutical products requires significant expertise and capital investment, including the development of advanced
manufacturing techniques and process controls. We do not own or operate manufacturing facilities for the production of CaPre, nor do we
have plans to develop our own manufacturing operations in the foreseeable future. Accordingly, we need to rely on one or more third party
manufacturers to produce and supply our required drug product for our nonclinical research and clinical trials for CaPre.

Although we are currently working with CordenPharma at its Chenôve facility in Dijon, France to develop a commercially viable
manufacturing process for CaPre, doing so is a difficult and uncertain task, and there are risks associated with scaling to the level required
for advanced clinical trials or commercialization, including, among others, cost overruns, potential problems with process scale up, process
reproducibility, stability issues, lot consistency and timely availability of reagents or raw materials. Any of these challenges could delay
completion  of  our  preclinical  studies  or  clinical  trials  for  CaPre,  require  bridging  or  repetition  of  studies  or  trials,  increase  development
costs,  delay  approval  of  CaPre,  impair  our  commercialization  efforts,  and  increase  our  costs.  We  may  have  to  delay  or  suspend  the
production of CaPre if a third-party manufacturer:

•

•

•

  becomes unavailable for any reason, including as a result of the failure to comply with current good manufacturing practices,
or cGMP, regulations;

  experiences manufacturing problems or other operational failures, such as equipment failures or unplanned facility shutdowns
required  to  comply  with  cGMP  or  damage  from  any  event,  including  fire,  flood,  earthquake,  business  restructuring  or
insolvency; or

  fails or refuses to perform its contractual obligations under its agreement with us, such as failing or refusing to deliver the
quantities of CaPre requested by us on a timely basis.

If our third-party manufacturers fail to achieve and maintain high manufacturing standards in compliance with cGMP regulations,
we  may  be  subject  to  sanctions,  including  fines,  product  recalls  or  seizures,  injunctions,  delays  or  suspensions  of  our  clinical  trials  for
CaPre,  total  or  partial  suspension  of  production  of  CaPre,  civil  penalties,  withdrawals  of  previously  granted  regulatory  approvals,  and
criminal  prosecution.  We  do  not  currently  have  arrangements  in  place  for  redundant  supply.  If  any  one  of  our  current  contract
manufacturers  cannot  perform  as  agreed,  we  may  be  required  to  replace  that  manufacturer. Although  we  believe  that  there  are  several
potential alternative manufacturers who could manufacture CaPre, we may incur added costs and delays in identifying and qualifying any
such replacement.

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The research, development and manufacture of CaPre involves using potentially hazardous materials.

Our research and development activities relating to CaPre involve the controlled use of potentially hazardous substances, including
chemical and biological materials. Our manufacturers for CaPre will be subject to federal, provincial, state and local laws and regulations in
Canada,  the  United  States  and  in  other  jurisdictions  governing  laboratory  procedures  and  the  use,  manufacture,  storage,  handling  and
disposal  of  medical  and  hazardous  materials. Although  we  believe  that  our  manufacturers’  procedures  for  using,  handling,  storing  and
disposing of these materials comply with legally prescribed standards, we cannot completely eliminate the risk of contamination or injury
resulting  from  medical  or  hazardous  materials.  If  any  such  contamination  or  injury  were  to  occur,  we  may  incur  liability  or  local,  city,
provincial,  state  or  federal  authorities  may  curtail  the  use  of  these  materials  and  interrupt  our  business  operations  and  the  production  of
CaPre. In the event of an accident, we could be held liable for damages or penalized with fines, and the liability could exceed our resources.
We do not have any insurance for liabilities arising from medical or hazardous materials. Complying with environmental, health and safety
laws and regulations is expensive, and current or future environmental regulations may impair our research, development and production
efforts  relating  to  CaPre,  which  could  harm  our  business,  prospects,  financial  condition  or  results  of  operations. Although  we  maintain
workers’ compensation insurance to cover us for costs and expenses we may incur due to injuries to our employees resulting from the use
of  hazardous  materials,  this  insurance  may  not  provide  adequate  coverage  against  potential  liabilities.  We  do  not  maintain  insurance  for
environmental  liability  or  toxic  tort  claims  that  may  be  asserted  against  us  in  connection  with  our  storage  or  disposal  of  biological,
hazardous  or  radioactive  materials.  In  addition,  we  may  incur  substantial  costs  in  order  to  comply  with  current  or  future  environmental,
health and safety laws and regulations. These laws and regulations may make it more difficult for us to conduct our research, development
or production activities relating to CaPre and if we fail to comply with them, we could have substantial fines, penalties or other sanctions
imposed against us.

We depend on Neptune for some important services.

Neptune provides us with some shared back office services and functions, including corporate affairs, public company reporting,
accounting, payroll, information technology, accounts payable, accounts receivable and shared premises. If our arrangements with Neptune
for these services were to be terminated or not renewed, we may have to incur additional costs to provide them ourselves or to source them
from another third party.

We rely on Neptune to supply us with the krill oil we need to produce CaPre for our clinical programs and commercial supply.

We depend on krill oil sourced from Neptune to produce CaPre. If we are not able to acquire krill oil in sufficient quantities from
Neptune, we may need to seek alternative suppliers of krill oil and may be required to pay higher prices. Any alternative supply of krill oil
may not be of comparable quality to that provided by Neptune, which could negatively affect the efficacy, or the markets’ perception of the
efficacy, of CaPre. Our reliance on Neptune or other third-party suppliers for krill oil exposes us to risks such as potential fluctuations in
supply and reduced control over our production costs and delivery schedules for CaPre.

Interruptions of our supply of CaPre could disrupt our planned Phase 3 program and, if CaPre reaches commercialization, impair any
future revenue streams.

We will require much larger amounts of CaPre for purposes of our planned Phase 3 program and potential commercialization than
we have in the past. Supply interruptions for CaPre could occur and our inventory of CaPre may not always be sufficient due to a number of
factors, including:

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•

•

  failure to have a third-party supply chain partner’s process validated in a timely manner;

  shortages of required raw materials, such as krill oil, and the packaging components required by our manufacturers;

  changes in our sources for manufacturing or packaging;

  failure to timely locate and obtain replacement manufacturers, as needed; and

  conditions affecting the cost and availability of raw materials.

We are also in the process of  scaling-up our production of CaPre and CaPre may not be of comparable quality when produced in
large 100 kilogram batches. If we experience interruptions in the production of CaPre, our ability to complete our planned Phase 3 program
could  be  interrupted.  If  CaPre  receives  regulatory  approval,  interruptions  in  the  production  of  CaPre  or  insufficient  inventory  levels  of
CaPre could have a material adverse effect on our results of operations.

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If product liability lawsuits are brought against us, we may incur substantial liabilities and be required to cease the sale, marketing and
distribution of CaPre.

We  face  a  potential  risk  of  product  liability  associated  with  any  future  commercialization  of  CaPre  or  any  other  future  product
candidate  we  develop.  For  example,  we  may  be  sued  if  CaPre  allegedly  causes  injury. Any  such  product  liability  claims  may  include
allegations of defects in manufacturing, defects in design, a failure to warn of dangers inherent in the product, negligence, strict liability and
a  breach  of  warranties.  Claims  could  also  be  asserted  under  U.S.  state  or  Canadian  provincial  or  other  foreign  consumer  protection
legislation. If we cannot successfully defend against product liability claims, we may incur substantial liabilities or be required to cease the
sale, marketing and distribution of CaPre. Even successful defense against product liability claims would require significant financial and
management resources. Regardless of the merits or eventual outcome, liability claims may result in:

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  decreased demand for CaPre or any future products that we may develop;

  injury to our reputation;

  costs to defend the related litigation;

  a diversion of management’s time and our resources;

  substantial monetary awards to consumers, trial participants or patients;

  product recalls, withdrawals or labeling, marketing or promotional restrictions;

  loss of revenue;

  an inability to commercialize CaPre; and

  a decline in the price of our common shares.

If we are unable to obtain and retain sufficient product liability insurance at an acceptable cost to protect against potential product
liability claims, the commercialization of CaPre or any other product candidates we develop could be hindered or prevented. We currently
carry product liability insurance, shared with Neptune, in the amount of $10.0 million in the aggregate. Any  claim  that  may  be  brought
against us could result in a court judgment or settlement in an amount that is not covered, in whole or in part, by our insurance or that is in
excess of the limits of our insurance coverage. Our insurance policies also have various exclusions, and we may be subject to a product
liability claim for which we have no coverage. In the event of a successful product liability claim against us, we may have to pay from our
own resources any amounts awarded by a court or negotiated in a settlement that exceed coverage limitations or that is not covered by our
insurance, and we may not have, or be able to obtain, sufficient funds to pay such amounts.

We may not achieve our publicly announced milestones on time, or at all.

From time to time, we may publicly announce the timing of certain events we expect to occur, such as the anticipated timing of
results from our clinical trials. These statements are forward-looking and are based on the best estimate of management at the time relating
to the occurrence of the events. However, the actual timing of these events may differ from what has been publicly disclosed. The timing
of events such as completion of a clinical trial, discovery of a new product candidate, filing of an application to obtain regulatory approval,
beginning of commercialization of products, or announcement of additional clinical trials for a product candidate may ultimately vary from
what is publicly disclosed. For example, we cannot provide assurances that we will conduct our planned Phase 3 clinical trial for CaPre,
that  we  will  make  regulatory  submissions  or  receive  regulatory  approvals  as  planned,  or  that  we  will  be  able  to  adhere  to  plans  for  the
scale-up of manufacturing and launch of CaPre. These variations in timing may occur as a result of different events, including the nature of
the results obtained during a clinical trial or during a research phase, problems with a supplier or a distribution partner or any other event
having  the  effect  of  delaying  the  publicly  announced  timeline.  We  undertake  no  obligation  to  update  or  revise  any  forward-looking
information, whether as a result of new information, future events or otherwise, except as otherwise required by law. Any variation in the
timing of previously-announced milestones could have a material adverse effect on our business, financial condition or operating results
and the trading price of our common shares.

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We may be subject to foreign exchange rate fluctuations.

Our  reporting  currency  is  the  Canadian  dollar.  However,  many  of  our  expenses,  such  as  CaPre’s  chief  manufacturing
organization’s production activities and certain CRO arrangements for our planned Phase 3 program, currently are and/or are expected to
be,  denominated  in  foreign  currencies,  including  European  euros  and  U.S.  dollars.  Though  we  plan  to  implement  measures  designed  to
reduce  our  foreign  exchange  rate  exposure,  the  U.S.  dollar/Canadian  dollar  and  European  euro/Canadian  dollar  exchange  rates  have
fluctuated significantly in the recent past and may continue to do so, which could have a material adverse effect on our business, financial
position and results of operations.

Risks Related to Intellectual Property

It is difficult and costly to protect our intellectual property rights.

The success of our business will largely depend on our ability to:

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  obtain and maintain patents, trade secret protection and operate without infringing the intellectual proprietary rights of third

parties;

  successfully defend our patents, including patents licensed to us by Neptune, against third-party challenges; and

  successfully enforce our patents against third party competitors.

Our  patents  and/or  proprietary  technologies  could  be  circumvented  through  the  adoption  of  competitive,  though non-infringing,
processes or products. The patent positions of pharmaceutical companies can be highly uncertain and involve complex legal, scientific and
factual questions for which important legal principles remain unresolved. Changes in either the patent laws or in interpretations of patent
laws may diminish the value of our intellectual property. We cannot predict the breadth of claims that may be allowable or enforceable in
our patents, including the patents licensed to us by Neptune.

We face risks that:

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  our rights under our Canadian, U.S. or foreign patents or other patents that Neptune or other third parties license to us could
be curtailed;

  we  may  not  be  the  first  inventor  of  inventions  covered  by  our  issued  patents  or  pending  applications  or  be  the  first  to  file
patent applications for those inventions;

  our pending or future patent applications may not be issued with the breadth of claim coverage sought by us, or be issued at
all;

  our  competitors  could  independently  develop  or  patent  technologies  that  are  substantially  equivalent  or  superior  to  our
technologies;

  our trade secrets could be learned independently by our competitors;

  the steps we take to protect our intellectual property may not be adequate; and

  effective  patent,  trademark,  copyright  and  trade  secret  protection  may  be  unavailable,  limited  or  not  sought  by  us  in  some
foreign countries.

Further, patents have a limited lifespan. In the United States, a patent generally expires 20 years after it is filed (or 20 years after
the filing date of the first non-provisional U.S. patent application to which it claims priority). While extensions may be available, the life of
a patent, and the protection it affords, is limited. Without patent protection for CaPre or any other of our future product candidates, we may
be open to competition from generic versions of CaPre or our other future product candidates. Further, the extensive period of time between
patent filing and regulatory approval for a product candidate limits the time during which we can market that product candidate under patent
protection.  Patents  owned  by  third  parties  could  have  priority  over  patent  applications  filed  or in-licensed  by  us,  or  we  or  our  licensors
could become involved in interference, opposition or invalidity proceedings before U.S., Canadian or foreign patent offices. The cost of
defending  and  enforcing  our  patent  rights  against  infringement  charges  by  other  patent  holders  may  be  significant  and  could  limit  our
operations.

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CaPre is partly covered by patents that are not owned by us but are instead licensed to us by Neptune.

In addition to our proprietary patent applications, we have an exclusive worldwide license under a license agreement with Neptune
to use certain patents and know-how owned by Neptune to develop and commercialize CaPre within a specified field of use. This limitation
on our field of use may prevent us from developing and commercializing CaPre in other fields. Also, our license from Neptune is subject to
termination  for  breach  of  its  terms,  and  therefore  our  license  rights  are  only  available  to  us  for  as  long  as  Neptune  agrees  that  our
development and commercialization activities meet the terms of the license.

Disputes may arise between us and Neptune regarding the intellectual property that is subject to the license agreement, including

with respect to:

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  the scope of rights granted under the license agreement and other interpretation-related issues;

  whether and the extent to which our technology and processes infringe on intellectual property of Neptune that is not subject

to the licensing agreement;

  our right to sublicense patent and other rights to third parties under collaborative development relationships;

  our  diligence  obligations  with  respect  to  our  use  of  the  licensed  technology  in  relation  to  our  development  and

commercialization of our product candidates, and what activities satisfy those diligence obligations; and

  the ownership of inventions and know-how resulting from the joint creation or use of intellectual property by Neptune and us

and our partners.

If our license is terminated for any reason and we are not able to negotiate another agreement with Neptune for use of its patents
and know-how, we would not be able to manufacture and market CaPre, which would have a material adverse effect on our business and
financial condition.

CaPre may infringe the intellectual property rights of others, which could increase our costs and delay or prevent our development and
commercialization efforts.

Our success depends in part on avoiding infringement of the proprietary technologies of others. The pharmaceutical industry has
been characterized by frequent litigation regarding patent and other intellectual property rights. Identification  of  third  party  patent  rights
that  may  be  relevant  to  our  proprietary  or  licensed  technology  is  difficult  because  patent  searching  is  imperfect  due  to  differences  in
terminology among patents, incomplete databases and the difficulty in assessing the meaning of patent claims. Additionally, because patent
applications are maintained in secrecy until the application is published, we may be unaware of third-party patents that may be infringed by
our development and commercialization of CaPre or any other future product candidate. There may be certain issued patents and patent
applications claiming subject matter that we may be required to license in order to research, develop or commercialize CaPre, and any such
patents and patent applications may not be available to license on commercially reasonable terms, or at all. If claims of patent infringement
are asserted by third parties against us, they could be time-consuming and may:

•

•

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•

•

•

  result in costly litigation;

  divert the time and attention of our technical personnel and management;

  delay our clinical trials for CaPre;

  prevent us from commercializing CaPre until the asserted patent expires or is held finally invalid or not infringed in court;

  require us to cease or to modify our use of the technology and/or develop non-infringing technology; or

  require us to enter into royalty or licensing agreements.

Others  may  hold  proprietary  rights  that  could  prevent  CaPre  from  being  marketed. Any  patent-related  legal  action  against  us
claiming damages and seeking to enjoin commercial activities relating to CaPre or our processes could subject us to potential liability for
damages and require us to obtain a license to continue to manufacture or market CaPre or any other future prescription drug candidates. We
might  not  prevail  in  any  such  actions  or  if  any  license  is  required  under  any  of  these  patents  it  may  not  be  available  on  commercially
acceptable terms, if at all.

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Even  if  a  license  can  be  obtained  on  acceptable  terms,  the  rights  may  be non-exclusive,  which  could  give  our  competitors  access  to  the
same technology or intellectual property rights licensed to us. We could be forced to redesign CaPre or any other future product candidates
or processes to avoid infringement.

In  addition,  we  may  find  it  necessary  to  pursue  claims  or  initiate  lawsuits  to  protect  or  enforce  our  patent  or  other  intellectual
property rights. The cost to us in defending or initiating any litigation or other proceeding relating to patent or other proprietary rights, even
if resolved in our favor, could be substantial, and litigation would divert our management’s attention. Some of our competitors may be able
to  sustain  the  costs  of  complex  patent  litigation  more  effectively  than  we  can  because  they  have  substantially  greater  resources.
Uncertainties  resulting  from  the  initiation  and  continuation  of  patent  litigation  or  other  proceedings  could  delay  our  research  and
development efforts and limit our ability to continue our operations.

A number of companies, including several major pharmaceutical companies, have conducted research on pharmaceutical uses of
OM3  fatty  acids,  which  has  resulted  in  the  filing  of  many  patent  applications  related  to  this  research.  We  are  aware  of  third-party  U.S.,
Canadian or other foreign patents that contain broad claims related to methods of using these general types of compounds, which may be
construed  to  include  potential  uses  of  CaPre.  If  we  were  to  challenge  the  validity  of  these  or  any  other  issued  U.S.,  Canadian  or  other
foreign patents in court, we would need to overcome a statutory presumption of validity that attaches to every U.S. and Canadian patent.
This means that, in order to prevail, we would have to present clear and convincing evidence as to the invalidity of the other party’s patent’s
claims. If we were to challenge the validity of any issued U.S. patent in an administrative trial before the Patent Trial and Appeal Board in
the United States Patent and Trademark Office, or USPTO, we would have to prove that the claims are unpatentable by a preponderance of
the  evidence.  If  there  are  disputes  over  our  intellectual  property  rights,  a  jury  and/or  court  may  not  find  in  our  favor  on  questions  of
infringement, validity or enforceability.

If we do not protect our trademark for CaPre, we may not be able to build name recognition in our markets of interest.

We have trademarked CaPre. Our trademark may be challenged, infringed, circumvented or declared generic or determined to be
infringing on other marks. We may not be able to protect our rights to this trademark or may be forced to stop using this name, which we
need  for  name  recognition  by  potential  strategic  partners  and  customers.  If  we  are  unable  to  establish  name  recognition  based  on  our
trademark, we may not be able to compete effectively and our business may be adversely affected.

We  may  be  involved  in  lawsuits  to  protect  or  enforce  our  patents  or  the  patents  of  our  licensors,  which  could  be  expensive,  time-
consuming and unsuccessful.

Competitors  may  infringe  our  patents  or  the  patents  of  our  licensors.  To  counter  infringement  or  unauthorized  use,  we  may  be
required to file infringement claims, which can be expensive and time-consuming. If we or our licensors were to initiate legal proceedings
against  a  third  party  to  enforce  a  patent  covering  CaPre  or  our  technology,  the  defendant  could  counterclaim  that  our  or  our  licensor’s
patent is invalid or unenforceable. In patent litigation in the United States, defendant counterclaims alleging invalidity or unenforceability
are commonplace. Grounds for a validity challenge could be an alleged failure to meet any of several statutory requirements; for example,
lack of novelty, obviousness or  non-enablement. Grounds for an unenforceability assertion could be an allegation that someone connected
with prosecution of the patent withheld relevant information from the USPTO, or made a misleading statement, during prosecution. The
outcome following legal assertions of invalidity and unenforceability during patent litigation is unpredictable. With respect to the validity
question, for example, we cannot be certain that there is no invalidating prior art, of which we or our licensors and the patent examiner
were unaware during prosecution. If a defendant were to prevail on a legal assertion of invalidity or unenforceability, we would lose at least
part, and perhaps all, of the patent protection on CaPre or certain aspects of our platform technology. Such a loss of patent protection could
have  a  material  adverse  impact  on  our  business.  Patents  and  other  intellectual  property  rights  also  will  not  protect  our  technology  if
competitors design around our protected technology without legally infringing our patents or other intellectual property rights.

In addition, in an infringement proceeding, a court may refuse to stop the other party from using the technology at issue on the
grounds that our patents do not cover the technology in question. An adverse result in any litigation or defense proceedings could put one
or more of our patents at risk of being invalidated, held unenforceable, or interpreted narrowly and could put our patent applications at risk
of not issuing. Defense of these claims, regardless of their merit, would involve substantial litigation expense and would be a substantial
diversion of employee resources from our business.

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Interference  proceedings  provoked  by  third  parties  or  brought  by  the  USPTO  may  be  necessary  to  determine  the  priority  of
inventions with respect to our patents or patent applications or those of our licensors. An unfavorable outcome could result in a loss of our
current patent rights and could require us to cease using the related technology or to attempt to license rights to it from the prevailing party.
Our business could be harmed if the prevailing party does not offer us a license on commercially reasonable terms, or at all. Litigation or
interference proceedings may result in a decision adverse to our interests and, even if we are successful, may result in substantial costs and
distract our management and other employees. We may not be able to prevent, alone or with our licensors, misappropriation of our trade
secrets or confidential information, particularly in countries where the laws may not protect those rights as fully as in the United States.
Furthermore, because of the substantial amount of discovery required in connection with intellectual property litigation, there is a risk that
some of our confidential information could be compromised by disclosure during this type of litigation. In addition, there could be public
announcements of the results of hearings, motions or other interim proceedings or developments. If securities analysts or investors perceive
these results to be negative, it could have a substantial adverse effect on the price of our common shares.

Obtaining  and  maintaining  our  patent  protection  depends  on  compliance  with  various  procedural,  document  submission,  fee
payment and other requirements imposed by governmental patent agencies, and our patent protection could be reduced or eliminated for
non-compliance with these requirements.

Changes in patent law could diminish the value of patents in general, thereby impairing our ability to protect CaPre and any of our
other future product candidates.

Numerous recent changes to the patent laws and proposed changes to the rules of the USPTO may have a significant impact on our
ability to protect our technology and enforce our intellectual property rights. For example, the Leahy-Smith America Invents Act , or AIA,
enacted  in  2011,  involves  significant  changes  in  patent  legislation. An  important  change  introduced  by  the AIA  is  that,  as  of  March  16,
2013, the United States transitioned to a “first-to-file” system for deciding which party should be granted a patent when two or more patent
applications are filed by different parties claiming the same invention. A third party that files a patent application in the USPTO after that
date but before us could therefore be awarded a patent covering an invention of ours even if we had made the invention before it was made
by the third party. This will require us to be cognizant going forward of the time from invention to filing of a patent application. Further, the
Supreme Court of the United States has ruled on several patent cases in recent years, some of which cases either narrow the scope of patent
protection  available  in  certain  circumstances  or  weaken  the  rights  of  patent  owners  in  certain  situations.  These  changes  have  led  to
increasing uncertainty with regard to the scope and value of our issued patents and to our ability to obtain patents in the future.

Among some of the other changes introduced by the AIA are changes that limit where a patentee may file a patent infringement
suit and providing opportunities for third parties to challenge any issued patent in the USPTO. This applies to all of our U.S. patents, even
those issued before March 16, 2013. Because of a lower evidentiary standard in USPTO proceedings compared to the evidentiary standard
in  United  States  federal  court  necessary  to  invalidate  a  patent  claim,  a  third  party  could  potentially  provide  evidence  in  a  USPTO
proceeding sufficient for the USPTO to hold a claim invalid even though the same evidence would be insufficient to invalidate the claim if
first presented in a district court action. Accordingly, a third party may attempt to use the USPTO procedures to invalidate our patent claims
that would not have been invalidated if first challenged by the third party as a defendant in a district court action.

Once  granted,  patents  may  remain  open  to  opposition,  interference, re-examination,  post-grant  review,  inter  partes  review,
nullification  derivation  and  opposition  proceedings  in  court  or  before  patent  offices  or  similar  proceedings  for  a  given  period  after
allowance  or  grant,  during  which  time  third  parties  can  raise  objections  against  the  initial  grant.  In  the  course  of  any  such  proceedings,
which may continue for a protracted period of time, the patent owner may be compelled to limit the scope of the allowed or granted claims
attacked, or may lose the allowed or granted claims altogether. Depending on decisions by the U.S. Congress, the U.S. federal courts, the
USPTO or similar authorities in foreign jurisdictions, the laws and regulations governing patents could change in unpredictable ways that
may weaken our and our licensors’ ability to obtain new patents or to enforce existing patents we and our licensors or partners may obtain
in the future.

We may not be able to protect our intellectual property rights throughout the world.

Many  companies  have  encountered  significant  problems  in  protecting  and  defending  intellectual  property  rights  in  foreign
jurisdictions. The legal systems of some countries, particularly certain developing countries, do not favor the enforcement of patents, trade
secrets and other intellectual property protection, which could make it difficult for us to stop the infringement of our patents or marketing
of competing products in violation of our

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proprietary rights generally. Proceedings to enforce our patent rights in foreign jurisdictions could result in substantial costs and divert our
efforts and attention from other aspects of our business, could put our patents at risk of being invalidated or interpreted narrowly and our
patent applications at risk of not issuing and could provoke third parties to assert claims against us. We may not prevail in any lawsuits that
we initiate and the damages or other remedies awarded, if any, may not be commercially meaningful. Accordingly, our efforts to enforce
our  intellectual  property  rights  around  the  world  may  be  inadequate  to  obtain  a  significant  commercial  advantage  from  the  intellectual
property that we develop or license.

Risks Relating to Our Common Shares

The trading price of our common shares may be volatile.

Market prices for securities in general, and those of pharmaceutical companies in particular, tend to fluctuate. The trading price for
our  common  shares  has  experienced  volatility  in  the  past.  Factors  that  could  affect  the  trading  price  of  our  common  shares  and  cause
volatility include, among others:

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•

  results or delays of pre-clinical and clinical studies by us or others;

  the commencement, enrollment or results of future clinical trials we may conduct, or changes in the development status of

CaPre or any of our other future product candidates;

  any delay in our regulatory filings for CaPre or any of our other future product candidates and any adverse development or

perceived adverse development with respect to the applicable regulatory authority’s review of our filings;

  filing or granting or invalidity of patents;

  exclusive rights obtained by us or others;

  disputes or other developments relating to proprietary rights, including patents;

  litigation matters and our ability to obtain patent protection for our technologies;

  changes in regulations;

  additions or departures of key scientific or management personnel;

  overall performance of the equity markets;

  general political and economic conditions;

  publications;

  failure to meet the estimates and projections of the investment community or that we may otherwise provide to the public;

  research reports or positive or negative recommendations or withdrawal of research coverage by securities analysts;

  announcements of significant acquisitions, strategic partnerships, joint ventures or capital commitments by us or our
competitors;

  public concerns over the risks of pharmaceutical products and dietary supplements;

  unanticipated serious safety concerns related to the use of CaPre; and

  future sales of securities by us in financings or by our shareholders.

As  a  result,  the  market  price  of  our  common  shares  may  fluctuate  significantly  in  the  future.  In  addition,  the  stock  market  in
general,  and  pharmaceutical  companies  in  particular,  have  experienced  extreme  price  and  volume  fluctuations  that  have  often  been
unrelated or disproportionate to the operating performance of these companies. Broad market and industry factors may negatively affect the
market price of our common shares, regardless of our actual operating performance. In the past, securities class action litigation has often
been instituted against companies following periods of volatility of the market price of a company’s securities. This type of litigation, if
brought against us, could result in substantial costs and liabilities for us and divert our management’s attention and resources, which would
harm our business, operating results or financial condition.

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Future securities issuances by us could result in significant dilution for existing shareholders.

Our articles of incorporation permit us to issue an unlimited number of common shares and preferred shares, issuable in series, and
our shareholders will have no pre-emptive rights in connection with further issuances of securities by us. Our directors have the discretion
to determine the provisions attaching to any series of preferred shares and the price of issue of further issuances of our common shares.
Also, additional common shares may be issued by us upon the exercise of outstanding stock options and warrants. The issuance of these
additional equity securities or the issuance of new stock options or warrants may have a dilutive effect on existing holders of our common
shares and, as a result, the market price for our common shares could decline. The market price of our common shares could also decline as
a  result  of  future  issuances  by  us  in  connection  with  strategic  partnerships,  or  sales  by  our  existing  shareholders,  or  the  perception  that
these sales could occur. Sales by our shareholders, including Neptune, might also make it more difficult for us to sell equity securities at a
time and price that we deem appropriate, which could reduce our ability to raise capital and have an adverse effect on our business.

Raising additional capital may cause dilution to our existing shareholders, restrict our operations or require us to relinquish rights to
our technologies or product candidates.

We may seek additional capital through a combination of public and private equity offerings, debt financings, strategic partnerships
and  alliances  and  licensing  arrangements.  To  the  extent  that  we  raise  additional  capital  through  the  sale  of  equity  or  convertible  debt
securities,  the  ownership  interests  of  our  shareholders  will  be  diluted,  and  the  terms  may  include  liquidation  or  other  preferences  that
adversely  affect  the  rights  of  our  common  shareholders.  The  incurrence  of  indebtedness  would  result  in  increased  fixed  payment
obligations  and  could  involve  certain  restrictive  covenants,  such  as  limitations  on  our  ability  to  incur  additional  debt,  limitations  on  our
ability to acquire or license intellectual property rights and other operating restrictions that could adversely impact our ability to conduct
our  business.  If  we  raise  additional  funds  through  strategic  partnerships  and  licensing  arrangements  with  third  parties,  we  may  have  to
relinquish valuable rights relating to CaPre or our other future product candidates, or grant licenses on terms unfavorable to us.

An active market for our common shares might not be sustained.

If an active market for our common shares is not sustained, holders of our common shares may be unable to sell their investments
on satisfactory terms. Declines in the value of our common shares may adversely affect the liquidity of the market for our common shares.
Factors unrelated to our performance may also have an effect on the price and liquidity of our common shares including:

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  extent of analyst coverage of us;

  lower trading volume and general market interest in our common shares;

  the size of our public float; and

  any event resulting in a delisting of our common shares from the NASDAQ Stock Market or the TSX Venture Exchange, or
TSXV.

A large number of our common shares may be issued and subsequently sold upon the exercise of our outstanding warrants and under
our convertible debentures, which could depress the trading price for our common shares.

As of March 31, 2017, we had up to 5,254,535 common shares issuable under our outstanding warrants and convertible debentures.
To  the  extent  that  holders  of  our  warrants  and  convertible  debentures  sell  underlying  common  shares  issued  under  those  warrants  and
convertible debentures, the market price of our common shares may decrease due to the additional selling pressure in the market and could
encourage short sales by third parties. In a short sale, a prospective seller borrows common shares from a shareholder or broker and sells the
borrowed  common  shares.  The  prospective  seller  anticipates  that  the  common  share  price  will  decline,  at  which  time  the  seller  can
purchase  common  shares  at  a  lower  price  for  delivery  back  to  the  lender.  The  risk  of  dilution  from  issuances  of  our  common  shares
underlying  our  warrants  and  convertible  debentures  could  also  cause  shareholders  to  sell  their  common  shares,  which  could  result  in  a
decline in their market price.

We do not intend to pay dividends on our common shares for the foreseeable future.

We have never paid dividends on our common shares and we do not anticipate paying any dividends on our common shares for the
foreseeable  future  because,  among  other  reasons,  we  currently  intend  to  retain  any  future  earnings  to  finance  our  business. Any  future
payment of dividends by us will depend on factors such as cash on hand

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and whether we achieve profitability, our financial requirements to fund our growth, our general financial condition and other factors our
board of directors may consider appropriate in the circumstances. Until we pay dividends, which we may never do, our shareholders will
not be able to receive a return on their common shares unless they sell them.

If we fail to meet applicable listing requirements, the NASDAQ Stock Market or the TSXV may delist our common shares from trading,
in which case the liquidity and market price of our common shares could decline.

Our common stock is currently listed on the NASDAQ Stock Market and the TSXV, but we cannot assure you that our securities
will  continue  to  be  listed  on  the  NASDAQ  Stock  Market  and  the  TSXV  in  the  future.  In  the  past,  we  have  received  notices  from  the
NASDAQ Stock Market that we have not been in compliance with its continued listing standards, and we have taken responsive actions and
regained compliance. If we fail to comply with listing standards and the NASDAQ Stock Market or TSXV delists our common shares, we
and our shareholders could face significant material adverse consequences, including:

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•

  a limited availability of market quotations for our common shares;

  reduced liquidity for our common shares;

  a determination that our common shares are “penny stock”, which would require brokers trading in our common shares to

adhere to more stringent rules and possibly result in a reduced level of trading activity in the secondary trading market for our
common shares;

  a limited amount of news about us and analyst coverage of us; and

  a decreased ability for us to issue additional equity securities or obtain additional equity or debt financing in the future.

We may pursue opportunities or transactions that adversely affect our business and financial condition.

In the ordinary course of our business, our management regularly explores potential strategic opportunities and transactions, which

may involve:

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  significant debt or equity investments in us by third parties;

  the acquisition or disposition by us of material assets;

  the licensing, acquisition or disposition by us of material intellectual property;

  the development of new product lines or new applications for our existing products;

  entering into distribution arrangements;

  issuance of our common shares; and

  other similar matters.

Public  announcement  by  us  of  strategic  opportunities  or  transactions  might  have  a  significant  effect  on  the  trading  price  of  our
common shares. Our policy is to not publicly disclose our pursuit of a potential strategic opportunity or transaction unless we are required
to do so by applicable law. Investors who buy or sell our common shares could be doing so at a time when we are pursuing a particular
strategic opportunity or transaction that, when announced, could have a significant effect on the trading price for our common shares.

In addition, any strategic transactions we enter into could carry significant risks, including:

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  exposure to unknown liabilities;

  higher than anticipated transaction costs and expenses;

  the difficulty and expense of integrating operations and personnel of any acquired companies;

  disruption of our ongoing business;

  diversion of our management’s time and attention; and

  possible dilution to our existing shareholders.

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As a foreign private issuer, we are subject to different U.S. securities laws and regulations than a domestic U.S. issuer, which may limit
the information publicly available to our U.S. shareholders.

We are a foreign private issuer under applicable U.S. federal securities laws, and therefore, we are not required to comply with all
the  periodic  disclosure  and  current  reporting  requirements  of  the  U.S.  Securities  and  Exchange Act  of  1934,  or  the  Exchange Act. As  a
result, we do not file the same reports that a U.S. domestic issuer would file with the SEC, although we are required to file with or furnish
to  the  SEC  the  continuous  disclosure  documents  that  we  are  required  to  file  in  Canada  under  Canadian  securities  laws.  In  addition,  our
officers, directors and principal shareholders are exempt from the reporting and short-swing profit recovery provisions of Section 16 of the
Exchange Act.  Therefore,  our  shareholders  may  not  know  on  as  timely  a  basis  when  our  officers,  directors  and  principal  shareholders
purchase or sell common shares as the reporting periods under the corresponding Canadian insider reporting requirements are longer. In
addition, as a foreign private issuer, we are exempt from the proxy rules under the Exchange Act.

As  an  “emerging  growth  company”,  we  are  exempt  from  the  requirement  to  comply  with  the  auditor  attestation  requirements  of  the
Sarbanes-Oxley Act.

We are an “emerging growth company”, as defined in the U.S. Jumpstart Our Business  Start-ups Act, and we use the exemption
provided to emerging growth companies from the auditor attestation requirements of Section 404(b) of the Sarbanes-Oxley Act of 2002.
Therefore, our internal controls over financial reporting will not receive the level of review provided by the process relating to the auditor
attestation included in annual reports of issuers that are not using an exemption. In addition, we cannot predict if investors will find our
common shares less attractive because we rely on this exemption. If some investors find our common shares less attractive as a result, there
may be a less active trading market for our common shares and trading price for our common shares may be negatively affected.

U.S. investors may be unable to enforce certain judgments.

We  are  a  company  existing  under  the  Business  Corporations  Act  (Québec).  Some  of  our  directors  and  officers  are  residents  of
Canada, and substantially all of our assets are located outside the United States. As a result, it may be difficult to effect service within the
United States upon us or upon some of our directors and officers. Execution by U.S. courts of any judgment obtained against us or any of
our directors or officers in U.S. courts may be limited to assets located in the United States. It may also be difficult for holders of securities
who reside in the United States to realize in the United States upon judgments of U.S. courts predicated upon civil liability of us and our
directors  and  executive  officers  under  the  U.S.  federal  securities  laws.  There  may  be  doubt  as  to  the  enforceability  in  Canada  against
non-U.S.  entities  or  their  controlling  persons,  directors  and  officers  who  are  not  residents  of  the  United  States,  in  original  actions  or  in
actions for enforcement of judgments of U.S. courts, of liabilities predicated solely upon U.S. federal or state securities laws.

Item 4.

Information on the Company

A. History and Development of the Company

We  were  incorporated  on  February  1,  2002  under  Part  1A  of  the  Companies Act  (Québec)  under  the  name  “9113-0310  Québec
Inc.” On February 14, 2011, the Business Corporations Act (Québec) came into effect and replaced the Companies Act (Québec). We are
now governed by the Business Corporations Act (Québec). On August 7, 2008, under a Certificate of Amendment, we changed our name
to “Acasti Pharma Inc.”, our share capital description, the provisions regarding restrictions on transfers of our securities and our borrowing
powers.  On  November  7,  2008,  under  a  Certificate  of Amendment,  we  changed  the  provisions  regarding  our  borrowing  powers.  We
became a reporting issuer in Québec on November 17, 2008.

Our  head  and  registered  office  is  located  at  545  Promenade  du  Centropolis,  Suite  100,  Laval,  Québec  H7T  0A3.  We  currently
employ 15 full-time employees, with the majority working out of our headquarters in Laval and our laboratory in Sherbrooke, Québec. Our
website  address  is  http://www.acastipharma.com.  We  do  not  incorporate  the  information  on  or  accessible  through  our  website  into  this
annual report, and you should not consider any information on, or that can be accessed through, our website as part of this annual report.

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Intercorporate Relationships

We have no subsidiaries. As of the date of June 26, 2017, Neptune owns 5,064,694 of our common shares, representing 34.4% of

our issued and outstanding common shares.

B. Our Business

We  are  a  biopharmaceutical  innovator  focused  on  the  research,  development  and  commercialization  of  prescription  drugs  using
omega-3, or OM3, fatty acids derived from krill oil. OM3 fatty acids have extensive clinical evidence of safety and efficacy in lowering
triglycerides, or TGs, in patients with hypertriglyceridemia, or HTG. Our lead product candidate is CaPre, an OM3 phospholipid, which we
are developing initially for the treatment of severe HTG, a condition characterized by abnormally high levels of TGs in the bloodstream
(over  500  mg/dL).  Market  research  commissioned  by  us  from  DP Analytics  suggests  there  is  a  significant  unmet  medical  need  for  an
effective,  safe  and  well-absorbing  OM3  therapeutic  that  demonstrates  a  positive  impact  on  the  major  blood  lipids  associated  with
cardiovascular disease risk. We believe that, if supported by our Phase 3 program that we plan to initiate during the second half of 2017,
CaPre  will  address  this  unmet  medical  need.  We  also  believe  the  potential  exists  to  expand  CaPre’s  initial  indication  to  the  mild  to
moderate  HTG  (200  –  499  mg/dL)  segment,  although  at  least  one  additional  clinical  trial  will  likely  be  required  to  expand  CaPre’s
indications  to  this  segment.  We  may  seek  to  identify  new  potential  indications  for  CaPre  that  may  be  appropriate  for  future  studies  and
pipeline  expansion.  In  addition,  we  may  also  seek  to in-license  other  cardiometabolic  drug  candidates  for  drug  development  and
commercialization.

In  four  clinical  trials  conducted  to  date,  we  saw  the  following  beneficial  effects  with  CaPre,  and  we  are  seeking  to  demonstrate

similar safety and efficacy in our planned Phase 3 program:

•

•

•

•

•

•

  significant reduction of TGs and non-high  density  lipoprotein  cholesterol  (non-HDL-C) levels in the blood of patients with

mild to severe HTG;

  no  deleterious  effect  on low-density  lipoprotein  cholesterol (LDL-C),  or  “bad”  cholesterol,  with  the  potential  to  reduce
LDL-C;

  potential to increase high-density lipoprotein cholesterol (HDL-C), or “good” cholesterol;

  good bioavailability (absorption by the body), even under fasting conditions;

  no significant food effect when taken with either low-fat or high-fat meals; and

  an overall safety profile similar to that demonstrated by currently marketed OM3s.

Our Successful Phase 1 and Phase 2 Studies Helps Reduce Phase 3 Program Risk

About Hypertriglyceridemia

According to The American Heart Association Scientific Statement on Triglycerides and Cardiovascular Disease from 2011, TG
levels provide important information as a marker associated with the risk for heart disease and stroke, especially when an individual also
has low levels of HDL-C, and elevated levels of LDL-C. HTG can be caused by both genetic and environmental factors, including obesity,
sedentary  lifestyle  and  high-calorie  diets.  HTG  is  also  associated  with  comorbid  conditions  such  as  chronic  renal  failure,  pancreatitis,
nephrotic syndrome and diabetes. Multiple epidemiological, clinical, genetic studies suggest that patients with elevated TG levels (greater

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than  or  equal  to  200  mg/dL)  are  at  a  greater  risk  of  coronary  artery  disease,  or  CAD,  and  pancreatitis,  a  life-threatening  condition,  as
compared to those with normal TG levels. The genes regulating TGs and LDL-C are equally strong predictors of CAD, but HDL-C is not.
Other studies suggest that lowering and managing TG levels may reduce these risks. In addition, the Japan EPA Lipid Intervention Study,
or  JELIS,  demonstrated  the  long-term  benefit  of  an  OM3  eicosapentaenoic  acid,  or  EPA,  in  preventing  major  coronary  events  in
hypercholesterolemic patients receiving statin treatment. JELIS found a 19% relative risk reduction in  major  coronary  events  in  patients
with relatively normal TGs but a more pronounced 53% reduction in the subgroup with TGs ³ 150mg/dL and HDL-C < 40mg/dL.

About CaPre

CaPre  is  a  krill oil-derived  mixture  containing  polyunsaturated  fatty  acids,  or  PUFAs,  primarily  composed  of  OM3  fatty  acids,
principally EPA, and docosahexaenoic acid, or DHA. EPA and DHA are well known to be beneficial for human health, and according to
numerous recent clinical studies, may promote healthy heart, brain and visual function, and may also contribute to reducing inflammation
and blood TGs. Krill is a natural source of phospholipids and OM3 fatty acids. The EPA and DHA contained in CaPre are delivered as a
combination of OM3s as free fatty acids and OM3s bound to phospholipid esters, allowing these PUFAs to reach the small intestine where
they undergo rapid absorption and transformation into complex fat molecules that are required for lipid transport in the bloodstream. We
believe that EPA and DHA are more efficiently transported by phospholipids sourced from krill oil than the EPA and DHA contained in
fish oil that are transported either by TGs (as in dietary supplements) or as ethyl esters in other prescription OM3 drugs (such as LOVAZA
and VASCEPA), which must then undergo additional digestion before they are ready for transport into the bloodstream. The digestion and
absorption of OM3 ethyl ester drugs requires a particular enzymatic process that is highly dependent on the fat meal content – the higher
the fat content of the meal, the better the OM3 ethyl ester absorption. High fat meal content is not recommended in patients with HTG. We
believe  that  CaPre’s  superior  absorption  profile  could  represent  a  significant  clinical  advantage,  since  taking  it  with  a low-fat  meal
represents a more realistic and attractive regimen for patients with HTG who must follow a restricted low-fat diet.

CaPre is intended to be used as a therapy combined with positive lifestyle changes, such as a healthy diet, and to be administered
either alone or with other drug treatment regimens such as statins (a class of drug used to reduce LDL-C). CaPre is intended to be taken
orally once or twice per day in capsule form.

Potential Market for CaPre

We believe a significant opportunity exists for OM3 market expansion because, among other things:

•

•

•

  cardiovascular  diseases,  or  CVD,  and  stroke  are  the  leading  causes  of  morbidity  and  mortality  in  the  United  States.  The
burden  of  CVD  and  stroke  in  terms  of  life-years  lost,  diminished  quality  of  life,  and  direct  and  indirect  medical  costs  also
remains enormous;

  evidence suggests potential for OM3s in other cardiometabolic indications; and

  based  on  the  assumption  that  the REDUCE-IT  trial  sponsored  by Amarin  and  the  STRENGTH  trial  sponsored  by Astra
Zeneca, or the CV outcome trials, will be positive, key opinion leaders interviewed by DP Analytics in the study described
further below estimated that they would increase their own prescribing of OM3s by 42% in mild to moderate HTG patients
(200 – 499 mg/dL) and by 35% in severe HTG patients.

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According to the American Heart Association, the prevalence of HTG in the United States and globally correlates to the aging of
the population and the increasing incidence of obesity and diabetes. Market participants, including the American Heart Association, have
estimated that one-third of adults in the United States have elevated levels of TGs (TGs  ³150 mg/dL), including approximately 36 million
people  diagnosed  with  mild  to  moderate  HTG,  and  3  to  4  million  people  diagnosed  with  severe  HTG.  Moreover,  according  to  Ford,
Archives  of  Internal  Medicine  in  a  study  conducted  between  1999  and  2004,  18%  of  adults  in  the  United  States,  corresponding  to
approximately 40 million people, had elevated TG levels equal to or greater than 200 mg/dl, of which only 3.6% were treated specifically
with TG-lowering medication. We believe this data indicates there is a large underserved market opportunity for CaPre.

In 2015, CaPre’s target market in the United States for severe HTG was estimated by IMS NSP Audit data to be approximately
$750 million, with approximately 5 million prescriptions written annually over the prior four years. The total global market was estimated
by GOED Proprietary Research in 2015 to be approximately $2.3 billion. We believe there is the potential to greatly expand the treatable
market in the United States to the approximately 36 million people with mild to moderate HTG, assuming favorable results from the CV
outcome studies that are currently ongoing. These CV outcome trials are expected to report in mid-2018 (the REDUCE-IT trial sponsored
by Amarin) and 2019 (the STRENGTH trial sponsored by Astra Zeneca) and are designed to evaluate the long-term benefit of lowering
TGs  on  cardiovascular  risks  with  prescription  drugs  containing  OM3  fatty  acids.  If  these  trials  are  successful,  additional  clinical  trials
would likely be required for CaPre to also expand its label claims to the mild to moderate HTG segment. Given the large portion of the
adult population in the United States that have elevated levels of TGs but who go largely untreated, we believe there is the potential for a
very significant increase in the total number of patients eligible for treatment if the CV outcome trials are positive.

The following charts illustrate the estimated global and U.S. markets for HTG in 2015, according to IMS NSP Audit data:

CaPre  has  two FDA-approved  and  marketed  branded  competitors  (LOVAZA  and  VASCEPA).  In  addition, Astra  Zeneca  has  an
FDA-approved product, EPANOVA, which has not yet been launched. LOVAZA generics became available on the U.S. market in 2013. In
spite of generic options, audited prescription data from IMS NSP Audit data suggests that over 50% of OM3 prescriptions are written for
branded products (LOVAZA or VASCEPA). By 2015, there had been only an approximately 25% decline in total market value, in spite of
some generic switching that occurs at pharmacies. This stability of branded products is due in part to the fact that the pricing differential
between  branded  and  generic  OM3  products  is  smaller  than  is  typically  the  case  between  branded  and  generic  products  in  the
pharmaceutical  industry.  Based  on  both  primary  market  research  with  pharmacy  benefit  managers,  or  PBMs,  and  audited  prescription
reports,  the  average  pricing  of  generics  is  currently  approximately  $160  per  month,  while  pricing  for  branded  products  averages  $250  -
$300 per month. Amarin has raised prices for VASCEPA annually since its launch in late 2013. PBMs offer “Preferred Brand” status (Tier
2 or Tier 3), without significant restrictions (i.e. no prior authorization, step edits, or high co-payments) for these branded OM3s.

Except  as  otherwise  indicated,  all  of  the  information  that  follows  under  this  heading  has  been  derived  from  secondary  sources,
including audited U.S. prescribing data, and from a qualitative U.S. commercial and primary market research assessment conducted for us
by DP Analytics, A Division of Destum Partners, Inc., or Destum, a market research firm, dated August 19, 2016, which we refer to as the
Destum  Market  Research.  In  its  market  analysis  for  CaPre,  Destum  utilized  secondary  market  data  and  reports  and  conducted  primary
qualitative market research with physicians and third-party payers, such as PBMs. One-on-one in-depth phone interviews lasting on

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average 30-60  minutes  were  conducted  with  22  physicians  and  5  PBMs,  and  key  qualitative  data  was  obtained  by  Destum  on  current
clinical practice for treating patients with HTG, and their perceptions of the current unmet medical need in treating patients with HTG. All
interviews were conducted by the same individual at Destum and recorded to ensure consistency and collection of key data points. Destum
utilized OM3 prescription data from 2009 to 2015 to estimate the size of CaPre’s potential market. Based on its discussions with the PBMs,
Destum  also  assumed  CaPre  would  be  viewed  favorably  by  payers  at  launch  (e.g.,  Tier  2  or  3,  depending  on  payer  plan,  which  is
comparable  to  LOVAZA  and  VASCEPA).  Upon  completing  the  screening  questionnaire  and  being  approved  for  inclusion  in  Destum’s
study, key opinion leaders, or KOLs, and high volume prescribers, or HVPs, were provided with a study questionnaire and were asked to
comment on a target profile for a potential new OM3 “Product X” offering a “trifecta” of cardio-metabolic benefits similar to the potential
efficacy and safety benefits demonstrated by CaPre in our two Phase 1 pharmacokinetic studies and two Phase 2 clinical trials, which we
refer  to  as  the  Target  Product  Profile.  Respondents  were  told  that  the  unidentified  product  was  being  prepared  for  a  Phase  3  program
designed to confirm with statistical significance the product’s safety and efficacy in patients with severe HTG. The Target Product Profile
was used by Destum strictly for market research analysis purposes and should not be construed as an indication of future performance of
CaPre  and  should  not  be  read  as  an  expectation  or  guarantee  of  future  performance  or  results  of  CaPre,  and  will  not  necessarily  be  an
accurate indication of whether or not such results will be achieved by CaPre in our planned Phase 3 program. We subsequently retained
Destum  as  our  exclusive  advisor  and  business  development  consultant  to  identify  potential  strategic  partners  for  CaPre,  under  which
Destum  may  be  entitled  to  a  success  fee  if  a  business  arrangement  or  transaction  is  consummated.  Destum’s  market  research  and  its
conclusions were substantially completed prior our entry into this agreement with Destum.

During the Destum Market Research, KOLs and HVPs interviewed by Destum were asked to assess the level of unmet medical
need associated with treating patients with severe HTG based on currently available treatment options. 91% of physicians interviewed by
Destum indicated that they believe that the current unmet medical need for treating HTG was moderate to high. The reasons identified by
these physicians for their dissatisfaction with the currently available OM3s included insufficient lowering of TGs (principally relating to
VASCEPA),  negative  LDL-C  effects  (principally  relating  to  LOVAZA),  gastrointestinal  side  effects,  and  the  fishy  taste  from  fish
oil-derived  OM3s.  Despite  the  availability  of  other  drug  classes  to  treat  severe  HTG,  interviewed  physicians  indicated  that  they  would
welcome the introduction of new and improved OM3 products, particularly if they can address these perceived deficiencies.

Interviewed physicians responded favorably in the Destum Market Research to the Target Product Profile. They indicated that their
weighted prescribing percentages of the Target Product Profile would increase by approximately 35% to 53% (with the range depending on
the  specific  profile  presented)  in  the  severe  HTG  patient  population  within  two  years  of  the  Target  Product  Profile’s  approval.
Approximately  60%  of  the  interviewed  physicians  indicated  that  they  would  switch  primarily  due  to  the  “trifecta  effect”  of  the  Target
Product Profile on reducing TGs and LDL-C while elevating HDL-C, and the remaining 40% indicated they would switch primarily due to
the  Target  Product  Profile’s  effective  reduction  of  TGs  alone.  In  connection  with  their  responses,  the  interviewed  physicians  were
instructed to assume the Target Product Profile and all currently available OM3 products were not subject to any reimbursement or coverage
hurdles  (e.g.,  all  products  were  on  an  equal  health  care  coverage  playing  field).  This  assumption  was  supported  by  our  interviews  with
leading PBMs in the United States.

We plan to conduct additional market research with KOLs, HVPs, primary care physicians and payers to further develop and refine

our understanding of the potential marketplace for CaPre.

Our Clinical Data

CaPre is being developed by us for the treatment of patients with severe HTG. In two Phase 2 clinical trials conducted by us in
Canada (our COLT and TRIFECTA trials), CaPre was found to be safe and well-tolerated at all doses tested, with no serious adverse events
that were considered treatment-related. Among the reported adverse events with an occurrence of greater than 2% of subjects and greater
than placebo, only diarrhea had an incidence of 2.2%.

In both Phase 2 clinical trials, CaPre significantly lowered TGs in patients with mild to severe HTG. Importantly, in these studies,
CaPre  also  demonstrated  no  deleterious  effect  on LDL-C  (unlike  LOVAZA  and  EPANOVA,  which  have  been  shown  to  significantly
increase LDL-C  in  patients  with  severe  HTG).  Further,  our  Phase  2  data  indicated  that  CaPre  may  actually  reduce LDL-C.  LDL-C  is
undesirable because it accumulates in the walls of blood vessels, where it can cause blockages (atherosclerosis). In the Phase 2 trials, CaPre
also reduced non-HDL-C (all cholesterol contained in the bloodstream except HDL-C), which is also considered to be a marker of

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cardiovascular disease. The COLT trial data showed a mean increase of 7.7% in HDL-C with CaPre at 4 grams per day (p=0.07). Further
studies in our planned Phase 3 program are required to demonstrate CaPre’s statistical significance with HDL-C.

We believe that these multiple potential cardiovascular benefits, if confirmed in our planned Phase 3 program, could be significant
differentiators for CaPre in the marketplace, as no currently approved OM3 drug has shown an ability to positively modulate these four
major blood lipid categories (TGs, non-HDL-C, LDL-C and HDL-C) in the treatment of severe HTG. We also believe that if supported by
additional clinical trials, CaPre has the potential to become the best-in-class OM3 compound for the treatment of mild to moderate HTG.

On September 14, 2016, we announced positive data from our completed comparative bioavailability study, or the Bridging Study.
The Bridging Study was an open-label, randomized, four-way, cross-over, bioavailability study comparing CaPre, given as a single dose of
4 grams in fasting and fed (high-fat) states, as compared to the FDA-approved HTG drug LOVAZA  (OM3-acid ethyl esters) in 56 healthy
volunteers.  The  protocol  was  reviewed  and  approved  by  the  FDA.  The  primary  objective  of  the  Bridging  Study  was  to  compare  the
bioavailability of CaPre to LOVAZA, each administered as a single 4 gram dose with a  high-fat meal, which is the condition under which
administration  of  OM3  drugs  will  yield  the  highest  levels  of  EPA  and  DHA  in  the  blood,  and  therefore  has  the  highest  potential  for
toxicity. To allow us to rely on the long-term safety data of LOVAZA to support a 505(b)(2) NDA for CaPre, our results had to show that
the blood levels of EPA and DHA resulting from a single 4 gram dose of CaPre are not significantly higher than from a single 4 gram dose
of LOVAZA under fed (high-fat meal) conditions. The Bridging Study met all of its objectives and demonstrated that the levels of EPA and
DHA following administration of CaPre did not exceed corresponding levels following administration of LOVAZA in subjects who were
fed  a high-fat meal. We expect that these results will support a claim by us that CaPre and LOVAZA have a comparable safety profile.
Also,  among  subjects  in  a  fasting  state,  CaPre  demonstrated  better  bioavailability  than  LOVAZA,  as  measured  by  significantly  higher
blood  levels  of  EPA  and  DHA.  Since  most  HTG  patients  must  follow  a  restricted  low-fat  diet,  we  believe  that  CaPre’s  strong
bioavailability profile could provide a more effective clinical solution for these patients.

We summarized and submitted data from our Bridging Study to the FDA for review and discussed it with the FDA at an End of
Phase 2 meeting during the first quarter of 2017. We also presented our Bridging Study data at the National Lipid Association Conference
in May 2017 and we plan to submit the data from our Bridging Study for peer review and publication.

The graph below illustrates that the Bridging Study achieved all of its objectives:

Absorption of EPA and DHA as ethyl ester formulations in the currently available prescription OM3 drugs derived from fish oil
(such as LOVAZA and VASCEPA) require the breakdown of the ethyl esters by pancreatic enzymes (lipases) to be released into the blood.
These particular enzymes are produced in response to the consumption of high-fat content meals, leading to optimal absorption of EPA and
DHA. As a result, these OM3 ethyl ester formulations have demonstrated lower absorption and bioavailability when taken with a low-fat
meal or on an empty stomach. As shown in our CAP13-101 study described further below, absorption of CaPre, which is

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formulated as OM3 phospholipids and free fatty acids, is not meaningfully affected by the fat content of a meal consumed prior to drug
administration. Since a low-fat diet is typically a critical component for treatment of patients with severe HTG, we believe that being able
to effectively combine CaPre with a low-fat diet could give CaPre a significant clinical and marketing advantage over the ethyl ester-based
OM3s, such as LOVAZA and VASCEPA, that must be taken with a high-fat meal to achieve optimal absorption.

Our CAP13-101 study was an open-label, randomized, multiple-dose, single-center, parallel-design study in healthy volunteers. 42
subjects were enrolled into 3 groups of 14 subjects who took 1 gram, 2 grams or 4 grams of CaPre, administered once a day 30 minutes
after breakfast. The objectives of the study were to determine the pharmacokinetic, or PK, profile and safety on Day 1 following a single
oral dose and Day 14 following multiple oral doses of CaPre in individuals pursuing a low-fat diet (therapeutic lifestyle changes diet). The
effect of a high-fat meal on the bioavailability of CaPre was also evaluated at Day 15. Blood samples were collected for assessment of EPA
and DHA total lipids in plasma to derive the PK parameters.

The PK profile of CaPre following multiple 4 gram doses obtained in the CAP13-101 study at Day 14 was compared to the results
obtained in a similar PK study (Offman 2013 - ECLIPSE 2) where LOVAZA was also administered at 4 grams a day for 14 days with a
low-fat  diet. Although  CaPre  contains  approximately  2.5  times  less  EPA  and  DHA  compared  to  LOVAZA  (approximately  310  mg/1g
capsule for CaPre versus 770 mg/1g capsule for LOVAZA), when administered with a  low-fat meal, CaPre plasma levels of EPA and DHA
are very similar to those of LOVAZA, as indicated by the area under the plasma drug concentration against time curve, or AUC, and the
maximal plasma drug concentration. This study gives us confidence in the dosing and design of our planned Phase 3 program.

As illustrated by the two graphs below, CaPre reached similar blood and therapeutic levels to LOVAZA after 14 daily doses of

CaPre at 4 grams/day, despite CaPre containing 2.5 times less EPA and DHA compared to LOVAZA:

The  graph  below  illustrates  that  the  bioavailability  of  CaPre  (total  EPA+DHA  levels  in  the  blood)  does  not  appear  to  be
meaningfully  affected  by  the  fat  content  of  a  meal  after  multiple  daily  doses  of  CaPre  at  4  grams/day  (<  20%  difference  in AUC).   We
believe that CaPre’s  strong  bioavailability  could  represent  a  significant  clinical  advantage  for  CaPre  since  taking  it  with  a  low-fat  meal
represents a more realistic and attractive regimen for patients with HTG who must follow a restricted low-fat diet.

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Our Study CAP13-101 CaPre Pharmacokinetics Shows No Significant Food Effect

The graph below presents a summary of the effects of CaPre on patients’ lipid profiles as obtained in our completed TRIFECTA
and COLT Phase 2 clinical trials. 90% of the patients in these clinical trials had mild to moderate HTG (levels between 200 – 499 mg/dL)
and  10%  of  patients  had  severe  HTG  (levels  between  500  and  877  mg/dL),  which  was  the  maximum  level  of  TGs  permitted  by  Health
Canada’s study protocol. Only 30% of the participating patients were taking statins, which we believe is important because statins appear
to  enhance  the TG-lowering  effect  of  OM3s.  In  contrast,  in  our  competitors’  summary  data  that  follows,  100%  of  the  patients  in  those
studies with mild to moderate HTG were taking statins with their OM3s.

The  summary  data  from  our  COLT  and  TRIFECTA  clinical  trials  shows  that  CaPre  significantly  reduces  TGs,  but  unlike  some
other prescription EPA/DHA-based OM3s, it has no deleterious effect on LDL-C and may potentially increase HDL-C (p=0.07), which we
refer to as the “trifecta effect”. Also, a dose response was seen for all of the major lipid markers; the greater the dose of CaPre, the greater
the beneficial effect of CaPre.

Our Phase 2 Study Results Show CaPre Dose Response and Potential for “Trifecta” Lipid Effect

* Indicates results reached statistical significance

TRIFECTA for 1g (N=130) & 2g (N=128) and COLT for 4g (N=62).  HDL-C results at 4g from COLT approached statistical significance at P=0.07.

We conducted a subgroup analysis including only patients with severe HTG, consisting of approximately 10% of the patients from
our TRIFECTA study, to compare the effects of CaPre versus other OM3 drugs in the initial target population of patients with severe HTG.
Despite being given at a lower dose (only 1 gram and 2 grams), CaPre’s results compared very well with data from independent studies for
the other prescription OM3 drugs that are FDA-approved for the treatment of severe HTG at higher doses of 2 grams and 4 grams. While
the results of this subgroup analysis were not statistically significant for CaPre (potentially due to the small sample size), numerically, the
results compared well with the other OM3 drugs, even though CaPre was given at a much lower dose. The results for LDL-C, HDL-C and
non-HDL-C levels in the subgroup shown in the table below are based on descriptive statistics only and are solely directional, meaning that
no statistical testing was conducted and so no “p” values were generated.

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Our Sub-Group Analysis in Patients with Severe HTG: CaPre1 at 1g and 2g Compares Well with Our Competitors2 at 2g and 4g

Only ~1/3 of all patients across all studies were on statins

* Indicates results reached statistical significance

1.

Subgroup analysis on CaPre Phase 2 TRIFECTA study data in patients with severe HTG; (N=10 for 1g & N=14 for 2g). Results are
not statistically significant for TGs, which may be explained by the small number of patients in this subgroup analysis. Results for
LDL-C, HDL-C and non-HDL-C are based on descriptive statistics only (no statistical testing conducted).

2.  LOVAZA 4g (N=103), VASCEPA 2g/4g (N=73/76), EPANOVA 2g/4g (N=100/99).

Since  statins  appear  to  enhance  the TG-lowering  property  of  OM3  drugs,  we  conducted  a  subgroup  analysis  that  only  included
patients  who  were  taking  a  statin  at  baseline  in  the  COLT  and  TRIFECTA  studies  (approximately  30%  of  the  population  of  both  trials,
combined). The graph below compares the TG-lowering effects of CaPre to other OM3s, all on a background of a statin drug, and shows
that CaPre’s TG-lowering effects compare well with other FDA-approved OM3 drugs. We believe it is noteworthy that only 39 patients on
2 grams of CaPre in our TRIFECTA study (out of a total of 128) and only 22 patients on 4 grams of CaPre in our COLT study (out of 62)
were taking statins.

The CaPre 2 gram bar graph in the table below shows the results from patients in our TRIFECTA trial who were taking statins. A
statistically significant reduction in TGs (-25.7% placebo corrected) was seen in that statin subgroup. The CaPre 4 gram bar graph in the
table below shows patient results only from our COLT trial (as there was no 4 gram component for our TRIFECTA). None of the results
were statistically significant at 4 grams of CaPre, potentially due to the small number of patients (22) in the statins subgroup.

As seen in the larger full study analyses in the tables above, CaPre does not show any deleterious effect on LDL, and shows the

potential to decrease LDL and increase HDL (p=0.07). These observations will need to be confirmed in our planned Phase 3 program.

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Our Sub-Group Analysis in Patients Treated with Statins1 vs Independent Competitor Data2: Potential for CaPre Trifecta Effect

* Indicates results reached statistical significance

1.

2.

CaPre subgroup analyses on patients treated with statins: TRIFECTA for 2g (N=39) and COLT for 4g (N=22). For CaPre 2g, results
for LDL-C, HDL-C, and non-HDL-C are based on descriptive statistics only (no statistical testing was conducted). For CaPre 4g, no
results are statistically significant which may be explained by the small number of patients.

All patients on a statin background: LOVAZA (N=122 for 4g), VASCEPA (N= 234 for 2g, N=227 for 4g), EPANOVA (N=209 for
2g, N=207 for 4g). Statins have been shown to enhance the efficacy of OM3 products – VASCEPA NDA 202057. Statistical review,
section 4.2 ‘‘Other special/Subgroup populations’, p. 107; and Maki K et al. Clin. Ther. 2013.

In summary, in addition to effectively reducing TG levels in patients with mild to severe HTG, clinical data collected by us to date

indicates that CaPre may also have:

•

•

•

  beneficial effects on other blood lipids, such as HDL-C (good cholesterol) and non-HDL-C;

  no deleterious effect on, and may potentially reduce, LDL-C (bad cholesterol) levels; and

  absorption  capability  that  is  not  meaningfully  affected  by  the  fat  content  of  a  meal  consumed  prior  to  drug  administration,
providing  patients  with  the  reassurance  that  following  their  physician-recommended low-fat  diet  will  still  result  in  high
absorption.

We  believe  that  these  features  could  set  CaPre  apart  from  currently  available  FDA-approved  OM3  treatment  options  in  the

marketplace and could give us a significant clinical and marketing advantage.

CaPre’s potential clinical benefits as compared to currently available FDA-approved OM3 treatment options are summarized in the

table below and indicate that CaPre may deliver a more complete lipid management solution for patients with severe HTG:

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Our Nonclinical Research

In addition to our Phase 2 clinical trials, we carried out an extensive nonclinical program to demonstrate the safety of CaPre in a
defined  set  of  studies  required  by  the  FDA.  These  studies  were  carried  out  by  contract  research  organizations  with  Good  Laboratory
Practice certification and conducted on various species of animals recommended by the FDA to investigate the long-term effects of CaPre
at doses of up to 65 grams of human equivalent dose over 39 weeks. In these studies, hematological, biochemical, coagulation and overall
health parameters of CaPre were evaluated and no toxic effects were observed in any of the segments of the studies. Other studies focused
on the potential toxic effects of CaPre on vital systems, such as the cardiovascular, respiratory and central nervous system as evaluated by
behavioural studies of the various species. These studies showed that CaPre did not have any adverse or toxic effects on any of the vital
systems investigated, again up to doses well above the recommended clinical dose of CaPre. To rule out short term toxic effects of CaPre
on  genes,  genomic  toxicity  studies  were  undertaken  on  accepted  cellular  and  animal  models.  These  studies  showed  no  toxic  effects  of
CaPre on any of the genetic markers indicative of potential gene altering toxic effects.

We  believe  the  studies  conducted  to  date  indicate  that  CaPre  is  well-tolerated  and  shows  no  toxic  effects  on  any  of  the
physiological  and  vital  systems  of  the  tested  animals  or  their  genes  or  molecules  at  doses  well  above  CaPre’s  anticipated  clinical
therapeutic dose of 4 grams daily.

In parallel to our planned Phase 3 program, we will have to complete additional nonclinical studies, including a pre- and postnatal
development  study  in  rodents  and  a 26-week oral carcinogenicity study in  transgenic  hemizygous  rasH2  mice.  These  nonclinical  studies
will be required to support a NDA for CaPre.

Our Planned Phase 3 Program Design

In March 2017, we announced our plans to proceed with our Phase 3 program following our End-of-Phase 2 meeting with the FDA
in February 2017. Based on the guidance we received from the FDA, we plan to conduct two pivotal, randomized, placebo-controlled Phase
3 studies to evaluate the safety and efficacy of CaPre in patients with severe HTG (TG levels >500 mg/dL). These studies will evaluate
CaPre’s  ability  to  lower  TGs  from  baseline  in  approximately  400  patients  randomized  to  either  4  grams  daily  or  placebo.  The  FDA’s
feedback supports our plan to conduct two studies instead of one large study, potentially shortening the time to an NDA submission, as no
open label extension to the studies is planned. We intend to initiate our Phase 3 program during the second half of 2017. The following
chart illustrates the expected design and dosing of our planned Phase 3 program for CaPre.

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Our Regulatory Strategy for CaPre

Our strategy is to develop and initially commercialize CaPre for the treatment of severe HTG. Our goal is to initiate our Phase 3
program  during  the  second  half  of  2017,  which  would  be  specifically  designed  to  fully  evaluate  the  clinical  effect  of  CaPre  on  TGs,
non-HDL-C, LDL-C, and HDL-C levels together with a variety of other cardiometabolic biomarkers in patients with severe HTG.

In December 2015, we announced that we intend to pursue a 505(b)(2) regulatory pathway towards an NDA approval in the United
States. A  505(b)(2)  regulatory  pathway  is  defined  in  the  U.S.  Federal  Food  Drug  and  Cosmetic Act  (FDCA)  as  an  NDA   containing
investigations of safety and effectiveness that are being relied upon for approval and were not, in whole, conducted by or for the applicant,
and for which the applicant has not obtained a right of reference. 505(b)(2) regulatory pathways differ from a typical NDA because they
allow a sponsor to rely, at least in part, on the FDA’s findings of safety and/or effectiveness for a previously-approved drug. We intend to
pursue the 505(b)(2) regulatory pathway as a strategy to leverage the large body of safety data for LOVAZA, which could accelerate and
streamline the development of CaPre and reduce associated costs and risks.

In connection with our intended use of the 505(b)(2) pathway, the FDA supported our proposal to conduct our Bridging Study that
compared CaPre (which has an OM3 free fatty acid/phospholipid composition) with the FDA-approved HTG drug LOVAZA (which has an
OM3-acid ethyl esters composition) in healthy volunteers. In February 2017, we met with the FDA to review our Bridging Study data. We
confirmed  with  the  FDA  the  505(b)(2)  regulatory  approach  to  use  the  safety  data  for  LOVAZA,  and  finalized  the  study  design  for  our
Phase 3 clinical trials, which will be required for NDA approval. We expect to continue our dialogue with the FDA during the second half
of 2017 to obtain feedback on our regulatory and clinical plans and to clarify or answer specific questions prior to our initiation of our Phase
3 clinical studies.

Our planned key milestones and development timeline are presented below.

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CaPre Development Timeline and Key Milestones

Our Intellectual Property Strategy

Under  a  license  agreement  we  entered  into  with  Neptune  in August  2008,  which  we  refer  to  as  the  “license  agreement”,  we
received  an  exclusive  license  to  use  Neptune’s  intellectual  property  portfolio  related  to  cardiovascular  pharmaceutical  applications.  The
license  agreement  allows  us  to  develop  and  commercialize  CaPre  and  our  novel  and  active  pharmaceutical  ingredients,  or APIs,  for  the
prescription drug and medical food markets. As a result of a royalty prepayment transaction we entered into with Neptune on December 4,
2012,  we  are  no  longer  required  to  pay  any  royalties  to  Neptune  under  the  license  agreement  during  its  term  for  the  use  of  the  licensed
intellectual property. The license agreement expires on the date of the last to expire patent, which is 2031.

In addition to the license agreement, we continue to expand our own intellectual property, or IP, portfolio and patents. We have
now filed patent applications in 22 jurisdictions, including Europe, North America, Asia and Australia for our “Concentrated Therapeutic
Phospholipid Composition” to treat HTG, and we currently have 17 issued or allowed patents and 17 patents pending. The last to expire of
our patents is valid until 2031.

Patent Description

Composition of Matter

WO (PCT) Application # &
U.S. Patent #

Expiration Date of
Patent Family

Number of Patents
Worldwide

CONCENTRATED THERAPEUTIC PHOSPHOLIPID
COMPOSITION

WO2011050474 &
US8,586,567;

2031*

14*
(20 patents pending in
approx. 19 countries)

* Five Australian innovation patents are valid until 2018, patent (ZL 201080059930.4) granted by the Chinese Patent Office is valid until 2030 and patent (US
9475830) granted by the United States Patent and Trademark Office is valid until 2031. Our Australian patent AU 2010312238 expires in 2030.

U.S.  patents  were  granted  to  us  protecting  a  method  of  reducing  serum  TG  levels  comprising  administering  a  composition
comprising  about  66%  phospholipid,  or  PL,  (US  8,586,567),  and  a  method  of  treating  HTG  comprising  administering  a  composition
comprising about 60% PL (US 9,475,830). We later filed a U.S. continuation patent application to pursue prosecution of composition of
matter claims encompassing an extract comprising a PL content between about 60% to about 99%. The U.S. patent covers concentrated
therapeutic  phospholipid  compositions  useful  for  treating  or  preventing  diseases  associated  with  cardiovascular  disease,  metabolic
syndrome,  inflammation  and  associated  diseases  associated,  neurodevelopmental  diseases,  and  neurodegenerative  diseases,  comprising
administering  an  effective  amount  of  a  concentrated  therapeutic  phospholipid  composition.  The  U.S.  patent  is  valid  until  2031.  The
corresponding US 8,586,567 patent has also been granted in South Africa and Japan. Chinese patent (ZL 201080059930.4), which is valid
until  2030,  relates  to  concentrated  therapeutic  phospholipid  OM3  compositions  and  covers  methods  for  treating  or  preventing  diseases
associated with cardiovascular diseases, metabolic syndrome, inflammation, neurodevelopmental diseases, and neurodegenerative diseases.
The patent had also been granted in Japan, Mexico and Taiwan.

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A patent is generally valid for 20 years from the date of first filing. Patent terms can vary slightly for other jurisdictions, with 20
years  from  filing  being  the  norm.  In  certain  jurisdictions,  exclusivity  can  be  formally  extended  beyond  the  normal  patent  term  to
compensate for regulatory delays during the pre-market approval process.

We  believe  these  patents  increase  potential  commercial  opportunities  for  CaPre,  including  through  possible  licensing  and
partnership opportunities. We are committed to building a global portfolio of patents to ensure long-lasting and comprehensive intellectual
property protection and to safeguard potentially valuable market expansion opportunities.

Our patent No. 600167 in New Zealand, which is enforceable until 2030 and relates to a concentrated phospholipid composition
comprising  60%  PL  and  method  of  using  the  same  for  treating  cardiovascular  diseases,  has  been  opposed  by BIO-MER  Ltd.  Our
corresponding Australian patent No. 2010312238 was opposed by Enzymotec Ltd., but that opposition has been since been dropped. The
New Zealand patent opposition is in its early stages. In our view, no new prior art has been presented that was not already considered in
other jurisdictions, such as in the United States and Japan, where our patents are in force.

The following table summarizes the patent applications related to our license agreement with Neptune.

  Patent Description

  Composition of Matter
(NATURAL PHOSPHOLIPIDS OF MARINE ORIGIN CONTAINING FLAVONOIDS AND
POLYUNSATURATED PHOSPHOLIPIDS AND THEIR USES)

  Method of Use for Dyslipidemia
(KRILL AND/OR MARINE EXTRACTS FOR PREVENTION AND/OR TREATMENT OF
CARDIOVASCULAR DISEASES,  ARTHRITIS,  SKIN CANCER,  PREMENSTRUAL SYNDROME,
DIABETES AND TRANSDERMAL TRANSPORT)

  Method of Extraction
  (METHOD OF EXTRACTING LIPIDS FROM MARINCE AND AQUATIC ANIMAL TISSUE)

US Patent #

Expiration Date of
Patent

US8,030,348 (1)

2022

Holder    

Neptune    

US8,057,825

2022

Neptune    

US6,800,299  

2019

Neptune    

  (1)    Three continuations also stem from U.S. Pat. 8,030,348 (U.S. Pat. 8,278,351; and 8,383,675).

We have applied for trademark protection of CaPre, and we are the owner of the trademark BREAKING DOWN THE WALLS OF
CHOLESTEROL in Canada, the United States and the European Union. The trademark CaPre® is registered in the United States, Canada,
Australia, China, Japan and Europe. In addition, we also protect our optimization and extraction processes through industrial trade secrets
and know-how.

Manufacturing of CaPre

We are developing CaPre as a NCE and we plan to implement our Phase 3 program using good manufacturing practices, or cGMP,
good clinical practices, or cGCP, and good laboratory practices, or cGLP. The contract manufacturing organizations, or CMOs, selected by
us for manufacturing and packaging are all cGMP compliant. As batch sizes of 10 to 12 kilograms of CaPre have already been successfully
produced and tested clinically, we are now scaling up  to  100  kg/day  to  fulfill  the  clinical  product  requirements  for  our  planned  Phase  3
program and initial commercial launch.

In  preparation  for  our  planned  Phase  3  program,  working  together  with  our  pharmaceutical  CMOs,  we  have  advanced  the
installation  and  qualification  of  the  proprietary  extraction  and  purification  equipment  used  to  manufacture  CaPre.  We  ran  our  first
engineered production run of CaPre in December 2016 and our first scaled cGMP batches of CaPre at CordenPharma’s Chenôve facility in
Dijon, France during the first half of 2017.

The graphic below illustrates the manufacturing sequence for CaPre:

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Our Business and Commercialization Strategy

Key  elements  of  our  business  and  commercialization  strategy  include  initially  obtaining  regulatory  approval  for  CaPre  in  the
United States for severe HTG. We do not have in-house sales and marketing capabilities. We are currently evaluating several alternative
approaches  to  commercializing  CaPre  in  the  United  States.  Our  preferred  strategy  is  to  commercialize  CaPre  outside  the  United  States
through  strategic  partnerships,  and  to  potentially  seek  funding  support  from  strategic  partnerships  for  these  development  and
commercialization activities. We believe that a late development-stage and differentiated drug candidate like CaPre could be attractive to
various global, regional or specialty pharmaceutical companies, and we are taking an opportunistic approach to partnering and licensing in
various geographies and indications.

If we reach commercialization of CaPre, as part of our sales and marketing strategy, we expect to focus our U.S. launch initially on
lipid specialists, cardiologists and primary care physicians who comprise the top prescribers of lipid-regulating therapies for patients with
severe HTG.

Our key commercialization goals include:

•

•

•

•

  initiating  and  completing  our  planned  Phase  3  program  and,  assuming  the  results  are  positive,  filing  an  NDA  to  obtain
regulatory approval for CaPre in the United States, initially for the treatment of severe HTG, with the potential to afterwards
expand CaPre’s indication to the treatment of mild to moderate HTG;

  continuing to strengthen our patent portfolio and other intellectual property rights;

  continuing to evaluate the optimal strategic approach for commercializing CaPre in the United States; and

  pursuing  strategic  opportunities  outside  of  the  United  States,  such  as  licensing  or  similar  transactions,  joint  ventures,
partnerships, strategic alliances or alternative financing transactions, to provide development capital, market access and other
strategic sources of capital for us.

In addition to completing our planned Phase 3 program, we expect that additional time and capital will be required to complete the
filing of an NDA to obtain FDA  pre-market approval for CaPre in the United States, and to complete business development collaborations,
marketing and other pre-commercialization activities before reaching the commercial launch of CaPre.

Competition

The  biotechnology  and  pharmaceutical  industries  are  highly  competitive.  There  are  many  pharmaceutical  companies,
biotechnology companies, public and private universities and research organizations actively engaged in the research and development of
products that may be similar to CaPre. We believe that the number of companies seeking to develop products and therapies similar to CaPre
will likely increase, particularly if the CV outcome trials by Amarin and/or Astra Zeneca are successful.

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Our  competitors  in  the  United  States  and  globally  include  large,  well-established  pharmaceutical  companies,  specialty
pharmaceutical sales and marketing companies, and specialized cardiovascular treatment companies. GlaxoSmithKline plc, which currently
sells LOVAZA, a prescription-only OM3 fatty acid indicated for patients with severe HTG, was approved by the FDA in 2004 and has been
available in the U.S. market since 2005. Multiple generic versions of LOVAZA are now available in the United States. Amarin launched its
prescription-only  OM3  drug  VASCEPA  in  2013,  and  reached  a  market  share  of  approximately  20%  by  the  end  of  2015.  In  addition,
EPANOVA (OM3-carboxylic acids) capsules, a free fatty acid form of OM3 (comprised of 55% EPA and 20% DHA), is  FDA-approved
for patients with severe HTG. Omtryg, another OM3-acid fatty acid composition developed by Trygg Pharma AS, received FDA approval
for  severe  HTG.  Neither  EPANOVA  nor  Omtryg  have  yet  been  commercially  launched,  but  could  launch  at  any  time.  Other  large
companies with products that would compete indirectly with CaPre include AbbVie, Inc., which currently sells Tricor and Trilipix for the
treatment of severe HTG, and Niaspan, which is primarily used to raise HDL-C but is also used to lower TGs. Generic versions of Tricor,
Trilipix, and Niaspan are also now available in the United States. In addition, we are aware of a number of other pharmaceutical companies
that are developing products that, if approved and marketed, would compete with CaPre.

Raw Materials

We use semi-refined raw krill oil as our primary raw material to produce CaPre. Krill is generally harvested in Antarctic waters.
The total quantity of the krill species is estimated to be at least 500,000,000 metric tons. The krill biomass is the world’s most abundant
biomass and is monitored to help ensure sustainable cultivation. Currently, we source all of our krill oil from Neptune.

Employees, Specialized Skills and Knowledge

Our management consists of professionals from business development, sales and marketing, clinical development, pharmaceutical
manufacturing,  finance  and  science  backgrounds.  Our  research  team  includes  scientists  with  expertise  in  pharmaceutical  development,
chemistry, manufacturing and controls, nonclinical and clinical studies, pharmacology, regulatory affairs, quality assurance/quality control,
intellectual property and strategic alliances. As of March 31, 2017, we employed 15 people in Canada and the United States, eight of whom
have advanced biology, engineering, chemistry, biochemistry or microbiology degrees. We generally require all of our employees to enter
into invention assignment, non-disclosure and non-compete agreements. We rely, in part, on some administrative and general accounting
support  from  Neptune,  and  we  also  rely  on  third-party  consultants  from  time  to  time.  Our  employees  are  not  covered  by  any  collective
bargaining agreement or represented by a trade union.

Additional Information About Our Phase 2 Clinical Trials

Our COLT Trial

Our COLT clinical trial, which was completed in 2014, was a randomized, open-label, dose-ranging, multi-center trial in Canada
designed  to  assess  the  safety  and  efficacy  of  CaPre  in  the  treatment  of  patients  with  TG  levels  between 200-877  mg/dL.  The  primary
objectives  of  the  COLT  study  were  to  evaluate  the  safety  and  efficacy  of  0.5  grams,  1  gram,  2  grams  and  4  grams  of  CaPre  per  day  in
reducing fasting plasma TGs over 4 and 8 weeks, as compared to the standard of care alone.

The secondary objectives of the COLT study were to evaluate:

•

•

•

  the effect of CaPre on fasting plasma TGs in patients with TGs between 200-499 mg/dL (mild to moderate HTG);

  the dose dependent effect on fasting plasma triglycerides in patients with TGs between 500-877 mg/dL (severe HTG); and

  the effect of CaPre on fasting plasma levels of LDL-C (direct measurement), HDL-C, non-HDL-C, hs-CRP and OM3 index.

The final results of the COLT trial indicated that CaPre was safe and effective in reducing TGs in patients with mild to severe HTG
with  significant  mean  (average)  TG  reductions  above  20%  after  8  weeks  of  treatment  with  daily  doses  of  4  grams  and  2  grams.
Demographics and baseline characteristics of the patient population were balanced in terms of age, race and gender. A total of 288 patients
were enrolled and randomized and 270 patients completed the study, which exceeded our targeted number of evaluable patients. From this
patient population, approximately 90% had mild to moderate HTG.

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The proportion of patients treated with CaPre that experienced one or more adverse events in the COLT trial was similar to that of
the standard of care group (30.0% versus 34.5%, respectively). A substantial majority of adverse events were mild (82.3%) and no severe
treatment-related  adverse  effects  were  reported.  Only  one  patient  was  discontinued  from  the  study  due  to  an  adverse  event  of  moderate
intensity. While the rate of gastrointestinal side effects was higher in the CaPre groups compared to standard of care alone and appeared to
increase in a dose-related manner, none of the subjects participating in the study suffered from a serious adverse event. The COLT study
results  showed  that  even  at  higher  doses,  CaPre  is  safe  and  well  tolerated  with  only  transient  and  predominantly  mild  adverse  events
occurring at low rates.

The COLT trial met its primary objective of showing CaPre to be safe and effective in reducing TGs in patients with mild to severe
HTG.  After  only  a  4-week  treatment,  CaPre  achieved  a  statistically  significant  TG  reduction  as  compared  to  standard  of  care  alone.
Standard of care could be any treatment physicians considered appropriate in a real-life clinical setting and included lifestyle modifications
as well as statins and/or ezetimibe. Patients treated with 4 grams of CaPre per day over 4 weeks reached a mean TG decrease of 15.4% from
baseline and a mean improvement of 18.0% over the standard of care. Results also showed increased benefits after 8 weeks of treatment,
with patients on a daily dose of 4 grams of CaPre registering a mean TG decrease of 21.6% from baseline and a mean improvement of
14.4% over the standard of care.

After 8 weeks of treatment, patients treated with 1 gram of CaPre for the first 4 weeks of treatment and 2 grams for the following 4
weeks, showed a statistically significant TG mean improvement of 16.2% over the standard of care, corresponding to a 23.3% reduction for
the 1-2 grams patient population as compared to a 7.1% reduction for the standard of care. After 8 weeks of treatment, patients treated with
2  grams  of  CaPre  for  the  entire  8  weeks  showed  statistically  significant  TG  mean  improvements  of  14.8%  over  the  standard  of  care,
corresponding  to  a  22.0%  reduction  for  the  2  grams  as  compared  to  a  7.1%  reduction  for  the  standard  of  care. Also,  after  8  weeks  of
treatment,  patients  treated  with  4  grams  for  the  entire  8  weeks  showed  statistically  significant  TG, non-HDL-C  and  HbA1C  mean
improvements  of  14.4%  and  9.8%  and  15.0%,  respectively,  as  compared  to  standard  of  care.  The  4  grams  group  showed  mean
improvements in:

•

•

•

  TGs of 14.4%, corresponding to a reduction of 21.6% as compared to a reduction of a 7.1% for the standard of care group,

  non-HDL-C of 9.8%, corresponding to a reduction of 12.0% as compared to a reduction of 2.3% for the standard of care group,
and

  HbA1C of 15.0%, corresponding to a reduction of 3.5% as compared to an increase of 11.5% for the standard of care group.

In addition, all combined doses of CaPre showed a statistically significant treatment effect on HDL-C levels, with an increase of
7.4%  as  compared  to  standard  of  care.  Trends (p-value  <  0.1)  were  also  noted  on  patients  treated  with  4  grams  of  CaPre  for  the  entire
8-week  treatment  period  with  mean  reduction  of  total  cholesterol  of  7.0%  and  increase  of HDL-C  levels  of  7.7%,  as  compared  to  the
standard of care. The results of the COLT trial indicated that CaPre has no significant deleterious effect on LDL-C (bad cholesterol) levels.

Our TRIFECTA Trial

Our TRIFECTA clinical trial, which was completed in 2015, was a  12-week, randomized, placebo-controlled, double-blind, dose-
ranging  trial  in  Canada,  designed  to  assess  the  safety  and  efficacy  of  CaPre  at  a  dose  of  1  gram  or  2  grams  on  fasting  plasma  TGs  as
compared  to  a  placebo  in  patients  with  TG  levels  between 200-877  mg/dL. A  total  of  387  patients  were  randomized  and  365  patients
completed the 12-week study, consistent with our targeted number of evaluable patients. From this patient population, approximately 90%
had mild to moderate HTG with baseline TGs between 200 and 499 mg/dL. The remainder had severe HTG with baseline TGs between
500  and  877  mg/dL. Approximately  30%  of  patients  were  on  lipid-lowering  medications,  such  as  statins,  and  approximately  10%  were
diabetic.

Similar to our COLT study, the primary objective of the TRIFECTA study was to evaluate the effect of CaPre on fasting plasma
TGs  in  patients  with  TGs  between 200-877  mg/dL  and  to  assess  the  tolerability  and  safety  of  CaPre.  The  secondary  objectives  of  the
TRIFECTA study were to evaluate:

•

•

  the effect of CaPre on fasting plasma TGs in patients with TGs between 200-499 mg/dL;

  the dose dependent effect on fasting plasma TGs in patients with TGs between 500-877 mg/dL; and

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•

  the  effect  of  CaPre  in  patients  with  mild  to  moderate  HTG  and  severe  HTG  on  fasting  plasma  levels  of LDL-C  (direct

measurement), and on fasting plasma levels of HDL-C, non-HDL-C, hs-CRP and OM3 index.

CaPre  successfully  met  the  TRIFECTA’s  study’s  primary  objective.  The  placebo-corrected  percentage  change  in  TGs  were
decreases of 9.1% (p=0.049) and 9.7% (p=0.044) for 1 gram and 2 grams of CaPre, respectively. Key secondary objectives were also met:

•

•

•

  there was a statistically significant decrease in non-HDL-C versus placebo (p=0.038), with the 2 gram group decreasing by

5.3% from baseline versus placebo over the 12-week period;

  HDL-C (good cholesterol) slightly increased at both the 1 gram and 2 gram levels; and

  LDL-C (bad cholesterol) and slightly decreased at the 2 gram level.

Finally, a statistically significant dose response increase in the OM3 index for patients on 1 gram and 2 grams versus placebo was
noted.  The  OM3  index  reflects  the  percentage  of  EPA  and  DHA  in  red  blood  cell  fatty  acids  and  the  risk  of  cardiovascular  disease  is
considered to be lower as the OM3 index increases.

CaPre was found to be safe and well tolerated at all doses tested, with no serious adverse events that were considered treatment-
related. Out of 387 randomized patients, a total of 7 (1.8%) were discontinued as a result of adverse events, three were on placebo, two
were on 1 gram and two were on 2 grams. The predominant incidence was gastrointestinal-related, with no difference between CaPre and
placebo. The safety profiles of patients on CaPre and placebo were similar.

The  COLT  and  TRIFECTA  clinical  trials  were  conducted  by  JSS  Medical  Research,  a  CRO  specializing  in  the  pharmaceutical,
biotechnology,  nutraceutical  and  medical  device  industries,  which  is  both  owned  and  managed  by  Dr.  John  Sampalis,  the  brother  of
Dr. Tina Sampalis, who previously was our President and Chief Global Strategy Officer. JSS was selected by us following a rigorous due
diligence  process.  Our  board  of  directors  appointed  an  external  independent  auditor,  SNC  Lavalin  Pharma,  to  confirm  and  validate  the
clinical trials’ achievements, milestones and payments.

Government Regulation

United States Drug Development

Government authorities in the United States, at the federal, state and local level, and in other countries extensively regulate, among
other  things,  the  research,  development,  testing,  manufacture,  quality  control,  approval,  labeling,  packaging,  storage,  record-keeping,
promotion,  advertising,  distribution,  post-approval  monitoring  and  reporting,  marketing  and  export  and  import  of  drug  products  such  as
CaPre. Generally, before a new drug can be marketed, considerable data demonstrating its quality, safety and efficacy must be obtained,
organized into a format specific to each regulatory authority, submitted for review and approved by the regulatory authority.

FDA Regulatory Process

In the United States, the FDA regulates drugs under the FDCA and its implementing regulations. Drugs are also subject to other
federal,  state  and  local  statutes  and  regulations.  The  process  of  obtaining  regulatory  approvals  and  the  subsequent  compliance  with
appropriate federal, state and local statutes and regulations require the expenditure of substantial time and financial resources.

In order to be marketed in the United States, CaPre must be approved by the FDA through the NDA review process. The process

required before a drug may be marketed in the United States generally involves the following:

•

•

•

•

  completion of extensive nonclinical (animal) and formulation studies in accordance with applicable regulations, including the
FDA’s Good Laboratory Practice, or GLP, regulations;

  submission of an investigational new drug, or IND, which must become effective before human clinical trials may begin in the
United States;

  performance of adequate and well-controlled clinical trials in accordance with the applicable IND and other clinical study-
related regulations, such as current Good Clinical Practices, to establish the safety and efficacy of the proposed drug for its
proposed indication;

  submission of an NDA for a new drug;

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•

•

•

  satisfactory completion of an FDA pre-approval inspection of the manufacturing facility or facilities where the drug is

produced to assess compliance with cGMP to assure that the facilities, methods and controls are adequate to preserve the
drug’s identity, strength, quality and purity;

  satisfactory completion of potential FDA audit of the nonclinical and/or clinical trial sites that generated the data in support of

the NDA; and

  FDA review and approval of the NDA prior to any commercial marketing or sale of the drug in the United States.

The  data  required  to  support  an  NDA  is  generated  in  two  distinct  development  stages:  nonclinical  and  clinical.  The  nonclinical
development  stage  generally  involves  synthesizing  or  otherwise  producing  the  active  component,  developing  the  formulation  and
determining the manufacturing process, as well as carrying out non-human toxicology, pharmacology and drug metabolism studies in the
laboratory,  which  support  subsequent  clinical  testing.  The  sponsor  must  submit  the  results  of  the  nonclinical  tests,  together  with
manufacturing information, analytical data, any available clinical data or literature and a proposed clinical protocol, to the FDA as part of
the  IND,  which  is  a  request  for  authorization  from  the  FDA  to  administer  an  investigational  drug  product  to  humans.  The  IND
automatically  becomes  effective  30  days  after  receipt  by  the  FDA,  unless  the  FDA  raises  concerns  or  questions  regarding  the  proposed
clinical trials. The FDA may also place the IND on clinical hold within that 30-day time period. In such a case, the IND sponsor and the
FDA must resolve any outstanding concerns before the clinical trial can begin. A clinical hold may be imposed at any time before or during
a clinical trial due to safety concerns or non-compliance.

The  clinical  stage  of  development  first  involves  the  administration  of  the  investigational  drug  to  healthy  volunteers  and  then  to
patients with the disease being targeted with the drug, all done under the supervision of qualified investigators, generally physicians not
employed by or under the trial sponsor’s control, in accordance with cGCP. All research subjects must provide their informed consent for
their  participation  in  any  clinical  trial.  Clinical  trials  are  conducted  under  protocols  detailing,  among  other  things,  the  objectives  of  the
clinical trial, dosing procedures, subject selection and exclusion criteria, data collection, and the parameters to be used to monitor subject
safety and assess the investigational drug’s efficacy. Each protocol, and any subsequent amendments to the protocol or new investigator’s
information, must be submitted to the FDA as part of the IND. Further, each clinical trial must be reviewed and approved by an independent
institutional  review  board,  or  IRB,  at  or  servicing  each  institution  at  which  the  clinical  trial  will  be  conducted. An  IRB  is  charged  with
protecting the welfare and rights of trial participants and considers such items as whether the risks to individuals participating in the clinical
trials are minimized and are reasonable in relation to anticipated benefits. The IRB also approves the informed consent form that must be
provided to each clinical trial subject or its legal representative. There are also requirements governing the reporting of ongoing clinical
trials and completed clinical trial results to public registries, as well as reporting of safety information under the IND.

Clinical  studies  are  generally  conducted  in  three  sequential  phases  that  may  overlap,  known  as  Phase  1,  Phase  2  and  Phase  3
clinical trials. Phase 1 generally involves a small number of healthy volunteers who are initially exposed to a single dose and then multiple
doses  of  the  investigational  drug.  The  primary  purpose  of  these  studies  is  to  assess  the  metabolism,  pharmacologic  action,  side  effect
tolerability  and  safety  of  the  drug.  Phase  2  trials  typically  involve  studies  in  disease-affected  patients  to  determine  the  dose  required  to
produce the desired benefits. At the same time, safety and further pharmacokinetic and pharmacodynamic information is collected, as well
as identification of possible adverse effects and safety risks and preliminary evaluation of efficacy. Phase 3 clinical trials generally involve
large numbers of patients at multiple sites, often in multiple countries (from several hundred to several thousand subjects) and are designed
to  provide  the  data  necessary  to  demonstrate  the  effectiveness  of  the  product  for  its  intended  use,  its  safety  in  use,  and  to  establish  the
overall benefit/risk relationship of the product and provide an adequate basis for product approval. Phase 3 clinical trials should, if possible,
include  comparisons  with  placebo  and  may  include  a  comparison  to  approved  therapies.  The  duration  of  treatment  is  often  extended  to
mimic the actual use of a product during marketing. Generally, two adequate and well-controlled Phase 3 clinical trials are required by the
FDA for approval of an NDA (Pivotal Studies).

Progress reports detailing the results of the clinical trials must be submitted at least annually to the FDA. In addition, written IND
safety reports must be submitted to the FDA and the investigators for serious and unexpected adverse events or any finding from tests in
laboratory  animals  that  suggests  a  significant  risk  for  human  subjects.  The  FDA,  the  IRB,  or  the  sponsor  may  suspend  or  terminate  a
clinical trial at any time on various grounds, including a finding that the research subjects or patients are being exposed to an unacceptable
health risk.

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Additionally, some clinical trials are overseen by an independent group of qualified experts organized by the clinical trial sponsor, known
as a data safety monitoring board or committee. This group provides oversight and will determine whether or not a trial may move forward
at  designated  check  points  based  on  review  of  interim  data  from  the  study. A  clinical  trial  may  be  terminated  or  suspended  based  on
evolving business objectives and/or competitive climate.

The manufacturing process must be capable of consistently producing quality batches of the investigational drug and, among other
things,  must  develop  methods  for  testing  the  identity,  strength,  quality  and  purity  of  the  final  drug  product.  The  sponsor  must  develop
appropriate  labeling  that  sets  forth  the  conditions  of  intended  use. Additionally,  appropriate  packaging  must  be  selected  and  tested  and
stability studies must be conducted to demonstrate that the drug candidate does not undergo unacceptable deterioration over its shelf life.

Post-approval studies, sometimes referred to as Phase 4 clinical trials, may be conducted  after  initial  marketing  approval.  These
studies are used to gain additional experience from the treatment of patients in the intended therapeutic indication. In certain instances, the
FDA may mandate the performance of Phase 4 studies as part of a post-approval commitment, such as pediatric studies.

NDA and FDA Review Process

Nonclinical  and  clinical  information  is  filed  with  the  FDA  in  an  NDA  along  with  proposed  labeling.  The  NDA  is  a  request  for
approval to market the drug and must contain proof of safety, purity, potency and efficacy, which is demonstrated by extensive nonclinical
and  clinical  testing.  Data  may  come  from  company-sponsored  clinical  trials  intended  to  test  the  safety  and  effectiveness  of  a  use  of  a
product,  or  from  a  number  of  alternative  sources,  including  studies  initiated  by  investigators.  To  support  marketing  approval,  the  data
submitted  must  be  sufficient  in  quality  and  quantity  to  establish  the  safety  and  effectiveness  of  the  investigational  drug  product  to  the
satisfaction of the FDA.

The submission of an NDA is subject to the payment of substantial user fees; a waiver of such fees may be obtained under certain
limited  circumstances.  FDA  approval  of  an  NDA  must  be  obtained  before  marketing  a  drug  in  the  United  States.  In  addition,  under  the
Pediatric Research Equity Act, an NDA or supplement to an NDA must contain data to assess the safety and effectiveness of the drug for
the claimed indications in all relevant pediatric subpopulations and to support dosing and administration for each pediatric subpopulation
for which the product is safe and effective. The FDA may grant deferrals for submission of data or full or partial waivers.

The  FDA  reviews  all  NDAs  submitted  before  it  accepts  them  for  filing  and  may  request  additional  information.  The  FDA  must
make a decision on accepting an NDA for filing within 60 days of receipt. Once the submission is accepted for filing, the FDA begins an
in-depth review of the NDA. Under the goals and policies agreed to by the FDA under the Prescription Drug User Fee Act, or PDUFA, the
FDA  has  ten  months  from  the  filing  date  in  which  to  complete  its  initial  review  of  a  standard  NDA  and  respond  to  the  applicant.  This
review typically takes 12 months from the date the NDA is submitted to the FDA including the screening which takes a period of 60 days.
The FDA does not always meet its PDUFA goal dates for standard NDAs, and the review process is often significantly extended by FDA
requests for additional information or clarification.

After  the  NDA  submission  is  accepted  for  filing,  the  FDA  reviews  the  NDA  to  determine,  among  other  things,  whether  the
proposed product is safe and effective for its intended use, and whether the product is being manufactured in accordance with cGMP to
assure and preserve the product’s identity, strength, quality and purity. The FDA will likely  re-analyze the clinical trial data, which could
result in extensive discussions with the FDA.

Before approving an NDA, the FDA will conduct a  pre-approval inspection of the manufacturing facilities for the new product to
determine whether they comply with cGMP. The FDA will not approve the product unless it determines that the manufacturing processes
and  facilities  are  in  compliance  with  cGMP  requirements  and  adequate  to  assure  consistent  production  of  the  product  within  required
specifications. In addition, before approving an NDA, the FDA may also audit data from clinical trials to ensure compliance with cGCP
requirements.  After  the  FDA  evaluates  the  application,  manufacturing  process  and  manufacturing  facilities,  it  will  issue  a  Complete
Response Letter, or CRL. A CRL indicates that the review cycle of the application is complete and whether the application is approved
and, when applicable, the CRL describes the specific deficiencies in the NDA and may require additional clinical data and/or an additional
Phase  3  clinical  trial(s),  and/or  other  significant  and  time-consuming  requirements  related  to  clinical  trials,  nonclinical  studies  or
manufacturing.  The  applicant  may  either  resubmit  the  NDA,  addressing  all  of  the  deficiencies  identified  in  the  letter,  or  withdraw  the
application. Even if such data and information is submitted, the FDA may ultimately decide that the NDA does not satisfy the criteria for
approval.

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If  a  product  receives  marketing  approval,  the  approval  may  be  significantly  limited  to  specific  diseases  and  dosages  or  the
indications for use may otherwise be limited, which could restrict the commercial value of the product. Further, the FDA may require that
certain  contraindications,  warnings  or  precautions  be  included  in  the  product  labeling,  may  condition  the  approval  of  the  NDA  on  other
changes  to  the  proposed  labeling,  or  may  require  a  Risk  Evaluation  and  Mitigation  Strategy  (REMS),  which  could  limit  the  ability  to
market the drug once approved. The FDA may also require the development of adequate controls and specifications, or a commitment to
conduct post-market testing or clinical trials and surveillance to monitor the effects of approved products.

U.S. Post-Marketing Requirements

Following approval of a new product, a pharmaceutical company and the approved product are subject to continuing regulation by
the  FDA,  including,  among  other  things,  monitoring  and  recordkeeping  activities,  reporting  to  the  applicable  regulatory  authorities  of
adverse experiences with the product, providing the regulatory authorities with updated safety and efficacy information, product sampling
and  distribution  requirements,  and  complying  with  promotion  and  advertising  requirements,  which  include,  among  others,  standards  for
direct-to-consumer  advertising,  restrictions  on  promoting  drugs  for  uses  or  in  patient  populations  that  are  not  described  in  the  drug’s
approved  labeling,  or “off-label  use”,  limitations  on  industry-sponsored  scientific  and  educational  activities,  and  requirements  for
promotional activities involving the internet. Although physicians may prescribe legally available drugs for off-label uses, manufacturers
and distributors may not market or promote such off-label uses. Modifications or enhancements to the product or its labeling or changes of
the site of manufacture are often subject to the approval of the FDA and other regulators, which may or may not be received or may result
in a lengthy review process. In some cases, these changes will require the submission of clinical data and the payment of a user fee.

U.S. Patent Term Restoration and Marketing Exclusivity

Depending  upon  the  timing,  duration  and  specifics  of  the  FDA  approval  of  our  prescription  drug  candidates,  some  of  our  U.S.
patents  may  be  eligible  for  limited  patent  term  extension  under  the  Drug  Price  Competition  and  Patent  Term  Restoration Act  of  1984,
commonly referred to as the Hatch-Waxman Amendments. The Hatch-Waxman Amendments permit a patent restoration term of up to five
years  as  compensation  for  patent  term  lost  during  product  development  and  the  FDA  regulatory  review  process.  However,  patent  term
restoration  cannot  extend  the  remaining  term  of  a  patent  beyond  a  total  of  14  years  from  the  product’s  approval  date.  The  patent  term
restoration  period  is  generally one-half the time between the effective date of an IND and the submission date of an NDA plus the time
between the submission date of an NDA and the approval of that application. Only one patent applicable to an approved drug is eligible for
the extension and the application for the extension must be submitted prior to the expiration of the patent. The USPTO in consultation with
the FDA, reviews and approves the application for any patent term extension or restoration. In the future, we intend to apply for restoration
of patent term for one of our currently owned or licensed patents to add patent life beyond its current expiration date, depending on the
expected length of the clinical trials and other factors involved in the filing and review of the relevant NDA.

Non-U.S. Drug Regulation

In Canada, biopharmaceutical product candidates are regulated by the Food and Drugs Act and the related rules and regulations,
which are enforced by the Therapeutic Products Directorate of Health Canada. In order to obtain approval for commercializing new drugs
in Canada, the sponsor must satisfy many regulatory conditions. The sponsor must first complete preclinical studies in order to file a clinical
trial application, or CTA, in Canada. The sponsor will then receive different clearance authorizations to proceed with Phase I clinical trials,
which can then lead to Phase 2 and Phase 3 clinical trials. Once all three phases of trials are completed, the sponsor must file a registration
file named a New Drug Submission, or NDS, in Canada. If the NDS demonstrates that the product was developed in accordance with the
regulatory authorities’ rules, regulations and guidelines and demonstrates favorable safety and efficacy and receives a favorable risk/benefit
analysis, then the regulatory authorities issue a notice of compliance, which allows the sponsor to market the product.

In addition to regulations in the United States and Canada, we are subject to a variety of regulations governing clinical studies and
commercial sales and distribution of our products in other jurisdictions around the world. These laws and regulations typically require the
licensing  of  manufacturing  and  contract  research  facilities,  carefully  controlled  research  and  testing  of  product  candidates  and
governmental  review  and  approval  of  results  prior  to  marketing  therapeutic  product  candidates. Additionally,  they  require  adherence  to
good laboratory practices, good clinical practices and good manufacturing practices during production. The process of new drug approvals
by regulators in the United States, Canada and the European Union are generally considered to be among the most rigorous in the world.

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Whether  or  not  the  FDA  or  Health  Canada  approval  is  obtained  for  a  product,  we  must  obtain  approval  from  the  comparable
regulatory  authorities  of  other  countries  before  we  can  commence  clinical  studies  or  marketing  of  the  product  in  those  countries.  The
approval process varies from country to country and the time may be longer or shorter than that required for the FDA or Health Canada
approval.  The  requirements  governing  the  conduct  of  clinical  studies,  product  licensing,  pricing  and  reimbursement  vary  greatly  from
country  to  country.  In  some  international  markets,  additional  clinical  trials  may  be  required  prior  to  the  filing  or  approval  of  marketing
applications within the country.

Active Pharmaceutical Ingredient Regulation

The FDA will regulate finished products containing APIs developed or under development by us. Depending on its intended uses, a
finished  product  containing  the API  may  be  regulated  as  a  drug  under  the  procedures  described  above.  It  may  be  possible  to  market  a
finished  product  containing  an API  developed  or  under  development  by  us  as  a  dietary  supplement.  Dietary  supplements  do  not  require
FDA premarket approval. However, it may be necessary to submit a notification to the FDA that a company intends to market a dietary
supplement containing a “new dietary ingredient.” In general, the regulatory requirements in other countries also depend on the nature of
the finished product and do not focus on the API itself.

C. Organizational Structure

We have no subsidiaries. As of June 26, 2017, Neptune owns 5,064,694 of our common shares, representing 34.4% of our common
shares issued and outstanding. Our common shares are voting, participating and have no par value. Neptune also owns a warrant entitling it
to acquire 592,500 common shares.

D.

Property, Plants and Equipment

Our head office and operations are located at 545, Promenade Centropolis, suite 100, Laval, Québec, Canada, H7T 0A3. We do
not own our own manufacturing facility for the production of CaPre; however, we do own the proprietary equipment for producing the API
and drug product. We currently do not have plans to develop our own manufacturing facility. However, this could change in the foreseeable
future,  as  we  consider  the  most  cost-effective  approaches  to  producing  CaPre  while  ensuring  the  highest  level  of  quality.  We  currently
depend on third party suppliers and manufacturers, such as Neptune, to produce our required raw krill oil and drug substance and products.
If  CaPre  is  approved  for  distribution  by  the  FDA,  we  initially  expect  to  rely  on  cGMP-compliant  third  parties  to  manufacture  NKPL66,
which is API in CaPre, encapsulate, bottle and package clinical supplies of CaPre.

We have entered into an agreement CordenPharma Chenôve, a third party CMO, for the manufacturing of CaPre clinical material

for the purposes of our planned Phase 3 program in accordance with cGMP regulations imposed by the FDA.

Item 4A. Unresolved Staff Comments

Not applicable.

Item 5. Operating and Financial Review and Prospects

This annual report contains forward-looking statements, principally in, but not limited to, “Item 4 - Information on the Company”
and  “Item  5  -  Operating  and  Financial  Review  and  Prospects”.  These  statements  may  be  identified  by  the  use  of  words  like  “plan”,
“expect”,  “aim”,  believe”,  “project”,  “anticipate”,  “intend”,  “estimate”,  “will”,  “should”,  “could”  and  similar  expressions  in  connection
with any discussion, expectation, or projection of future operating or financial performance, events or trends. In particular, these include
statements  about  our  strategy  for  growth,  future  performance  or  results  of  current  sales  and  production,  interest  rates,  foreign  exchange
rates, and the outcome of contingencies, such as acquisitions and/or legal proceedings and intellectual property issues.

Forward-looking  statements  are  based  on  certain  assumptions  and  expectations  of  future  events  that  are  subject  to  risks  and
uncertainties.  Actual  future  results  and  trends  may  differ  materially  from  historical  results  or  those  projected  in  any  forward-looking
statements depending on a variety of factors, including, among other things, the factors discussed in this annual report under “Item 3.D -
Risk Factors” and factors described in documents that

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we may furnish from time to time to the SEC. Although the forward-looking information is based upon what we believe to be reasonable
assumptions,  no  person  should  place  undue  reliance  on  forward-looking  information  since  actual  results  may  vary  materially  from  the
forward-looking  information.  Except  as  required  by  law,  we  undertake  no  obligation  to  update  publicly  or  revise  any  forward-looking
statements  because  of  new  information.  Please  refer  to  “Special  Note  Regarding  Forward-Looking  Statements”  at  the  beginning  of  this
annual report for additional details.

Management’s Discussion and Analysis of Financial Situation and Operating Results
Fiscal Years Ended March 31, 2017, February 29, 2016 and February 28, 2015

Introduction

This management discussion and analysis, or MD&A, is presented in order to provide the reader with an overview of our financial
results  and  changes  to  our  financial  position  as  at  March  31,  2017  and  for  the  year  then  ended.  This  MD&A  also  explains  the  material
variations  in  our  financial  statements  of  operations,  financial  position  and  cash  flows  for  our  fiscal  years  ended  March  31,  2017
February 29, 2016 and February 28, 2015.

This MD&A, should be read together with our audited financial statements for the fiscal years ended March 31, 2017, February 29,
2016 and February 28, 2015 under “Item 17. Financial Statements” in this annual report. Our audited financial statements were prepared in
accordance  with  IFRS,  as  issued  by  the  IASB.  Our  financial  results  are  published  in  Canadian  dollars. All  amounts  appearing  in  this
MD&A are in thousands of Canadian dollars, except share and per share amounts or unless otherwise indicated.

Caution Regarding Non-IFRS Financial Measures

We  use  multiple  financial  measures  for  the  review  of  our  operating  performance.  These  measures  are  generally  IFRS  financial
measures, but one adjusted financial measure, Non-IFRS operating loss (adding to net loss, finance expenses, depreciation and amortization
and impairment loss, change in fair value of derivative warrant liabilities, stock-based compensation and by subtracting finance income and
deferred  income  tax  recovery),  is  also  used  to  assess  our  operating  performance.  This non-IFRS  financial  measure  is  derived  from  our
financial  statements  and  is  presented  in  a  consistent  manner.  We  use  this  measure,  in  addition  to  the  IFRS  financial  measures,  for  the
purposes of evaluating our historical and prospective financial performance, as well as our performance relative to competitors. All of these
measures also help us to plan and forecast future periods as well as to make operational and strategic decisions. We believe that providing
this Non-IFRS information to investors, in addition to IFRS measures, allows them to see our results through the eyes of our management,
and to better understand our historical and future financial performance.

Securities regulations require that companies caution readers that earnings and other measures adjusted to a basis other than IFRS
do  not  have  standardized  meanings  and  are  unlikely  to  be  comparable  to  similar  measures  used  by  other  companies. Accordingly,  they
should not be considered in isolation. We use Non-IFRS operating loss to measure our performance from one period to the next without the
variation caused by certain adjustments that could potentially distort the analysis of trends in our operating performance, and because we
believe  it  provides  meaningful  information  on  our  financial  condition  and  operating  results.  Our  method  for  calculating Non-IFRS
operating loss may differ from that used by other corporations.

We calculate our Non-IFRS operating loss measurement by adding to net loss, finance expenses, depreciation and amortization and
impairment  loss,  change  in  fair  value  of  derivative  warrant  liabilities,  stock-based  compensation  and  by  subtracting  finance  income  and
deferred tax recovery. Other items that do not impact our core operating performance are excluded from the calculation as they may vary
significantly from one period to another. Finance income/costs include foreign exchange gain (loss). We also exclude the effects of certain
non-monetary  transactions  recorded,  such  as  stock-based  compensation,  from  our Non-IFRS operating loss calculation. We believes it is
useful to exclude this item as it is a non-cash expense. Excluding this item does not imply it is necessarily non-recurring. A reconciliation of
net loss to Non-IFRS operating loss is presented further below.

Basis of Presentation of the Financial Statements

Beginning  in  fiscal  2017,  our  fiscal  year  end  is  on  March  31.  Fiscal  2017  is  a  transition  year,  and  includes  thirteen  months  of
operations, beginning on March 1, 2016 and ending on March 31, 2017. As a result, the financial statements and corresponding notes to
financial  statements  include  two  unaudited  periods:  the one-month  period  ended  March  31,  2017  and  the  twelve-month  period  ended
February 28, 2017.

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Following the change of our year end to March 31, 2017 and the inclusion of thirteen months of operations, this MD&A discusses
and compares the thirteen-month period ended March 31, 2017, the twelve-month period ended February 29, 2016 and the twelve-month
period ended February 28, 2015. In addition, there is comparative discussion of our results of operations for the three-month periods ended
February 28, 2017 and February 29, 2016 and a discussion on notable items related to the one-month result of operations ending March 31,
2017. The selected quarterly financial data includes the eight most recent fiscal quarters and are presented including the most recent quarter
as the four-month quarter ended March 31, 2017.

We  are  subject  to  a  number  of  risks  associated  with  the  conduct  of  our  clinical  program  and  their  results,  the  establishment  of
strategic alliances and the successful development of new products and their marketing. We have incurred significant operating losses and
negative  cash  flows  from  operations  since  inception.  To  date,  we  have  financed  our  operations  through  the  public  offering  and  private
placement  of  common  shares  and  convertible  debt,  the  proceeds  from  research  grants  and  research  tax  credits,  and  the  exercises  of
warrants,  rights,  and  options.  To  achieve  the  objectives  of  our  business  plan,  we  plan  to  raise  the  necessary  funds  through  additional
securities offerings and the establishment of strategic alliances as well as additional research grants and research tax credits. We anticipate
that  the  products  developed  by  us  will  require  approval  from  the  FDA  and  equivalent  regulatory  organizations  in  other  countries  before
their  sale  can  be  authorized.  Our  ability  to  ultimately  achieve  profitable  operations  is  dependent  on  a  number  of  factors  outside  of  our
control.

Our current assets of $10,187 as at March 31, 2017 include cash and cash equivalents totaling $9,772, mainly generated by the net
proceeds  from  our  public  offering  and  private  placement  completed  on  February  21,  2017  as  well  as  the  public  offering  completed  on
December  3,  2013  and  private  offering  completed  on  February  7,  2014,  which  we  refer  to  as  the  previous  offerings.  Our  liabilities  total
$3,753  at  March  31,  2017  and  are  comprised  primarily  of  $2,138  in  amounts  due  to  or  accrued  for  creditors,  $1,406  for  unsecured
convertible  debentures  and  $209  for  derivative  warrant  liabilities.  Our  current  assets  as  at  this  date  are  projected  to  be  significantly  less
than needed to support our current liabilities as at that date when combined with the projected level of our expenses for the next twelve
months, including not only the preparation for, but the planned initiation of our Phase 3 program for our drug candidate, CaPre. Additional
funds  will  also  be  needed  for  our  expected  expenses  for  the  total  CaPre  Phase  3  research  and  development  phase  and  other  needed
operations  beyond  the  next  twelve  months.  In  addition  to  having  raised  additional  funds  during  the  thirteen-month  period  ended
March 31, 2017, we are working towards development of strategic partner relationships and plan to raise additional funds in the future, but
there can be no assurance as to when or whether we will complete any financing or strategic collaborations. In particular, raising financing
is subject to market conditions and is not within our control. Additionally, although we intend to continue to rely on the support of Neptune
for a portion of our general and administrative needs, the continuance of this support is outside of our control. If we do not raise additional
funds, find one or more strategic partners or do not receive the continued support from Neptune, it may not be able to realize our assets and
discharge our liabilities in the normal course of business. As a result, there exists a material uncertainty that casts substantial doubt about
our ability to continue as a going concern and, therefore, realize our assets and discharge our liabilities in the normal course of business. We
currently have no other arranged sources of financing.

Our  financial  statements  have  been  prepared  on  a  going  concern  basis,  which  assumes  we  will  continue  our  operations  in  the
foreseeable future and will be able to realize our assets and discharge our liabilities and commitments in the ordinary course of business.
Our  financial  statements  do  not  include  any  adjustments  to  the  carrying  values  and  classification  of  assets  and  liabilities  and  reported
expenses that may be necessary if the going concern basis was not appropriate for our financial statements. If we are unable to continue as a
going concern, material write-downs to the carrying values of our assets, including the intangible asset, could be required.

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Selected Financial Information

(In thousands of dollars, except per share data)

Net loss
Basic and diluted loss per share
Non-IFRS operating loss (1)
Total assets
Working capital(2)
Total non-current financial liabilities
Total equity

One-month
period ended   
March 31,

Three-month
period ended   
February 28,

Three-month
period ended   
February 29,

2017   
$   
(769)   
(0.05)   
(406)   
25,456   
8,049   
1,615   
21,703   

2017   
$   
(2,598)   
(0.23)   
(1,745)   
26,367   
8,510   
1,576   
22,386   

2016   
$   
(1,919)   
(0.18)   
(1,163)   
28,517   
12,185   
156   
27,220   

Thirteen-
month period

March 31,

February 29,

ended    Year ended    Year ended 
February 28,
2015 
$ 
(1,655) 
(0.16) 
(8,507) 
37,208 
18,020 
2,357 
33,228 

2016   
$   
(6,317)   
(0.59)   
(6,569)   
28,517   
10,184   
156   
27,220   

2017   
$   
(11,247)   
(1.01)   
(7,798)   
25,456   
8,049   
1,615   
21,703   

(1) Non-IFRS operating loss (adding to net loss financial expenses (income), depreciation and amortization and impairment of intangible asset, change in fair value of
derivative  warrant  liabilities,  stock-based  compensation  and  by  subtracting  deferred  income  tax  recovery)  is  not  a  standard  measure  endorsed  by  IFRS
requirements. A reconciliation to our net loss is presented further below.

(2) Working  capital  is  presented  for  information  purposes  only  and  represents  a  measurement  of  our  short-term  financial  health  mostly  used  in  financial  circles.
Working  capital  is  calculated  by  subtracting  current  liabilities  from  current  assets.  Because  there  is  no  standard  method  endorsed  by  IFRS  requirements,  the
results may not be comparable to similar measurements presented by other public companies.

Reconciliation of Net Loss to Non-IFRS Operating Loss

(In thousands of dollars, except per share data)

One-month
period ended   
March 31,

Three-month
period ended   
February 28,

Three-month
period ended   
February 29,

Net loss
Add (deduct):

Stock-based compensation
Depreciation and amortization/

Impairment of intangible assets

Financial expenses (income)
Change in fair value of derivative warrant

liabilities

Deferred income tax recovery
Non-IFRS operating loss

2017   
$   

(769)   

86   

226   
29   

22   
—   
(406)   

Thirteen-
month period

March 31,

ended    Year ended    Year ended 
February 28,
2015 
$ 

2017   
$   

2016   
$   

February 29,

2017   
$   

2016   
$   

(2,598)   

(1,919)   

(11,247)   

(6,317)   

(1,655) 

158   

669   
28   

127   
(129)   
(1,745)   

108   

674   

309   

1,553 

938   
(176)   

(114)   
—   
(1,163)   

2,738   
113   

53   
(129)   
(7,798)   

2,734   
(1,094)   

(2,201)   
—   
(6,569)   

2,335 
(1,916) 

(8,824) 
— 
(8,507) 

Stock-based compensation expense increased for the three-month period ended February 28, 2017 as 465,000 stock options were
granted on February 24, 2017 compared to nil for the three-month period ended February 29, 2016. There are no notable matters in stock-
based  compensation  expense  and  no  grants  for  the one-month  period  ended  March  31,  2017.  The  overall  stock-based  compensation
expense  increased  for  the  thirteen-month  period  ending  March  31,  2017  as  a  total  of  1,300,400  stock  options  were  granted  compared  to
109,188 stock options being granted for the year ended February 29, 2016. The stock-based compensation expense decreased for the year
ended February 29, 2016 compared to the same period in 2015 as the 2012 grants had fully vested.

Depreciation, amortization and impairment expense totaled $669 for the three-month period ended February 28, 2017 or $269 less
than  $938  for  the  three-month  period  ended  February  29,  2016  based  on  $70  increased  depreciation  in  the  current  period  associated
primarily with the new production equipment first used during this period offset by no current period impairment charge compared to the
$339 impairment charge recognized during the three-month period ended February 28, 2016. Depreciation, amortization and impairment
expense totaled $2,738 for the thirteen-month period ended March 31, 2017 which approximated the same amount when compared to the
year ended February 29, 2016. However, there was a change in the mix of this expense as the thirteen-month period ended March 31, 2017
included  only  depreciation  and  amortization  with  the  impact  of  one  additional  month  of  depreciation  and  amortization  expense  and  the
addition of new equipment generating incremental depreciation expense, but not the $339 impairment charge recognized during the year
ended  February  29,  2016.  If  the  impairment  charge  is  excluded  from  the  expense  for  the  year  ended  February  29,  2016,  then  the
depreciation and amortization expense totaling $2,395 approximates the expense for the year ended February 28, 2015.

Financial  expenses  (income)  totaled  $28  for  the  three-month  period  ended  February  28,  2017  or  $204  less  than  ($176)  for  the
three-month period ended February 29, 2016 based primarily on a $134 foreign exchange gain in the prior period changing to a $22 foreign
exchange loss in the current period combined with less interest income in

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the  current  period  without  the  prior  year  pledge  impact  supporting  Neptune  and  interest  expense  associated  with  the  convertible  debt
included  in  our  recent  private  placement.  The  net  financial  expenses  (income)  totaling  $29  for  the  month  ended  March  31,  2017  also
resulted  primarily  from  the  interest  expense  from  our  recent  private  placement.  Net  financial  expenses  (income)  totaling  $113  for  the
thirteen-month  period  ended  March  31,  2017  reflect  a  $1,207  decrease  compared  to  ($1,094)  for  the  year  ended  February  29,  2016
primarily  resulting  from  the  $1,023  foreign  exchange  gain  recognized  during  the  year  ended  February  29,  2016  changing  to  the  $180
foreign  exchange  loss  recognized  during  the  thirteen-month  period  ended  March  31,  2017.  The  foreign  exchange  changes  resulted
primarily from the utilization of US$-denominated cash and cash equivalents over the periods generating lower US$-denominated cash and
cash equivalents throughout the periods and at March 31, 2017 compared to February 29, 2016 and, the periods then ended combined with a
decrease in the reporting US$ exchange rate. The US$-denominated cash, cash equivalents and short-term investments totaled US$3,524 at
March 31, 2017 and US$10,314 at February 29, 2016 and the exchange rate reporting of CA$ per US$ was $1.3299 at March 31, 2017
compared to $1.3531 at February 29, 2016. Additionally, interest income for the thirteen-month period ended March 31, 2017 totaled $125
compared to $73 for the year ended February 29, 2016, and $39 in interest expense was incurred in the current period, including $31 in
March, in connection with the convertible debentures from the private placement. The net financial expenses (income) of ($1,094) for the
year ended February 29, 2016 was $822 less than ($1,916) for the year ended February 28, 2015 based on the lower foreign exchange gain
that year.

The  fair  value  of  the  derivative  warrant  liabilities  totaled  $209  at  March  31,  2017,  or  $53  more  than  the  $156  fair  value  at
February  29,  2016,  $22  of  which  was  recognized  during  the one-month  ended  March  31,  1017.  The  $156  fair  value  of  the  derivative
warrant liabilities at February 29, 2016 was $2,201 less than the $2,357 value at February 28, 2015 and the decline in value for the year-
ended  February  28,  2015  was  $8,824.  The  fair  value  of  the  warrants  is  estimated  at  each  reporting  date  using  the  Black-Scholes  option
pricing model. The fair value of the warrants issued in connection with our previous offerings was determined to be $0.58 per warrant upon
issuance, $0.09 per warrant at February 29, 2016 and $0.11 per warrant as of March 31, 2017. In fiscal years 2016 and 2015, the decline in
our  stock  price  resulted  in  gains  based  on  the  change  in  fair  value  of  the  warrant  liabilities  reducing  the  corresponding  liability  in  the
statement of financial position.

We recorded a $129 deferred income tax recovery at February 28, 2017 to reduce to nil an income tax liability that was attributable

to the difference between the tax basis and the carrying amount of the unsecured convertible debentures.

The non-IFRS operating loss increased by $582 for the three-month period ended February 28, 2017 to $1,745 compared to $1,163
for the three-month period ended February 29, 2016, mainly due to an increase in general and administrative (G&A) expenses and a smaller
increase  in  research  and  development  or  (R&D)  expenses,  before  consideration  of  stock-based  compensation,  amortization  and
depreciation. The non-IFRS operating loss increased by $1,229 for the thirteen-month period ended March 31, 2017 to $7,798 compared to
$6,569  for  the  year-ended  February  29,  2016.  This  increase  was  primarily  due  to  the  incremental one-month  period non-IFRS  operating
loss  of  $406  for  March  2017  as  well  as  increased  G&A  expenses  compared  to  the  prior  period  before  consideration  of  stock-based
compensation  and  amortization  and  depreciation.  There  were  no  notable  matters  for  the one-month  period  ended  March  31,  2017.  The
non-IFRS operating loss for the year ended February 29, 2015 totaled $8,507 or a $1,938 decrease compared to the year ended February 29,
2016.

Selected Quarterly Financial Data

Fiscal Year ended March 31, 2017

(In thousands of dollars, except per share data)

   March 31,   

November 30,   

August 31,    May 31, 

Net loss
Basic and diluted loss per share
Non-IFRS operating loss (2)

(1) This fiscal quarter represents a period of four months ended March 31, 2017.

53

2017(1)   
$   

(3,367)   
(0.28)   
(2,151)   

2016   
$   

(2,397)   
(0.22)   
(1,737)   

2016   
$   

2016 
$ 

(2,330)   
(0.22)   
(1,625)   

  (3,154) 
(0.29) 
  (2,286) 

 
 
  
  
  
  
  
  
   
  
   
  
   
  
 
  
 
 
 
  
 
 
 
 
  
 
 
 
 
 
Table of Contents

(2) Non-IFRS operating loss (adding to net loss financial expenses (income), depreciation and amortization and impairment of intangible assets, change in fair value
of  derivative  warrant  liabilities,  stock-based  compensation  and  by  subtracting  deferred  income  tax  recovery)  is  not  a  standard  measure  endorsed  by  IFRS
requirements. A reconciliation to our net loss is presented above.

Fiscal Year ended February 29, 2016

(In thousands of dollars, except per share data)

February 29,   

November 30,   

August 31,    May 31, 

Net loss
Basic and diluted loss per share
Non-IFRS operating loss (1)

2016   
$   

(1,919)   
(0.18)   
(1,163)   

2015   
$   

(2,191)   
(0.20)   
(1,988)   

2015   
$   

2015 
$ 

(1,241)   
(0.12)   
(1,485)   

(966) 
(0.09) 
  (1,933) 

(1) Non-IFRS operating loss (adding to net loss financial expenses (income), depreciation and amortization and impairment of intangible assets, change in fair value
of  derivative  warrant  liabilities,  stock-based  compensation  and  by  subtracting  deferred  income  tax  recovery)  is  not  a  standard  measure  endorsed  by  IFRS
requirements. A reconciliation to our net loss is presented above.

The increase in net loss, net loss per share and non-IFRS operating loss in the fourth quarter of 2017 can partially be explained by
the  inclusion  of  the  additional  month  in  comparison  to  the  comparative  three-month  quarterly  financial  data.  The  month  of  March  2017
explains an increase in the fourth quarter net loss of $769 or ($0.05) per share as well as an increase in non-IFRS operating loss of $406.
The variances in net loss from quarter to quarter are mainly due to the changes in fair value of the warrant liabilities, notably for the quarter
ended  May  31,  2015  with  a  gain  of  $1,708,  as  well  as  variations  in  foreign  exchange  gains  or  losses,  particularly  for  the  quarter  ended
August  31,  2015  with  a  foreign  exchange  gain  of  $890.  The  quarterly year-to-year  non-IFRS  operating  loss  variances  are  mainly
attributable  to  fluctuations  in  research  and  development  expenses  from quarter-to-quarter  as  well  as  an  increase  in  general  and
administrative expenses over the prior year in the last three quarters of fiscal 2017.

Results  from  Operations  for  the One-Month  and  Thirteen-Month  Periods  ended  March  31,  2017  and  the  Three-Month  Periods
ended February 28, 2017 and February 29, 2016 and Years ended February 29, 2016 and February 28, 2015

The net loss totaling $2,598 or ($0.23) per share for the three-month period ended February 28, 2017 increased $679 or ($0.05) per
share  compared  to  a  net  loss  totaling  $1,919  or  ($0.18)  per  share  for  the  three-month  period  ended  February  29,  2016.  This  resulted
primarily from the $582 increased non-IFRS operating loss explained below, $241 from the increased loss due to the change in value of the
warrant derivative liability due to the reduction in our share price and a $204 financial expense increase led by a foreign exchange gain
during  the  prior  period  transitioning  to  a  foreign  exchange  loss  during  the  current  period  offset  by  no  impairment  charge  in  the  current
period compared to the $339 charge in the prior period combined with the $129 tax benefit recognized in the current period.

The net loss totaling $11,247 or ($1.01) per share for the thirteen-month period ended March 31, 2017 increased $4,930 or ($0.42)
per share compared to the net loss totaling $6,317 or ($0.59) per share for the year ended February 29, 2016. This change resulted primarily
based on the $1,229 increased non-IFRS operating loss explained below, $2,254 from the increased loss due to the change in value of the
warrant  derivative  liability  due  to  the  reduction  in  our  share  price,  a  $1,207  financial  expense  increase  (led  by  a  foreign  exchange  gain
during  the  prior  period  transitioning  to  a  foreign  exchange  loss  during  the  current  period),  and  increased  depreciation  and  stock
compensation expense offset by no impairment charge in the current period compared to the $339 charge in the prior period combined with
the $129 tax benefit recognized in the current period.

The  net  loss  totaling  $6,317  or  ($0.59)  per  share  for  the  year  ended  February  29,  2016  increased  $4,662  or  ($0.43)  per  share
compared to the net loss totaling $1,655 or ($0.16) per share for the year ended February 28, 2015. This change resulted primarily based on
the $7,445 decrease in net financial income, including a $6,623 decrease in the fair value of the warrant liabilities and the $810 decrease in
the foreign exchange gain offset by the $1,527 decrease in G&A expenses and $1,256 decrease in R&D expenses.

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Breakdown of Major Components of Statement of Earnings and Comprehensive Loss for the  One-Month and Thirteen-Month Periods
ended March 31, 2017; Three-Month Periods ended February 28, 2017 and February 29, 2016; and Fiscal Years ended February 29,
2016 and February 28, 2015

Research and development expenses

Salaries and benefits
Stock-based compensation
Research contracts
Professional fees
Depreciation and amortization
Impairment of intangible assets
Other
Government grants and tax credits
Total

General and administrative expenses

Salaries and benefits
Administrative fees
Stock-based compensation
Professional fees
Rent
Other
Total

One-month
period ended   
March 31,

Three-month
period ended   
February 28,

Three-month
period ended   
February 29,

Thirteen-
month period

ended   

Year ended   

March 31,

February 29,

2017   
$   

104   
18   
63   
57   
226   
—   
3   
(45)   
426   

2017   
$   

376   
27   
435   
238   
668   
—   
30   
(215)   
1,559   

2016   
$   

332   
12   
761   
(118)   
611   
339   
88   
(291)   
1,734   

2017   
$   

1,294   
107   
3,149   
634   
2,738   
—   
61   
(330)   
7,653   

2016   
$   

989   
53   
2,730   
1,171   
2,395   
339   
238   
(349)   
7,566   

One-month
period ended   
March 31,

Three-month
period ended   
February 28,

Three-month
period ended   
February 29,

Thirteen-
month period

ended   

Year ended   

March 31,

February 29,

2017   
$   

110   
25   
68   
52   
10   
27   
292   

2017   
$   

493   
75   
132   
231   
30   
52   
1,013   

2016   
$   

64   
184   
95   
137   
(12)   
(37)   
431   

2017   
$   

1,198   
325   
567   
1,053   
121   
293   
3,557   

2016   
$   

409   
579   
256   
616   
67   
119   
2,046   

Year ended 
February 28,
2015 
$ 

465 
258 
5,062 
865 
2,335 
— 
101 
(264) 
8,822 

Year ended 
February 28,
2015 
$ 

617 
650 
1,296 
593 
99 
318 
3,573 

Three-month period ended February 28, 2017 compared to three-month period ended February 29, 2016

During  the  three-month  period  ended  February  28,  2017,  we  continued  to  move  our  R&D  program  forward  as  planned  on  its
previously announced timeline for the conduct of our clinical program and production scale-up. Though the $1,559 in total R&D expenses
for the three-month period ended February 28, 2017 decreased $175 from $1,734 in total R&D expenses for the three-month period ended
February  29,  2016,  R&D  expenses,  before  depreciation,  amortization,  intangible  asset  impairment,  and  stock-based  compensation,
increased by $92 for the three-month period ended February 28, 2017 to $864 compared to $772 for the same period ended February 29,
2016.  This  increase  was  mainly  attributable  to  the  $356  increase  in  professional  fees  and  a  $76  reduction  in  government  grants  and  tax
credits  mitigated  by  a  $326  decrease  in  research  contracts.  This  expense  mix  changed  with  the  transition  of  expenses  from  completed
contracts  under  our  successful  Phase  2  bioavailability  bridging  clinical  study  to  consultants  to  support  preparation  for  our  clinical  study
program  review  with  the  FDA  on  the  Phase  2  outcome  combined  with  Phase  3  planning.  This  increase  also  resulted  from  $44  in
incremental salaries and benefits primarily sourced from full-time compared to half-time direct leadership and management of R&D when
compared to the same period last year.

G&A expenses totaling $1,013 for the three-month period ended February 28, 2017 increased $582 from $431 for the three-month
period ended February 29, 2016. This increase primarily resulted from the $545 increase in G&A expenses, before consideration of stock-
based  compensation,  to  $881  for  the  three-month  period  ended  February  28,  2017  compared  to  $336  for  the  same  period  ended
February 29, 2016. This $545 increase was mainly

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Table of Contents

attributable to a $429 increase in salaries and benefits associated with the added full-time executive and managerial headcount to support
our strategy and financing while becoming more independent from Neptune, which was demonstrated with a $109 reduction in its related
administrative  fee.  This  increase  also  resulted  from  increased  professional  fees  of  $94  due  primarily  to  expenses  for  maintaining  the
reactivated public and investor relations programs, $42 in rent expense resulting primarily from a net credit recognized for the three-month
period ended February 29, 2016 after a positive adjustment was negotiated with the lessor and other administration expense increase of $89
after another cost management credit impact during the prior year period.

Thirteen-Month and One-Month Periods ended March 31, 2017 compared to the Fiscal Year-Ended February 29, 2016

R&D expenses totaled $7,653 for the thirteen-month period ended March 31, 2017, or an increase of $87 compared to $7,566 in
total R&D expenses for the year ended February 29, 2016. The R&D expense increase resulted primarily from $426 in total R&D expenses
during  March  2017,  the  thirteenth  month  of  the  period  ended  March  31,  2017,  offset  by  no  intangible  asset  impairment  charge  in  the
thirteen-month period ended March 31, 2017 compared to the $339 charge last year. R&D expenses, before consideration of stock-based
compensation, amortization and depreciation and impairments of intangible assets, increased by $29 for the thirteen-month period ended
March 31, 2017, including $182 during the month of March 2017, to $4,808 compared to $4,779 for the year ended February 29, 2016. The
increase of $29 was mainly attributable to the increase in research contracts of $419 and salaries and benefits of $305, principally offset by
decreases in professional fees of $537, other expenses of $177 and government grants of $19. The increase of $419 in research contracts
during the thirteen-month period ended March 31, 2017 includes $63 relating to the additional one-month period ended March 31, 2017,
but was primarily due to the cost of our Phase 2 bioavailability bridging clinical study initiated early in fiscal 2017 exceeding the cost of
our other Phase 2 and non-clinical testing completed in fiscal 2016. The increased salaries and benefits represented the cost of the expanded
team  headcount,  led  by  full-time  dedicated  management  (only  part  time  in  prior  years),  needed  for  us  to  continue  our  pharmaceutical
process and analytical development and chemistry manufacturing control scale-up, as planned on our previously announced timeline. The
decrease of $537 in professional fees is primarily due to a decrease in the development consulting fees incurred last year for our prior Phase
2 clinical study analytics and the planning for our Phase 2 bridging clinical study during the thirteen-month period ended March 31, 2017.

G&A  expenses  totaled  $3,557  for  the  thirteen-month  period  ended  March  31,  2017,  or  an  increase  of  $1,511  compared  to  total
G&A expenses of $2,046 for the year ended February 29, 2016. This period-to-period increase includes $292 in total G&A expenses for the
thirteenth  month  of  March  2017,  $243  in  increased  stock-based  compensation  expense  and  a  $976  increase  in  other  G&A  expenses,
excluding  the  thirteenth  month  and  stock-based  compensation  expenses.  G&A  expenses,  excluding  the  stock-based  compensation,
increased  $1,200  to  $2,990  for  the  thirteen-month  period  ended  March  31,  2017,  including  $224  during  the  month  of  March  2017,
compared  to  $1,790  for  the  year  ended  February  29,  2016.  This  increase  was  primarily  attributable  to  a  $789  increase  in  salaries  and
benefits offset by a $254 decrease in Neptune administrative fees, combined with increased professional fees of $437, rent of $54 and other
expenses of $174. The increase in salaries and benefit expenses resulted from our need for the added full-time executive and managerial
headcount  to  lead  our  strategy,  incremental  financing  and  back  office  while  supporting  continued  and  expanded  R&D  with  the  need  for
full-time  leadership  from  our  management  (which  was  only  part  time  in  prior  years).  The  increased  professional  fees  were  principally
comprised  of  expenses  associated  with  our  investor  and  public  relations  program,  the  achievement  of  business  development  milestones,
increased  market  research  expenses,  and non-recurring  project  legal  and  accounting  fees  associated  with  the year-end  change  and
immigration-related fees for the U.S.-resident executives.

Fiscal Year ended February 29, 2016 compared to Fiscal Year ended February 28, 2015

R&D expenses totaled $7,566 for the year ended February 29, 2016, or $1,256 less than $8,822 in total R&D expenses for the year
ended  February  28,  2015.  This  R&D  expense  decrease  resulted  primarily  from  R&D  expenses,  before  consideration  of  stock-based
compensation,  amortization  and  depreciation  and  impairment  of  intangible  assets,  decreasing  by  $1,450  to  $4,779  from  $6,229.  This
decrease is mainly attributable to a significant decrease in contract expenses related to our clinical studies of $2,332 and government grants
increase of $85, partially offset by an increase in salaries and benefits of $524, professional fees of $306 and other expenses of $137.

G&A expenses totaled $2,046 for the year ended February 29, 2016, or $1,527 less than $3,573 for the year ended February 28,
2015. This G&A expense decrease resulted primarily from G&A expenses, before consideration of stock-based compensation, decreasing
by $487 to $1,790 for the year ended February 29, 2016 from $2,277 for

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the year ended February 28, 2015. This decrease is mainly attributable to decreases in salaries of $208, administrative fees of $71, rent of
$32 and other expenses of $199 partially offset by an increase in professional fees of $23.

Liquidity and Capital Resources

Share Capital Structure

Our authorized share capital consists of an unlimited number of Class A (which we refer to in this annual report as our common
shares),  Class  B,  Class  C,  Class  D  and  Class  E  shares,  without  par  value.  Our  issued  and  outstanding  fully  paid  shares,  stock  options,
restricted shares units and warrants, were as follows as at March 31, 2017, February 28, 2017 and February 29, 2016:

  Class A shares, voting, participating and without par value
  Stock options granted and outstanding
  Restricted share units granted and outstanding
  2017 Public offering warrants exercisable at $2.15,

until February 21, 2022

  Series 2017 BW Broker warrants exercisable at $2.15, until

February 21, 2018

  Series 2017 unsecured convertible debentures conversion option

contingent warrants exercisable at $1.90, until February 21, 2020 (1)
  Series 8 warrants exercisable at $1.50 USD, until December 3, 2018 (2)
  Series 9 warrants exercisable at $13.30 until December 3, 2018
  Total fully-diluted shares

March 31,

February 28, 2017

February 29, 2016

2017   

 14,702,556   
  1,424,788   
—   

  1,965,259   

234,992   

  1,052,630   
  1,840,000   
161,654   
 21,381,879   

10,712,038   
454,151   
—   

10,644,440 
429,625 
18,398 

—   

—   

— 

— 

—   
1,840,000   
161,654   
13,167,843   

— 
1,840,000 
161,654 
13,094,117 

(1) The debentures are convertible into common shares at a fixed price of $1.90 per common share, except if we pay before the maturity all or any portion of the

convertible debentures. Should we pay all or any portion of the convertible debenture before maturity, then warrants become exercisable at $1.90 per common share
for the equivalent convertible debenture amount prepaid.

(2) Total of 18,400,000 warrants, in order to obtain one common share, 10 warrants must be exercised for a total amount of $15.00 USD.

Cash Flows and Financial Condition between the One-Month Period ended March 31, 2017; Three-Month Periods ended February 28,
2017  and  February  29,  2016;  Thirteen-Month  Period  ended  March  31,  2017;  and  Fiscal  Years  ended  February  29,  2016  and
February 28, 2015

Operating Activities

During  the one-month  period  ended  March  31,  2017,  our  operating  activities  used  cash  of  $746,  as  primarily  explained  in  the
non-IFRS  operating  loss  section  above.  The  use  of  cash  flow  in  operating  activities  for  the one-month  period  ended  March  31,  2017  is
mainly attributable to net loss, as explained in the Reconciliation of Net Loss to Non-IFRS Operating Loss section above, further modified
by changes in working capital, excluding cash.

During the three-month periods ended February 28, 2017 and February 29, 2016, our operating activities used cash of $1,425 and
$1,691, respectively, as primarily explained in the non-IFRS operating loss section above. The use of cash flows in operating activities for
the  three-month  periods  ended  February  28,  2017  and  February  29,  2016  when  compared  to  the  net  losses  for  each  period  are  mainly
attributable to the change in non-cash operating items, as explained in the Reconciliation of Net Loss to Non-IFRS Operating Loss section
above, further modified by changes in working capital, excluding cash.

During  the  thirteen-month  period  ended  March  31,  2017  and  the  years  ended  February  29,  2016  and  February  28,  2015,  our
operating  activities  used  cash  of  $6,958,  $6,574  and  7,198,  respectively,  as  primarily  explained  in  the  Reconciliation  of  Net  Loss  to
Non-IFRS Operating Loss section above. The use of cash flows in operating activities for the thirteen-month period ended March 31, 2017
and the years ended February 29, 2016 and February 28, 2015 when compared to the net losses for each period are mainly attributable to
the change in non-cash operating items, as explained in the Reconciliation of Net Loss to Non-IFRS Operation Loss section above, offset
by reductions in working capital, excluding cash.

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Investing Activities

During the three-month period ended February 28, 2017, our investing activities generated cash of $3,327, compared to using cash
of $11 for the three-month period ended February 29, 2016. The cash generated by investing activities during the three-month period ended
February  28,  2017  was  mainly  due  to  the  maturity  of  short-term  investments  of  $4,031,  offset  by  the  acquisition  of  equipment  totaling
$733.

During  the  thirteen-month  period  ended  March  31,  2017  and  the  years  ended  February  29,  2016  and  February  28,  2015,  our
investing  activities  generated  cash  of  $6,888,  $8,229  and  $7,627,  respectively.  The  cash  generated  by  investing  activities  during  the
thirteen-month period ended March 31, 2017 was mainly due to the maturity of short-term investments of $22,030, offset by reinvestment
in  short-term  investments  totaling  $12,765  and  the  acquisition  of  equipment  totaling  $2,527.  The  cash  generated  by  investing  activities
during the year-ended February 29, 2016 was mainly due to the maturity of short-term investments of $20,437, offset by the reinvestment
in  short-term  investments  totaling  $11,954  and  acquisition  of  equipment  of  $276.  The  cash  generated  by  investing  activities  during  the
year-ended February 28, 2015 was mainly due to the maturity of short-term investments of $22,150, offset by the reinvestment in short-
term investments totaling $14,478.

Financing Activities

During the three-month period ended February 28, 2017, our financing activities generated cash of $6,924 The cash generated by
financing activities during the three-month period ended February 28, 2017 was mainly due to the net proceeds from our public offering of
$5,044 and net proceeds from our private placement of $1,882.

During the thirteen-month period ended March 31, 2017, our financing activities generated cash of $6,864 and decreased from the
three-month  period  ending  February  28,  2017,  as  certain  transaction  costs  associated  with  the  financing  activities  were  paid.  The  cash
generated  by  financing  activities  during  the  thirteen-month  period  ended  March  31,  2017  was  mainly  due  to  the  net  proceeds  from  our
public offering of $5,010 and net proceeds from our private placement of $1,872.

Overall,  our  cash  increased  by  $6,745,  $1,716  and  by  $635,  for  the  thirteen-month  period  ended  March  31,  2017  and  the  years

ended February 29, 2016 and February 28, 2015, respectively. Cash and cash equivalents as at March 31, 2017 totaled $9,772.

We  are  subject  to  a  number  of  risks  associated  with  the  conduct  of  our  clinical  program  and  their  results,  the  establishment  of
strategic alliances and the successful development of new products and their marketing. We have incurred significant operating losses and
negative  cash  flows  from  operations  since  inception.  To  date,  we  have  financed  our  operations  through  the  public  offering  and  private
placement  of  common  shares  and  convertible  debt,  the  proceeds  from  research  grants  and  research  tax  credits,  and  the  exercises  of
warrants,  rights,  and  options.  To  achieve  the  objectives  of  our  business  plan,  we  plan  to  raise  the  necessary  funds  through  additional
securities offerings and the establishment of strategic alliances as well as additional research grants and research tax credits. We anticipate
that  the  products  developed  by  us  will  require  approval  from  the  FDA  and  equivalent  regulatory  organizations  in  other  countries  before
their  sale  can  be  authorized.  Our  ability  to  ultimately  achieve  profitable  operations  is  dependent  on  a  number  of  factors  outside  of  our
control.

Our current assets of $10,187 as at March 31, 2017 include cash and cash equivalents totaling $9,772, mainly generated by the net
proceeds  from  our  public  offering  and  private  placement  completed  on  February  21,  2017  as  well  as  the  public  offering  completed  on
December  3,  2013  and  private  offering  completed  on  February  7,  2014,  which  we  refer  to  as  the  previous  offerings.  Our  liabilities  total
$3,753  at  March  31,  2017  and  are  comprised  primarily  of  $2,138  in  amounts  due  to  or  accrued  for  creditors,  $1,406  for  unsecured
convertible  debentures  and  $209  for  derivative  warrant  liabilities.  Our  current  assets  as  at  this  date  are  projected  to  be  significantly  less
than needed to support our current liabilities as at that date when combined with the projected level of our expenses for the next twelve
months, including not only the preparation for, but the planned initiation of our Phase 3 program for our drug candidate, CaPre. Additional
funds will also be needed for our expected expenses for the total CaPre Phase 3 research and development phase beyond the next twelve
months.  In  addition  to  having  raised  additional  funds  during  the  thirteen-month  period  ended  March  31,  2017,  we  are  working  towards
development of strategic partner relationships and plan to raise additional funds in the future, but there can be no assurance as to when or
whether we will complete any financing or strategic collaborations. In particular, raising financing is subject to market conditions and is not
within  our  control.  Additionally,  although  we  intend  to  continue  to  rely  on  the  support  of  Neptune  for  a  portion  of  our  general  and
administrative needs, the continuance of this support is outside of our control. If we do not raise additional funds, find one or more strategic
partners or do not receive the continued

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support from Neptune, it may not be able to realize our assets and discharge our liabilities in the normal course of business. As a result,
there exists a material uncertainty that casts substantial doubt about our ability to continue as a going concern and, therefore, realize our
assets and discharge our liabilities in the normal course of business. We currently have no other arranged sources of financing.

2017 Public Offering

On February 21, 2017, we closed a public offering issuing 3,930,518 units at a price of $1.45 per unit for gross proceeds of $5,699.
Each unit consists of one common share and one half of one common share purchase warrant. Each whole warrant entitles the holder to
purchase one common share at an exercise price of $2.15 per common share, at any time until February 21, 2022. The units issued as part of
the public offering are considered equity instruments. The transaction costs associated with the public offering amounted to $1,190. The
proceeds and transaction costs were allocated to share capital.

As part of the transaction, we also issued broker warrants to purchase up to 234,992 common shares. Each broker warrant entitles
the holder to acquire one common share at an exercise price of $2.15 per common share, at any time until February 21, 2018. The total costs
associated with the broker warrants are accounted for at fair value using the Black-Scholes pricing model; they amounted to $144 and were
recorded to contributed surplus with the offsetting entry as a reduction of share capital.

The warrants issued as part of the units of the public offering and the broker warrants, include an “acceleration right”, related to our
right to accelerate the expiry date of the warrants. The acceleration right clause means our right to accelerate the expiry date to a date that
is not less than 30 days following delivery of the acceleration notice if, at any time at least four months after the effective date, the volume
weighted average trading price of our common shares equals or exceeds $2.65 for a period of 20 consecutive trading days on the TSXV.

Additionally, as part of the public offering and convertible debt transactions, a total of 60,000 common shares were issued by us as
equity settled share-based payments for services received from an employee of Neptune at a price of $1.57 per share for a total cost of $94.
The equity settled share-based payment costs have been allocated between the share capital for a cost that amounted to $85 and debt for a
cost that amounted to $9 based on relative value.

Unsecured Convertible Debentures and Contingent Warrants

Concurrent with our public offering, on February 21, 2017, we issued $2,000 aggregate principal amount of unsecured convertible
debentures  maturing  on  February  21,  2020  and  contingent  warrants  to  acquire  up  to  1,052,630  common  shares  in  a  private  placement
transaction.  The  principal  may  be  prepaid,  in  whole  or  in  part,  at  any  time  and  from  time  to  time,  in  cash,  at  our  sole  discretion.  The
debentures  are  convertible  into  common  shares  at  any  time  by  the  holder  at  a  fixed  price  of  $1.90  per  common  share,  except  if  we  pay
before the maturity all or any portion of the convertible debentures. Should we pay all or any portion of the convertible debentures before
maturity,  then  warrants  become  exercisable  at  $1.90  per  common  share  for  the  equivalent  convertible  debenture  amount  prepaid.  The
contingent warrants will be exercisable for the remaining term of the convertible debentures for the same price as the conversion options.
The unsecured convertible debentures were issued at a discount of 3.5% to the principal amount, for aggregate gross proceeds of $1,930.

The convertible debentures provide us with an accelerated conversion right whereby we may, at any time at least four months after
the  date  of  issuance  of  the  convertible  debentures,  accelerate  the  conversion  of  the  debentures  to  common  shares  in  the  event  that  the
volume  weighted  average  price  of  our  common  shares  on  the  TSXV  is  equal  to  or  exceeds  $2.65,  subject  to  customary  adjustment
provisions, during 20 consecutive trading days.

The interest to be paid on the convertible debentures is 8% per annum, payable on a quarterly basis in cash or common shares or a
combination thereof, commencing on March 31, 2017. The decision to pay the interest due in cash or shares is at our discretion and the
number  of  common  shares  to  be  issued  will  be  calculated  at  the  current  market  price  as  at  the  close  of  business  on  the  day  before  the
interest  payment  is  to  be  made.  Payment  in  shares  will  be  at  a  floor  price  of  $0.10  per  share,  with  the  difference  between  the  amount
payable and the amount computed at floor price payable in cash.

The proceeds of the private placement were split between the liability and the equity at the time of issuance. Both the conversion
option and contingent warrants are considered the equity component of the private placement. The fair value of the liability component was
determined through a discounted cash flow analysis using a

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discount  rate  of  20%  that  was  set  based  on  a  similar  debt  and  maturity  considering  our  credit  risk  excluding  the  conversion  option  and
contingent warrants. The amount allocated to the equity component is the residual amount after deducting the fair value of the financial
liability  component  from  the  fair  value  of  the  entire  compound  instrument.  Subsequent  to  initial  recognition,  the  liability  is  measured  at
amortized  cost  calculated  using  the  effective  interest  rate  method  and  will  accrete  up  to  the  principal  balance  at  maturity.  The  interest
accretion is presented as a financial expense. The equity component is not re-measured. Transaction costs were allocated to the components
in proportion to their initial carrying amounts. The portion allocated to the liability was recognized as a reduction of the debt whereas the
portion allocated to other equity was recognized as a reduction to other equity.

The  fair  value  of  the  liability  portion  at  the  time  of  issuance  was  determined  to  be  $1,519  and  the  transaction  costs  and  debt
discount  amounted  to  $134,  of  which  $30  is  still  unpaid  as  at  March  31,  2017.  The  residual  of  the  proceeds  allocated  to  the  equity
component amounted to $481 and the transactions costs amounted to $43, of which $10 is unpaid at March 31, 2017.

Use of Funds

We  have  used  and  intend  to  continue  to  use  the  net  proceeds  from  the  public  offering,  the  private  placement  and  our  previous
offerings to fund the completion of our manufacturing scale-up and the clinical and regulatory planning and preparations necessary to be
ready to enroll the first patient in our planned Phase 3 program for CaPre, intellectual property expansion, business development activities,
general and administrative expenses, and working capital. We currently project, however, after our end of Phase 2 meeting with the FDA,
which  took  place  after  the  closing  of  our  public  offering  and  private  placement  financing,  that  most  of  the  more  than  $1  million  net
proceeds that we raised over our originally anticipated offering amount will be used for the clinical program preparation based now on the
plan being better defined after the FDA meeting, including our plan to conduct two smaller studies instead of one larger study.

Financial Position

The  following  table  details  the  significant  changes  to  our  statements  of  financial  position  as  at  March  31,  2017  compared  to

February 29, 2016:

(In thousands of dollars)

 Accounts

 Cash and cash equivalents
 Short-term investments, including restricted investments
 Receivable
 Prepaid expenses
 Equipment
 Intangible asset
 Trade and other payables
 Payable to parent corporation
 Derivative warrant liabilities
 Unsecured convertible debentures

Increase
(Decrease)

6,745    
(9,443)    
(193)    
(247)    
2,594    
(2,517)    
1,000    
(3)    
53    
1,406    

Comments 

See cash flow statement 
Maturity of short-term investments, decrease in investments 
Payments received 
Completion of research contracts 
Acquisition of laboratory and production equipment 
Amortization 
Increase in expenses and research contracts 
Payment made to parent company 
Change in fair value 
Debt issued in Private Placement transaction 

See the statement of changes in equity in our financial statements in “Item 17. Financial Statements” for details of changes to the equity
accounts from February 29, 2016.

Derivative Warrant Liabilities

As  of  March  31,  2017,  the  amount  of  $209  included  in  liabilities  represents  the  fair  value  of  the  warrants  issued  as  part  of  our
previous  offerings.  The  warrants  forming  part  of  the  units  issued  in  connection  with  our  previous  offerings  are  derivative  liabilities  for
accounting  purposes  due  to  the  currency  of  the  exercise  price  (US$)  being  different  from  our  functional  currency  (CA$).  The  warrant
liabilities will be settled in common shares. The fair value of the warrants issued in connection with our previous offerings was determined
to  be  $0.58  per  warrant  upon  issuance  and  $0.11  per  warrant  as  of  March  31,  2017.  The  fair  value  of  the  warrants  is  revalued  at  each
reporting date.

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Contractual Obligations, Off-Balance-Sheet Arrangements and Commitments

We  have  no  off-balance  sheet  arrangements,  except  for  the  following  commitments. As  at  March  31,  2017,  our  liabilities  are
$3,753, of which $2,138 is due within twelve months, $209 relates to a derivative warrant liability that will be settled in common shares and
$1,406  relates  to  unsecured  convertible  debentures,  described  in  note  11  of  our  financial  statements,  which  includes  $21  in  interest
accretion and will be settled either in cash or common shares. The principal amount of unsecured convertible debentures may be prepaid, in
whole or in part, at any time and from time to time, in cash, at our sole discretion. The debentures are convertible into common shares at a
fixed price of $1.90 per common share, except if we pay before the maturity all or any portion of the convertible debentures.

A summary of our contractual obligations at March 31, 2017, is as follows:

  (In thousands of dollars)

  Trade and other payables
  Research and development contracts
  Purchase obligation of equipment
  Unsecured convertible debentures

  Total

Significant commitments as of March 31, 2017 include:

Research and Development Agreements

Total    
$   
 2,138   
  917   
21   
 2,463   
 5,539   

1 year or less   
$   
2,138   
917   
21   
160   
3,236   

1 to 3 years 
$ 

— 
— 
— 
2,303 

2,303 

In the normal course of business, we have signed agreements with various partners and suppliers for them to execute R&D projects
and to produce certain tools and equipment. We have reserved certain rights relating to these projects. We initiated R&D projects that are
planned to be conducted over the next 12-month period for a total cost of $2,169, of which an amount of $785 has been paid to date. As at
March 31, 2017, an amount of $467 is included in “Trade and other payables” in relation to these projects. We have also entered into a
contract to purchase production equipment for a total cost of $1,162 to be used in the manufacturing of the clinical and future commercial
supply of CaPre, of which an amount of $853 has been paid to date. As at March 31, 2017, an amount of $288 is included in “Trade and
other payables” related to this equipment.

Related Party Transactions

During  the  periods  specified  below,  we  were  charged  by  Neptune  for  the  purchase  of  research  supplies  and  for  certain  costs

incurred by Neptune for our benefit, as follows:

  (In thousands of dollars)

  Research and development expenses
  General and administrative expenses
  Total

One-month
period ended   
March 31,
2017

Three-month
period ended   
February 28,
2017

Three-month
period ended   
February 29,
2016

$   

1   
41   
42   

$   

6   
241   
247   

$   

24   
215   
239   

Thirteen-
month
period
ended    Year ended    Year ended 
February 28,
2015
$ 

February 29,
2016

March 31,
2017

$   

$   

60   
618   
678   

371   
790   
1,161   

344 
876 
1,220 

We purchased from Neptune research and development supplies totaling $113, of which $73 as at March 31, 2017 is recorded in

prepaid expenses and will be expensed as used.

Where Neptune incurs specific incremental costs for our benefit, it charges those amounts directly. Costs that benefit more than
one entity of the Neptune group are charged by allocating a fraction of costs incurred by Neptune that is commensurate to the estimated
fraction of services or benefits received by each entity for those items. These charges do not represent all charges incurred by Neptune that
may have benefited us. Also, these charges do not necessarily represent the cost that we would otherwise need to incur, should we not
receive these services or benefits through the shared resources of Neptune.

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On January 7, 2016, Neptune announced the acquisition of Biodroga Nutraceuticals Inc. As part of this transaction, we pledged an
amount of $2 million, or the committed funds, to partly guarantee the financing for the transaction under a pledge agreement. Neptune had
agreed to pay us an annual fee on the committed funds outstanding at an annual rate of 9% during the first six months and 11% for the
remaining  term  of  the  pledge  agreement.  On  September  20,  2016,  Neptune  fully  released  the  pledged  amount.  We  recognized  interest
revenue in the amount of $89 during the thirteen-month period ended March 31, 2017 and nil for the month ended March 31, 2017.

The  payable  to  Neptune  primarily  for  general  and  administrative  shared  services  has  no  specified  maturity  date  for  payment  or

reimbursement and does not bear interest.

Use of Estimates and Measurement of Uncertainty

The preparation of the financial statements in conformity with IFRS requires our management to make judgments, estimates and
assumptions that affect the application of accounting policies and the reported amounts of assets, liabilities, income and expenses. Actual
results may differ from these estimates. Estimates are based on management’s best knowledge of current events and actions that we may
undertake  in  the  future.  Estimates  and  underlying  assumptions  are  reviewed  on  an  ongoing  basis.  Revisions  to  accounting  estimates  are
recognized in the period in which the estimates are revised and in any future periods affected. Critical judgments in applying accounting
policies  that  have  the  most  significant  effect  on  the  amounts  recognized  in  the  financial  statements  include  identification  of  triggering
events  indicating  that  the  intangible  assets  might  be  impaired  and  the  use  of  the  going  concern  basis  of  preparation  of  the  financial
statements. At  the  end  of  each  reporting  period,  management  assesses  the  basis  of  preparation  of  the  financial  statements.  The  financial
statements have been prepared on a going concern basis in accordance with IFRS. The going concern basis of presentation assumes that we
will  continue  our  operations  for  the  foreseeable  future  and  can  realize  our  assets  and  discharge  our  liabilities  and  commitments  in  the
normal course of business. Assumptions and estimation uncertainties that have a significant risk of resulting in a material adjustment within
the  next  financial  year  include  determination  of  the  recoverable  amount  of  our  cash  generating  unit,  or  CGU,  and  measurement  of
derivative  warrant  liabilities  and  stock-based  compensation.  Also,  management  uses  judgment  to  determine  which  research  and
development, or R&D, expenses qualify for R&D tax credits and in what amounts. We recognize the tax credits once we have reasonable
assurance  that  they  will  be  realized.  Recorded  tax  credits  are  subject  to  review  and  approval  by  tax  authorities  and  therefore,  could  be
different from the amounts recorded.

Critical Accounting Policies

Impairment of Non-Financial Assets

The  carrying  value  of  our  license  asset  is  reviewed  at  each  reporting  date  to  determine  whether  there  is  any  indication  of
impairment. If any such indication exists, then the CGU’s recoverable amount is estimated. The identification of impairment indicators and
the estimation of recoverable amounts require the use of judgment.

Derivative Warrant Liabilities

The  warrants  forming  part  of  the  units  issued  in  our  public  offering  are  derivative  liabilities  for  accounting  purposes  due  to  the
currency of the exercise price being different from our functional currency. The derivative warrant liabilities are required to be measured at
fair value at each reporting date with changes in fair value recognized in earnings. We use Black-Scholes pricing model to determine the
fair  value.  The  model  requires  the  assumption  of  future  stock  price  volatility,  which  is  estimated  based  on  weighted  average  historic
volatility.  Changes  to  the  expected  volatility  could  cause  significant  variations  in  the  estimated  fair  value  of  the  derivative  warrant
liabilities.

Stock-based Compensation

We  have  a  stock-based  compensation  plan,  which  is  described  in  note  15  of  our  financial  statements  in  “Item  17.  Financial
Statements”.  We  account  for  stock  options  granted  to  employees  based  on  the  fair  value  method,  with  fair  value  determined  using  the
Black-Scholes model. The Black Scholes model requires certain assumptions such as future stock price volatility and expected life of the
instrument. Expected volatility is estimated based on weighted average historic volatility. The expected life of the instrument is estimated
based on historical experience and general holder behavior. Under the fair value method, compensation cost is measured at fair value at
date of

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grant and is expensed over the award’s vesting period with a corresponding increase in contributed surplus. For stock options granted to
non-employees, we measure based on the fair value of services received, unless those are not reliably estimable, in which case we measure
the fair value of the equity instruments granted. Compensation cost is measured when we obtain the goods or the counterparty renders the
service.

Tax Credits

Refundable tax credits related to eligible expenses are accounted for as a reduction of related costs in the year during which the

expenses are incurred as long as there is reasonable assurance of their realization.

Future Accounting Changes

A  number  of  new  standards,  interpretations  and  amendments  to  existing  standards  were  issued  by  the  IASB,  or  the  IFRS
Interpretations  Committee,  or  IFRIC,  that  are  mandatory  but  not  yet  effective  for  the  thirteen-month  and one-month  periods  March  31,
2017 and have not been applied in preparing our financial statements. The following standards have been issued by the IASB with effective
dates in the future that have been determined by management to impact the financial statements:

Financial Instruments

On  July  24,  2014,  the  IASB  issued  the  final  version  of  IFRS  9, Financial Instruments,  which  addresses  the  classification  and
measurement  of  financial  assets  and  liabilities,  impairment  and  hedge  accounting,  replacing  IAS  39, Financial  Instruments:  Recognition
and Measurement. IFRS 9 is effective for annual periods beginning on or after January 1, 2018, with earlier adoption permitted. We intend
to  adopt  IFRS  9  in  our  financial  statements  for  the  annual  period  beginning  on April  1,  2018.  We  have  not  yet  assessed  the  impact  of
adoption of IFRS 9, and do not intend to early-adopt IFRS 9 in our financial statements.

Amendments to IFRS 2 – Classification and Measurement of Share-Based Payment Transactions

On June 20, 2016, the IASB issued amendments to IFRS 2, Share-Based Payment, clarifying how to account for certain types of
share-based payment transactions. The amendments apply for annual periods beginning on or after January 1, 2018. Earlier application is
permitted. As a practical simplification, the amendments can be applied prospectively. Retrospective, or early application is permitted if
information is available without the use of hindsight. The amendments provide requirements on the accounting for the effects of vesting
and non-vesting  conditions  on  the  measurement  of  cash-settled  share-based  payments;  share-based  payment  transactions  with  a  net
settlement feature for withholding tax obligations; and a modification to the terms and conditions of a share-based payment that changes the
classification  of  the  transaction  from  cash-settled  to  equity-settled.  We  intend  to  adopt  the  amendments  to  IFRS  2  in  our  financial
statements for the annual period beginning on April 1, 2018. We have not yet assessed the impact of adoption of the amendments of IFRS
2, and do not intend to early-adopt these amendments in our financial statements.

Credit Risk

Credit risk is the risk of a loss if a customer or counterparty to a financial asset fails to meet its contractual obligations. We have
credit  risk  relating  to  cash,  cash  equivalents  and  short-term  investments,  which  we  manage  by  dealing  only  with  highly-rated  Canadian
financial  institutions.  The  carrying  amount  of  financial  assets,  as  disclosed  in  the  statements  of  financial  position,  represents  our  credit
exposure at the reporting date.

Currency Risk

We are exposed to the financial risk related to the fluctuation of foreign exchange rates and the degrees of volatility of those rates.
Foreign  currency  risk  is  limited  to  the  portion  of  our  business  transactions  denominated  in  currencies  other  than  the  Canadian  dollar.
Fluctuations  related  to  foreign  exchange  rates  could  cause  unforeseen  fluctuations  in  our  operating  results. A  portion  of  our  expenses,
mainly related to research contracts and purchase of production equipment, is incurred in US dollars and in Euros, for which no financial
hedging is required. There is a financial risk related to the fluctuation in the value of the US dollar and the Euro in relation to the Canadian
dollar. In order to minimize the financial risk related to the fluctuation in the value of the US dollar in relation to the Canadian dollar, funds
continue to be invested as short-term investments in the US dollar. A significant portion of our cash and cash equivalents are denominated
in  US  dollars,  further  exposing  us  to  fluctuations  in  the  value  of  the  US  dollar  in  relation  to  the  Canadian  dollar.  See  Note  19  of  our
financial statements in “Item 17. Financial Statements”.

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Interest Rate Risk

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of changes in
market  rates.  As  at  March  31,  2017,  February  28,  2017  and  February  29,  2016,  our  cash  and  cash  equivalents  and  our  short  term
investments were subject to fluctuations in short-term fixed interest rates.

Our capacity to reinvest the short-term amounts with equivalent return will be impacted by variations in short-term fixed interest
rates available on the market. Management believes the risk we will realize a loss as a result of the decline in the fair value of its short-term
investments is limited because these investments have short-term maturities and are generally held to maturity. Our capacity to reinvest the
short-term  amounts  with  equivalent  return  will  be  impacted  by  variations  in  short-term  fixed  interest  rates  available  on  the  market.
Management  believes  the  risk  we  will  realize  a  loss  as  a  result  of  the  decline  in  the  fair  value  of  our  short-term  investments  is  limited
because these investments have short-term maturities and are generally held to maturity.

Liquidity Risk

Liquidity  risk  is  the  risk  that  we  will  not  be  able  to  meet  our  financial  obligations  as  they  fall  due.  We  manage  liquidity  risk
through  the  management  of  its  capital  structure  and  financial  leverage,  as  outlined  in  Note  22  to  our  financial  statements  in  “Item  17.
Financial Statements”. We also manage liquidity risk by continuously monitoring actual and projected cash flows. Our board of directors
reviews  and  approves  our  operating  budgets,  and  reviews  material  transactions  outside  the  normal  course  of  business.  Our  contractual
obligations  related  to  financial  instruments  and  other  obligations  and  liquidity  resources  are  presented  in  “–Liquidity  and  Capital
Resources”.

Item 6.

Directors, Senior Management and Employees

A. Directors and Senior Management

The following table sets out the name and the province or state and country of residence of each of our directors and all offices
with us held by them, their principal occupation, the year in which they became a director, and the number of common shares they have
declared to beneficially own, directly or indirectly, or over which control or direction is exercised by them.

Name, Province or State, as the case may be, and
Country of Residence of each Director

Principal Occupation

First Year 
as Director   

Number of Common Shares
Beneficially Owned or 
Controlled  
or Directed by Each Director

Roderick N. Carter
California, United States
Chairman of the Board

Jean-Marie (John) Canan
Florida, United States

Janelle D’Alvise
California, United States

James S. Hamilton
Québec, Canada

Leendert H. Staal
Maryland, United States

Principal, Aquila Life
Sciences LLC

Corporate Director

2015

2016

President and CEO of Acasti

2016

President and CEO of
Neptune Technologies &
Bioressources Inc.

Independent consultant and  
owner of Staal Consulting
LLC

2015

2016

-

57,500

52,500

-

-

The following is a brief biography of our directors and senior management:

Dr. Roderick N. Carter

Dr.  Carter  has  a  strong  history  of  contributions  to  healthcare  through  clinical,  research,  business  and  people  leadership.  He  has
significant experience developing and commercializing nutraceutical and pharmaceutical products and has successfully led clinical research
and business development strategies for cardiovascular and inflammation related diseases. Dr. Carter is currently Principal at Aquila Life
Sciences LLC, a consulting firm he

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founded  in April  2008  focusing  on  pharmaceutical  development  and  commercialization.  Prior  to  this,  he  was  Vice  President  of  Clinical
Development  at  Reliant  Pharmaceuticals,  which  developed  the  OM3  cardiovascular  drug  LOVAZA,  and  today  is  a  wholly-owned
subsidiary of GlaxoSmithKline. He also served as Executive Director at Merck and Co., USA, President and Chief Executive Officer of
WellGen and Senior Medical Director at Pfizer Inc., USA. Dr. Carter received his Medical Degree from the University of Witwatersrand,
Johannesburg, along with a Master of Science degree in Sports Medicine from Trinity College, Dublin.

Janelle D’Alvise (also our CEO)

Ms. D’Alvise has extensive experience in diagnostics, medical devices, pharmaceuticals and drug discovery research tools. Until
recently,  Ms.  D’Alvise  was  the  President  and  Chairman  of  Pediatric  Bioscience.  Before  that,  she  was  the  CEO  of  Gish  Biomedical,  a
cardiopulmonary medical device company. Prior to Gish, Ms. D’Alvise was the CEO of the Sidney Kimmel Cancer Center (SKCC), a drug
discovery research institute. From 1995 until 1998, she was also the Co-Founder and Executive VP/COO of Metrika Inc., and in 1999 was
the Co-  Founder/President/CEO/Chairman  of  NuGEN,  Inc.  Ms.  D’Alvise  built  both  companies  from  technology  concept  through  to
successful  regulatory  approvals,  product  introduction  and  sustainable  revenue  growth.  Prior  to  1995,  Ms.  D’Alvise  was  a  VP  of  Drug
Development at Syntex/Roche and Business Unit Director of their Pain and Inflammation business, and also VP of Commercial Operations
at SYVA, (Syntex’s clinical diagnostics division), and began her career with Diagnostic Products Corporation. Ms. D’Alvise has a B.S. in
Biochemistry  from  Michigan  Technological  University.  She  has  completed  post-  graduate  work  at  the  University  of  Michigan,  Stanford
University, and the Wharton Business Schools. Ms. D’Alvise has served on the board of numerous private companies and  non-profits, and
is an Entrepreneur-in-Residence for the von Liebig Institute for Entrepreneurship at the University of California, San Diego.

James S. Hamilton

Mr.  Hamilton  is  currently  President  and  Chief  Executive  Officer  of  Neptune.  Prior  to  joining  Neptune,  from  2006  to  2015,
Mr.  Hamilton  served  as  Vice  President  Human  Nutrition  and  Health,  North America,  and  President  of  DSM  Nutritional  Products  USA,
Inc., based in Parsippany, New Jersey. He was serving on the global management team of DSM Nutritional Products’ Human Nutrition &
Health business, an organization with over $2 billion in global sales and operations in more than 40 countries. DSM Nutritional Products is
an  important  division  of  the  life  sciences  and  material  sciences  corporation,  DSM  N.V.  of  the  Netherlands.  Mr.  Hamilton’s  industry
knowledge has made him a valuable contributor to several trade associations and he a director and is the immediate past chairman of the
board of directors of the Council for Responsible Nutrition, the dietary supplement industry’s leading trade association. Mr. Hamilton is a
graduate  of  Concordia  University  in  Montreal,  Canada  and  has  attended  a  number  of  business  education  and  leadership  programs  at  the
London Business School and INSEAD.

Jean-Marie (John) Canan

Mr. Canan is an accomplished business executive with over 34 years of strategic, business development and financial leadership
experience.  Mr.  Canan  recently  retired  from  Merck  &  Co.,  Inc.  where  his  last  senior  position  was  as  Senior  Vice-President,  Global
Controller, and Chief Accounting Officer for Merck from November 2009 to March 2014. He has managed all interactions with the audit
committee  of  the  Merck  board  of  directors,  while  participating  extensively  with  the  main  board  and  the  compensation  &  benefits
committee. Mr. Canan serves as a director of REV Group, a public company, where he chairs the audit committee. Mr. Canan also provides
consulting  services  to  Willow  BioPharma,  a  Canadian start-up,  engaged  in  the  acquisition  and  development  of  legacy  pharmaceutical
assets. He also serves on the board of trustees of Angkor Hospital for Children, where he also chairs the audit & risk committee. Mr. Canan
is a graduate of McGill University, Montreal, Canada, and is a Canadian Chartered Accountant.

Dr. Leendert H. Staal

Dr. Staal is a member of the board of directors of Neptune. He is a seasoned and accomplished senior executive with a strong track
record of value creation. Dr. Staal has held numerous senior level positions within the DSM group, most recently as President and Chief
Executive Officer of DSM Nutritional Products from January 2008 to March 2013 and previously as President and Chief Executive Officer
of DSM Pharmaceuticals. Dr. Staal also held the position of Group Vice President of Quest International and was Chairman of Unipath (a
wholly  owned  subsidiary  of  Unilever).  He  is  currently  an  independent  consultant  and  owner  of  Staal  Consulting  LLC,  focusing  on
mergers  and  acquisitions  and  business  strategy.  Recently,  he  has  been  providing  consulting  services  in  connection  with  Neptune’s
Sherbrooke plant, where he is part of a team enhancing and optimizing plant output. Dr. Staal has a Ph.D. in Chemistry from the University
of Amsterdam.

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The  following  are  brief  biographies  of  our  senior  managers,  other  than  our  President  and  Chief  Financial  Officer,  Janelle  D’

Alvise, whose biography appears further above:

Linda P. O’Keefe – Chief Financial Officer (CFO)

Ms.  O’Keefe  has  been  our  Chief  Financial  Officer  since  November  28,  2016.  She  has  worked  with  both  public  and  private
biotechnology,  diagnostics,  medical  devices  and  healthcare  services  firms,  and  also  in  other  private  equity-financed  markets,  including
business services, education and technology. Prior to joining us, Ms. O’Keefe consulted with various firms after serving as Chief Financial
Officer  and executive-in-residence  for  Gryphon  Investors,  a  San  Francisco-based  private  equity  firm.  At  Gryphon  Investors,  she  led
fundraising, limited partner relations, risk management and advised portfolio company management teams on growth, financing and back
office strategies. In addition, Ms. O’Keefe provided mergers & acquisitions and integration support, established and led audit committees,
and supported the expansion of teams and systems to meet the needs of growing companies. Ms. O’Keefe also served as Chief Financial
Officer  of  Delphi  Ventures,  a  healthcare-focused  venture  capital  firm,  and  Elevate  Ventures;  as  Vice  President  of  Finance  at  Genelabs
Technologies and Target Therapeutics; and as Controller at Collagen Corporation. Ms. O’Keefe is an active Certified Public Accountant
and Chartered Global Management Accountant in California and Indiana and was formerly an audit senior with Ernst & Young. She is a
member  of  the American  Institute  of  CPAs,  the  California  and  Indiana  Societies  of  CPAs, Association  for  Corporate  Growth,  Financial
Executives International, and Healthcare Financial Management Association. Ms. O’Keefe holds a Bachelor of Science in Business from
the University of California, Berkeley.

Dr. Pierre Lemieux – Chief Operating Officer (COO)

Dr. Lemieux has been our Chief Operating Officer since April 12, 2010. He holds a post-doctoral degree in Oncology from the
Health Science Center, University of Texas (San Antonio), USA, and a PhD in biochemistry from Laval University, Canada, jointly with
University of Nottingham, England. Prior to joining us, Dr. Lemieux was the President, Chief Executive Officer and the chairman of the
board as well as being the founder of Technologie Biolactis Inc., a late-stage biotechnology company specialized in the commercialization
of  proteins  to  better  serve  the  nutraceutical,  cosmetic  and  pharmaceutical  industries.  Dr.  Lemieux  has  20  years  of  experience  in
pharmaceutical development and has occupied a variety of high management positions in the pharmaceutical industry.

Mr. Laurent Harvey – Vice President, Clinical and Non-Clinical Affairs

Mr.  Harvey  has  more  than  25  years’  experience  in  the  biopharmaceutical  industry,  primarily  in  drug  development  and  clinical
research. Before joining us, he occupied different management positions at Bristol-Myers Squibb, Æterna-Zentaris, Innodia, Bellus Health
and  KLOX  Technologies.  During  his  career,  he  participated  in  many  national  and  international  clinical  programs  in  various  therapeutic
fields such as cardiovascular, endocrinology, oncology and neurology. Mr. Harvey holds a Bachelor’s degree in pharmacy and M.Sc. in
hospital pharmacy, both from Université de Montréal.

B.

Compensation

Summary of our Compensation Programs

Our executive compensation program is intended to attract, motivate and retain high-performing senior executives, encourage and
reward  superior  performance  and  align  the  executives’  interests  with  ours  by  providing  compensation  which  is  competitive  with  the
compensation  received  by  executives  employed  by  comparable  companies  and  ensuring  that  the  achievement  of  annual  objectives  is
rewarded through the payment of bonuses and providing executives with long-term incentive through the grant of stock options.

Our  governance  &  human  resources,  or  GHR,  committee  has  authority  to  retain  the  services  of  independent  compensation
consultants to advise its members on executive compensation and related matters, and to determine the fees and the terms and conditions of
the engagement of those consultants. During our fiscal year ended March 31, 2017, the GHR committee retained compensation consulting
services, including those led by Lockton Companies, to review our executive compensation programs, including base salary, short-term and
long-term incentives, total cash compensation levels and total direct compensation of certain senior positions, against those of peer groups
of similar and larger size, as

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measured  by  market  capitalization,  biotechnology  and  pharmaceutical  companies  listed  or  headquartered  in  North America. All  of  the
services  provided  by  the  consultants  were  provided  to  the  GHR  committee.  The  GHR  committee  assessed  the  independence  of  the
consultants and concluded that its engagement of the consultants did not raise any conflict of interest with us or any of  our  directors  or
executive officers. As influenced by the consultants’ fiscal period 2017 executive compensation review, the board and GHR committee set
the following executive compensation program.

Use of Fixed and Variable Pay Components

Compensation of NEOs is revised each year and has been structured to encourage and reward executive officers on the basis of
short-term and long-term corporate performance. In the context of its analysis of compensation for our fiscal year ended March 31, 2017,
the following components were examined by the GHR committee:

  base salary;

  short term incentive plan, consisting of a cash bonus;

  long term incentive plan, consisting of stock options and equity incentive grants based on performance and/or time vesting

conditions; and

  other elements of compensation, consisting of group benefits and perquisites.

•

•

•

•

Base Salary

We  intend  to  be  competitive  with  comparator  companies  and  to  attract  and  retain  top  talent.  The  GHR  committee  will  review
compensation periodically to be sure it meets this strategic imperative. Base salary is set to reflect an individual’s skills, experience and
contributions within a salary structure consistent with our gender pay equity policy. Base salary structure is revised annually by the GHR
committee as our financial and market conditions evolve.

Short Term Incentive Plan (STIP)

Our  Short-Term  Incentive  Plan,  or  STIP,  provides  for  potential  rewards  when  a  threshold  of  corporate  performance  is  met.
Personal objectives that support corporate goals are established annually with each employee and are assessed at the end of each financial
year. Personal objectives are assessed through a performance grid, with pre-specified, objective performance criteria. STIP awards are paid
out in proportion to individual performance, determined in end-of-year performance reviews. For the most senior participants in the STIP,
greater  weight  is  assigned  to  corporate  objectives.  Target  payout  is  expressed  as  a  percentage  of  base  salary  and  is  determined  by
employment contracts and board discretion. Annual salary for STIP purposes is the annual salary in effect at the end of the plan year (i.e.,
prior to annual salary increases).

The  actual  amount  awarded  ranges  from  zero  for  performance  well  below  expectation  and  is  capped  at  two  times  target  for
exceptional  performance.  The  STIP  is  a  discretionary  variable  compensation  plan  and  all  STIP  payments  are  subject  to  board  approval.
Participants must be employed by us at the end of the financial year to qualify. We reserve the right to modify or discontinue the STIP at
any time.

Ms. D’Alvise, our CEO, is eligible for up to a 50% bonus of her annual base salary and Ms. O’Keefe, our CFO, is eligible for up to
a 40% bonus of her annual base salary. Dr. Lemieux, our COO, is eligible for up to a 40% bonus of his annual base salary and Mr. Harvey,
Vice President, Clinical and Non-Clinical Affairs, is eligible for up to a 30% bonus of his annual base salary.

These performance goals will take into account the achievement of R&D milestones within timelines and budget and individual

objectives determined annually by the board according to short-term priorities.

Long Term Incentive Plan (LITP)

The  LTIP  has  been  adopted  as  a  reward  and  retention  mechanism.  Participation  is  determined  annually  at  the  discretion  of  the
board. Employees approved by our board of directors may participate in our stock option plan, which is designed to align the long-term
interests of participants with those of shareholders, in order to promote shareholder value.

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The GHR committee determines the number of stock options to be granted to a participant based on peer group data and taking into
account corporate performance and level in the organization. The LTIP calculation is based on a guideline percentage of base salary and the
number of options is determined based on an approved dollar value (rather than a specific number of shares). The guideline ranges from
15%  to  200%  and  is  subject  to  adjustment  by  the  board  in  reviewing  annual  achievement  of  corporate  performance  and  availability  of
shares. The GHR committee may also determine, in its sole discretion, ad hoc stock option awards to be granted to participants in order to
address extraordinary situations. Awards at any level may be adjusted as necessary to maintain an equity burn rate and overhang similar to
comparator companies. In addition to our stock option plan, the board is also empowered to grant ad hoc awards, from time to time, under
our equity incentive plan to provide for a share-related mechanism to attract, retain and motivate qualified directors, senior employees and
consultants.

Our directors and executive officers are not permitted to purchase financial instruments, such as prepaid variable forward contracts,
equity swaps, collars or units of exchange funds that are designed to hedge or offset a decrease in market value of equity securities granted
as compensation or held, directly or indirectly, by the director or officer.

Share Ownership Guidelines

To  further  align  the  interests  of  our  executives  with  those  of  our  other  shareholders,  the  board  has  adopted  share  ownership
guidelines. Under these guidelines, the CEO and other executives (i.e., CFO, COO, VPs) are required to retain and hold 50% of the shares
acquired by them under any equity incentive award granted on or after June 8, 2017 (after subtracting shares sold to pay for option exercise
costs, and relevant federal, state, and local taxes which are assumed to be at the highest marginal tax rates). In addition, the share retention
rule applies unless the executive beneficially owns shares with a value at or in excess of the following share ownership guidelines:

•

•

  CEO — 2x then-current annual base salary

  Other executives — 1x then-current annual base salary.

The value of an individual’s shares for purposes of the share ownership guidelines is deemed to be the greater of the then-current
fair market value of the shares, or the individual’s cost basis in the shares. Shares counted in calculating the share ownership guidelines
include  shares  beneficially  owned  outright,  whether  from  open  market  purchases,  shares  retained  after  option  exercises,  and  shares  of
restricted stock or deferred stock units that have fully vested. In addition, in the case of vested, unexercised, in-the-money stock options,
the in-the-money value of the stock options will be included in the share ownership calculation. Executives have five years from their date
of hire or promotion to satisfy the share ownership guidelines.

Stock Option Plan

Our  stock  option  plan  was  adopted  by  our  board  of  directors  on  October  8,  2008  and  has  been  amended  from  time  to  time,
including  most  recently  on  June  14,  2017.  The  grant  of  options  is  part  of  the  long-term  incentive  component  of  executive  and  director
compensation  and  an  essential  part  of  compensation.  Qualified  directors,  employees  and  consultants  may  participate  in  our  stock  option
plan, which is designed to encourage optionnees to link their interests with those of our shareholders, in order to promote an increase in
shareholder value. Awards and the determination of any exercise price are made by our board of directors, after recommendation by the
GHR committee. Awards are established, among other things, according to the role and  responsibilities  associated  with  the  participant’s
position  and  his  or  her  influence  over  appreciation  in  shareholder  value. Any  award  grants  a  participant  the  right  to  purchase  a  certain
number  of  common  shares  during  a  specified  term  in  the  future,  after  a  vesting  period  and/or  specific  performance  conditions,  at  an
exercise price equal to at least 100% of the market price (as defined below) of our common shares on the grant date. The “market price” of
common shares as of a particular date generally means the closing price per common share on the TSXV, or any other exchange on which
the common shares are listed from time to time, for the last preceding date on which there was a sale of common shares on that exchange
(subject to certain exceptions set forth in the stock option plan in the event that we are no longer traded on any stock exchange). Previous
awards may sometimes be taken into account when new awards are considered.

In accordance with the stock option plan, all of an option holder’s options will immediately vest on the date of a Change of Control
event (as defined in the stock option plan), subject to the terms of any employment agreement or other contractual arrangement between the
option holder and us.

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However,  in  no  case  will  the  grant  of  options  under  the  plan,  together  with  any  proposed  or  previously  existing  security  based
compensation arrangement, result in (in each case, as determined on the grant date): the grant to any one consultant within any 12-month
period,  of  options  reserving  for  issuance  a  number  of  common  shares  exceeding  in  the  aggregate  2%  of  our  issued  and  outstanding
common shares (on a non-diluted basis); or the grant to any one employee, which provides investor relations services, within any 12-month
period,  of  options  reserving  for  issuance  a  number  of  common  shares  exceeding  in  the  aggregate  2%  of  our  issued  and  outstanding
common shares (on a non-diluted basis).

Options granted under the stock option plan are non-transferable and are subject to a minimum vesting period of 18 months, with
gradual  and  equal  vesting  on  no  less  than  a  quarterly  basis.  They  are  exercisable,  subject  to  vesting  and/or  performance  conditions,  at  a
price equal to the closing price of the common shares on the TSXV on the day prior to the grant of such options. In addition, and unless
otherwise provided for in the agreement between us and the holder, options will also lapse upon termination of employment or the end of
the business relationship with us except that they may be exercised for 60 days after termination or the end of the business relationship (30
days for investor relations services employees), to the extent that they will have vested on such date of termination of employment, except
in the case of death, disability or retirement where this period is extended to 12 months.

Subject to the approval of relevant regulatory authorities, including the TSXV, if applicable, and compliance with any conditions
attached to that approval (including, in certain circumstances, approval by disinterested shareholders) if applicable, the board of directors
has the right to amend or terminate the stock option plan. However, unless option holders consent to the amendment or termination of the
stock option plan in writing, any such amendment or termination of the stock option plan cannot affect the conditions of options that have
already been granted and that have not been exercised under the stock option plan.

Options for common shares representing a fixed rate of 20% of our outstanding issued common shares as of February 29, 2016
may  be  granted  by  the  board  under  the  stock  option  plan. As  at  the  March  31,  2017,  there  were  657,619  common  shares  reserved  for
issuance  under  the  stock  option  plan. As  of  March  31,  2017,  there  were  1,424,788  options  outstanding  under  the  stock  option  plan.  On
June  14,  2017,  in  connection  with  amendments  to  the  stock  option  plan  discussed  below,  the  board  granted  1,021,500  stock  options  to
employees, executives and members of the board, of which 373,600 of these stock options are subject to shareholder approval at our next
annual general and special shareholders meeting.

On June 14, 2017, the board approved amendments to the existing limits for common shares reserved for issuance under the stock
option  plan  as  described  below,  which  are  subject  to  shareholder  approval.  At  our  next  annual  and  special  shareholders  meeting,
shareholders will be asked to consider a resolution to approve amendments to the equity incentive plan to set the total number of common
shares reserved for issuance pursuant to awards granted under the equity incentive plan to an aggregate number that:

•

  if, and for so long as the common shares are listed on the TSXV, will not exceed the lower of:

•

•

  367,563 Common Shares, and

  20% of the issued and outstanding common shares as of March 31, 2017, (equating to 2,940,511 common shares), which
number will include common shares issuable pursuant to options issued under the amended stock option plan; or

•

  if, and for so long as the common shares are listed on the TSX, will not exceed 2.5% of the issued and outstanding common
shares from time to time.

The proposed amendments would also change certain limits to the number of common shares that can be reserved for issuance for

specific grants.

Equity Incentive Plan

On May 22, 2013, our equity incentive plan was adopted by the board in order to, among other things, provide us with a share-
related mechanism to attract, retain and motivate qualified directors, employees and consultants. The adoption of the equity incentive plan
was initially approved by shareholders at our 2013 Shareholders’ meeting held on June 27, 2013.

Eligible  persons  may  participate  in  the  equity  incentive  plan.  “Eligible  persons”  under  the  equity  incentive  plan  consist  of  any
director, officer, employee or consultant (as defined in the equity incentive plan) of us or a subsidiary. A participant is an eligible person to
whom an award has been granted under the equity incentive plan. The equity incentive plan provides us with the option to grant to eligible
persons bonus shares, restricted shares, restricted share units, performance share units, deferred share units and other share-based awards.

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If, and for so long as our common shares are listed on the TSXV, no more than 2% of the issued and outstanding common shares

may be granted to any one consultant or employee conducting investor relations activities in any 12-month period.

The board has the right to determine that any unvested or unearned restricted share units, deferred share units, performance share
units  or  other  share-based  awards  or  restricted  shares  subject  to  a  restricted  period  outstanding  immediately  prior  to  the  occurrence  of  a
change in control will become fully vested or earned or free of restriction upon the occurrence of a change in control. The board may also
determine that any vested or earned restricted share units, deferred share units, performance share units or other share-based awards will be
cashed out at the market price as of the date a change in control is deemed to have occurred, or as of such other date as the board may
determine prior to the change in control. Further, the board has the right to provide for the conversion or exchange of any restricted share
unit, deferred share unit, performance share unit or other share-based award into or for rights or other securities in any entity participating
in or resulting from the change in control.

The equity incentive plan is administered by the board and the board has sole and complete authority, in its discretion, to determine
the type of awards under the equity incentive plan relating to the issuance of common shares (including any combination of bonus shares,
restricted share units, performance share units, deferred share units, restricted shares or other share-based awards) in such amounts, to such
persons and under such terms and conditions as the board may determine, in accordance with the provisions of the equity incentive plan
and the recommendations made by the GHR committee.

Subject  to  the  adjustment  provisions  provided  for  in  the  equity  incentive  plan  and  the  applicable  rules  and  regulations  of  all
regulatory authorities to which we are subject (including any stock exchange), the total number of common shares reserved for issuance
pursuant to awards granted under the equity incentive plan will be equal to a number that (A) if, and for so long as the common shares are
listed on the TSXV, will not exceed either (i) 267,800 common shares, and (ii) 20% of the issued and outstanding common shares as of
February 29, 2016, representing 2,142,407 common shares, which includes common shares issuable pursuant to options issued under our
stock option plan.

On June 14, 2017, the board approved amendments to the existing limits of common shares reserved for issuance under the stock

option plan as described above, which are subject to shareholder approval.

Other Forms of Compensation

RRSP Matching Program. Effective June 1, 2016, we sponsor a voluntary Registered Retirement Savings Plan, or RRSP, matching
program, which is open to all eligible employees, including NEOs. The RRSP matching program matches employees’ contributions up to a
maximum  of  $1,000  per  fiscal  year  for  eligible  employees  who  participate  in  the  program.  Other  than  matching  contributions  under  the
RRSP matching program (which amounts are disclosed in the column entitled “All Other  Compensation”  in  the  summary  compensation
table below), we do not provide pension or retirement benefits to our executive officers or directors.

Other  Benefits  and  Perquisites. Our  executive  employee  benefit  program  also  includes  life,  medical,  dental  and  disability
insurance. These benefits and perquisites are designed to be competitive overall with equivalent positions in comparable organizations. We
do not have a pension plan for employees.

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Compensation Paid to Named Executive Officers

The following table sets forth the compensation information for the NEOs during the thirteen months ended March 31, 2017, and

the fiscal years ended February 29, 2016 and February 28, 2015.

Name and
Principal Position

Period
ended

Salary
($)

Janelle D’Alvise(4)
CEO

Linda P. O’Keefe(5)
CFO

Pierre Lemieux
COO

Laurent Harvey
Vice President,
Clinical and Non-
Clinical Affairs

March 31,
2017

March 31,
2017

March 31,
2017
February 29,
2016
February 28,
2015
March 31,
2017
February 29,
2016
February 28,
2015

365,072

114,183

275,819

239,565

202,115

194,846

159,808

107,977

Share-
Based
Awards(1)(2)
($)

Option-Based
Awards
(1) (2)

($)

Annual
Incentive
Plans
($)

All Other
Compensation
($)(3)

Total
Compensation
($)

-

-

-

-

-

-

-

-

502,163

136,049(6)

-

1,003,284

237,340

39,897(7)

109,414(8)

500,834

96,522

33,320

22,163

84,205

17,153

7,388

49,000

42,000

12,000

35,000

16,000

8,000

-

-

-

-

-

-

421,341

314,885

236,278

314,051

192,961

123,365

(1) We have adopted IFRS 2 Share-Based Payment to account for the issuance of stock options to employees and  non-employees. The fair value of stock options is

estimated at the grant date using the Black-Scholes option pricing model. This model requires the input of a number of parameters, including share price, share
exercise price, expected share price volatility, expected time until exercise and risk-free interest rates. Although the assumptions used reflect management’s
best estimates, they involve inherent uncertainties based on market conditions generally outside of our control.

(2)

The fair value of the option-based awards granted in the thirteen-month period ended March 31, 2017 is as follows: (i) the May 12, 2016 option-based awards
are based on a fair value of $0.96 per option granted to Ms. D’Alvise; (ii) the May 30, 2016 option-based awards are based on a fair value of $1.18 per option
granted to Dr. Lemieux and Mr. Harvey; (iii) the February 24, 2017 option-based awards are based on a fair value of $1.19 per option granted to Ms. O’Keefe
and Dr. Lemieux and Mr. Harvey.

For the period ended on February 29, 2016, the fair market value of the June 1, 2015 option-based awards are based on a fair value of $1.97 per option granted to
Messrs. Harvey and Lemieux.

For the period ended on February 28, 2015, the fair market value of the October 20, 2014 option-based awards granted to Dr. Lemieux is based on a fair value of
$3.00 per option, prior to our reverse share split.

(3)

The value of perquisites and other personal benefits received by these executives did not total an aggregate value of $50,000 or more, and does not represent
10% or more of their total salary during the financial years ended March 31, 2017, February 29, 2016 and February 28, 2015.

(4) Ms.  D’Alvise  was  appointed  our  President  and  CEO  on  May  11,  2016  and  began  her  functions  on  June  1,  2016.  Her  employment  agreement  provides  for

payments in U.S. dollars with an annual base salary of US$330,000.

(5) Ms. O’Keefe was appointed our CFO effective as of November 27, 2016. Her employment agreement provides for payments in U.S. dollars with an annual

base salary of US$250,000.

  (6)

US$102,300, converted as at March 31, 2017, based on a closing exchange rate of US1.00= $1.3299.

  (7)

US$30,000 converted as at March 31, 2017, based on a closing exchange rate of US1.00= $1.3299.

(8)

Consulting services from July 2016 to November 2016 which provided for payments in U.S. dollars: US$82,273, converted as at March 31, 2017 based on a
closing exchange rate of US1.00= $1.3299.

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Outstanding Share-Based and Option-Based Awards

The following tables provide information about the number and value of the outstanding option-based awards held by the NEOs  as

of March 31, 2017. There are no share-based awards outstanding as of the date of this annual report.

Name / Grant Date

Number of Securities      
Underlying      
Unexercised Options      
(#)      

Option Exercise    
Price ($)    

Option Expiration    
Date    

Value of Unexercised    
In-The-Money    
Options(1)    
($)    

May 12, 2023    

1.56    

1.65    

200,000      

525,000      

Janelle D’Alvise (2)
May 12, 2016
Linda P. O’Keefe (3)
February 24, 2017
Pierre Lemieux
February 24, 2017
May 30, 2016
June 1, 2015
October 20, 2014
Laurent Harvey
February 24, 2017
May 30, 2016
June 1, 2015
October 20, 2014
(1) Calculation is based on a trading price of $1.83 for our common shares on the TSXV, as at closing on March 31, 2017.
(2) Ms. D’Alvise was appointed as our President and CEO on May 11, 2016 and began her functions on June 1, 2016.
(3) Ms. O’Keefe was appointed as our CFO effective November 27, 2016.

50,000      
31,400      
16,900(1)      
7,500(1)      

50,000      
21,000      
8,700(1)      
2,500(1)      

1.65    
1.99    
4.50(1)    
6.50(1)    

1.65    
1.99    
4.50(1)    
6.50(1)    

February 24, 2027      
May 29, 2023    
June 1, 2022    
October 19, 2019    

February 24, 2027      
May 29, 2023    
June 1, 2022    
October 19, 2019    

February 24, 2027      

141,750    

36,000    

9,000    
-    
-    
-    

9,000    
-    
-    
-    

The following table sets out the value of share-based, option-based, and warrant-based awards held by the NEOs that vested during

the fiscal year ended March 31, 2017:

Name

Janelle D’Alvise

Compensation of Directors

Share-Based Awards
($)

-

Option-Based Awards
($)

28,875

Our directors’ compensation consists of an annual fixed compensation of US$35,000. While our compensation structure does not
include meeting fees, a discretionary reduction of 20% may be applied to the annual retainer payment each time a director fails to attend a
quarterly board or committee session. In addition, the chairman of the board and each chairperson of the audit and the GHR committees
received  additional  compensation  of  US$25,000  and  US$10,000,  respectively,  for  their  additional  work  during  the  fiscal  year  ended
March 31, 2017. The directors are also entitled to be reimbursed for travelling and other reasonable expenses properly incurred by them in
attending meetings of the board or any committee or in otherwise serving us, in accordance with our policy on travel and expenses.

Following their first election to our board of directors, non-executive directors are eligible to receive an initial equity grant of up to
150% of their annual cash retainer worth of stock options vesting annually in equal installments over a 3-year period, subject to the other
terms and conditions set forth under the heading “–Stock Option Plan”. In addition to their initial grant, non-executive directors are eligible
to receive an annual equity-based award equal to 100% of their total annual cash retainer vesting quarterly in equal installments over an
18-month period. These awards will be granted at the same time that we are performing our annual performance review for our employees,
subject to availability of common shares and subject to the terms and conditions described under the headings “–Stock Purchase Plan” and
“–Equity Incentive Plan”. The level of these awards will be consistent with equivalent awards in comparable companies obtained from the
benchmark exercise and in accordance with the recommendations obtained from our independent compensation consultant.

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The total compensation for our non-executive directors during the thirteen-month period ended March 31, 2017 was as follows:

Name

Roderick N.
Carter

Jean-Marie
(John) Canan

James S.
Hamilton

Leendert H.
Staal(6)

Pierre
Fitzgibbon(6)

Thirteen
Months
Ended March
31

Fees Earned
($)

Option-Based
Awards(1)(2)
($)

All Other
Compensation
($)(5)

2017

2017

2017

2017

2017

188,517(3)

236,860

44,884(4)

58,520

-

-

44,884(4)

58,520

21,917

-

-

-

-

-

-

Total
($)

425,377

103,404

-

103,404

21,917

(1) We have adopted IFRS 2 Share-Based Payment to account for the issuance of stock options to employees and  non-employees. The fair value of the awards
is estimated at the grant date using the Black-Scholes option pricing model. This model requires the input of a number of parameters, including share price,
share  exercise  price,  expected  share  price  volatility,  expected  time  until  exercise  and  risk-free  interest  rates.  Although  the  assumptions  used  reflect
management’s best estimates, they involve inherent uncertainties based on market conditions generally outside of our control.

(2)

(3)

For the thirteen-month period ended on March 31, 2017, (i) the fair market value of the May 30, 2016 option-based awards is based on a fair value of $1.18
per option granted to Dr. Carter; and (ii) the fair market value of the February 24, 2017 option-based awards is based on a fair value of $1.17 per option
granted to Mr. Canan and Dr. Staal.

Dr. Carter was appointed Executive Chairman of the board on March 1, 2016 and earned compensation of US$98,980 for this role through June 30, 2016.
After that date and Ms. D’Alvise’s appointment as CEO on June 1, 2016, Dr. Carter earned compensation of US$45,000 for being Chairman of the board
through March 31, 2017.

(4) Mr. Canan and Dr. Staal earned a director compensation of US$33,750 and were appointed to the board of directors in July 2016.

(5)

(6)

The directors do not receive pension benefits or other  non-equity based annual compensation.

After the resignation of certain directors on February 29, 2016, Mr. Fitzgibbon, Chairman of the board of directors of Neptune, joined until July 12, 2016
as member of our board of directors and Chair of the audit and GHR committees to help insure a proper transition between the departing directors and the
election of the new nominees at our 2016 annual general shareholders meeting.

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Outstanding Share-Based and Option-Based Awards for Directors

The  following  table  provides  information  about  the  number  and  value  of  the  outstanding  share-based  and  option-based  awards

held by non-executive directors. There were no share-based awards outstanding as of the date of this annual report.

Name / Grant Date  

Number of Securities    
Underlying    
Unexercised Options    

  Option Exercise  
Price ($)(1)

Option Expiration Date         

Value of Unexercised        
in-the-Money        
Options        
($)(2)        

Roderick N. Carter
May 30, 2016
August 19, 2015
Jean-Marie (John) Canan
February 24, 2017
Leendert H. Staal
February 24, 2017

200,000    
10,000(1)    

50,000    

50,000    

1.99  
4.80  

1.65  

1.65  

May 29, 2023         
August 19, 2022         

February 24, 2027         

February 24, 2027         

-        
-        

9,000        

9,000        

(1)    Option-based awards were consolidated following our share consolidation. The exercise price was increased proportionally to reflect the consolidation.

(2)    Calculation is based on a trading price of $1.83 for our common shares on the TSXV, as at closing on March 31, 2017.

None  of  the  share-based  and  stock  options  of  the  Corporation  held  by non-executive  Directors  that  vested  during  the  financial

year ended on March 31, 2017 were in-the-money at their respective vesting date.

C.

Board Practices

Board of Directors

Director Independence

Our board of directors believes that, in order to maximize its effectiveness, the board must be able to operate independently. A
majority  of  directors  must  satisfy  the  applicable  tests  of  independence,  such  that  the  board  of  directors  complies  with  all  independence
requirements  under  applicable  corporate  and  securities  laws  and  stock  exchange  requirements  applicable  to  us.  No  director  will  be
independent unless the board of directors has affirmatively determined that the director has no material relationship with us or any of our
affiliates,  either  directly  or  indirectly  or  as  a  partner,  shareholder  or  officer  of  an  organization  that  has  a  relationship  with  us  or  our
affiliates. Such determinations will be made on an annual basis and, if a director joins the board of directors between annual meetings, at
such time.

Independent Directors

The board of directors determined that Mr. Canan, Dr. Carter and Dr. Staal are independent within the meaning of NI  52-110 and

NASDAQ Stock Market rules.

Directors Who are Not Independent

The board of directors determined that Mr. Hamilton is not independent within the meaning of NI  52-110 and NASDAQ rules
given that he is President and CEO of Neptune. In addition, the board of directors determined that Ms. D’Alvise is not independent within
the meaning of NI 52-110 and NASDAQ given that she is our President and CEO.

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Attendance Record of Directors for Board Meetings

During the fiscal year ended March 31, 2017, the board of directors held 12 meetings. Attendance of directors at those meetings

is indicated in the table below:

Board Members

Roderick N. Carter

Jean-Marie (John) Canan (1)

Janelle D’Alvise(1)

James S. Hamilton

Leendert H. Staal(1)

Pierre Fitzgibbon(2)

Attendance    

12/12    

8/8    

8/8    

12/12    

8/8    

4/4    

(1) Ms. D’Alvise, Mr. Canan and Dr. Staal joined the board of director at our last annual general meeting on July 12, 2016.

(2) Mr. Fitzgibbon was temporarily appointed as a member of the board from March 1, 2016 to July 12, 2016 following the resignation of certain directors.

During  the  fiscal  year  ended  March  31,  2017,  the  independent  directors  held  at  least  5  scheduled  meetings  at  which

non-independent directors and members of management were not in attendance.

Chairman of the Board

Dr. Carter acts as Chairman of the board. His duties and responsibilities consist of the oversight of the quality and integrity of the

board of directors’ practices.

Board Mandate

There is no specific mandate for the board of directors, since the board has plenary power. Any responsibility that is not delegated

to senior management or a committee of the board remains with the full board of directors.

Position Descriptions

No written position description has been approved for the chair of the board of directors and for the chairs of each committee.
The primary role and responsibility of the chair of each committee of the board of directors is to: (i) in general, ensure that the committee
fulfills its mandate, as determined by the board of directors; (ii) chair meetings of the committee; (iii) report to the board of directors; and
(iv) act as liaison between the committee and the board of directors and, if necessary, our management.

Orientation and Continuing Education

We  provide  orientation  for  new  appointees  to  the  board  of  directors  and  committees  in  the  form  of  informal  meetings  with
members  of  the  board  and  senior  management,  complemented  by  presentations  on  the  main  areas  of  our  business.  The  board  does  not
formally provide continuing education to its directors, as directors are experienced members. The board of directors relies on professional
assistance, when judged necessary, in order to be educated/updated on a particular topic.

Code of Business Conduct and Ethics

The  board  of  directors  adopted  a  Code  of  Business  Conduct  and  Ethics,  or  Code  of  Conduct,  for  our  directors,  officers  and
employees on May 31, 2007, as amended from time to time. Our Code of Conduct can be found on SEDAR at www.sedar.com and on our
web site on www.acastipharma.com. A copy of the Code of Conduct can also be obtained by contacting our Corporate Secretary. Since its
adoption by the board of directors, any breach of the Code of Conduct must be brought to the attention of the board of directors by our CEO
or other senior executives. No report has ever been filed which pertains to any conduct of a director or executive officer that constitutes a
breach to our Code of Conduct.

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Since the adoption of the Code of Conduct and the following policies, the board of directors actively monitors compliance with
the Code Conduct and promotes a business environment where employees are encouraged to report malfeasance, irregularities and other
concerns. The Code of Conduct provides for specific procedures for reporting non-compliant practices in a manner which, in the opinion of
the board of directors, encourages and promotes a culture of ethical business conduct.

The  board  of  directors  also  adopted  a  disclosure  policy,  insider  trading  policy,  majority  voting  policy,  management  and  board

compensation policies, and a whistleblower policy.

In  addition,  under  the Civil  Code  of  Québec,  to  which  we  are  subject  as  a  legal  person  incorporated  under  the Business
Corporations Act (Québec) (L.R.Q., c. S-31), a director o must immediately disclose to the board any situation that may place him or her in
a  conflict  of  interest. Any  such  declaration  of  interest  is  recorded  in  the  minutes  of  proceeding  of  the  board  of  directors.  The  director
abstains, except if required, from the discussion and voting on the question. In addition, it is our policy that an interested director recuse
himself or herself from the decision-making process pertaining to a contract or transaction in which he or she has an interest.

Nomination of Directors

The  board  of  directors  receives  recommendations  from  the  GHR  committee,  but  retains  responsibility  for  managing  its  own
affairs by, among other things, giving its approval for the composition and size of the board of directors, and the selection of candidates
nominated for election to the board of directors. The GHR committee initially evaluates candidates for nomination for election as directors,
having regard to the background, employment and qualifications of possible candidates.

The selection of the nominees for the board of directors is made by the other members of the board, based on our needs and the
qualities required for the board of directors, including ethical character, integrity and maturity of judgment of the candidates; the level of
experience of the candidates, their ideas regarding the material aspects of our business, the expertise of the candidates in fields relevant to
us while complementing the training and experience of the other members of the board of directors; the will and ability of the candidates to
devote the necessary time to their duties to the board of directors and its committees, the will of the candidates to serve on the board of
directors  for  numerous  consecutive  financial  periods  and  finally,  the  will  of  the  candidates  to  refrain  from  engaging  in  activities  which
conflict  with  the  responsibilities  and  duties  of  a  director.  The  board  researches  the  training  and  qualifications  of  potential  new  directors
which  seem  to  correspond  to  the  selection  criteria  of  the  board  of  directors  and,  depending  on  the  results  of  said  research,  organizes
meetings with the potential candidates.

In the case of incumbent directors whose terms of office are set to expire, the board will review such directors’ overall service to
us  during  their  term  of  office,  including  the  number  of  meetings  attended,  level  of  participation,  quality  of  performance  and  any
transactions of such directors with us during their term of office.

We  may  use  various  sources  in  order  to  identify  the  candidates  for  the  board  of  directors,  including  our  own  contacts  and  the
references of other directors, officers, advisors and executive placement agencies. We will consider director candidates recommended by
shareholders  and  will  evaluate  those  director  candidates  in  the  same  manner  in  which  we  evaluate  candidates  recommended  by  other
sources.  In  making  recommendations  for  director  nominees  for  the  annual  meeting  of  shareholders,  we  will  consider  any  written
recommendations of director candidates by shareholders received by our Corporate Secretary not later than 120 days before the anniversary
of  the  previous  year’s  annual  meeting  of  shareholders.  Recommendations  must  include  the  candidate’s  name,  contact  information  and  a
statement  of  the  candidate’s  background  and  qualifications,  and  must  be  mailed  to  us.  Following  the  selection  of  the  candidates  by  the
board of directors, we will propose a list of candidates to the shareholders, for our annual meeting of shareholders.

The board of directors does not have a nominating committee and has not adopted any formal written director term limit policy.

Proposed nominations of director candidates are evaluated by our GHR committee.

GHR Committee

The  mandate  of  the  GHR  committee  consists  of  the  evaluation  of  the  proposed  nominations  of  senior  executives  and  director
candidates to our board of directors, recommending for board approval, if appropriate, revisions of our corporate governance practices and
procedures,  developing  new  charters  for  any  new  committees  established  by  the  board  of  directors,  monitoring  relationships  and
communication between management and the board of directors, monitoring emerging best practices in corporate governance and oversight
of governance matters and assessing the board of directors and its committees. The GHR committee is also in charge of establishing the
procedure  which  must  be  followed  by  us  to  comply  with  applicable  guidelines  of  the  TSXV  and  NASDAQ  Stock  Market  regarding
corporate governance.

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The  GHR  committee  has  the  responsibility  of  evaluating  the  compensation,  performance  incentives  as  well  as  the  benefits
granted  to  our  upper  management  in  accordance  with  their  responsibilities  and  performance  as  well  as  to  recommend  the  necessary
adjustments to our board of directors. The GHR committee also reviews the amount and method of compensation granted to the directors.
The GHR committee may retain an external firm in order to assist it during the execution of its mandate. The GHR committee considers
time commitment, comparative fees and responsibilities in determining compensation.

The  GHR  committee  is  composed  of  independent  members  within  the  meaning  of  NI  52-110  and  NASDAQ  Stock  Exchange

rules, namely Dr. Staal, acting as chairperson, Dr. Carter and Mr. Canan.

Periodic Assessments

The board of directors, its committees and each director are subject to periodic evaluations of their efficacy and contribution. The
evaluation procedure consists in identifying any shortcomings and implementing adjustments proposed by directors at the beginning and
during  meetings  of  the  board  of  directors  and  of  each  of  its  committees. Among  other  things,  these  adjustments  deal  with  the  level  of
preparation  of  directors,  management  and  consultants  employed  by  us,  the  relevance  and  sufficiency  of  the  documentation  provided  to
directors and the time allowed to directors for discussion and debate of items on the agenda.

Director Term Limits

The board actively considers the issue of term limits from time to time. At this time, the board does not believe that it is in our
best  interests  to  establish  a  limit  on  the  number  of  times  a  director  may  stand  for  election.  While  such  a  limit  could  help  create  an
environment where fresh ideas and viewpoints are available to the board, a director term limit could also disadvantage us through the loss
of  the  beneficial  contribution  of  directors  who  have  developed  increasing  knowledge  of,  and  insight  into,  us  and  our  operations  over  a
period of time. As we operate in a unique industry, it is difficult to find qualified directors with the appropriate background and experience
and the introduction of a director term limit would impose further difficulty.

Policies Regarding the Representation of Women on the Board and Among Executive Officers

We  have  not  adopted  a  formal  written  policy  regarding  diversity  amongst  executive  officers  and  members  of  the  board  of
directors, including mechanisms for board renewal, in connection with, among other things, the identification and nomination of women
directors.  Nevertheless,  we  recognize  that  gender  diversity  is  a  significant  aspect  of  diversity  and  acknowledges  the  important  role  that
women with appropriate and relevant skills and experience can play in contributing to the diversity of perspective on the board of directors.

Rather than considering the level of representation of women for directorship and executive officer positions when making board
or executive officer appointments, we consider all candidates based on their merit and qualifications relevant to the specific role. While we
recognize the benefits of diversity at all levels within its organization, we do not currently have any targets, rules or formal policies that
specifically  require  the  identification,  consideration,  nomination  or  appointment  of  candidates  for  directorship  or  executive  management
positions or that would otherwise force the composition of our board of directors and executive management team. Currently, we have one
women director who is also our CEO. In addition, our CFO is a woman.

Audit Committee

Our audit committee is responsible for assisting the board of directors in fulfilling its oversight responsibilities with respect to

financial reporting, including:

•

•

•

•

•

  reviewing our procedures for internal control with our auditor and management performing financial functions;

  reviewing and approving the engagement of the auditor;

  reviewing annual and quarterly financial statements and all other material continuous disclosure documents, including our
annual information form and management’s discussion and analysis;

  assessing our financial and accounting personnel;

  assessing our accounting policies;

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•

•

  reviewing our risk management procedures; and

  reviewing any significant transactions outside our ordinary course of business and any pending litigation involving us.

The audit committee has direct communication channels with our management performing financial functions and our external
auditor  to  discuss  and  review  such  issues  as  the  audit  committee  may  deem  appropriate. As  of  March  31,  2017,  the  audit  committee  is
composed of Mr. Canan, as chairperson, Dr. Carter and Dr. Staal. Each is “financially literate” and “independent” within the meaning of NI
52-110 and the Exchange Act.

Compensation Governance

Compensation  of  our  executive  officers  and  directors  is  recommended  to  the  board  of  directors  by  the  GHR  committee.  In  its
review process, the GHR committee relies on input from management on the assessment of executives and corporate performance. During
the  fiscal  year  ended  March  31,  2017,  the  GHR  committee  was  composed  of  the  following  members,  each  of  whom  is  independent:
Dr.  Staal,  acting  as  chairperson,  Dr.  Carter  and  Mr.  Canan.  The  GHR  committee  establishes  management  compensation  policies  and
oversees their general implementation. All members of the GHR committee have direct experience which is relevant to their responsibilities
as GHR committee members. All members are or have held senior executive or director roles within significant businesses, several also
having  public  companies  experience,  and  have  a  good  financial  understanding  which  allows  them  to  assess  the  costs  versus  benefits  of
compensation  plans.  The  members  combined  experience  in  our  sector  provides  them  with  the  understanding  of  our  success  factors  and
risks, which is very important when determining metrics for measuring success.

Risk management is a primary consideration of the GHR committee when implementing its compensation program. We do
not  believe  that  our  compensation  program  results  in  unnecessary  or  inappropriate  risk  taking,  including  risks  that  are  likely  to  have  a
material adverse effect on us. Payments of bonuses, if any, are not made unless performance goals are met.

For  executives,  more  than  half  of  target  direct  compensation  (base  salary  +  target  STIP  awards  +  target  LTIP  awards)  is
considered “at risk”. We believe this mix results in a strong pay-for-performance relationship and an alignment with shareholders and is
competitive with other firms of comparable size in similar fields. The CEO (or any person acting in that capacity) makes recommendations
to the GHR committee as to the compensation of our executive officers, other than himself or herself, for approval by the board. The GHR
committee makes recommendations to the board of directors as to the compensation of the CEO, for approval. The CEO’s salary is based
on  comparable  market  consideration  and  the  GHR  committee’s  assessment  of  his  or  her  performance,  with  regard  to  our  financial
performance and progress in achieving strategic goals.

Qualitative factors beyond the quantitative financial metrics are also a key consideration in determination of individual executive
compensation payments. How executives achieve their financial results and demonstrate leadership consistent with our values are key to
individual compensation decisions.

D. Employees

Our management consists of professionals experienced in business development, finance and science. Our research team includes
scientists  with  expertise  in  pharmaceutical  development,  chemistry,  manufacturing  and  controls,  nonclinical  and  clinical  studies,
pharmacology, regulatory affairs, quality assurance/quality control, intellectual property and strategic alliances. As of March 31, 2017, we
had  13  full-time  employees  located  in  Canada  and  2  full-time  employees  located  in  the  United  States.  We  generally  require  all  of  our
employees to enter into an invention assignment, non-disclosure and non-compete agreement. We rely, in part, on the administrative and
other  staff  of  Neptune  and  also  rely  on  consultants  from  time  to  time.  Our  employees  are  not  covered  by  any  collective  bargaining
agreement or represented by a trade union. We consider our relations with our employees to be good and our operations have never been
interrupted as the result of a labor dispute.

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E.

Share Ownership

The following table shows the total number of common shares beneficially owned by each of our directors and executive officers

and the percentage of the total issued and outstanding common shares that such holdings represent.

Name
Roderick N. Carter
Jean-Marie (John) Canan
James S. Hamilton
Leendert H. Staal
Janelle D’Alvise
Linda P. O’Keefe
Pierre Lemieux
Laurent Harvey

    Common shares beneficially owned    
as of March 31, 2017
-
57,500
-
-
52,500
30,000
7,000
-

Percentage of total issued and
outstanding common shares
as of March 31, 2017(1)
-
*
-
-
*
*
*
-

(1)
*

Based on 14,702,556 common shares outstanding.
Less than 1%.

See  “Item  6.B.  Compensation”  above  for  information  regarding  the  share-based,  option-based,  call-option-based,  and  warrant-

based awards held by our directors and executive officers and for a description of our stock option plan and equity incentive plan.

Item 7.

Major Shareholders and Related Party Transactions

A. Major Shareholders

As of June 26, 2017, Neptune owns 5,064,694 common shares representing 34% of our common shares issued and outstanding.
The common shares are voting, participating, and have no par value. Neptune also owns a warrant entitling it to acquire 592,500 common
shares (in order to obtain 1 common share, 10 warrants must be exercised). Neptune does not have different voting rights than other holders
of common shares. To the best of our knowledge, there are no other beneficial owners of 5% or more of any class of our voting securities
other  than  Mr.  George  W.  Haywood,  who,  according  to  a  beneficial  ownership  report  on  Schedule  13G  filed  by  Mr.  Haywood  with  the
Commission, owns 1,479,000 of our common shares, representing 9.9% of our issued and outstanding common shares.

All common shares, including those held by Neptune, are common shares with the same voting rights. Based on the records of
our registrar and transfer agent, Computershare Trust Company of Canada, as of March 31, 2017, there were approximately 10 registered
holders  (including  The  Depository  Trust  Company)  of  our  common  shares  resident  in  the  United  States  (approximately  10%  of  all
registered holders).

B.

Related Party Transactions

Please see the section entitled “—Related Party Transactions” in “Item 5. Operating and Financial Review and Prospects”.

C.

Interests of Experts and Counsel

Not applicable.

Item 8.

Financial Statements

A.

Consolidated Statements and Other Financial Information

Financial Statements

See “Item 17. Financial Statements” for our audited consolidated financial statements.

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Legal Proceedings

Due to the fact that a significant portion of our intellectual property rights are licensed to us by Neptune, we rely on Neptune to
protect a significant portion of the intellectual property rights that we use under our license agreement with Neptune. Neptune is engaged in
a number of legal actions related to its intellectual property.

Our former CEO is claiming the payment of approximately $8.5 million and the issuance of equity instruments from the Neptune
group. As  our  management  believes  that  these  claims  are  not  valid,  no  provision  has  been  recognized.  Neptune  and  its  subsidiaries  also
filed an additional claim to recover certain amounts from the former officer.

We are also involved in other matters arising in the ordinary course of our business. Since management believes that all related
claims  are  not  valid  and  it  is  presently  not  possible  to  determine  the  outcome  of  these  matters,  no  provisions  have  been  made  in  our
financial statements for their ultimate resolution beyond the amounts incurred and recorded for such matters. The resolution of these other
matters could have an effect on our financial statements in the year that a determination is made, however, in management’s opinion, the
final resolution of all such matters is not projected to have a material adverse effect on our financial position.

Dividend Policy

We  do  not  anticipate  paying  any  cash  dividend  on  the  common  shares  in  the  foreseeable  future.  We  presently  intend  to  retain
future earnings to finance the expansion and growth of our business. Any future determination to pay dividends will be at the discretion of
our board of directors and will depend on our financial condition, results of operations, capital requirements and other factors the board of
directors deems relevant. In addition, the terms of any future debt or credit facility may preclude us from paying dividends.

Item 9.

The Offer and Listing

A.

Listing Details

Since March 31, 2011, our common shares have been listed on the  TSX-V under the ticker symbol APO. Since January 7, 2013,
our common shares have been listed on the NASDAQ Stock Market under the ticker symbol ACST. The following tables set forth, for the
periods indicated, the high and low market prices of our common shares as reported on the TSX-V and the NASDAQ Stock Market.

(a)        For the five most recent full fiscal years:

Fiscal year ended

Feb. 28, 2013(1)

Feb. 28, 2014(1)

Feb. 28, 2015(1)

Feb. 29, 2016

Mar. 31, 2017

TSX-V

   NASDAQ Stock Market

    High $      

    Low $      

    High US$      

    Low US$    

27.60

43.20

14.90

7.60

4.03

16.00   

39.90

11.50   

42.00

11.50   

13.40

1.83

1.47

6.10

3.09

20.00

10.90

10.90

1.30

1.11

(1)

Our  common  shares  were  consolidated  on  October  15,  2015,  on  the  basis  of  one  (1)  post-consolidation  common  share  for  every  10
pre-consolidation common shares, and each fractional common share resulting from the consolidation was rounded up. The common share
price was increased proportionally to reflect the consolidation.

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(b)        For each full financial quarter of the two most recent full fiscal years and any subsequent period:

TSX-V

NASDAQ Stock Market

Period
1st Quarter ended May 31, 2015 (1)
2nd Quarter ended Aug. 31, 2015 (1)
3rd Quarter ended Nov. 30, 2015 (1)
4th Quarter ended Feb. 29, 2016
1st Quarter ended May 31, 2016
2nd Quarter ended Aug. 31, 2016
3rd Quarter ended Nov. 30, 2016
Four-month period ended Mar. 31, 2017

    High $           Low $           High US$           Low US$     
5.00 
3.90 
2.01 
1.30 
1.20 
1.21 
1.20 
1.11 

6.10    
4.20    
3.80    
3.20    
1.88    
1.79    
3.09    
2.03    

7.60    
5.50    
4.70    
4.40    
2.45    
2.25    
4.03    
2.66    

4.00    
3.50    
2.65    
1.83    
1.50    
1.66    
1.62    
1.47    

(1)

Our  common  shares  were  consolidated  on  October  15,  2015,  on  the  basis  of  one  (1)  post-consolidation  common  share  for  every  10
pre-consolidation common shares, and each fractional common share resulting from the consolidation was rounded up. The common share
price was increased proportionally to reflect the consolidation.

(c)        For the most recent six months:

            TSX-V             

    NASDAQ Stock Market      

Period
November 2016

December 2016

January 2017

February 2017

March 2017

April 2017

May 2017

    High $      
3.32    

    Low $      
1.62    

    High US$      
2.46    

    Low US$     
1.20 

2.66    

1.47    

2.32    

1.64    

1.88    

1.53    

2.12    

1.53    

1.88    

1.70    

1.83    

1.65    

2.03    

1.75    

1.48    

1.65    

1.44    

1.35    

1.11 

1.20 

1.16 

1.14 

1.24 

1.23 

The holders of common shares are entitled to vote at all meetings of our shareholders except meetings at which only holders of a
specified class or series of shares are entitled to vote. The holders of common shares are entitled to receive dividends as and when declared
by the board, if any.

No  common  shares  have  been  issued  subject  to  call  or  assessment.  There  are  no pre-emptive  or  conversion  rights  and  no
provisions  for  redemption  or  purchase  for  cancellation,  surrender,  or  sinking  or  purchase  funds.  Our  common  shares  must  be  issued  as
fully-paid and non-assessable, and are not subject to further capital calls by us. All of the common shares rank equally as to voting rights,
participation in a distribution of our assets on a liquidation, dissolution or winding-up, and the entitlement to dividends. Common shares are
transferable at the offices of our transfer agent and registrar, Computershare Trust Company of Canada, in Toronto, Ontario, Canada and
Montreal, Québec, Canada. There are no restrictions in our corporate documents on the free transferability of the common shares.

B.

Plan of Distribution

Not applicable.

C. Markets

Since March 31, 2011, the common shares have been listed on the  TSX-V under the ticker symbol APO. Since January 7, 2013,

the common shares have been listed on the NASDAQ Stock Market under the ticker symbol ACST.

D.

Selling Shareholders

Not applicable.

E. Dilution

Not applicable.

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F.

Expenses of the Issuer

Not applicable.

Item 10.

Additional Information

A.

Share Capital

Not applicable.

B. Memorandum and Articles of Association

We were incorporated on February 1, 2002 under Part 1A of the  Companies Act (Québec)  under  the  name “9113-0310 Québec
Inc”. On August 7, 2008, pursuant to a Certificate of Amendment, we changed our name to “Acasti Pharma Inc.”, our share capital, the
provisions regarding the restrictions on securities transfers and our borrowing powers. On November 7, 2008, pursuant to a Certificate of
Amendment, we further revised our provisions regarding our borrowing powers. We became a reporting issuer in Québec on November 17,
2008. On February 14, 2011, the Business Corporations Act (Québec) came into effect and replaced the Companies Act (Québec). We are
now governed by the Business Corporations Act (Québec), or the BCA.

Register, Entry Number and Purposes

Our articles of incorporation, as amended, or Articles, and general  by-laws, do not define any of our objects and purposes. In that

respect, we have no limit on the type of business we can carry out.

Directors’ Powers

Our Articles and by-laws do not contain any provision regarding: (a) a director’s power in the absence of an independent quorum,
to vote compensation to itself or any members of the committees of the board; (b) retirement or non-retirement of directors under an age
limit requirement; and (c) number of shares, if any, required for a director’s qualification.

Our by-laws provide that a director may not vote on a resolution to approve, amend or terminate a contract or transaction in which
the  director  has  any  financial  stake  that  may  reasonably  be  considered  to  influence  decision-making  or  be  present  during  deliberations
concerning  the  approval,  amendment  or  termination  of  such  a  contract  or  transaction,  unless  the  contract  or  transaction:  (a)  relates
primarily to the remuneration of the director or an associate of the director as a director of us or an affiliate of us, (b) relates primarily to the
remuneration of the director or an associate of the director as an officer, employee or mandatary of us or an affiliate of us, if we are not a
reporting issuer, (c) is for indemnity or liability insurance, or (d) is with an affiliate of us, and the sole interest of the director is as a director
or officer of the affiliate. In addition, our by-laws provide that a director must avoid placing himself or herself in any situation where his or
her personal interests would be in conflict with his obligations as a director of ours, and that a director must disclose to us any interest he or
she has in a business or association that may place him or her in a situation of conflict of interest and of any right he or she may set up
against us, indicating their nature and value, where applicable.

Our Articles  provide  that  the  board  may,  on  behalf  us,  (a)  borrow  money,  (b)  issue,  reissue,  sell  or  pledge  debt  instruments,
(c)  guarantee  the  obligations  of  a  third  party,  and  (d)  hypothecate  all  or  any  of  its  assets,  both  present  and  future,  to  guarantee  the
performance of any of our obligations.    

The quorum at every meeting of the board has been set to the minimum number of directors required under our Articles. In the
absence of a quorum, a director has no power to make any decision regarding, among other things, compensation to himself or herself or to
any member of the committees of the board.

Our by-laws  do  not  contain  any  requirements  with  respect  to  a  mandatory  retirement  age  for  our  directors  and  the  number  of

shares required for directors’ qualifications.

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Rights, Preferences and Restrictions Attaching to Each Class of Shares

Our authorized capital consists of an unlimited number of no par value common shares and an unlimited number of no par value
Class B, Class C, Class D and Class E preferred shares (collectively, the preferred shares), issuable in one or more series. As of March 31,
2017, there were:

•

•

•

•

•

•

•

  a total of 14,702,556 common shares issued and outstanding and no preferred shares issued and outstanding;

  990,726 options to purchase common shares issued and outstanding, at a weighted average exercise price of $3.49 per

common share;

  18,400,000  Series  8  public  offering  warrants  issued  in  2014  to  purchase  common  shares  issued  and  outstanding
(including 592,500 warrants held by Neptune), at an exercise price of US$1.50 per common share (10 warrants must be
exercised in order to acquire one common share);

  161,654 Series 9 private placement warrants issued in 2014 to purchase common shares issued and outstanding, at an

exercise price of $13.30 per common share;

  $2,000,000 aggregate principal amount of unsecured convertible debentures, maturing on February 21, 2020, issued in

our February 2017 private placement and contingent warrants to acquire up to 1,052,630 common shares:

○

○

○

the debentures are convertible into common shares at any time by the holder at a fixed price of $1.90 per
common share, except if we pay before the maturity all or any portion of the convertible debentures;

if  we  pay  all  or  any  portion  of  the  convertible  debentures  before  maturity,  then  warrants  become
exercisable at $1.90 per common share for the equivalent convertible debenture amount prepaid.

the  contingent  warrants  will  be  exercisable  for  the  remaining  term  of  the  convertible  debentures  for  the
same price as the conversion options;

  warrants issued in connection with our February 2017 public offering to purchase up to 1,965,259 common shares at an
exercise price of $2.15 per common share, at any time until February 21, 2022; and

  broker warrants issued in connection with our February 2017 public offering to purchase up to 234,992 common shares
at an exercise price of $2.15 per common share, at any time until February 21, 2018.

The  following  is  a  brief  description  of  the  rights,  privileges,  conditions  and  restrictions  attaching  to  the  common  shares  and

preferred shares.

Common Shares

Voting Rights

Each  common  share  entitles  its  holder  to  receive  notice  of,  and  to  attend  and  vote  at,  all  annual  or  special  meetings  of  our
shareholders. Each common share entitles its holder to one vote at any meeting of our shareholders, other than meetings at which only the
holders of a particular class or series of shares are entitled to vote due to statutory provisions or the specific attributes of this class or series.

Dividends

Subject  to  the  prior  rights  of  the  holders  of  preferred  shares  ranking  before  the  common  shares  as  to  dividends,  the  holders  of

common shares are entitled to receive dividends as declared by the board our funds that are available for the payment of dividends.

Winding-up and Dissolution

In  the  event  of  our  voluntary  or  involuntary winding-up  or  dissolution,  or  any  other  distribution  of  our  assets  among  our
shareholders for the purposes of winding up its affairs, the holders of common shares shall be entitled to receive, after payment by us to the
holders of preferred shares ranking prior to common shares regarding the distribution of our assets in the case of winding-up or dissolution,
share for share, the remainder of our property, with neither preference nor distinction. The order of priority, applicable to all classes of our
shares with respect to the redemption, liquidation, dissolution or distribution of property (the order of priority) is as follows: First, the

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Class  E non-voting  shares;  Second,  the  Class  D non-voting  shares;  Third,  the  Class  B  multiple  voting  shares  and  Class  C non-voting
shares, pari passu; and Fourth, the common shares. Notwithstanding the order of priority, shareholders of a class of shares may renounce
the order of priority by unanimous approval by all shareholders of that class of shares.

Preferred Shares

Class B Multiple Voting Shares

Each Class B multiple voting share entitles the holder thereof to 10 votes per share in all of our shareholder meetings.

Dividends. Holders of Class B multiple voting shares are entitled to receive, as and when such dividends are declared, an annual
non-cumulative  dividend  of  5%  on  the  amount  paid  for  the  said  shares,  payable  at  the  time  and  in  the  manner  which  the  directors  may
determine and subject to the order of priority.

Participation. Subject to the provisions of subsection 5.2.2 of our Articles, holders of Class B multiple voting shares do not have

the right to participate in our profits or surplus assets.

Conversion.  Holders  of  Class  B  multiple  voting  shares  have  the  right,  at  their  entire  discretion,  to  convert,  part  or  all  of  the
Class  B  multiple  voting  shares  they  hold  into  common  shares  on  the  basis  of  1  common  share  for  each  Class  B  multiple  voting  share
converted.

Redemption. Subject to the provisions of the BCA and the order of priority, holders of Class B multiple voting shares have the
right  to  demand  from  us,  upon  30  days’  written  notice,  that  we  redeem  the  Class  B  multiple  voting  shares  at  a  price  equivalent  to  the
amount paid for such shares plus the redemption premium, as defined in subsection 5.2.4.1 of the Articles, and any and all declared but yet
unpaid dividends on same.

Liquidation.  In  the  event  of  our  dissolution  or  liquidation  or  any  other  distribution  of  our  property,  the  Class  B  voting
shareholders have the right to be reimbursed for the amount paid for their Class B multiple voting shares plus the redemption premium, as
defined in subsection 5.2.4.1 of our Articles as well as the amount of any and all declared but yet unpaid dividends on their shares, subject
to the order of priority.

Class C Non-Voting Shares

Subject  to  the  provisions  of  the  BCA,  holders  of  Class  C non-voting  shares  are  neither  entitled  to  vote  at  any  meeting  of  our

shareholders, receive a notice of any such meeting, nor attend any such meeting.

Dividends.  Holders  of  Class  C non-voting  shares  are  entitled  to  receive,  as  and  when  such  dividends  are  declared,  an  annual
non-cumulative dividend of 5% on the amount paid for the said shares, plus a redemption premium as defined in subsection 5.3.6.1 of our
Articles, payable at the time and in the manner which the directors may determine and subject to the order of priority.

Participation. Subject to the provisions of subsection 5.3.2 of our Articles, holders of Class C  non-voting shares do not have the

right to participate in our profits or surplus assets.

Conversion. Holders of Class C non-voting shares have the right, at their entire discretion, to convert, part or all of the Class C

non-voting shares they hold into common shares on the basis of 1 common share for each Class C non-voting share converted.

Forced Conversion. All of our Class C non-voting shares shall automatically be converted in common shares upon the request of
an unrelated third-party investor in us investing more than $500,000, or any other amount to be determined by the board of directors in us
and  requesting  as  a  condition  to  the  investment  that  the  Class  C non-voting  shares  be  converted  into  common  shares  on  the  basis  of  1
common share for each Class C non-voting share converted.

Redemption. Subject to the provisions of the BCA and the order of priority, holders of Class C  non-voting shares have the right to
demand,  upon  30  days’  written  notice,  that  we  redeem  their  Class  C non-voting  shares  at  a  price  equivalent  to  the  amount  paid  for  the
shares plus the redemption premium, as defined in subsection 5.3.6.1 of our Articles, and any and all declared but yet unpaid dividends on
the shares.

Liquidation.  In  the  event  of  our  dissolution  or  liquidation  or  any  other  distribution  of  our  property,  Class  C  non-voting
shareholders  have  the  right  to  be  reimbursed  for  the  amount  paid  for  their  Class  C non-voting  shares  plus  the  redemption  premium,  as
defined in subsection 5.3.6.1 of our Articles, as well as the amount of any and all declared but yet unpaid dividends on their shares, subject
to the order of priority.

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Class D Non-Voting Shares

Subject  to  the  provisions  of  the  BCA,  holders  of  Class  D non-voting  shares  are  neither  entitled  to  vote  at  any  meeting  of  the

shareholders, receive a notice of any such meeting, nor attend any such meeting.

Dividends. Holders  of  Class  D non-voting  shares  are  entitled  to  receive,  as  and  when  such  dividends  are  declared,  a  monthly
non-cumulative dividend of 0.5% to 2% on the amount paid for the shares, plus a redemption premium as defined in subsection 5.4.6.1 of
our Articles, payable at the time and in the manner which the directors may determine and subject to the order of priority.

Participation. Subject to the provisions of subsection 5.4.2 of our Articles, holders of Class D  non-voting shares do not have the

right to participate in our profits or surplus assets.

Conversion. Holders  of  Class  D non-voting  shares  have  the  right,  at  their  discretion,  to  convert,  part  or  all  of  their  Class  D
non-voting  shares  into  common  shares  on  the  basis  of  a  number  of  common  shares  equal  to  the  number  of  Class  D  non-voting  shares
converted multiplied by a conversion ratio, calculated as follows:

Conversion Ratio =  

The product obtained by multiplying a factor to be agreed at the time of the issuance of the Class D  non-voting shares
by the average amount paid per share for the Class D non-voting shares plus the redemption premium per share, as
defined in subsection 5.4.6.1 of our Articles as well as the amount of any and all declared but yet paid dividends on
the shares
Fair  market  value  of  the  common  shares  at  the  date  of  any  conversion  of  Class  D  non-voting  shares  into  common
shares

Conversion All of our Class C non-voting shares automatically convert into common shares upon the request of an unrelated third
party investor in us, investing more than $500,000, or any other amount to be determined by the board of directors, in us and requesting as
a condition to the investment that the Class C non-voting shares be converted into common shares in all cases, on the basis of a number of
common shares equal to the number of Class D non-voting shares converted multiplied by the conversion ratio, calculated as follows:

Conversion Ratio =  

The product obtained by multiplying a factor to be agreed at the time of the issuance of the Class D  non-voting shares
by the average amount paid per share for the Class D non-voting shares plus the redemption premium per share, as
defined in subsection 5.4.6.1 of our Articles as well as the amount of any and all declared but yet paid dividends on
the shares
Fair  market  value  of  the  common  shares  at  the  date  of  any  conversion  of  Class  D  non-voting  shares  into  common
shares

Redemption. Subject to the provisions of the BCA and the order of priority, holders of Class D non-voting shares have the right to
demand,  upon  30  days’  written  notice,  that  we  redeem  their  Class  D non-voting  shares  at  a  price  equivalent  to  the  amount  paid  for  the
shares plus the redemption premium, as defined in subsection 5.4.6.1 of our Articles, and any and all declared but yet unpaid dividends on
the shares.

Liquidation. In  the  event  of  our  dissolution  or  liquidation  or  any  other  distribution  of  our  property,  the  Class  D  non-voting
shareholders shall have the right to be reimbursed for the amount paid for their Class D non-voting shares plus the redemption premium, as
defined in subsection 5.4.6.1 of our Articles as well as the amount of any and all declared but yet unpaid dividends on their shares, subject
to the order of priority.

Class E Non-Voting Shares

Subject  to  the  provisions  of  the  BCA,  holders  of  Class  E non-voting  shares  are  neither  entitled  to  vote  at  any  meeting  of  the

shareholders, receive a notice of any such meeting, nor attend any such meeting.

Dividends. Holders  of  Class  E non-voting  shares  are  entitled  to  receive,  as  and  when  such  dividends  are  declared,  a  monthly
non-cumulative dividend of 0.5% to 2% on the amount paid for the shares, payable at the time and in the manner which the directors may
determine and subject to the order of priority.

Participation. Subject to the provisions of subsection 5.5.2 of our Articles, holders of Class E non-voting shares do not have the

right to participate in our profits.

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Conversion.  Holders  of  Class  E non-voting  shares  have  the  right,  at  their  discretion,  to  convert,  part  or  all  of  their  Class  E
non-voting  shares  into  common  shares  on  the  basis  of  a  number  of  common  shares  equal  to  the  number  of  Class  E  non-voting  shares
converted multiplied by the conversion ratio, calculated as follows:

Conversion Ratio =

The product obtained by multiplying a factor to be agreed at the time of the issuance of the Class E non-voting shares
by the average amount paid per share for the Class E non-voting shares plus the amount of any and all declared but
yet paid dividends on the shares
Fair  market  value  of  the  common  shares  at  the  date  of  any  conversion  of  Class  E non-voting  shares  into  common
shares

Redemption. Subject to the provisions of the BCA and the order of priority, we have the right, upon 30 days’ written notice, to
redeem  the  Class  E non-voting  shares  at  a  price  equivalent  to  the  amount  paid  for  the  shares  and  any  and  all  declared  but  yet  unpaid
dividends on the shares.

Liquidation.  In  the  event  of  our  dissolution  or  liquidation  or  any  other  distribution  of  our  property,  the  Class  E  non-voting
shareholders have the right to be reimbursed for the amount paid for their Class E non-voting shares as well as the amount of any and all
declared but yet unpaid dividends on the shares, subject to the order of priority.

Procedures to Change the Rights of Shareholders

In order to change the rights attached to all classes of our shares, the vote of at least 66 2/3% of the holders of each class, must be

cast at a shareholders meeting called for amending the rights attached to our common shares or preferred shares, as the case may be.

Ordinary and Extraordinary Shareholders’ Meetings

Our by-laws provide that our annual meeting of shareholders must be held on a yearly basis on such date and on such time as may
be fixed by the board. Our by-laws provide that special meetings of shareholders may be called at any time as determined by the board. Our
shareholders are entitled to call special meetings of shareholders, provided that they hold at least 10% of the issued and outstanding shares
entitled to vote at the meeting so called. Our by-laws provide that notice of each annual and special meeting of shareholders must be sent to
the shareholders entitled to attend such meetings not less than 21 days and not more than 60 days before the date fixed for such meeting.
Our by-laws  provide  that  during  any  meeting  of  shareholders,  the  attendance,  in  person  or  by  proxy,  of  at  least  two  shareholders
representing at least 10% of the issued and outstanding shares entitled to vote at the meeting will constitute a quorum.

Limitations on Rights to Own Securities

There exists no limitation on the right to own our securities.

Impediments to Change of Control

Neither our Articles nor  by-laws contain any provision that would have an effect of delaying, deferring or preventing a change in

control of us.

Stockholder Ownership Disclosure Threshold in Bylaws

Our  Articles  and By-laws  do  not  contain  any  provision  requiring  a  shareholder  to  disclose  his  ownership  above  a  particular

threshold.

C. Material Contracts

For the two years preceding this annual report, we have not entered into any material contracts, other than contracts entered into
in the ordinary course of our business, besides the indenture relating to the warrants that we issued in connection our public offering of
units in February 2017.

D. Exchange Controls

Subject  to  the  following  paragraph,  there  is  no  law  or  governmental  decree  or  regulation  in  Canada  that  restricts  the  export  or
import of capital, or affects the remittance of dividends, interest or other payments to non-resident holders of our subordinate voting shares,
other than withholding tax requirements.

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There is no limitation imposed by Canadian law or by our Articles or our other charter documents on the right of a non-resident to
hold or vote voting shares, other than as provided by the Investment Canada Act (Canada), or Investment Canada Act, the North American
Free  Trade  Agreement  Implementation  Act  (Canada),  or  North  American  Free  Trade  Agreement,  and  the  World  Trade  Organization
Agreement Implementation Act. The Investment Canada Act requires notification and, in certain cases, advance review and approval by the
Government of Canada of an investment to establish a new Canadian business by a non-Canadian or of the acquisition by a “non-Canadian”
of “control” of a “Canadian business”, all as defined in the Investment Canada Act. Generally, the threshold for review will be higher in
monetary terms for a member of the World Trade Organization or North American Free Trade Agreement.

E.

Taxation

The following is a summary of certain U.S. federal income tax considerations to a U.S. Holder (as defined below) arising from

and relating to the acquisition, ownership, and disposition of our common shares as capital assets.

This summary provides only general information and does not purport to be a complete analysis or listing of all potential U.S.
federal income tax consequences that may apply to a U.S. Holder as a result of the acquisition, ownership, and disposition of our common
shares. In addition, this summary does not take into account the individual facts and circumstances of any particular U.S. Holder that may
affect the U.S. federal income tax consequences applicable to that U.S. Holder. Accordingly, this summary is not intended to be, and should
not be construed as, legal or U.S. federal income tax advice with respect to any U.S. Holder. Each U.S. Holder should consult its own tax
advisor  regarding  the  U.S.  federal,  U.S.  state  and  local,  and non-U.S.  tax  consequences  arising  from  or  relating  to  the  acquisition,
ownership, and disposition of our common shares.

No  legal  opinion  from  U.S.  legal  counsel  or  ruling  from  the  Internal  Revenue  Service,  or  IRS,  has  been  requested,  or  will  be
obtained, regarding the U.S. federal income tax consequences to U.S. Holders of the acquisition, ownership, and disposition of our common
shares. This summary is not binding on the IRS, and the IRS is not precluded from taking a position that is different from, and contrary to,
the  positions  taken  in  this  summary.  In  addition,  because  the  authorities  on  which  this  summary  is  based  are  subject  to  various
interpretations, the IRS and the U.S. courts could disagree with one or more of the positions taken in this summary.

Scope of this Disclosure

Authorities

This  summary  is  based  on  the  U.S.  Internal  Revenue  Code  of  1986,  as  amended,  or  the  Code,  U.S.  Treasury  Regulations
promulgated  thereunder  (whether  final,  temporary  or  proposed),  published  IRS  rulings,  judicial  decisions,  published  administrative
positions  of  the  IRS,  and  the  Convention  between  Canada  and  the  United  States  of America  with  Respect  to  Taxes  on  Income  and  on
Capital,  signed  September  26,  1980,  as  amended  (the Canada-U.S.  Tax  Treaty). Any  of  the  authorities  on  which  this  summary  is  based
could  be  changed  in  a  material  and  adverse  manner  at  any  time,  and  any  such  change  could  be  applied  on  a  retroactive  basis.  Unless
otherwise discussed, this summary does not discuss the potential effects, whether adverse or beneficial, of any proposed legislation.

U.S. Holders

For  purposes  of  this  summary,  a  “U.S.  Holder”  is  a  beneficial  owner  of  common  shares  that,  for  U.S.  federal  income  tax
purposes, is (a) an individual who is a citizen or resident of the United States, (b) a corporation, or other entity classified as a corporation
for  U.S.  federal  income  tax  purposes,  that  is  created  or  organized  in  or  under  the  laws  of  the  U.S.,  any  state  in  the  United  States  or  the
District of Columbia, (c) an estate if the income of such estate is subject to U.S. federal income tax regardless of the source of such income,
or (d) a trust if (i) such trust has validly elected to be treated as a U.S. person for U.S. federal income tax purposes or (ii) a U.S. court is able
to  exercise  primary  supervision  over  the  administration  of  such  trust  and  one  or  more  U.S.  persons  have  the  authority  to  control  all
substantial decisions of such trust.

U.S. Holders Subject to Special U.S. Federal Income Tax Rules Not Addressed

This summary does not address the U.S. federal income tax consequences applicable to U.S. Holders that are subject to special

provisions under the Code, including, but not limited to, the following U.S. Holders: (a) U.S.

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Holders  that  are tax-exempt  organizations,  qualified  retirement  plans,  individual  retirement  accounts,  or  other  tax  deferred  accounts;
(b)  U.S.  Holders  that  are  financial  institutions,  insurance  companies,  real  estate  investment  trusts,  or  regulated  investment  companies;
(c) U.S. Holders that are dealers in securities or currencies or U.S. Holders that are traders in securities that elect to apply a mark-to-market
accounting method; (d) U.S. Holders that have a “functional currency” other than the U.S. dollar; (e) U.S. Holders subject to the alternative
minimum  tax  provisions  of  the  Code;  (f)  U.S.  Holders  that  own  common  shares  as  part  of  a  straddle,  hedging  transaction,  conversion
transaction, integrated transaction, constructive sale, or other arrangement involving more than one position; (g) U.S. Holders that acquired
common  shares  through  the  exercise  of  employee  stock  options  or  otherwise  as  compensation  for  services;  (h)  U.S.  Holders  that  hold
common  shares  other  than  as  a  capital  asset  within  the  meaning  of  Section  1221  of  the  Code;  (i)  U.S.  Holders  that  beneficially  own
(directly, indirectly or by attribution) 10% or more of our voting securities or otherwise held 10% or more of our total combined voting
power; and (j) U.S. expatriates. U.S. Holders that are subject to special provisions under the Code, including U.S. Holders described above,
should consult their own tax advisor regarding the U.S. federal, U.S. federal alternative minimum, U.S. federal estate and gift, U.S. state
and local, and non-U.S. tax consequences arising from and relating to the acquisition, ownership, and disposition of the common shares.

If an entity or arrangement that is classified as a partnership for U.S. federal income tax purposes holds common shares, the U.S.
federal  income  tax  consequences  to  that  partnership  and  the  partners  of  that  partnership  generally  will  depend  on  the  activities  of  the
partnership and the status of the partners. Partners of entities that are classified as partnerships for U.S. federal income tax purposes should
consult their own tax advisors regarding the U.S. federal income tax consequences arising from and relating to the acquisition, ownership
and disposition of the common shares.

Tax Consequences Other than U.S. Federal Income Tax Consequences Not Addressed

This summary does not address the U.S. estate and gift, alternative minimum, state, local or non-U.S. tax consequences to U.S.
Holders  of  the  acquisition,  ownership,  and  disposition  of  our  common  shares.  Each  U.S.  Holder  should  consult  its  own  tax  advisor
regarding  the  U.S.  estate  and  gift,  alternative  minimum,  state,  local  and  foreign  tax  consequences  arising  from  and  relating  to  the
acquisition, ownership, and disposition of our common shares.

U.S. Federal Income Tax Considerations of the Acquisition, Ownership, and Disposition of Common Shares

Distributions on Common Shares

Subject  to  the  possible  application  of  the  passive  foreign  investment  company,  or  PFIC,  rules  described  below  (see  the  more
detailed  discussion  below  at  “—Passive  Foreign  Investment  Company  Rules”),  a  U.S.  Holder  that  receives  a  distribution,  including  a
constructive distribution or a taxable stock distribution, with respect to the common shares generally will be required to include the amount
of that distribution in gross income as a dividend (without reduction for any Canadian income tax withheld from such distribution) to the
extent  of  our  current  or  accumulated  “earnings  and  profits”  (as  computed  for  U.S.  federal  income  tax  purposes).  To  the  extent  that  a
distribution exceeds our current and accumulated “earnings and profits”, the excess amount will be treated (a) first, as a tax-free return of
capital to the extent of a U.S. Holder’s adjusted tax basis in the common shares with respect to which the distribution is made (resulting in a
corresponding reduction in the tax basis of those common shares) and, (b) thereafter, as gain from the sale or exchange of those common
shares  (see  the  more  detailed  discussion  at  “—Disposition  of  Common  Shares”  below).  We  do  not  intend  to  calculate  our  current  or
accumulated earnings and profits for U.S. federal income tax purposes and, therefore, will not be able to provide U.S. Holders with that
information. U.S. Holders should therefore assume that any distribution by us with respect to our common shares will constitute a dividend.
However, U.S. Holders should consult their own tax advisors regarding whether distributions from us should be treated as dividends for
U.S.  federal  income  tax  purposes.  Dividends  paid  on  our  common  shares  generally  will  not  be  eligible  for  the  “dividends  received
deduction” allowed to corporations under the Code with respect to dividends received from U.S. corporations.

A dividend paid by us generally will be taxed at the preferential tax rates applicable to long-term capital gains if, among other
requirements, (a) we are a “qualified foreign corporation” (as defined below), (b) the U.S. Holder receiving the dividend is an individual,
estate,  or  trust,  and  (c)  the  dividend  is  paid  on  common  shares  that  have  been  held  by  the  U.S.  Holder  for  at  least  61  days  during  the
121-day  period  beginning  60  days  before  the  “ex-dividend  date”  (i.e.,  the  first  date  that  a  purchaser  of  the  common  shares  will  not  be
entitled to receive the dividend).

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For purposes of the rules described in the preceding paragraph, we generally will be a “qualified foreign corporation”, or a QFC,
if  (a)  we  are  eligible  for  the  benefits  of  the Canada-U.S.  Tax  Treaty,  or  (b)  our  common  shares  are  readily  tradable  on  an  established
securities  market  in  the  United  States,  within  the  meaning  provided  in  the  Code.  However,  even  we  satisfy  one  or  more  of  the
requirements, we will not be treated as a QFC if we are classified as a PFIC (as discussed below) for the taxable year during which we pay
the applicable dividend or for the preceding taxable year. The dividend rules are complex, and each U.S. Holder should consult its own tax
advisor  regarding  the  application  of  those  rules  to  them  in  their  particular  circumstances.  Even  if  we  satisfy  one  or  more  of  the
requirements, as noted below, there can be no assurance that we will not become a PFIC in the future. Thus, there can be no assurance that
we will qualify as a QFC.

Disposition of Common Shares

Subject to the possible application of the PFIC rules described below (see more detailed discussion below at “—Passive Foreign
Investment Company Rules”), a U.S. Holder will recognize gain or loss on the sale or other taxable disposition of common shares (that is
treated as a sale or exchange for U.S. federal income tax purposes) equal to the difference, if any, between (a) the U.S. dollar value of the
amount  realized  on  the  date  of  the  sale  or  disposition  and  (b)  the  U.S.  Holder’s  adjusted  tax  basis  (determined  in  U.S.  dollars)  in  the
common shares sold or otherwise disposed of. Any such gain or loss generally will be capital gain or loss, which will be long-term capital
gain  or  loss  if  the  common  shares  are  held  for  more  than  one  year.  Each  U.S.  Holder  should  consult  its  own  tax  advisor  as  to  the  tax
treatment of dispositions of common shares in exchange for Canadian dollars.

Preferential tax rates apply to long-term capital gains of a U.S. Holder that is an individual, estate, or trust. There are currently no
preferential tax rates for long-term capital gains of a U.S. Holder that is a corporation. Deductions for capital losses are subject to complex
limitations.

Passive Foreign Investment Company Rules

Special, generally unfavorable, rules apply to the ownership and disposition of the stock of a PFIC. For U.S. federal income tax

purposes, a non-U.S. corporation is classified as a PFIC for each taxable year in which either:

•

•

  at least 75% of its gross income is “passive” income (referred to as the “income test”); or

  at  least  50%  of  the  average  value  of  its  assets  is  attributable  to  assets  that  produce  passive  income  or  are  held  for  the
production of passive income (referred to as the “asset test”).

Passive income includes the following types of income:

•

•

  dividends, royalties, rents, annuities, interest, and income equivalent to interest; and

  net gains from the sale or exchange of property that gives rise to dividends, interest, royalties, rents, or annuities and certain
gains from the commodities transactions.

In determining whether we are a PFIC, we will be required to take into account a pro rata portion of the income and assets of each

corporation in which we own, directly or indirectly, at least 25% by value.

We have not made a determination as to whether we were a PFIC for the 2017 taxable year(s) or whether we will be a PFIC for
the current taxable year. Accordingly, there can be no assurance that we were not a PFIC for the 2017 taxable year(s). Whether we are a
PFIC depends on complex U.S. federal income tax rules that are subject to differing interpretations and whose application to us is uncertain.
Further, since our PFIC status will depend upon the composition of our income and assets and the fair market value of our assets from time
to time (including whether we own, directly or indirectly, at least 25% by value, of the stock of any subsidiary) and generally cannot be
determined until the end of a taxable year, there can be no assurance that we will not be a PFIC for the current taxable year. In addition, we
cannot predict whether the composition of our income and assets (including income and assets held indirectly) or the fair market value of its
assets from time to time may result in it being treated as a PFIC in any future taxable year. Accordingly, no assurance can be given that we
are not a PFIC or will not become a PFIC in subsequent taxable years.

Generally, if we are or have been treated as a PFIC for any taxable year during a U.S. Holder’s holding period of common shares,
any  “excess  distribution”  with  respect  to  the  common  shares  would  be  allocated  rateably  over  the  U.S.  Holder’s  holding  period.  The
amounts allocated to the taxable year of the excess distribution and to

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any year before we became a PFIC would be taxed as ordinary income. The amount allocated to each other taxable year would be subject to
tax at the highest rate in effect for individuals or corporations in that taxable year, as appropriate, and an interest charge would be imposed
on  the  amount  allocated  to  that  taxable  year.  Distributions  made  in  respect  of  common  shares  during  a  taxable  year  will  be  excess
distributions  to  the  extent  they  exceed  125%  of  the  average  of  the  annual  distributions  on  common  shares  received  by  the  U.S.  Holder
during the preceding three taxable years or the U.S. Holder’s holding period, whichever is shorter.

Generally, if we are treated as a PFIC for any taxable year during which a U.S. Holder owns common shares, any gain on the
disposition of the common shares would be treated as an excess distribution and would be allocated rateably over the U.S. Holder’s holding
period and subject to taxation in the same manner as described in the preceding paragraph.

Certain elections may be available (including a “mark-to-market” or “qualified electing fund” election) to U.S. Holders in limited
circumstances that may mitigate the adverse consequences resulting from PFIC status, particularly if they are made in the first taxable year
during such holder’s holding period in which we are treated as a PFIC. U.S. Holders should be aware that, for each tax year, if any, that we
are  a  PFIC,  we  can  provide  no  assurances  that  we  will  make  available  to  U.S.  Holders  the  information  U.S.  Holders  require  to  make  a
“qualified electing fund” election with respect to us.

If we were were to be treated as a PFIC in any taxable year, a U.S. Holder will generally be required to file an annual report with

the IRS containing such information as the U.S. Treasury Department may require.

Each current or prospective U.S. Holder should consult its own tax advisor regarding our status as a PFIC, the possible
effect  of  the  PFIC  rules  to  such  holder  and  information  reporting  required  if  we  were  a  PFIC,  as  well  as  the  availability  of  any
election that may be available to the holder to mitigate adverse U.S. federal income tax consequences of holding shares in a PFIC.

Receipt of Foreign Currency

The  amount  of  a  distribution  paid  in  Canadian  dollars  or  Canadian  dollar  proceeds  received  on  the  sale  or  other  taxable
disposition of common shares will generally be equal to the U.S. dollar value of the currency on the date of receipt. If any Canadian dollars
received with respect to the common shares are later converted into U.S. dollars, U.S. Holders may realize gain or loss on the conversion.
Any gain or loss generally will be treated as ordinary income or loss and generally will be from sources within the United States for U.S.
foreign tax credit purposes. Each U.S. Holder should consult its own tax advisor concerning the possibility of foreign currency gain or loss
if any such currency is not converted into U.S. dollars on the date of receipt.

Foreign Tax Credit

Subject  to  certain  limitations,  a  U.S.  Holder  who  pays  (whether  directly  or  through  withholding)  Canadian  or  other  foreign
income tax with respect to the common shares may be entitled, at the election of the U.S. Holder, to receive either a deduction or a credit
for Canadian or other foreign income tax paid. Dividends paid on common shares generally will constitute income from sources outside the
United States. The foreign tax credit rules (including the limitations with respect thereto) are complex, and each U.S. Holder should consult
its own tax advisor regarding the foreign tax credit rules, having regard to such holder’s particular circumstances.

Information Reporting; Backup Withholding

Generally, information reporting and backup withholding will apply to distributions on, and the  payment  of  proceeds  from  the
sale or other taxable disposition of, the common shares unless (i) the U.S. Holder is a corporation or other exempt entity, or (ii) in the case
of backup withholding, the U.S. Holder provides a correct taxpayer identification number and certifies that the U.S. Holder is not subject to
backup withholding.

Backup  withholding  is  not  an  additional  tax. Any  amount  withheld  generally  will  be  creditable  against  a  U.S.  Holder’s  U.S.
federal income tax liability or refundable to the extent that it exceeds such liability provided the required information is provided to the IRS
in a timely manner.

In  addition,  certain  categories  of  U.S.  Holders  must  file  information  returns  with  respect  to  their  investment  in  a non-U.S.
corporation. For example, certain U.S. Holders must file IRS Form 8938 with respect to certain “specified foreign financial assets” (such as
the  common  shares)  with  an  aggregate  value  in  excess  of  US$50,000  (and,  in  some  circumstances,  a  higher  threshold).  Failure  to  do  so
could result in substantial penalties and in the extension of the statute of limitations with respect to such holder’s U.S. federal income tax
returns. Each U.S. Holder should consult its own tax advisor regarding application of the information reporting and backup withholding
rules to it in connection with an investment in our common shares.

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Medicare Contribution Tax

U.S. Holders that are individuals, estates or certain trusts generally will be subject to a 3.8% Medicare contribution tax on, among
other things, dividends on, and capital gains from the sale or other taxable disposition of, common shares, subject to certain limitations and
exceptions. Each U.S. Holder should consult its own tax advisor regarding possible application of this additional tax to income earned in
connection with an investment in our common shares.

F. Dividends and Paying Agents

Not applicable.

G.

Statement by Experts

Not applicable.

H. Documents on Display

Any statement in this annual report about any of our contracts or other documents is not necessarily complete. If the contract or
document is filed as an exhibit to this annual report, the contract or document is deemed to modify the description contained in this annual
report. You must review the exhibits themselves for a complete description of the contract or document.

Our SEC filings are available at the SEC’s website at www.sec.gov. You may also read and copy any document we file with the
SEC  at  the  public  reference  facilities  maintained  by  the  SEC  at  SEC  Headquarters,  Public  Reference  Section,  100  F  Street,  N.E.,
Washington  D.C.  20549.  You  may  obtain  information  on  the  operation  of  the  SEC’s  public  reference  facilities  by  calling  the  SEC  at
1-800-SEC-0330.  In  addition,  we  are  required  by  Canadian  securities  laws  to  file  documents  electronically  with  Canadian  securities
regulatory  authorities  and  these  filings  are  available  on  our  SEDAR  profile  at  www.sedar.com.  Requests  for  such  documents  should  be
directed to our Corporate Secretary.

I.

Subsidiary Information

Not applicable.

Item 11.

Quantitative and Qualitative Disclosure about Market Risk

Information relating to quantitative and qualitative disclosures about market risks is detailed in “Item 5. Operating and Financial
Review and Prospects”, as well as in Note 19 to our audited consolidated financial statements contained in “Item 17. Financial Statements”.

Item 12.

Description of Securities other than Equity Securities

A. Debt Securities

Not applicable.

B. Warrants and Rights

Not applicable.

C. Other Securities

Not applicable.

D. American Depositary Shares

Not applicable.

91

 
 
 
 
 
 
 
 
 
 
 
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Item 13.

Defaults, Dividend Arrearages and Delinquencies

None.

PART II

Item 14.

Material Modification to the Rights of Security Holdings and Use of Proceeds

None.

Item 15.

Controls and Procedures

Disclosure Controls and Procedures

As  of  the  end  of  the  period  covered  by  this  annual  report,  our  management,  with  the  participation  of  our  CEO  and  CFO,  has
performed  an  evaluation  of  the  effectiveness  of  our  disclosure  controls  and  procedures  within  the  meaning  of  Rules 13a-15  (e)  and
15d-15(e)  of  the  Exchange Act.  Based  upon  this  evaluation,  our  management  has  concluded  that,  as  of  March  31,  2017,  our  existing
disclosure controls and procedures were effective. It should be noted that while the CEO and CFO believe that our disclosure controls and
procedures provide a reasonable level of assurance that they are effective, they do not expect the disclosure controls and procedures to be
capable of preventing all errors and fraud. A control system, no matter how well conceived or operated, can provide only reasonable, not
absolute, assurance that the objectives of the control system are met.

Management’s Report on Internal Controls over Financial Reporting

Our management, with the participation of our CEO and CFO, is responsible for establishing and maintaining adequate internal
control  over  financial  reporting.  Our  internal  control  system  was  designed  to  provide  reasonable  assurance  regarding  the  reliability  of
financial reporting and the preparation and fair presentation of its published consolidated financial statements. All internal control systems,
no matter how well designed, have inherent limitations. Therefore, even those systems determined to be effective may not prevent or detect
misstatements and can provide only reasonable assurance with respect to financial statement preparation and presentation. Also, projections
of  any  evaluation  of  effectiveness  to  future  periods  are  subject  to  the  risk  that  controls  may  become  inadequate  because  of  changes  in
conditions, or that the degree of compliance with the policies or procedures may deteriorate. Our management conducted an assessment of
the design and operation effectiveness of our internal control over financial reporting as of March 31, 2017. In making this assessment, we
used  the  criteria  established  within  the  Internal  Control—Integrated  Framework  (2013)  issued  by  the  Committee  of  Sponsoring
Organizations of the Treadway Commission (COSO). Based on this assessment, our management has concluded that, as of March 31, 2017,
our internal control over financial reporting was effective.

Changes in Internal Control over Financial Reporting

No changes were made to our internal controls over financial reporting that occurred during the four-month period and fiscal year
ended  March  31,  2017  that  have  materially  affected,  or  are  reasonably  likely  to  materially  affect,  our  internal  controls  over  financial
reporting.

We  qualify  as  an  “emerging  growth  company”  under  Section  3(a)(80)  of  the  Exchange Act,  as  a  result  of  enactment  of  the
Jumpstart  Our  Business  Startups  Act  of  2012,  or  JOBS  Act.  Under  the  JOBS  Act,  emerging  growth  companies  are  exempt  from
Section  404(b)  of  the  Sarbanes-Oxley Act  of  2002,  which  generally  requires  that  a  public  company’s  registered  public  accounting  firm
provide an attestation report relating to management’s assessment of internal control over financial reporting. We qualify as an emerging
growth company and therefore have not included in, or incorporated by reference into, this annual report such an attestation report as of the
end of the period covered by this annual report.

Item 16.

Reserved

Item 16A. Audit Committee Financial Expert

Our  board  of  directors  has  determined  that  Mr.  Canan  is  the  “audit  committee  financial  expert”,  as  defined  by  applicable
regulations of the Commission. The Commission has indicated that the designation of Mr. Canan as an audit committee financial expert
does not make him an “expert” for any purpose, impose any duties, obligations

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or liability on Mr. Canan that are greater than those imposed on members of the audit committee and board of directors who do not carry
this designation or affect the duties, obligations or liability of any other member of the audit committee or board of directors.

Item 16B. Code of Ethics

The  board  of  directors  adopted  a  Code  of  Business  Conduct  and  Ethics  for  our  directors,  officers  and  employees  on  May  31,
2007, which can be found on SEDAR at www.sedar.com and on our web site on www.acastipharma.com. A copy of the Code of Ethics and
Conduct can also be obtained by contacting our Corporate Secretary. Any breach of the Code of Ethics must be brought to the attention of
the  board  of  directors  by  our  CEO  or  other  senior  executive  officer.  No  report  has  ever  been  filed  which  pertains  to  any  conduct  of  a
director or executive officer that constitutes a breach of the Code of Business Conduct and Ethics.

The board of directors also adopted an insider trading program for its directors, officers and employees and adopted recently a

majority voting policy for the election of proposed director candidates at our annual general shareholders meeting.

Item 16C.

Principal Accountant Fees and Services

Audit Fees

“Audit fees” consist of fees for professional services for the audit of our annual financial statements, interim reviews and limited
procedures  on  interim  financial  statements,  securities  filings  and  consultations  on  accounting  or  disclosure  issues.  KPMG  LLP,  our
external  auditors,  billed  $235,400  for  audit  fees  for  the  fiscal  year  ended  March  31,  2017  and  $77,250  for  the  fiscal  year  ended
February 29, 2016.

Audit-Related Fees

“Audit-related fees” consist of fees for professional services that are reasonably related to the performance of the audit or review
of  our  financial  statements  and  which  are  not  reported  under  “Audit  Fees”  above.  KPMG  LLP  billed  $6,550  for  the  fiscal  year  ended
March 31, 2017 and $14,675 for the fiscal year ended February 29, 2016.

Tax Fees

“Tax fees” consist of fees for professional services for tax compliance, tax advice and tax planning. KPMG LLP billed $31,600
for tax fees for fiscal year ended March 31, 2017 and $26,600 for tax fees for the fiscal year ended February 29, 2016. Tax fees include, but
are not limited to, preparation of tax returns.

All Other Fees

“Other fees” include all other fees billed for professional services other than those mentioned hereinabove. KPMG LLP billed no

fees under this category for the fiscal years ended March 31, 2017 and February 29, 2016.

Pre-Approval Policies and Procedures

The audit committee approves all audit, audit-related services, tax services and other  non-audit related services provided by the
external auditors in advance of any engagement. Under the Sarbanes-Oxley Act of 2002, audit committees are permitted to approve certain
fees for non-audit related services pursuant to a de minimus exception prior to the completion of an audit engagement. Non-audit related
services satisfy the de minimus exception if the following conditions are met:

•

•

•

  the aggregate amount of all non-audit services that were not pre-approved is reasonably expected to constitute no more than
five  per  cent  of  the  total  amount  of  fees  paid  by  us  and  our  subsidiaries  to  our  external  auditors  during  the  fiscal  year  in
which the services are provided;

  we  or  our  subsidiaries,  as  the  case  may  be,  did  not  recognize  the  services  as  non-audit  services  at  the  time  of  the
engagement; and

  the services are promptly brought to the attention of the audit committee and approved, prior to the completion of the audit,
by the audit committee or by one or more of its members to whom authority to grant such approvals had been delegated by
the audit committee.

None  of  the  services  described  above  under  “Principal Accountant  Fees  and  Services”  were  approved  by  the  audit  committee

pursuant to the de minimus exception.

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Item 16D.

Exemptions from the Listing Standards for Audit Committees

Not applicable.

Item 16E.

Purchases of Equity Securities by the Issuer and Affiliated Purchasers

Not applicable.

Item 16F.

Change in Registrant’s Certifying Accountant

None.

Item 16G. Corporation Governance

NASDAQ Marketplace Rule 5615(a)(3) permits a foreign private issuer to follow its home country practice in lieu of certain of
the requirements of the Rule 5600 Series. A foreign private issuer that follows a home country practice in lieu of one or more provisions of
the Rule 5600 Series is required to disclose in its annual report filed with the SEC, or on its website, each requirement of the Rule 5600
Series that it does not follow and describe the home country practice followed by the issuer in lieu of such NASDAQ corporate governance
requirements.  We  do  not  follow  NASDAQ  Marketplace  Rule  5620(c),  but  instead  follow  our  home  country  practice.  The  NASDAQ
minimum quorum requirement under Rule 5620(c) for a meeting of shareholders is 33.33% of the outstanding shares of common voting
stock.  Our  quorum  requirement,  as  set  forth  in  our by-laws,  is  that  a  quorum  for  a  meeting  of  our  holders  of  common  shares  is  the
attendance, in person or by proxy, of the shareholders representing 10% of our common shares. The foregoing is consistent with the laws,
customs and practices in Québec, Canada, and the rules and policies of the TSX-V.

Item 16H. Mining Safety Disclosure

Not applicable.

Item 17.

Statements

PART III

The consolidated financial statements of Acasti Pharma Inc. are located at the end of this annual report, beginning on  page F-1.

Item 18.

Financial Statements

See Item 17.

Item 19.

Exhibits

94

 
 
 
 
 
 
 
 
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Exhibit

    Number      Description of Document

EXHIBITS INDEX

  1.1

  1.2

  2.1

  2.2

Articles of Incorporation (incorporated by reference to Exhibit 4.1 from Form S-8 (File No. 333-191383) filed with the
Commission on September 25, 2013)

Amended and Restated General By-Law (incorporated by reference to Exhibit 99.1 from Form 6-K (File No. 001-35776) filed
with the Commission on February 21, 2017)

Specimen Certificate for Common Shares of Acasti Pharma Inc. (incorporated by reference to Exhibit 2.1 from Form 20-F
(File No. 001-35776) filed with the Commission on June 6, 2014)

Warrant Indenture dated December 3, 2013 between Acasti Pharma Inc. and Computershare Trust Company of Canada
(incorporated by reference to Exhibit 99.1 from Form 6-K (File No. 001-35776) filed with the Commission on December 3,
2013)

  2.3*

  Warrant Indenture dated February 21, 2017 between Acasti Pharma Inc. and Computershare Trust Company of Canada

  4.1

  4.2*

  4.3*

  11.1

Prepayment Agreement, dated December 4, 2012, between Neptune Technologies & Bioressources Inc. and Acasti Pharma
Inc. (incorporated by reference to Exhibit 99.1 from Form 6-K (File No. 001-35776) filed with the Commission on
October 29, 2013)

  Equity Incentive Plan, as amended June 8, 2017

  Stock Option Plan, as amended June 8, 2017

Code of Business Conduct and Ethics for Directors, Officers and Employees (incorporated by reference to Exhibit 99.4 from
Form 40-F (File No. 001-35776) filed with the Commission on May 30, 2013)

  12.1*

  Principal Executive Officer Certification Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

  12.2*

  Principal Financial Officer Certification Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

  13.1*

  Principal Executive Officer Certification Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

  13.2*

  Principal Financial Officer Certification Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

* Filed herewith.

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The registrant hereby certifies that it meets all of the requirements for filing on this Annual Report and that it has duly caused and

authorized the undersigned to sign this Annual Report on its behalf.

SIGNATURES

ACASTI PHARMA INC.

 /s/ Janelle D’Alvise

By:
Name: Janelle D’Alvise
Title:  Principal Executive Officer

Date: June 27, 2017

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Financial Statements of

ACASTI PHARMA INC.

For the thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended
February 29, 2016 and February 28, 2015

F-1

 
 
 
 
 
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INDEPENDENT AUDITORS’ REPORT OF REGISTERED PUBLIC ACCOUNTING FIRM

To the Shareholders of Acasti Pharma Inc.

We  have  audited  the  accompanying  financial  statements  of  Acasti  Pharma  Inc.,  which  comprise  the  statements  of  financial  position  as  at
March 31, 2017 and February 29, 2016, the statements of earnings and comprehensive loss, changes in equity and cash flows for the thirteen-month
period  ended  March  31,  2017  and  the  years  ended  February  29,  2016  and  February  28,  2015,  and  notes,  comprising  a  summary  of  significant
accounting policies and other explanatory information.

Management’s Responsibility for the Financial Statements

Management is responsible for the preparation and fair presentation of these financial statements in accordance with International Financial Reporting
Standards as issued by the International Accounting Standards Board, and for such internal control as management determines is necessary to enable the
preparation of financial statements that are free from material misstatement, whether due to fraud or error.

Auditors’ Responsibility

Our  responsibility  is  to  express  an  opinion  on  these  financial  statements  based  on  our  audits.  We  conducted  our  audits  in  accordance  with  Canadian
generally accepted auditing standards and the standards of the Public Company Accounting Oversight Board (United States). Those standards require
that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether the financial statements are free
from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected
depend on our judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In
making those risk assessments, we consider internal control relevant to the entity’s preparation and fair presentation of the financial statements in order
to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity’s
internal  control.  An  audit  also  includes  examining,  on  a  test  basis,  evidence  supporting  the  amounts  and  disclosures  in  the  financial  statements,
evaluating the appropriateness of accounting policies used and the reasonableness of accounting estimates made by management, as well as evaluating
the overall presentation of the financial statements.

We believe that the audit evidence we have obtained in our audits is sufficient and appropriate to provide a basis for our audit opinion.

Opinion

In our opinion, the financial statements present fairly, in all material respects, the financial position of Acasti Pharma Inc. as at March 31, 2017 and
February  29,  2016,  and  its  financial  performance  and  its  cash  flows  for  the  thirteen-month  period  ended  March  31,  2017  and  years  ended
February  29,  2016  and  February  28,  2015  in  accordance  with  International  Financial  Reporting  Standards  as  issued  by  the  International Accounting
Standards Board.

Other matter

The financial statements of Acasti Pharma Inc. as at February 28, 2017 and for the twelve-month and one-month periods ended February 28, 2017 and
March 31, 2017 respectively are unaudited. Accordingly, we do not express an opinion on them.

Emphasis of matter

Without qualifying our opinion, we draw attention to Note 2(c) in the financial statements which indicates that Acasti Pharma Inc. has incurred operating
losses  and  negative  cash  flows  from  operations  since  inception,  that  the  Corporation’s  current  assets  as  at  March  31,  2017  are  projected  to  be
significantly less than needed and that its future operations are dependent on obtaining additional financing and on the continued support of its parent
corporation  for  a  portion  of  its  general  and  administrative  needs.  These  conditions,  along  with  other  matters  as  set  forth  in  2(c)  in  the  financial
statements, indicate the existence of a material uncertainty that casts substantial doubt about Acasti Pharma Inc.’s ability to continue as a going concern.

/s/ KPMG LLP*

June 6, 2017

Montréal, Canada
*CPA auditor, CA, public accountancy permit No. A119178 

  KPMG LLP is a Canadian limited liability partnership and a member firm of the KPMG
  network of independent member firms affiliated with KPMG International Cooperative
  (“KPMG International”), a Swiss entity.
  KPMG Canada provides services to KPMG LLP.

F-2

 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015

Financial Statements

Statements of Financial Position

Statements of Earnings and Comprehensive Loss

Statements of Changes in Equity

Statements of Cash Flows

Notes to Financial Statements

F-3

 F-4 

 F-5 

 F-6 

 F-8 

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Table of Contents

ACASTI PHARMA INC.
Statements of Financial Position

March 31, 2017, February 28, 2017 and February 29, 2016

    (thousands of Canadian dollars)

Assets

Current assets:

Cash and cash equivalents
Short-term investments
Receivables
Prepaid expenses

Restricted short-term investment
Equipment
Intangible assets

Total assets

Liabilities and Equity

Current liabilities:

Trade and other payables
Payable to parent corporation

Derivative warrant liabilities
Unsecured convertible debentures
Total liabilities

Equity:

Share capital
Other equity
Contributed surplus
Deficit

Total equity

Commitments and contingencies

Total liabilities and equity

        March 31, 2017

February 28, 2017

February 29, 2016  

Notes

22

4

5(b)
7
8

9
5(c)

 10, 12(d)   
11

12
11

20

$   

(Unaudited)   
$   

9,772   
—   
206   
209   
10,187   

—   
2,881   
12,388   

25,456   

2,126   
12   
2,138   

209   
1,406   
3,753   

66,576   
309   
5,693   
(50,875)   

        21,703

10,573   
—   
166   
176   
10,915   

—   
2,870   
12,582   

26,367   

2,390   
15   
2,405   

187   
1,389   
3,981   

66,576   
309   
5,607   
(50,106)   

22,386   

$  

3,027 
7,443 
399 
456 
11,325 

2,000 
287 
14,905 

28,517 

1,126 
15 
1,141 

156 
— 
1,297 

61,973 
— 
4,875 
(39,628) 

27,220 

25,456   

26,367   

28,517 

    See accompanying notes to financial statements.

    On behalf of the Board:

/s/ Dr. Roderick Carter
Roderick Carter
Chair of the Board

  /s/ Jean-Marie Canan
  Jean-Marie Canan
  Director

F-4

 
  
  
   
   
  
  
   
  
  
  
  
  
  
  
  
  
 
   
 
 
 
  
  
 
 
 
  
 
   
 
 
 
  
  
   
 
 
 
  
  
 
 
 
  
 
   
 
 
 
  
 
   
 
 
 
  
 
   
 
 
 
  
  
  
  
  
  
   
 
 
 
  
  
  
  
  
  
  
  
  
 
   
 
 
 
  
 
   
 
 
 
  
  
 
 
 
  
 
 
 
  
 
   
 
 
 
  
  
   
 
 
 
  
  
  
  
  
 
   
 
 
 
  
 
   
 
 
 
  
  
 
 
 
  
  
   
 
 
 
  
  
   
 
 
  
 
   
  
  
  
  
  
  
  
  
   
 
 
 
 
 
 
 
 
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ACASTI PHARMA INC.
Statements of Earnings and Comprehensive Loss

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015

Thirteen-months

Twelve-months

   Notes   

ended    Month ended   

March 31,

March 31,

2017   

$   

2017   
(Unaudited)   
$   

February 28,

2017   
(Unaudited)   
$   

ended    Year ended    Year ended  
February 28, 
2015  

February 29,

2016   

$   

$  

    (thousands of Canadian dollars, except per share data )

Research and development expenses, net of government
assistance of $330 (March 2017 - $45 (unaudited);
February 2017- $285 (unaudited), 2016 - $349, 2015 -
$264)
General and administrative expenses
Loss from operating activities

Financial (expenses) income
Change in fair value of warrant liabilities
Net financial (expenses) income

     14      
     10      

Net loss and comprehensive loss before income tax
Deferred income tax recovery
Net loss and total comprehensive loss

(7,653)     
(3,557)     
(11,210)     

(113)     
(53)     
(166)     

(11,376)     
129     
(11,247)     

(426)     
(292)     
(718)     

(29)     
(22)     
(51)     

(769)     
—     
(769)     

(7,227)   
(3,265)   
(10,492)   

(84)   
(31)   
(115)   

(10,607)   
129   
(10,478)   

(7,566)   
(2,046)   
(9,612)   

1,094   
2,201   
3,295   

(6,317)   
—   
(6,317)   

(8,822)  
(3,573)  
(12,395)  

1,916  
8,824  
10,740  

(1,655)  
—  
(1,655)  

Basic and diluted loss per share

     16      

(1.01)     

(0.05)     

(0.97)   

(0.59)   

(0.16)  

Weighted average number of shares outstanding

11,094,512      14,702,556     

10,788,075   

  10,659,936   

  10,617,704  

    See accompanying notes to financial statements

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ACASTI PHARMA INC.
Statements of Changes in Equity

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015

    (thousands of Canadian dollars )

   Notes             

Number

Share capital

                Dollar       
$   

Other   
    equity   
$   

    Contributed   
surplus   
$   

        Deficit   
$   

        Total  
$  

Balance, February 29, 2016

 10,712,038   

61,973   

—   

—   

—   
 10,712,038   

—   

—   

—   
61,973   

—   

—   

—   

—   
—   

4,875   

(39,628)   

27,220  

—   

—   

(10,478)   

  (10,478)  

(769)   

(769)  

—   
4,875   

(11,247)   
(50,875)   

  (11,247)  
15,973  

Net loss and total comprehensive loss for
the twelve-month period (unaudited)
Net loss and total comprehensive loss for

the one-month period (unaudited)

Net loss and total comprehensive loss for

the thirteen-month period

Transactions with owners, recorded

directly in equity

Contributions by and distributions to

equity holders

Public offering
Issue of unsecured convertible

debentures, net of deferred income
tax expense of $129

Equity settled non-employee share-

based payment

Share-based payment transactions for

the twelve-month period (unaudited)

Share-based payment transactions for
the one-month period (unaudited)
Share-based payment transactions for

the thirteen-month period

Total contributions by and distributions

to equity holders for the twelve-month
period (unaudited)

Total contributions by and distributions
to equity holders for the one-month
period (unaudited)

Total contributions by and distributions
to equity holders for the thirteen-
month period

Balance at February 28, 2017

(unaudited)

Balance at March 31, 2017

12(b)

  3,930,518   

4,509   

—   

144   

—   

4,653  

11,18

12(b)

15

15

15

—   

60,000   

—   

—   

—   

—   

94   

—   

—   

—   

309   

—   

—   

—   

—   

—   

—   

588   

86   

674   

—   

—   

—   

—   

—   

309  

94  

588  

86  

674  

  3,990,518   

4,603   

309   

732   

—   

5,644  

—   

—   

—   

86   

—   

86  

  3,990,518   

4,603   

309   

818   

—   

5,730  

 14,702,556   

 14,702,556   

66,576   

66,576   

309   

309   

5,607   

5,693   

(50,106)   

(50,875)   

22,386  

21,703  

    See accompanying notes to financial statements.

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ACASTI PHARMA INC.
Statements of Changes in Equity, Continued

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015

   Notes              

Amount   

Share capital

Other   
    equity   

    Contributed   
surplus   

        Deficit   

        Total  

    (thousands of Canadian dollars)

Balance, February 28, 2015

Net loss and total comprehensive loss for the

year

Transactions with owners, recorded directly

in equity

Contributions by and distributions to equity

holders

Share-based payment transactions
Issuance of shares
Share options exercised
RSUs released
Total contributions by and distributions to

equity holders

   15
   12(c)
   15

    Dollar                   
$   

10,644,440   

61,628   

—   
10,644,440   

—   
61,628   

—   
50,000   
250   
17,348   

67,598   

—   
101   
1   
243   

345   

Balance at February 29, 2016

10,712,038   

61,973   

$   

—   

—   
—   

—   
—   
—   
—   

—   

—   

$   

$   

$  

4,911   

(33,311)   

33,228  

—   
4,911   

(6,317)   
(39,628)   

(6,317)  
26,911  

309   
(102)   
—   
(243)   

(36)   

—   
—   
—   
—   

—   

309  
(1)  
1  
—  

309  

4,875   

(39,628)   

27,220  

    (thousands of Canadian dollars)

Balance, February 28, 2014

Net loss and total comprehensive loss for the

year

Transactions with owners, recorded directly

in equity

Contributions by and distributions to equity

holders

Share-based payment transactions
Share options exercised
RSUs released
Expiration of warrants
Total contributions by and distributions to

equity holders

   15
   15

Share capital

Notes  

   Amount

    Dollar

Other   
equity   

Contributed   
surplus   

Deficit   

Total  

$   

$   

$   

$   

$  

61,027   

407   

3,502   

(31,656)   

33,280  

 10,586,258       

—   

—   
61,027   

—   
407   

—   
3,502   

(1,655)   
(33,311)   

(1,655)  
31,625  

 10,586,258       

—   
20,000   
38,182   
—   

58,182   

—   
50   
551   
—   

—   
—   
—   
(407)   

1,553   
—   
(551)   
407   

601   

(407)   

1,409   

—   
—   
—   
—   

—   

1,553  
50  
—  
—  

1,603  

Balance at February 28, 2015

10,644,440   

61,628   

—   

4,911   

(33,311)   

33,228  

    See accompanying notes to financial statements.

F-7

 
 
 
  
 
  
   
 
   
 
 
 
 
   
  
  
  
  
  
  
   
  
   
  
   
  
 
  
  
  
  
   
  
  
 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
  
  
 
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
 
 
 
 
 
 
  
 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
  
 
  
  
   
   
   
   
   
   
   
  
   
  
 
  
 
  
 
 
 
 
 
 
 
  
 
  
  
   
   
   
   
   
   
   
  
   
  
 
 
  
 
  
   
 
   
 
 
 
  
 
   
 
   
  
  
  
   
  
   
  
   
  
   
  
 
  
  
  
  
   
  
  
  
 
 
 
 
 
  
  
  
  
  
  
  
 
  
 
 
 
 
 
 
  
  
  
 
 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
  
 
 
 
 
 
 
  
  
 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
  
  
 
 
 
 
 
 
 
  
 
  
  
   
   
   
   
   
   
   
  
   
  
 
  
 
  
 
 
 
 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Statements of Cash Flows

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015

Thirteen-months ended

    Month ended

    Twelve-months
ended  

Year ended

Year ended 

   Notes

March 31,
2017  

$  

March 31,

2017  
(Unaudited)  
$  

February 28,

    February 29,

2017  

(Unaudited)     

$  

2016  

$  

    February 28, 
2015  

$  

    (11,247)    

(769)    

(10,478)    

(6,317)    

(1,655)  

    (thousands of Canadian dollars)

Cash flows used in operating activities:

Net loss for the period
Adjustments:

Depreciation of equipment
Amortization of intangible assets
Impairment loss related to intangible

assets

Stock-based compensation
Net financial expenses (income)
Realized foreign exchange gain (loss)
Deferred income tax recovery

Changes in non-cash operating items
Net cash used in operating activities

Cash flows from (used in) investing

activities:
Interest received
Acquisition of equipment
Acquisition of intangible assets
Acquisition of short-term investments
Maturity of short-term investments
Net cash (used in) investing activities

Cash flows from (used in) financing

activities:
Net proceeds from public offering
Net proceeds from private placement
Proceeds from exercise of warrants and

options

7
8

8
15
14

17

     7, 17  
8

     12(b)
    11, 12(c) 

Share issue costs
Interest paid
Net cash from (used in) financing activities

     12(d)

Foreign exchange (loss) gain on cash and
cash equivalents held in foreign currencies
Net increase (decrease) in cash and cash

equivalents

Cash and cash equivalents, beginning of

period

Cash and cash equivalents, end of period

  Cash and cash equivalents is comprised

of:
Cash
Cash equivalents

    See accompanying notes to financial statements.

221    
2,517    

—    
674    
166    
48    
(129)    
(7,750)    
792    
(6,958)    

150    
(2,527)    
—    
    (12,765)    
22,030    
6,888    

5,010    
1,872    

—    
—    
(18)    
6,864    

32    
194    

—    
86    
51    
(12)    
—    
(418)    
(328)    
(746)    

4    
(24)    
—    
—    
—    
(20)    

(34)    
(10)    

—    
—    
—    
(44)    

189    
2,323    

—    
588    
115    
60    
(129)    
(7,332)    
1,120    
(6,212)    

59    
2,336    

339    
309    
(3,295)    
36    
—    
(6,533)    
(41)    
(6,574)    

146    
(2,503)    
—    
(12,765)    
22,030    
6,908    

114    
(276)    
(92)    
(11,954)    
20,437    
8,229    

5,044    
1,882    

—    
—    
(18)    
6,908    

—    
—    

—    
(1)    
(2)    
(3)    

(49)    

9    

(58)    

64    

6,745    

(801)    

7,546    

1,716    

4  
2,331  

—  
1,553  
(10,740)  
3  
—  
(8,504)  
1,306  
(7,198)  

41  
(35)  
(51)  
(14,478)  
22,150  
7,627  

—  
—  

50  
—  
(4)  
46  

160  

635  

3,027    
9,772    

10,573    
9,772    

3,027    
10,573    

1,311    
3,027    

676  
1,311  

6,778    
2,994    

6,778    
2,994    

7,584    
2,989    

3,027    
—    

1,311  
—  

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Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

1. Reporting entity

Acasti Pharma Inc. ( Acasti or the Corporation) is incorporated under the  Business Corporations Act (Québec) (formerly Part 1A of the  Companies
Act (Québec)).  The  Corporation  is  domiciled  in  Canada  and  its  registered  office  is  located  at  545,  Promenade  du  Centropolis,  Laval,  Québec,
H7T 0A3. Neptune Technologies and Bioressources Inc. (Neptune or the parent) currently owns approximately 34% of the issued and outstanding
Class A shares ( Common Shares)  of  the  Corporation.  The  Corporation,  Neptune  and  Biodroga  Nutraceuticals  Inc.,  a  subsidiary  of  Neptune,  are
collectively referred to as the “Group”.

Pursuant to a license agreement entered into with Neptune in August 2008, as amended, Acasti has been granted an exclusive worldwide license to
use Neptune’s intellectual property to develop, clinically study and market new pharmaceutical products to treat human cardiovascular conditions.
Neptune’s intellectual property is related to the extraction of ingredients from marine biomasses, such as krill. The eventual products are aimed at
applications  in  the  prescription  drug,  over-the-counter  medicine  and  medical  foods  markets.  In  December  2012,  the  Corporation  entered  into  a
prepayment agreement with Neptune pursuant to which the Corporation exercised its option under the License Agreement to pay in advance all of
the future royalties payable under the license which was exercised in fiscal 2014. As a result of the royalty prepayment, Acasti is no longer required
to pay any royalties to Neptune under the License Agreement during its term for the use of the intellectual property under license. The license allows
Acasti to exploit the intellectual property rights in order to develop novel active pharmaceutical ingredients (“APIs”) into commercial products for
the prescription drugs and the medical food markets.

The  Corporation  is  subject  to  a  number  of  risks  associated  with  the  conduct  of  its  clinical  program  and  its  results,  the  establishment  of  strategic
alliances and the successful development of new pharmaceutical products and their marketing. The Corporation has incurred significant operating
losses and negative cash flows from operations since inception. To date, the Corporation has financed its operations through the public offering and
private placement of Common Shares and convertible debt, the proceeds from research grants and research tax credits, and the exercises of warrants,
rights and options. To achieve the objectives of its business plan, Acasti plans to raise the necessary funds through additional securities offerings and
the establishment of strategic alliances as well as additional research grants and research tax credits. The Corporation anticipates that the products
developed  by  the  Corporation  will  require  approval  from  the  U.S  Food  and  Drug Administration  and  equivalent  regulatory  organizations  in  other
countries before their sale can be authorized. The ability of the Corporation to ultimately achieve profitable operations is dependent on a number of
factors outside of the Corporation’s control.

2. Basis of preparation

(a)

Statement of compliance:

These  financial  statements  have  been  prepared  in  accordance  with  International  Financial  Reporting  Standards  (“IFRS”)  as  issued  by  the
International Accounting Standards Board (“IASB”). Beginning in fiscal 2017, the Corporation’s fiscal year end is on March 31. Fiscal 2017
is a transition year, and includes thirteen months of operations, beginning on March 1, 2016 and ending on March 31, 2017. As a result, the
above  financial  statements  and  corresponding  notes  to  financial  statements  include  two  unaudited  periods:  the  one-month  period  ended
March 31, 2017 and the twelve-month period ended February 28, 2017. The Canadian Securities regulator permits, in the transition year, the
presentation of a thirteen-month period for the financial year ended March 31, 2017.

The financial statements were approved by the Board of Directors on June 6, 2017.

(b) Basis of measurement:

The financial statements have been prepared on the historical cost basis, except for:

•

•

  Stock-based compensation which is measured pursuant to IFRS 2,  Share-based payments (Note 3(e) (ii )); and,

  Derivative warrant liabilities measured at fair value on a recurring basis  (Note 10).

F-9

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

2. Basis of preparation (continued):

(c) Going concern uncertainty:

The Corporation has incurred operating losses and negative cash flows from operations since inception. The Corporation’s current assets of
$10.2 million as at March 31, 2017 include cash and cash equivalents totalling $9.8 million, mainly generated by the net proceeds from the
Public Offering and Private Placement completed on February 21, 2017 as well as the public offering completed on December 3, 2013 and
private offering completed on February 7, 2014 (the Previous Offerings). The Corporation’s liabilities total $3.8 million at March 31, 2017
and are comprised primarily of $2.1 million in amounts due to or accrued for creditors, $1.4 million for unsecured convertible debentures and
$0.2 million for derivative warrant liabilities. The Corporation’s current assets as at this date are projected to be significantly less than needed
to support the current liabilities as at that date when combined with the projected level of expenses for the next twelve months, including not
only the preparation for, but the planned initiation of the Phase 3 clinical study program for its drug candidate, CaPre. Additional funds will
also  be  needed  for  the  expected  expenses  for  the  total  CaPre  Phase  3  research  and  development  phase  beyond  the  next  twelve  months.  In
addition  to  having  raised  additional  funds  during  the  thirteen-month  period  ended  March  31,  2017,  the  Corporation  is  working  towards
development  of  strategic  partner  relationships  and  plans  to  raise  additional  funds  in  the  future,  but  there  can  be  no  assurance  as  to  when  or
whether Acasti will complete any financing or strategic collaborations. In particular, raising financing is subject to market conditions and is not
within the Corporation’s control. Additionally, although the Corporation intends to continue to rely on the support of Neptune for a portion of
its general and administrative needs, the continuance of this support is outside of the Corporation’s control. If the Corporation does not raise
additional funds, find one or more strategic partners or does not receive the continued support from its parent, it may not be able to realize its
assets and discharge its liabilities in the normal course of business. As a result, there exists a material uncertainty that casts substantial doubt
about the Corporation’s ability to continue as a going concern and, therefore, realize its assets and discharge its liabilities in the normal course
of business. The Corporation currently has no other arranged sources of financing.

The  financial  statements  have  been  prepared  on  a  going  concern  basis,  which  assumes  the  Corporation  will  continue  its  operations  in  the
foreseeable future and will be able to realize its assets and discharge its liabilities and commitments in the ordinary course of business. These
financial statements do not include any adjustments to the carrying values and classification of assets and liabilities and reported expenses that
may be necessary if the going concern basis was not appropriate for these financial statements. If the Corporation was unable to continue as a
going concern, material write-downs to the carrying values of the Corporation’s assets, including the intangible asset, could be required.

(d)

Functional and presentation currency:

These financial statements are presented in Canadian dollars, which is the Corporation’s functional currency.

(e) Use of estimates and judgments:

The preparation of the financial statements in conformity with IFRS requires management to make judgments, estimates and assumptions that
affect the application of accounting policies and the reported amounts of assets, liabilities, income and expenses. Actual results may differ from
these estimates.

Estimates are based on management’s best knowledge of current events and actions that the Corporation may undertake in the future. Estimates
and  underlying  assumptions  are  reviewed  on  an  ongoing  basis.  Revisions  to  accounting  estimates  are  recognized  in  the  period  in  which  the
estimates are revised and in any future periods affected.

Critical judgments in applying accounting policies that have the most significant effect on the amounts recognized in the financial statements
include the following:

•

•

  Identification of triggering events indicating that the intangible assets might be impaired.

  The use of the going concern basis of preparation of the financial statements. At the end of each reporting period, management assesses

the basis of preparation of the financial statements (Note 2(c)).

F-10

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

2. Basis of preparation (continued):

(e) Use of estimates and judgments (continued):

Assumptions and estimation uncertainties that have a significant risk of resulting in a material adjustment within the next financial year include
the following:

●   Determination of the recoverable amount of the Corporation’s cash generating unit (“CGU”).

●   Measurement of derivative warrant liabilities ( note 10) and stock-based compensation ( note 15).

Also, management uses judgment to determine which research and development (“R&D”) expenses qualify for R&D tax credits and in what
amounts. The Corporation recognizes the tax credits once it has reasonable assurance that they will be realized. Recorded tax credits are subject
to review and approval by tax authorities and therefore, could be different from the amounts recorded.

3. Significant accounting policies:

The accounting policies set out below have been applied consistently to all periods presented in these financial statements.

(a)

Financial instruments:

A financial instrument is any contract that gives rise to a financial asset of one party and a financial liability or equity instrument of another
party.

(i)

Non-derivative financial assets:

The Corporation has the following non-derivative financial assets: cash, cash equivalents, short-term investments and receivables. The
Corporation  determines  the  classification  of  its  financial  assets  at  initial  recognition.  The  subsequent  measurement  of  financial  assets
depends on their classification.

Financial assets and liabilities are offset and the net amount presented in the statements of financial position when, and only when, the
Corporation has a legal right to offset the amounts and intends either to settle on a net basis or to realize the asset and settle the liability
simultaneously.

Loans and receivables

The classification “loans and receivables” comprises financial assets with fixed or determinable payments that are not quoted in an active
market. Such assets are recognized initially at fair value plus any directly attributable transaction costs. Subsequent to initial recognition,
loans and receivables are measured at amortized cost using the effective interest method, less any impairment losses.

Cash,  cash  equivalents,  short-term  investments  and  receivables  with  maturities  of  less  than  one  year  are  classified  as  loans  and
receivables.

Cash and cash equivalents comprise cash balances and highly liquid investments purchased three months or less from maturity.

(ii) Non-derivative financial liabilities:

The  Corporation  has  the  following  non-derivative  financial  liabilities:  trade  and  other  payables,  payable  to  parent  corporation  and
unsecured convertible debentures. Such financial liabilities are recognized initially at fair value plus any directly attributable transaction
costs. Subsequent to initial recognition, these financial liabilities are measured at amortized cost using the effective interest method.

The Corporation derecognizes a financial liability when its contractual obligations are discharged, cancelled or expire.

F-11

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

3. Significant accounting policies (continued):

(a)

Financial instruments (continued):

(iii) Compound financial instruments:

Compound  financial  instruments  are  instruments  that  can  be  converted  to  share  capital  at  the  option  of  the  holder,  and  the  number  of
shares to be issued is fixed.

The  unsecured  convertible  debentures  are  compound  instruments  and  have  been  separated  into  liability  and  equity  components.  The
liability  component  is  recognized  initially  at  the  fair  value  of  a  similar  liability  that  does  not  have  an  equity  conversion  option.  The
equity component is recognized initially as the difference between the fair value of the compound financial instrument as a whole and the
fair value of the liability component. Any directly attributable transaction costs are allocated to the liability and equity components in
proportion to their initial carrying amounts. Subsequent to initial recognition, the liability component of a compound financial instrument
is  measured  at  amortized  cost  using  the  effective  interest  method.  The  equity  component  of  a  compound  financial  instrument  is  not
remeasured subsequent to initial recognition.

(iv) Share capital:

Common Shares

Class A Common Shares are classified as equity. Incremental costs directly attributable to the issue of Common Shares and share options
are recognized as a deduction from share capital, net of any tax effects.

(v) Derivative financial instruments:

The  Corporation  has  issued  liability-classified  derivatives  over  its  own  equity.  Derivatives  are  recognized  initially  at  fair  value;
attributable transaction costs are recognized in profit and loss as incurred. Subsequent to initial recognition, derivatives are measured at
fair value, and all changes in their fair value are recognized immediately in profit or loss.

(vi) Other equity instruments:

Warrants,  options  and  rights  over  the  Corporation’s  equity  issued  outside  of  share-based  payment  transactions  that  do  not  meet  the
definition of a liability instrument are recognized in equity.

(b)

Equipment:

(i)

Recognition and measurement:

Equipment is measured at cost less accumulated depreciation and accumulated impairment losses, if any.

Cost includes expenditures that are directly attributable to the acquisition of the asset, including all costs incurred in bringing the asset to
its present location and condition.

Purchased software that is integral to the functionality of the related equipment is capitalized as part of that equipment.

Gains  and  losses  on  disposal  of  equipment  are  determined  by  comparing  the  proceeds  from  disposal  with  the  carrying  amount  of
equipment, and are recognized net within “other income or expenses” in profit or loss.

(ii)

Subsequent costs:

The cost of replacing a part of an equipment is recognized in the carrying amount of the item if it is probable that the future economic
benefits  embodied  within  the  part  will  flow  to  the  Corporation,  and  its  cost  can  be  measured  reliably.  The  carrying  amount  of  the
replaced part is derecognized. The costs of the day-to-day servicing of equipment are recognized in profit or loss as incurred.

F-12

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

3. Significant accounting policies (continued):

(b)

Equipment (continued):

(iii) Depreciation:

Depreciation is recognized in profit or loss on either a straight-line basis or a declining basis over the estimated useful lives of each part
of an item of equipment, since this most closely reflects the expected pattern of consumption of the future economic benefits embodied in
the asset. Items of equipment are depreciated from the date that they are available for use or, in respect of assets not yet in service, from
the date they are ready for their intended use.

The estimated useful lives and rates for the current and comparative periods are as follows:

Assets

Furniture and office equipment
Computer equipment
Laboratory equipment
Production equipment

Method  

Declining balance  
Declining balance  
Declining balance  
Straight-line  

Period/Rate

20% to 30%
30%
30%
10 years

Depreciation methods, useful lives and residual values are reviewed at each financial year-end and adjusted prospectively if appropriate.

(c)

Intangible assets:

(i)

Research and development:

Expenditure on research activities, undertaken with the prospect of gaining new scientific or technical knowledge and understanding, is
recognized in profit or loss as incurred.

Development  activities  involve  a  plan  or  design  for  the  production  of  new  or  substantially  improved  products  and  processes.
Development  expenditure  is  capitalized  only  if  development  costs  can  be  measured  reliably,  the  product  or  process  is  technically  and
commercially feasible, future economic benefits are probable, and the Corporation intends to and has sufficient resources to complete
development and to use or sell the asset. The expenditure capitalized includes the cost of materials, direct labour, overhead costs that are
directly  attributable  to  preparing  the  asset  for  its  intended  use,  and  borrowing  costs  on  qualifying  assets.  Other  development
expenditures are recognized in profit or loss as incurred.

Capitalized development expenditure is measured at cost less accumulated amortization and accumulated impairment losses. As of the
reporting periods presented, the Corporation has not capitalized any development expenditure.

(ii) Other intangible assets:

Patent costs

Patents for technologies that are no longer in the research phase are recorded at cost. Patent costs include legal fees to obtain patents and
patent application fees. When the technology is still in the research and development phase, those costs are expensed as incurred.

Licenses

Licenses  that  are  acquired  by  the  Corporation  and  have  finite  useful  lives  are  measured  at  cost  less  accumulated  amortization  and
accumulated impairment losses.

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Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

3. Significant accounting policies (continued):

(c)

Intangible assets (continued):

(iii) Subsequent expenditure:

Subsequent  expenditure  is  capitalized  only  when  it  increases  the  future  economic  benefits  embodied  in  the  specific  asset  to  which  it
relates. All  other  expenditures,  including  expenditure  on  internally  generated  goodwill  and  brands,  are  recognized  in  profit  or  loss  as
incurred.

(iv) Amortization:

Amortization is calculated over the cost of the asset less its residual value.

Amortization is recognized in profit or loss on a straight-line basis over the estimated useful lives of intangible assets from the date that
they are available for use, since this most closely reflects the expected pattern of consumption of the future economic benefits embodied
in the asset. The estimated useful lives for the current and comparative periods are as follows:

Assets

Patents
License

(d)

Impairment:

(i)

Financial assets:

Period

20 years
8 to 14 years

A financial asset not carried at fair value through profit or loss is assessed at each reporting date to determine whether there is objective
evidence that it is impaired. A financial asset is impaired if objective evidence, such as default or delinquency by a debtor, indicates that
a loss event has occurred after the initial recognition of the asset, and that the loss event had a negative effect on the estimated future
cash flows of that asset that can be estimated reliably.

An impairment loss in respect of a financial asset measured at amortized cost is calculated as the difference between its carrying amount
and the present value of the estimated future cash flows discounted at the asset’s original effective interest rate. Losses are recognized in
profit  or  loss  and  reflected  in  an  allowance  account  against  the  financial  asset.  When  a  subsequent  event  causes  the  amount  of
impairment loss to decrease, the decrease in impairment loss is reversed through profit or loss.

(ii) Non-financial assets:

The  carrying  amounts  of  the  Corporation’s  non-financial  assets  are  reviewed  at  each  reporting  date  to  determine  whether  there  is  any
indication of impairment. If any such indication exists, then the asset’s recoverable amount is estimated.

The  recoverable  amount  of  an  asset  or  cash-generating  unit  is  the  greater  of  its  value  in  use  and  its  fair  value  less  costs  to  sell.  In
assessing  value  in  use,  the  estimated  future  cash  flows  are  discounted  to  their  present  value  using  a  pre-tax  discount  rate  that  reflects
current market assessments of the time value of money and the risks specific to the asset. For the purpose of impairment testing, assets
that cannot be tested individually are grouped together into the smallest group of assets that generates cash inflows from continuing use
that are largely independent of the cash inflows of other assets or groups of assets (the “cash-generating unit, or “CGU”).

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ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

3. Significant accounting policies (continued):

(d)

Impairment (continued):

(ii) Non-financial assets (continued):

The Corporation’s corporate assets do not generate separate cash inflows. If there is an indication that a corporate asset may be impaired,
then the recoverable amount is determined for the CGU to which the corporate asset belongs.

An impairment loss is recognized if the carrying amount of an asset or its CGU exceeds its estimated recoverable amount. Impairment
losses are recognized in profit or loss.

Impairment  losses  recognized  in  prior  years  are  assessed  at  each  reporting  date  for  any  indications  that  the  loss  has  decreased  or  no
longer exists. An impairment loss is reversed if there has been a change in the estimates used to determine the recoverable amount. An
impairment loss is reversed only to the extent that the asset’s carrying amount does not exceed the carrying amount that would have been
determined, net of depreciation or amortization, if no impairment loss had been recognized.

(e)

Employee benefits:

(i)

Short-term employee benefits:

Short-term employee benefit obligations are measured on an undiscounted basis and are expensed as the related service is provided.

A liability is recognized for the amount expected to be paid under short-term cash bonus or profit-sharing plans if the Corporation has a
present legal or constructive obligation to pay this amount as a result of past service provided by the employee, and the obligation can be
estimated reliably.

(ii)

Share-based payment transactions:

The  grant  date  fair  value  of  share-based  payment  awards  granted  to  employees  is  recognized  as  an  employee  expense,  with  a
corresponding  increase  in  contributed  surplus,  over  the  period  that  the  employees  unconditionally  become  entitled  to  the  awards.  The
grant date fair value takes into consideration market performance conditions when applicable. The amount recognized as an expense is
adjusted to reflect the number of awards for which the related service and non-market vesting conditions are expected to be met, such
that the amount ultimately recognized as an expense is based on the number of awards that do meet the related service and non-market
performance conditions at the vesting date.

Share-based payment arrangements in which the Corporation receives goods or services as consideration for its own equity instruments
are  accounted  for  as  equity-settled  share-based  payment  transactions,  regardless  of  how  the  equity  instruments  are  obtained  by  the
Corporation.

(iii) Termination benefits:

Termination  benefits  are  recognized  as  an  expense  when  the  Corporation  is  committed  demonstrably,  without  realistic  possibility  of
withdrawal,  to  a  formal  detailed  plan  to  either  terminate  employment  before  the  normal  retirement  date,  or  to  provide  termination
benefits as a result of an offer made to encourage voluntary redundancy. Termination benefits for voluntary redundancies are recognized
as an expense if the Corporation has made an offer of voluntary redundancy, it is probable that the offer will be accepted, and the number
of acceptances can be estimated reliably. If benefits are payable more than 12 months after the reporting year, then they are discounted to
their present value.

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ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

3. Significant accounting policies (continued):

(f)

Provisions:

A provision is recognized if, as a result of a past event, the Corporation has a present legal or constructive obligation that can be estimated
reliably,  and  it  is  probable  that  an  outflow  of  economic  benefits  will  be  required  to  settle  the  obligation.  Provisions  are  determined  by
discounting the expected future cash flows at a pre-tax rate that reflects current market assessments of the time value of money and the risks
specific to the liability. The unwinding of the discount is recognized as finance cost.

(i)

Onerous contracts:

A provision for onerous contracts is recognized when the expected benefits to be derived by the Corporation from a contract are lower
than the unavoidable cost of meeting its obligations under the contract. The provision is measured at the present value of the lower of the
expected cost of terminating the contract and the expected net cost of continuing with the contract. Before a provision is established, the
Corporation recognizes any impairment loss on the assets associated with that contract.

(ii) Contingent liability:

A  contingent  liability  is  a  possible  obligation  that  arises  from  past  events  and  of  which  the  existence  will  be  confirmed  only  by  the
occurrence or non-occurrence of one or more uncertain future events not within the control of the Corporation; or a present obligation
that  arises  from  past  events  (and  therefore  exists),  but  is  not  recognized  because  it  is  not  probable  that  a  transfer  or  use  of  assets,
provision of services or any other transfer of economic benefits will be required to settle the obligation; or the amount of the obligation
cannot be estimated reliably.

(g) Government grants:

Government grants are recorded as a reduction of the related expense or cost of the asset acquired. Government grants are recognized when
there is reasonable assurance that the Corporation has met the requirements of the approved grant program and there is reasonable assurance
that the grant will be received.

Grants that compensate the Corporation for expenses incurred are recognized in profit or loss in reduction thereof on a systematic basis in the
same years in which the expenses are recognized. Grants that compensate the Corporation for the cost of an asset are recognized in profit or
loss on a systematic basis over the useful life of the asset.

(h)

Lease payments:

Payments  made  under  operating  leases  are  recognized  in  profit  or  loss  on  a  straight-line  basis  over  the  term  of  the  lease.  Lease  incentives
received are recognized as an integral part of the total lease expense, over the term of the lease.

(i)

Foreign currency:

Transactions in foreign currencies are translated into the functional currency at exchange rates at the dates of the transactions. Monetary assets
and liabilities denominated in foreign currencies at the reporting date are retranslated to the functional currency at the exchange rate at that
date. The foreign currency gain or loss on monetary items is the difference between amortized cost in the functional currency at the beginning
of  the  period,  adjusted  for  effective  interest  and  payments  during  the  period,  and  the  amortized  cost  in  foreign  currency  translated  at  the
exchange rate at the end of the reporting period. Foreign currency differences arising on retranslation are recognized in profit or loss.

F-16

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

3. Significant accounting policies (continued):

(j)

Finance income and finance costs:

Finance income comprises interest income on funds invested. Interest income is recognized as it accrues in profit or loss, using the effective
interest method.

Finance  costs  comprise  interest  expense  and  accretion  on  borrowings,  unwinding  of  the  discount  on  provisions  and  impairment  losses
recognized on financial assets. Borrowing costs that are not directly attributable to the acquisition, construction or production of a qualifying
asset are recognized in profit or loss using the effective interest method.

Foreign currency gains and losses are reported on a net basis.

The Corporation recognizes interest income as a component of investing activities and interest expense as a component of financing activities
in the statements of cash flows.

(k)

Income tax:

Income tax expense comprises current and deferred taxes. Current and deferred taxes are recognized in profit or loss except to the extent that
they relate to items recognized directly in equity or in other comprehensive income.

Current tax is the expected tax payable or receivable on the taxable income or loss for the year, using tax rates enacted or substantively enacted
at the reporting date, and any adjustment to tax payable in respect of previous years.

Deferred  tax  is  recognized  in  respect  of  temporary  differences  between  the  carrying  amounts  of  assets  and  liabilities  for  financial  reporting
purposes  and  the  amounts  used  for  taxation  purposes.  Deferred  tax  is  not  recognized  for  temporary  differences  arising  from  the  initial
recognition of assets or liabilities in a transaction that is not a business combination and that affects neither accounting nor taxable profit or
loss. Deferred tax is measured at the tax rates that are expected to be applied to temporary differences when they reverse, based on the laws that
have been enacted or substantively enacted by the reporting date. Deferred tax assets and liabilities are offset if there is a legally enforceable
right to offset current tax liabilities and assets, and they relate to income taxes levied by the same tax authority on the same taxable entity, or on
different tax entities, but they intend to settle current tax liabilities and assets on a net basis or their tax assets and liabilities will be realized
simultaneously. A deferred tax asset is recognized for unused tax losses, tax credits and deductible temporary differences, to the extent that it is
probable that future taxable profits will be available against which they can be utilized. Deferred tax assets are reviewed at each reporting date
and are reduced to the extent that it is no longer probable that the related tax benefit will be realized.

(l)

Earnings per share:

The  Corporation  presents  basic  and  diluted  earnings  per  share  (“EPS”)  data  for  its  Class A  shares  (or  “Common  Shares”).  Basic  EPS  is
calculated  by  dividing  the  profit  or  loss  attributable  to  the  holders  of  Class A  shares  (Common  Shares)  of  the  Corporation  by  the  weighted
average  number  of  Common  Shares  outstanding  during  the  year,  adjusted  for  own  shares  held.  Diluted  EPS  is  determined  by  adjusting  the
profit or loss attributable to the holders of Class A shares (Common Shares) and the weighted average number of Class A shares (Common
Shares) outstanding adjusted for the effects of all dilutive potential Common Shares, which comprise warrants, rights and share options granted
to employees.

(m) Segment reporting:

An  operating  segment  is  a  component  of  the  Corporation  that  engages  in  business  activities  from  which  it  may  earn  revenues  and  incur
expenses. The Corporation has one reportable operating segment: the development and commercialization of pharmaceutical applications of its
licensed rights for cardiovascular diseases. The majority of the Corporation’s assets are located in Canada, while one major production unit,
with a carrying value of $2,394, is located in France.

F-17

 
 
 
 
 
 
 
 
 
 
 
 
 
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ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

3. Significant accounting policies (continued):

(n) Change in accounting policy:

Future accounting change:

The following new standards, and amendments to standards and interpretations, are not yet effective for the period ended March 31, 2017, and
have not been applied in preparing these financial statements.

New standards and interpretations not yet adopted:

(i)

Financial instruments:

On  July  24,  2014,  the  International Accounting  Standards  Board  (IASB)  issued  the  final  version  of  IFRS  9,  Financial Instruments,  which
addresses the classification and measurement of financial assets and liabilities, impairment and hedge accounting, replacing IAS 39, Financial
Instruments: Recognition and Measurement. IFRS 9 is effective for annual periods beginning on or after January 1, 2018, with earlier adoption
permitted.  The  Corporation  intends  to  adopt  IFRS  9  in  its  financial  statements  for  the  annual  period  beginning  on  April  1,  2018.  The
Corporation has not yet assessed the impact of adoption of IFRS 9, and does not intend to early adopt IFRS 9 in its financial statements.

(ii) Amendments to IFRS 2 – Classification and Measurement of Share-Based Payment Transactions:

On June 20, 2016, the IASB issued amendments to IFRS 2,  Share-Based Payment, clarifying how to account for certain types of share-based
payment transactions. The amendments apply for annual periods beginning on or after January 1, 2018. Earlier application is permitted. As a
practical  simplification,  the  amendments  can  be  applied  prospectively.  Retrospective,  or  early  application  is  permitted  if  information  is
available  without  the  use  of  hindsight.  The  amendments  provide  requirements  on  the  accounting  for:  the  effects  of  vesting  and  non-vesting
conditions  on  the  measurement  of  cash-settled  share-based  payments;  share-based  payment  transactions  with  a  net  settlement  feature  for
withholding  tax  obligations;  and  a  modification  to  the  terms  and  conditions  of  a  share-based  payment  that  changes  the  classification  of  the
transaction from cash-settled to equity-settled. The Corporation intends to adopt the amendments to IFRS 2 in its financial statements for the
annual period beginning on April 1, 2018. The Corporation has not yet assessed the impact of adoption of the amendments of IFRS 2, and does
not intend to early adopt these amendments in its financial statements.

4. Receivables:

Sales tax receivables
Government assistance and tax credits receivable
Other receivables

March 31, 2017

February 28, 2017

February 29, 2016 

$   
89   
115   
2   
206   

(Unaudited)   
$   
83   
81   
2   
166   

$  
182  
217  
—  
399  

   Notes   

6   

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ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

5. Related parties:

(a) Administrative and research and development expenses:

The Corporation was charged by Neptune for the purchase of research supplies and for certain costs incurred by Neptune for the benefit of the
Corporation, as follows:

Thirteen-months

March 31,
2017

ended        Month ended 
March 31,
2017
(Unaudited) 
$ 

$ 

  Twelve-months
ended 
February 28,
2017
(Unaudited) 
$ 

Research and development expenses
General and administrative expenses

60 
618 
678 

1 
41 
42 

59 
577 
636 

Year ended 
      February 29,
2016

Year ended  
      February 28,  
2015  

$ 

371 
790 
1,161 

$  

344  
876  
1,220  

The Corporation purchased from the parent company research and development supplies totaling $113, of which $73 as at March 31, 2017 and
as at February 28, 2017 (unaudited) is recorded in prepaid expenses and will be expensed as used.

Where Neptune incurs specific incremental costs for the benefit of the Corporation, it charges those amounts directly. Costs that benefit more
than one entity of the Group are charged by allocating a fraction of costs incurred by Neptune that is commensurate to the estimated fraction of
services or benefits received by each entity for those items.

These  charges  do  not  represent  all  charges  incurred  by  Neptune  that  may  have  benefited  the  Corporation.  Also,  these  charges  do  not
necessarily represent the cost that the Corporation would otherwise need to incur, should it not receive these services or benefits through the
shared resources of Neptune.

(b)

Interest revenue:

On January 7, 2016 Neptune announced the acquisition of Biodroga Nutraceuticals Inc. As part of this transaction, the Corporation pledged an
amount  of  $2  million  (“Committed  Funds”)  to  partly  guarantee  the  financing  for  the  said  transaction  (“Pledge Agreement”).  Neptune  had
agreed to pay Acasti an annual fee on the Committed Funds outstanding at an annual rate of 9% during the first six months and 11% for the
remaining term of the Pledge Agreement. On September 20, 2016, Neptune fully released the pledged amount. The Corporation recognized
interest  revenue  in  the  amount  of  $89  for  the  thirteen-month  period  ended  March  31,  2017,  nil  (unaudited)  for  the  month  ended  March  31,
2017, $89 (unaudited) for the twelve-month period ended February 28, 2017 and $27 for the year ended February 29, 2016.

(c)

Payable to parent corporation:

Payable  to  parent  corporation,  primarily  for  general  and  administrative  shared  services,  has  no  specified  maturity  date  for  payment  or
reimbursement and does not bear interest.

(d) Key management personnel compensation:

The key management personnel are the officers of the Corporation, the members of the Board of Directors of the Corporation and of the parent
company. They control in the aggregate less than 2% of the voting shares of the Corporation (1% in 2016 and 2% in 2015).

F-19

 
 
 
 
 
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

5. Related parties (continued):

(d) Key management personnel compensation (continued):

Key management personnel compensation includes the following for the thirteen-month and one-month periods ended March 31, 2017, twelve-
month period ended February 28, 2017 and years ended February 29, 2016 and February 28, 2015:

Thirteen-months

March 31,
2017

ended        Month ended 
March 31,
2017
(Unaudited) 
$ 

$ 

  Twelve-months
ended 
February 28,
2017
(Unaudited) 
$ 

Short-term benefits
Severance
Share-based compensation costs

6. Government assistance:

1,311 
— 
619 
1,930 

202 
— 
78 
280 

1,109 
— 
541 
1,650 

Year ended 
      February 29,
2016

Year ended  
      February 28,  
2015  

$ 

688 
103 
120 
911 

$  

742  
175  
1,339  
2,256  

Government  assistance  is  comprised  of  a  government  grant  from  the  federal  government  and  research  and  development  investment  tax  credits
receivable  from  the  provincial  government  which  relate  to  qualifiable  research  and  development  expenditures  under  the  applicable  tax  laws.  The
amounts recorded as receivables are subject to a government tax audit and the final amounts received may differ from those recorded.
Unrecognized federal tax credits may be used to reduce future income tax and expire as follows:

     $
2029
2030
2031
2032
2033
2034
2035
2036
2037

11
30
45
431
441
436
519
286
251

2,450

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ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

7. Equipment:

Cost:
Balance at February 28, 2014
Additions
Balance at February 28, 2015
Additions
Balance at February 29, 2016
Additions for the twelve-month period (Unaudited)  
Balance at February 28, 2017 (Unaudited)
Additions for the one-month period (Unaudited)
Additions for the thirteen-month period
Balance at March 31, 2017

Accumulated depreciation:
Balance at February 28, 2014
Depreciation for the year
Balance at February 28, 2015
Depreciation for the year
Balance at February 29, 2016
Depreciation for the twelve-month period

(Unaudited)

Balance at February 28, 2017 (Unaudited)
Depreciation for the one-month period (Unaudited)  
Depreciation for thirteen-month period

Balance at March 31, 2017

Net carrying amounts:
February 29, 2016
February 28, 2017 (Unaudited)
March 31, 2017

Furniture and
office equipment   
$   

Computer
equipment   
$   

Laboratory
equipment   
$   

Production
equipment     
$     

59   
—   
59   
—   
59   
—   
59   
—   
—   
59   

45   
4   
49   
3   
52   

7   
59   
—   

7   
59   

7   
—   
—   

3   
—   
3   
—   
3   
8   
11   
—   
8   
11   

3   
—   
3   
—   
3   

1   
4   
—   

1   
4   

—   
7   
7   

25   
35   
60   
276   
336   
186   
522   
—   
186   
522   

—   
—   
—   
56   
56   

129   
185   
11   

140   
196   

280   
337   
326   

—     
—     
—     
—     
—     
2,578     
2,578     
43     
2,621     
2,621     

—     
—     
—     
—     
—     

52     
52     
21     

73     
73     

—     
2,526     
2,548     

Total   
$   

87   
35   
  122   
  276   
  398   
 2,772   
 3,170   
43   
 2,815   
 3,213   

48   
4   
52   
59   
  111   

  189   
  300   
32   

  221   
  332   

  287   
 2,870   
 2,881   

Depreciation expense for the thirteen-month and one-month periods ended March 31, 2017 and twelve-month period ended February 28, 2017 and
years ended February 29, 2016 and February 28, 2015 has been recorded in “research and development expenses” in the statements of earnings and
comprehensive loss.

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ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

8.

Intangible assets :

Cost:
Balance at February 28, 2014
Additions
Balance at February 28, 2015
Additions
Balance at February 29, 2016, February 28, 2017

(Unaudited) and March 31, 2017

Accumulated amortization:
Balance at February 28, 2014
Amortization for the year
Balance at February 28, 2015
Amortization for the year
Impairment loss
Balance at February 29, 2016
Amortization for the twelve-month period (Unaudited)
Balance at February 28, 2017 (Unaudited)
Amortization for the one-month period (Unaudited)
Amortization for the thirteen-month period
Balance at March 31, 2017

Net carrying amounts:
February 29, 2016
February 28, 2017 (Unaudited)
March 31, 2017

   Patents        
$        

License        
$        

Total   
$   

227 
51 
278 
84 

362 

1 
9 
10 
13 
339 
362 
— 
362 
— 
— 
362 

— 
— 
— 

24,330 
— 
24,330 
— 

 24,557   
51   
 24,608   
84   

24,330 

 24,692   

4,780 
2,322 
7,102 
2,323 
— 
9,425 
2,323 
11,748 
194 
2,517 
11,942 

14,905 
12,582 
12,388 

  4,781   
  2,331   
  7,112   
  2,336   
339   
  9,787   
  2,323   
 12,110   
194   
  2,517   
 12,304   

 14,905   
 12,582   
 12,388   

Amortization  expense  and  impairment  loss  for  the  thirteen-month  and  one-month  periods  ended  March  31,  2017,  the  twelve-month  period  ended
February 28, 2017 and years ended February 29, 2016 and February 28, 2015 have been recorded in “research and development expenses” in the
statements of earnings and comprehensive loss.

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ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

9. Trade and other payables:

Trade payables
Accrued liabilities and other payables
Employee salaries and benefits payable

March 31, 2017

February 28, 2017

February 29, 2016 

$   

259   
1,354   
513   
2,126   

(Unaudited)   
$   

534   
1,372   
484   
2,390   

$  

375  
543  
208  
1,126  

The Corporation’s exposure to currency and liquidity risks related to trade and other payables is presented in Note 19.

10. Derivative warrant liabilities:

Warrants issued as part of a public offering of units composed of class A share (Common Share) and Common Share purchase warrants in 2014 are
derivative  liabilities  (“Derivative  warrant  liabilities”)  for  accounting  purposes  due  to  the  currency  of  the  exercise  price  being  different  from  the
Corporation’s functional currency.

The derivative warrant liabilities are measured at fair value at each reporting period and the reconciliation of changes in fair value is presented in the
following table:

Thirteen-month period   
ended March 31, 2017

Month ended  
March 31, 2017

Twelve-month period   

ended February 28, 2017
(Unaudited)

Year ended  
February 29, 
2016 

$   

156   

53   
209   

(Unaudited)  
$  

187  

22  
209  

$   

156   

31   
187   

$  

2,357  

(2,201)  
156  

Balance – beginning of period
Change in fair value of derivative

warrant liabilities
Balance – end of period

The  fair  value  of  the  derivative  warrant  liabilities  was  estimated  using  the  Black-Scholes  option  pricing  model  and  based  on  the  following
assumptions:

Exercise price
Share price(1)
Dividend
Risk-free interest
Estimated life
Expected volatility

March 31, 2017

February 28, 2017

February 29, 2016 

US $1.50   
US $1.36   
—   
1.22%   
1.68 years   
108.35%   

(Unaudited)   

US $1.50   
US $1.25   
—   
1.24%   
1.76 years   
107.36%   

US $1.50  
US $1.50  
—  
0.87%  
2.76 years  
76.34%  

(1) In order to obtain one Common Share, 10 warrants must be exercised.

The fair value of the warrants issued was determined to be $0.11 per share issuable as at March 31, 2017 and $0.10 (unaudited) per share issuable as
at February 28, 2017 ($0.09 per share issuable as at February 29, 2016).

F-23

 
 
 
 
 
  
  
   
 
  
  
  
 
 
 
  
 
 
 
  
 
 
 
 
  
 
 
 
 
 
  
  
  
  
   
    
   
 
  
  
  
 
 
 
 
  
 
 
 
 
  
 
 
 
 
 
  
  
   
  
   
  
   
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
     
 
     
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

11. Unsecured convertible debentures

Concurrent  with  the  Public  Offering  described  in  note  12,  on  February  21,  2017,  the  Company  issued  $2,000  aggregate  principal  amount  of
unsecured  convertible  debentures  maturing  February  21,  2020  and  contingent  warrants  to  acquire  up  to  1,052,630  Common  Shares  (the  “Private
Placement”). The principal may be prepaid, in whole or in part, at any time and from time to time, in cash, at the sole discretion of the Corporation.
The debentures are convertible into Common Shares at anytime by the holder at a fixed price of $1.90 per Common Share except if the Corporation
pays before the maturity, all or any portion of the convertible debentures. Should the Corporation pay all or any portion of the convertible debenture
before  maturity,  then  warrants  become  exercisable  at  $1.90  per  Common  Share  for  the  equivalent  convertible  debenture  amount  prepaid.  The
contingent warrants will be exercisable for the remaining term of the convertible debt for the same price as the conversion options. The unsecured
convertible debentures were issued at a discount of 3.5% to the principal amount, for aggregate gross proceeds of $1,930.

The convertible debentures provide the Corporation an accelerated conversion right whereby the Corporation may, at any time at least four months
after the date of issuance of the convertible debentures, accelerate the conversion of the debentures to Common Shares in the event that the volume
weighted  average  price  of  the  Corporation’s  Common  Shares  on  the  TSX  Venture  Exchange  is  equal  to  or  exceeds  $2.65,  subject  to  customary
adjustment provisions, during 20 consecutive trading days.

The  interest  to  be  paid  on  the  convertible  debentures  under  the  terms  of  the  agreement  is  8%  per  annum,  payable  on  a  quarterly  basis  in  cash  or
Common Shares of the Corporation or a combination thereof, commencing on March 31, 2017. The decision to pay the interest due in cash or shares
is at the discretion of the Corporation and the number of Common Shares to be issued will be calculated at the current market price as at the close of
business  on  the  day  before  the  interest  payment  is  to  be  made.  Payment  in  shares  shall  be  at  a  floor  price  of  $0.10  per  share,  with  the  difference
between the amount payable and the amount computed at floor price payable in cash.

The  proceeds  of  the  Private  Placement  were  split  between  the  liability  and  the  equity  at  the  time  of  issuance  of  the  Private  Placement.  Both  the
conversion option and contingent warrants are considered the equity component of the Private Placement. The fair value of the liability component
was determined through a discounted cash flow analysis using a discount rate of 20% that was set based on a similar debt and maturity considering
the Corporation’s credit risk excluding the conversion option and contingent warrants. The amount allocated to the equity component is the residual
amount after deducting the fair value of the financial liability component from the fair value of the entire compound instrument. Subsequent to initial
recognition, the liability is measured at amortized cost calculated using the effective interest rate method and will accrete up to the principal balance
at maturity. The interest accretion is presented as a financial expense. The equity component is not re-measured. Transaction costs were allocated to
the components in proportion to their initial carrying amounts. The portion allocated to the liability was recognized as a reduction of the debt whereas
the portion allocated to other equity was recognized as a reduction to other equity.

The fair value of the liability portion at the time of issuance was determined to be $1,519 and the transaction costs and debt discount amounted to
$134, of which $30 is still unpaid as at March 31, 2017. The residual of the proceeds allocated to the equity component amounted to $481 and the
transactions costs amounted to $43, of which $10 is unpaid at March 31, 2017.

F-24

 
 
 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

11. Unsecured convertible debentures (continued):

  The split between the liability and equity component portions of the Private Placement are summarized below:

Liability component

          Equity component

    Total Private Placement  

$  

1,519  
(134)  
—  
8  
(4)  
1,389  
31  
(14)  
39  
(18)  
1,406  

$  

481  
(43)  
(129)  
—  
—  
309  
—  
—  
—  
—  
309  

$  

2,000  
(177)  
(129)  
8  
(4)  
1,698  
31  
(14)  
39  
(18)  
1,715  

Components at date of issue
Transaction costs and debt discount
Deferred income tax expense (note 18)
Effective interest for the twelve-month period (Unaudited)
Interest payable (Unaudited)
February 28, 2017 (Unaudited)
Effective interest for the one-month period (Unaudited)
Interest payable (Unaudited)
Effective interest for the thirteen-month period
Interest payable
March 31, 2017

12. Capital and other components of equity

(a)

Share capital:
Authorized capital stock:

Unlimited number of shares:

Ø   Class A shares (Common Shares), voting (one vote per share), participating and without par value

Ø   Class B shares, voting (ten votes per share), non-participating, without par value and maximum annual non-cumulative dividend
of 5% on the amount paid for said shares. Class B shares are convertible, at the holder’s discretion, into Class A shares (Common
Shares),  on  a  one-for-one  basis,  and  Class  B  shares  are  redeemable  at  the  holder’s  discretion  for  $0.80  per  share,  subject  to
certain conditions. (1)

Ø   Class  C  shares,  non-voting,  non-participating,  without  par  value  and  maximum  annual  non-cumulative  dividend  of  5%  on  the
amount paid for said shares. Class C shares are convertible, at the holder’s discretion, into Class A shares (Common Shares), on a
one-for-one basis, and Class C shares are redeemable at the holder’s discretion for $0.20 per share, subject to certain conditions.
(1)

Ø   Class D and E shares, non-voting, non-participating, without par value and maximum monthly non-cumulative dividend between
0.5% and 2% on the amount paid for said shares. Class D and E shares are convertible, at the holder’s discretion, into Class A
shares (Common Shares), on a one-for-one basis, and Class D and E shares are redeemable at the holder’s discretion, subject to
certain conditions. (1)

(1) None issued and outstanding

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Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

12. Capital and other components of equity (continued):

(b)

Public offering 2017:

Concurrent  with  the  private  placement  described  in  Note  11,  on  February  21,  2017,  the  Corporation  closed  a  public  offering  (“Public
Offering”)  issuing  3,930,518  units  of Acasti  (“Units”)  at  a  price  of  $1.45  per  Unit  for  gross  proceeds  of  $5,699.  Each  Unit  consists  of  one
class A share (Common Share) and one half of one class A or common share purchase warrant. Each whole warrant entitles the holder thereof
to purchase one common share at an exercise price of $2.15 per common share, at any time until February 21, 2022. The Units issued as part
of  the  public  offering  are  considered  equity  instruments.  The  transaction  costs  associated  with  the  Public  Offering  amounted  to  $1,190,  of
which $381 remains unpaid as at March 31, 2017 (February 28, 2017 - $416 (unaudited)). The proceeds and transaction costs were allocated to
share capital.

As part of the transaction, the Company also issued broker warrants (the “Broker Warrants”) to purchase up to 234,992 Common Shares. Each
Broker Warrant entitles the holder thereof to acquire one Common Share of the Corporation at an exercise price of $2.15 per common share, at
any  time  until  February  21,  2018.  The  broker  warrants  are  considered  for  compensation  to  non-employees  under  IFRS  2,  stock-based
compensation, and are accounted for at fair value through contributed surplus. To determine the fair value of the Broker Warrants, the Black-
Scholes pricing model was used. The total costs associated with the Broker Warrants amounted to $144 and were allocated to share capital.

The  warrants  issued  as  part  of  the  Units  of  the  Public  Offering  and  the  broker  warrants  include  an  “Acceleration  Right”,  related  to  the
Corporation’s right to accelerate the expiry date of the warrants. The Acceleration Right clause means the right of the Corporation to accelerate
the expiry date to a date that is not less than 30 days following delivery of the acceleration notice if, at any time at least four months after the
effective date, the volume weighted average trading price of the common shares equals or exceeds $2.65 for a period of 20 consecutive trading
days on the TSXV.

Furthermore, as part of the February 2017 Public Offering and convertible debt transactions, a total of 60,000 Common Shares were issued as
equity settled share-based payments for services received from an employee of the parent at a price of $1.57 per share for a total cost of $94.
The equity settled share-based payment costs have been allocated to share capital for a cost that amounted to $85 and to debt for a cost that
amounted to $9 based on relative value.

The value of the broker warrants was estimated using the Black-Scholes option pricing model and based on the following assumptions:

Exercise price
Share price
Dividend
Risk-free interest
Estimated life
Expected volatility

(c)

Issuance of shares:

Thirteen-month period ended  
March 31, 2017   

$2.15   
$1.70   
—   
0.79%   
1.00 year   
112.09%   

On February 5, 2016, 50,000 shares were issued on the settlement of a liability. An amount of $102, net of share issuance costs of $1, was
recorded in share capital.

F-26

 
 
 
 
 
 
 
  
  
  
 
  
 
  
 
  
 
  
 
  
 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

12. Capital and other components of equity (continued):

(d) Warrants:

The warrants of the Corporation are composed of the following as at March 31, 2017, February 28, 2017, February 29, 2016 and February 28,
2015:

March 31,
2017

February 28,
2017
(Unaudited)  

February 29,
2016

February 28,  
2015  

Number outstanding

   Amount  

Number
outstanding  

Amount  

Number
outstanding  

Amount  

Number
outstanding  

$     

$     

$     

Amount   
$   

18,400,000    
18,400,000    

209    18,400,000    
209    18,400,000    

187    18,400,000    
187    18,400,000    

156    18,400,000    
156    18,400,000    

2,357   
2,357   

Liability
Series 8 Public

offering Warrants
2014 (note 10) (i)

Equity
Public offering
warrants
Public offering

warrants 2017 (ii)    

1,965,259    

—     1,965,259    

—    

—    

—    

—    

—   

Series 2017-BW

Broker warrants
(iii)

Private Placement –

contingent warrants  
2017 Unsecured
convertible
debenture
conversion option
and contingent
warrants (iv)
Series 9 Private
Placement
warrants 2014 (v)    

234,992    

144    

234,992    

144    

—    

—    

—    

—   

1,052,630    

309     1,052,630    

309    

—    

—    

—    

—   

161,654    
3,414,535    

—    

161,654    
453     3,414,535    

—    
453    

161,654    
161,654    

—    
—    

161,654    
161,654    

—   
—   

(i)

In order to obtain one Common Share of the Corporation at an exercise price of US$15.00, 10 warrants must be exercised. Warrants
expire on December 3, 2018.

(ii) Warrant to acquire one Common Share of the Corporation at an exercise price of $2.15, expiring on February 21, 2022.
(iii) Warrant to acquire one Common Share of the Corporation at an exercise price of $2.15 expiring on February 21, 2018.
(iv) Warrant to acquire one Common Share of the Corporation at an exercise price of $1.90 expiring on February 21, 2020, net of deferred

tax expense of $129.

(v) Warrant to acquire one Common Share of the Corporation at an exercise price of $13.30, expiring on December 3, 2018.

F-27

 
 
 
 
 
 
 
  
 
  
  
  
  
  
  
  
  
  
  
 
  
 
  
    
  
  
  
  
 
 
 
 
 
 
 
 
   
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
   
 
   
 
 
 
 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

13. Personnel expenses:

  Salaries and other short-term employee

benefits

  Share-based compensation costs
  Severance

14. Financial (expenses) income:

  Interest income
  Foreign exchange gain
  Financial income

  Foreign exchange loss
  Interest on convertible debenture
  Other charges
  Financial expenses

  Financial (expenses) income

Thirteen-months

ended   

March 31,
2017

$   

2,483   
674   
—   
3,157   

Thirteen-months

ended   

March 31,
2017

$   

125   
—   
125   

(180)   
(39)   
(19)   
(238)   

(113)   

Month ended   
March 31,
2017

(Unaudited)   
$   

Twelve-month

period ended   
February 28,
2017

(Unaudited)   
$   

Year ended   

February 29,
2016

Year ended   
February 28,  
2015  

$   

$   

214   
86   
—   
300   

2,269   
588   
—   
2,857   

1,902   
309   
210   
2,421   

1,554   
1,553   
171   
3,278   

Month ended   
March 31,
2017

(Unaudited)   
$   

Twelve-month

period ended   
February 28,
2017

(Unaudited)   
$   

6   
—   
6   

(3)   
(31)   
(1)   
(35)   

(29)   

F-28

Year ended   

February 29,
2016

Year ended   
February 28,  
2015  

$   

73   
1,023   
1,096   

—   
—   
(2)   
(2)   

$   

87   
1,833   
1,920   

—   
—   
(4)   
(4)   

119   
—   
119   

(177)   
(8)   
(18)   
(203)   

(84)   

1,094   

1,916   

 
 
 
 
 
  
  
  
  
  
    
  
    
  
   
   
 
    
  
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
 
  
 
 
 
 
 
 
 
  
  
  
  
  
 
  
  
  
  
  
  
 
  
   
   
 
  
  
  
  
  
 
  
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
 
  
   
   
   
   
   
   
   
   
   
 
  
 
 
 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

15. Share-based payments:

At March 31, 2017, the Corporation has the following share-based payment arrangement:

(a)

Corporation stock option plan:
The Corporation has in place a stock option plan for directors, officers, employees and consultants of the Corporation. The plan provides for
the granting of options to purchase Class A shares (Common Shares). The exercise price of the stock options granted under this plan is not
lower than the closing price of the shares listed on the TSXV at the close of markets the day preceding the grant. Under this plan, the maximum
number  of  Class A  shares  (Common  Shares)  that  may  be  issued  upon  exercise  of  options  granted  under  the  plan  is  2,142,407,  representing
20%  of  the  number  of  Class A  shares  (Common  Shares)  issued  and  outstanding  as  at  February  29,  2016.  The  terms  and  conditions  for
acquiring and exercising options are set by the Corporation’s Board of Directors, subject among others, to the following limitations: the term of
the options cannot exceed ten years and every stock option granted under the stock option plan will be subject to conditions no less restrictive
than a minimum vesting period of 18 months and a gradual and equal acquisition of vesting rights not shorter than on a quarterly basis. The
total  number  of  shares  issued  to  any  one  consultant  cannot  exceed  2%  of  the  Corporation’s  total  issued  and  outstanding  shares.  The
Corporation  is  not  authorized  to  grant  such  number  of  options  under  the  stock  option  plan  that  could  result  in  a  number  of  Class A  shares
(Common  Shares)  issuable  pursuant  to  options  granted  to  (a)  related  persons  exceeding  10%  of  the  Corporation’s  issued  and  outstanding
Class A shares (Common Shares) (on a non-diluted basis) on the date an option is granted, or (b) any one eligible person in a twelve month
period  exceeding  5%  of  the  Corporation’s  issued  and  outstanding  Class A  shares  (Common  Shares)  (on  a  non-diluted  basis)  on  the  date  an
option is granted.

The following tables summarize information about activities within the stock option plan:

Outstanding at beginning of period
Granted
Forfeited
Expired
Outstanding at end of period

Exercisable at end of period

Outstanding at beginning of period
Granted
Forfeited
Expired
Outstanding at end of period

Thirteen-month period ended
March 31, 2017

Weighted average 

exercise price   

13.52       
1.69       
13.27       
15.38       
2.58       

Number of
options 
$ 

  454,151 
  1,300,400
  (190,138) 
  (139,625) 
  1,424,788 

6.44       

  238,482 

Month ended
March 31, 2017
(Unaudited)

Twelve-month period ended
February 28, 2017
(Unaudited)

Weighted average

Number of

Weighted average

exercise price   
$   

options   

exercise price   
$   

Number of
options 

2.59   
—   
11.50   
—   
2.58   

  1,427,288   
—   
(2,500)  
—   
  1,424,788   

13.52   
1.69   
13.29   
15.38   
2.59   

  454,151 
  1,300,400
  (187,638) 
  (139,625) 
  1,427,288 

Exercisable at end of period

6.44   

  238,482   

6.49   

  240,982 

F-29

 
 
 
 
 
 
 
 
  
 
 
  
 
  
 
  
  
  
 
  
 
  
 
  
 
  
 
  
 
  
 
  
  
 
  
   
 
 
  
   
 
  
 
  
  
 
 
 
  
 
 
  
 
 
 
  
 
 
 
  
 
 
 
  
 
 
  
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

15. Share-based payments (continued):

(a)

Corporation stock option plan (continued):

Outstanding at beginning of year
Granted
Exercised
Forfeited
Expired
Cancelled
Outstanding at end of year

Year ended
February 29, 2016

Year ended
February 28, 2015

Weighted average

Number of

Weighted average

exercise price   
$   

options   

exercise price   
$   

Number of
options 

15.33   
4.65   
2.50   
9.40   
18.57   
—   
13.52   

  429,625   
  109,188   
(250)  
(66,912)  
(17,500)  
—   
  454,151   

15.72   
9.51   
2.50   
14.90   
18.00   
17.50   
15.33   

  491,100 
51,250
(20,000) 
(22,725) 
(10,000) 
(60,000) 
  429,625 

Exercisable at end of year

15.28   

  375,563   

15.48   

  332,039 

The  weighted  average  of  the  fair  value  of  the  options  granted  to  employees  and  directors  of  the  Company  during  the  thirteen-month  period
ended March 31, 2017 is $1.40 and during the twelve-month period ended February 28, 2017 is $1.40 (unaudited) (2016 -$2.14 and 2015 -
$3.52). There were no options granted during the month ended March 31, 2017 and no options granted to consultants during the thirteen-month
period ended March 31, 2017 and years ended February 29, 2016 and February 28, 2015.

No options were exercised during the thirteen-month period ended March 31, 2017. The weighted average share price at the date of exercise
for share options exercised during the year ended February 29, 2016 was $4.20 (2015 - $9.20). Stock-based compensation recognized under
this  plan  for  the  thirteen-month  and  one-month  periods  ended  March  31,  2017  amounted  to  $674  and  $86  (unaudited),  respectively  and
amounted to $588 (unaudited) for the twelve-month period ended February 28, 2017 (2016 - $234 and 2015 - $526).

The  fair  value  of  options  granted  was  estimated  using  the  Black-Scholes  option  pricing  model,  resulting  in  the  following  weighted  average
assumptions for options granted during the periods ended:

  Exercise price
  Share price
  Dividend
  Risk-free interest
  Estimated life
  Expected volatility

Thirteen-month

period ended   
March 31,

2017   

$1.69   
$1.69   
—   
0.87%   
4.94 years   
123.54%   

Twelve-month

Period ended   

Year ended   

February 28, 2017

February 29, 2016

Year ended   
February 28, 2015  

(Unaudited)   

$1.69   
$1.69   
—   
0.87%   
4.94 years   
123.54%   

$4.65   
$4.65   
—   
0.66%   
4.20 years   
65.63%   

$9.51   
$9.51   
—   
1.14%   
3.00 years   
60.34%   

The expected life of the stock options is based on historical data and current expectation and is not necessarily indicative of exercise patterns
that may occur. The expected volatility reflects the assumption that the historical volatility over a period similar to the life of the options is
indicative of future trends, which may also not necessarily be the actual outcome.

F-30

 
 
 
 
 
 
 
 
  
   
 
 
  
   
 
  
 
  
  
 
 
 
  
 
 
  
 
 
 
  
 
 
 
 
  
 
 
 
 
  
 
 
 
 
  
 
 
 
 
  
 
 
  
 
 
 
 
  
 
  
   
 
  
 
 
 
 
  
 
 
 
 
  
 
 
 
 
  
 
 
 
 
  
 
 
 
 
  
 
 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

15. Share-based payments (continued):

(a)

Corporation stock option plan (continued):

The following tables summarize the status of the outstanding and exercisable options of the Corporation:

March 31, 2017

    Exercise price

$1.56 - $1.61
$1.62 - $1.82
$1.83 - $2.25
$2.26 - $5.65
$5.66 - $21.00

    Exercise price

$1.56 - $1.61
$1.62 - $1.82
$1.83 - $2.25
$2.26 - $5.65
$5.66 - $21.00

Options outstanding
Weighted
remaining
contractual life

outstanding   

Number of
options
outstanding   

6.11   
9.90   
6.16   
4.08   
0.64   

525,000   
465,000   
286,700   
79,588   
68,500   

Exercisable options
Weighed
average
exercise price

Number of
options
exercisable 

  131,250 
— 
— 
38,732 
68,500 

$   

1.56   
—   
—   
3.84   
17.26   

6.98   

  1,424,788   

6.44   

  238,482 

February 28, 2017 (Unaudited)

Options outstanding
Weighted
remaining
contractual life

Number of
options

Outstanding   

Outstanding   

6.20   
9.99   
6.25   
4.17   
0.71   

525,000   
465,000   
286,700   
79,588   
71,000   

Exercisable options
Weighed
average
exercise price

Number of
options
exercisable 

  131,250 
— 
— 
38,732 
71,000 

$   

1.56   
—   
—   
3.84   
17.06   

7.06   

  1,427,288   

6.49   

  240,982 

Share-based payment transactions and broker warrants:

The fair value of share-based payment transaction is measured using the Black-Scholes valuation model. Measurement inputs include share price on
measurement date, exercise price of the instrument, expected volatility (based on weighted average historic volatility), weighted average expected
life of the instruments (based on historical experience and general option holder behaviour unless no entity-specific information exists in which case
the average of the vesting and contractual periods is used), expected dividends, and the risk-free interest rate (based on government bonds). Service
and non-market performance conditions attached to the transactions, if any, are not taken into account in determining fair value.

b)

Corporation equity incentive plan:

The Corporation established an equity incentive plan for employees, directors and consultants. The plan provides for the issuance of restricted
share  units  (“RSU”),  performance  share  units,  restricted  shares,  deferred  share  units  and  other  share-based  awards,  subject  to  restricted
conditions as may be determined by the Board of Directors. There are no such awards outstanding as of March 31, 2017, February 28, 2017
and February 29, 2016 and no stock-based compensation was recognized for the one-month and thirteen-month periods ended March 31, 2017
and $64 for the twelve-month period ended February 29, 2016 (2015 - $466).

F-31

 
 
 
 
 
 
 
 
 
 
  
   
     
 
  
     
  
 
 
  
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
     
 
 
 
  
 
     
 
    
 
  
  
 
 
  
   
     
 
  
     
  
 
 
  
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
     
 
 
 
  
 
     
 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

16. Loss per share:

Diluted  loss  per  share  was  the  same  amount  as  basic  loss  per  share,  as  the  effect  of  options,  RSUs  and  warrants  would  have  been  anti-dilutive,
because the Corporation incurred losses in each of the periods presented. All outstanding options, RSUs and warrants could potentially be dilutive in
the future.

17. Supplemental cash flow disclosure:

(a)

Changes in non-cash operating items:

Thirteen-months

Twelve-months

  Receivables

Receivable from corporation under common

control
  Inventories
  Prepaid expenses
  Trade and other payables
  Receivable/payable to parent corporation

(b)     Non-cash transactions:

Equity settled share-based payment included
in equity ($85) and unsecured convertible
debentures ($9)

Issuance of broker warrants included in net

proceeds from public offering

Public offering transaction costs included in

trade and other payables

Reduction in share issue costs from reduction

in trade and other payables

Private Placement transaction costs included

in trade and other payables

Equipment included in trade and other

payables

Interest payable included in trade and other

payables

Issuance of shares on settlement of a liability   
Intangible assets included in trade and other

payables

Interest receivable included in payable to

parent corporation

ended   

March 31,
2017

$   

193   

—   
—   
247   
382   
(30)   
792   

Thirteen-
months
ended   

March 31,
2017

$   

94   

144   

381   

109   

40   

288   

18   
—   

—   

—   

Month ended   
March 31,
2017

(Unaudited)   
$   

(40)   

—   
—   
(33)   
(252)   
(3)   
(328)   

ended   

Year ended   

February 28,
2017

(Unaudited)   
$   

233   

—   
—   
280   
634   
(27)   
1,120   

February 29,
2016

$   

406   

50   
88   
(138)   
50   
(497)   
(41)   

Year ended 
February 28,
2015

$ 

248 

47 
174 
385 
(87) 
539 
1,306 

Month ended

Twelve-months
ended

Year ended

Year ended

March 31,
2017

(Unaudited)   
$   

February 28,
2017

(Unaudited)   
$   

February
29,
2016   
$   

February
28,
2015 
$ 

—   

—   

381   

—   

40   

288   

18   
—   

—   

—   

94   

144   

416   

109   

50   

269   

4   
—   

—   

—   

—   

—   

—   

—   

—   

—   

—   
103   

—   

27   

— 

— 

— 

— 

— 

— 

— 
— 

8 

— 

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Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

18. Income taxes:

Deferred tax (recovery) expense:

Thirteen-months

ended   

March 31,
2017

$   

Month
ended   

March 31,
2017

(Unaudited)   
$   

Twelve-months

ended   

Year ended   

February 28, 2017
(Unaudited)

February 29,
2016

Year ended 
February 28,
2015

$   

$   

$ 

2,240       

163          

2,077            

2,065   

2,221 

(2,369)   

(129)   

(163)         
—   

(2,206)   

(2,065)   

(2,221) 

(129)   

—   

— 

Thirteen-
months

ended   

March 31,
2017

$   

(11,376)   

Month
ended

Twelve-months
ended

February 28, 2017
(Unaudited)

Year ended   

February 29,
2016

Year ended 
February 28,
2015

$   

$   

$ 

(10,607)   

(6,317)   

(1,654) 

March 31,
2017

(Unaudited)   
$   

(769)       

26.87%   

(3,057)   

  26.80%      
(207)   

26.88%   

26.90%   

26.90% 

(2,850)   

(1,699)   

(445) 

2,369   
178   
14   
166   
201   
(129)   

163   
23   
6   
12   
3   
—   

2,206   
155   
8   
154   
198   
(129)   

2,065   
83   
(592)   
143   
—   
—   

2,221 
418 
(2,374) 
180 
— 
— 

  Origination and reversal of temporary

differences

Change in unrecognized deductible temporary

differences

  Deferred tax (recovery) expense

Reconciliation of effective tax rate:

  Loss before income taxes

Basic combined Canadian statutory income tax

rate 1

  Computed income tax recovery
  Increase resulting from:

Change in unrecognized deductible

temporary differences

  Non-deductible stock-based compensation   
  Non-deductible change in fair value
  Permanent differences and other
  Change in statutory income tax rate

  Total tax (recovery) expense

1 The Canadian combined statutory income tax rate has decreased due to a reduction in the provincial statutory income tax rate.

F-33

 
 
 
 
 
  
  
  
  
   
   
   
 
 
  
 
 
 
 
 
  
  
  
  
 
 
  
 
 
 
  
  
 
  
 
 
 
 
  
   
   
 
   
   
   
   
   
 
  
 
 
 
 
 
 
 
  
  
  
  
  
  
  
   
   
  
  
   
   
   
 
 
  
 
 
 
 
 
  
 
  
 
 
 
 
  
   
   
 
   
   
   
   
   
 
  
 
  
 
 
 
  
  
  
  
  
 
 
 
 
 
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
  
 
 
 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

18. Income taxes (continued):

Unrecognized deferred tax assets:

At  March  31,  2017,  February  28,  2017  and  February  29,  2016,  the  net  deferred  tax  assets,  which  have  not  been  recognized  in  these  financial
statements because the criteria for recognition of these assets were not met, were as follows:

  Deferred tax assets
  Tax losses carried forward
  Research and development expenses
  Property, plan and equipment and intangible assets
  Other deductible temporary differences
  Deferred tax assets

  Deferred tax liabilities
  Tax basis of unsecured convertible
  debentures in excess of carrying value
  Deferred tax liabilities

  Net deferred tax assets

March 31, 2017   

$   

8,293   
4,220   
435   
522   
13,470   

122   
122   

13,348   

February 28, 2017   
(Unaudited)   
$   

8,153   
4,196   
423   
539   
13,311   

126   
126   

13,185   

February 29, 2016  

$  

6,020  
3,866  
340  
388  
10,614  

—  
—  

10,614  

On  initial  recognition  of  the  unsecured  convertible  debenture  equity  component,  a  deferred  tax  liability  of  $129  was  recognized  with  the
corresponding entry recognized directly in Other equity. Consequently, an equal amount of deferred tax asset related to unrecognized tax losses was
recognized with the offsetting entry in the Corporation statement of earnings and comprehensive loss.

As at March 31, 2017 and February 28, 2017, the amounts and expiry dates of tax attributes and temporary differences, which are available to reduce
future years’ taxable income, were as follows:

March 31, 2017     

Federal     
$     

Provincial     
$     

February 28, 2017  
(Unaudited)  
Provincial  
$  

Federal     
$     

  Tax losses carried forward
  2029
  2030
  2031
  2032
  2033
  2034
  2035
  2036
  2037

714     
  1,627     
  2,071     
  2,262     
  1,854     
  3,597     
  4,595     
  5,494     
  9,109     
 31,323     

714     
1,620     
2,063     
2,241     
1,825     
3,597     
4,595     
5,494     
9,109     
31,260     

714     
  1,627     
  2,071     
  2,262     
  1,854     
  3,597     
  4,595     
  5,494     
  8,579     
 30,793     

  Research and development expenses, without time limitation

 15,436     

16,559     

 15,347     

  Other deductible temporary differences, without time limitation

  3,154     

3,154     

  3,158     

F-34

714  
1,620  
2,063  
2,241  
1,825  
3,597  
4,595  
5,494  
8,579  
30,728  

16,469  

3,158  

 
 
 
 
 
 
  
  
 
  
  
   
  
 
  
  
  
  
  
  
 
 
 
  
 
 
 
  
 
 
 
  
 
 
 
  
 
 
 
  
  
  
  
 
 
 
  
 
 
 
  
 
 
 
 
  
    
  
    
  
     
  
    
  
    
    
    
    
    
    
 
 
 
 
    
 
 
    
 
 
    
 
 
    
 
 
    
 
 
    
 
 
    
 
 
    
 
 
 
    
 
 
    
 
 
    
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
(thousands of Canadian dollars, except where noted and for share and per share amounts)

19. Financial instruments:

This note provides disclosures relating to the nature and extent of the Corporation’s exposure to risks arising from financial instruments, including
credit risk, foreign currency risk, interest rate risk and liquidity risk, and how the Corporation manages those risks.

(a)

Credit risk:

Credit risk is the risk of a loss if a customer or counterparty to a financial asset fails to meet its contractual obligations. The Corporation has
credit  risk  relating  to  cash  and  cash  equivalents  and  short-term  investments,  which  it  manages  by  dealing  only  with  highly-rated  Canadian
institutions.  The  carrying  amount  of  financial  assets,  as  disclosed  in  the  statements  of  financial  position,  represents  the  Corporation’s  credit
exposure at the reporting date.

(b) Currency risk:

The Corporation is exposed to the financial risk related to the fluctuation of foreign exchange rates and the degrees of volatility of those rates.
Foreign currency risk is limited to the portion of the Corporation’s business transactions denominated in currencies other than the Canadian
dollar. Fluctuations related to foreign exchange rates could cause unforeseen fluctuations in the Corporation’s operating results.

A portion of the expenses, mainly related to research contracts and purchase of production equipment, is incurred in US dollars and in Euros,
for  which  no  financial  hedging  is  required.  There  is  a  financial  risk  related  to  the  fluctuation  in  the  value  of  the  US  dollar  and  the  Euro  in
relation to the Canadian dollar. In order to minimize the financial risk related to the fluctuation in the value of the US dollar in relation to the
Canadian dollar, funds continue to be invested as short-term investments in the US dollar.

The following table provides an indication of the Corporation’s significant foreign exchange currency exposures as stated in Canadian dollars
at the following dates:

  Cash and cash equivalents
  Short-term investments
  Receivables
  Trade and other payables

   US$     

March 31, 2017      
Euro     

 3,524     
  —     
2     
  (503)     
 3,023     

  —     
  —     
  —     
  (317)     
  (317)     

February 28, 2017

US$     

  3,691     
  —     
3     
  (376)     
  3,318     

(Unaudited)     
Euro     

  —     
  —     
  —     
  (603)     
  (603)     

February 29, 
2016  
US$  

2,872  
7,442  
1  
(275)  
10,040  

The following exchange rates are those applicable to the following periods and dates:

March 31,

2017     

   Average     

Reporting     

Average     

February 28,

2017     
(Unaudited)     
Reporting     

February 29, 
2016  

Average     

Reporting  

  CA$ per US$
  CA$ per Euro

 1.3134     
 1.4424     

  1.3299     
  1.4251     

 1.3113     
 1.4434     

1.3281     
1.4066     

 1.3071     
 1.4393     

1.3531  
—  

F-35

 
 
 
 
 
 
 
 
 
  
  
 
  
 
  
 
  
 
 
 
  
 
 
  
 
 
  
  
  
     
  
     
  
     
  
  
  
     
  
     
  
     
  
     
  
 
  
  
 
 
  
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
(thousands of Canadian dollars, except where noted and for share and per share amounts)

19. Financial instruments (continued):

(b) Currency risk (continued):

Based on the Corporation’s foreign currency exposures noted above, varying the above foreign exchange rates to reflect a 5% strengthening of
the US dollar and Euro would have decrease in net loss as follows, assuming that all other variables remain constant:

  Decrease in net loss

March 31, 2017   

$   

139   

February 28, 2017   
(Unaudited)   
$   

151   

February 29, 2016  

$  

502 

An assumed 5% weakening of the foreign currencies would have an equal but opposite effect on the basis that all other variables remained
constant.

(c)

Interest rate risk:

Interest rate risk is the risk that the fair value or future cash flows of a financial instrument will fluctuate because of changes in market rates.

The Corporation’s exposure to interest rate risk as at March 31, 2017, February 28, 2017 and February 29, 2016 is as follows:

  Cash and cash equivalents
  Short-term investments
  Unsecured convertible debentures

 Short-term fixed interest rate  
 Short-term fixed interest rate  
 Long-term fixed interest rate  

The capacity of the Corporation to reinvest the short-term amounts with equivalent return will be impacted by variations in short-term fixed
interest rates available on the market. Management believes that the risk the Corporation will realize a loss as a result of the decline in the fair
value of its cash equivalents is limited because these investments have short-term maturities and are generally held to maturity.

(d)

Liquidity risk:

Liquidity  risk  is  the  risk  that  the  Corporation  will  not  be  able  to  meet  its  financial  obligations  as  they  fall  due.  The  Corporation  manages
liquidity risk through the management of its capital structure and financial leverage, as outlined in Note 22. It also manages liquidity risk by
continuously monitoring actual and projected cash flows. The Board of Directors reviews and approves the Corporation’s operating budgets,
and reviews material transactions outside the normal course of business. Refer to Note 2(c).

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Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
(thousands of Canadian dollars, except where noted and for share and per share amounts)

19. Financial instruments (continued):

(d)

Liquidity risk (continued):

The following are the contractual maturities of financial liabilities as at March 31, 2017, February 28, 2017 and February 29, 2016:

  Required payments per year

Total

Carrying amount

Less than 1 year

  Trade and other payables
  Payable to parent corporation
  Unsecured convertible debentures

  Notes    

   9     
   5(c)     
   11     

$  

 2,126  
12  
 2,463  
 4,601  

$  

2,126  
12  
1,406  
3,544  

$  

2,126  
12  
160  
2,298  

  Required payments per year

Total

Carrying amount

Less than 1 year

  Trade and other payables
  Payable to parent corporation
  Unsecured convertible debentures

   9     
   5(c)     
   11     

$  

 2,390  
15  
 2,480  
 4,885  

$  

2,390  
15  
1,389  
3,794  

$  

2,390  
15  
160  
2,565  

  Required payments per year

Total

Carrying amount

Less than 1 year

  Trade and other payables
  Payable to parent corporation

   9     
   5(c)     

$  

 1,126  
15  
 1,141  

$  

1,126  
15  
1,141  

$  

1,126  
15  
1,141  

March 31, 2017  
1 to 3 years 
$  

—  
—  
2,303  
2,303  

February 28, 2017 
(Unaudited)  
1 to 3 years 
$  

—  
—  
2,316  
2,316  

February 29, 2016  
1 to 3 years 
$  

—  
—  
—  

The Derivative warrant liabilities are excluded from the above tables as they will be settled in shares and not by the use of liquidities.

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Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

20. Commitments and contingencies:

Research and development agreements:

In  the  normal  course  of  business,  the  Corporation  has  signed  agreements  with  various  partners  and  suppliers  for  them  to  execute  research  and
development projects and to produce certain tools and equipment. The Corporation has reserved certain rights relating to these projects.

The  Corporation  initiated  research  and  development  projects  that  are  planned  to  be  conducted  over  the  next  12-month  period  for  a  total  cost  of
$2,169 of which an amount of $785 has been paid to date. As at March 31, 2017, an amount of $467 is included in “Trade and other payables” in
relation to these projects.

The Corporation has also entered into a contract to purchase production equipment for a total cost of $1,162 to be used in the manufacturing of the
clinical and future commercial supply of CaPre®, of which an amount of $853 has been paid to date. As at March 31, 2017, an amount of $288 is
included in “Trade and other payables” related to this equipment.

Contingencies:

A former CEO of the Corporation is claiming the payment of approximately $8.5 million and the issuance of equity instruments from the Group. As
the Corporation’s management believes that these claims are not valid, no provision has been recognized. Neptune and its subsidiaries also filed an
additional  claim  to  recover  certain  amounts  from  the  former  officer. All  outstanding  share-based  payments  held  by  the  former  CEO  have  been
cancelled during the year ended February 28, 2015.

The Corporation is also involved in other matters arising in the ordinary course of its business. Since management believes that all related claims are
not valid and it is presently not possible to determine the outcome of these matters, no provisions have been made in the financial statements for
their  ultimate  resolution  beyond  the  amounts  incurred  and  recorded  for  such  matters.  The  resolution  of  such  matters  could  have  an  effect  on  the
Corporation’s  financial  statements  in  the  year  that  a  determination  is  made,  however,  in  management’s  opinion,  the  final  resolution  of  all  such
matters is not projected to have a material adverse effect on the Corporation’s financial position.

21. Determination of fair values:

Certain of the Corporation’s accounting policies and disclosures require the determination of fair value, for both financial assets and liabilities. Fair
values have been determined for measurement and/or disclosure purposes based on the following methods.

Financial assets and liabilities:

In establishing fair value, the Corporation uses a fair value hierarchy based on levels as defined below:

•

•

•

  Level 1:  defined as observable inputs such as quoted prices in active markets.

  Level 2:  defined as inputs other than quoted prices in active markets that are either directly or indirectly observable.

  Level  3:    defined  as  inputs  that  are  based  on  little  or  no  observable  market  data,  therefore  requiring  entities  to  develop  their  own

assumptions.

The Corporation has determined that the carrying values of its short-term financial assets and liabilities approximate their fair value given the short-
term  nature  of  these  instruments.  The  fair  value  of  the  liability  component  of  the  convertible  debenture  is  determined  by  discounting  future  cash
flows  using  a  rate  that  the  Corporation  could  obtain  for  loans  with  similar  terms,  conditions  and  maturity  dates.  The  fair  value  of  this  liability  at
February 28, 2017 and March 31, 2017 has not changed from the issuance date of February 21, 2017 and was measured using level 3 inputs.

F-38

 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents

ACASTI PHARMA INC.
Notes to Financial Statements

Thirteen-month and one-month periods ended March 31, 2017, twelve-month period ended February 28, 2017 and years ended February 29, 2016 and
February 28, 2015
 (thousands of Canadian dollars, except where noted and for share and per share amounts)

21. Determination of fair values (continued):

Derivative warrant liabilities:

The Corporation measured its derivative warrant liabilities at fair value on a recurring basis. These financial liabilities were measured using a level 3
inputs (Note 10).

As at March 31, 2017, the effect of an increase or a decrease of 5% of the volatility used, which is the significant unobservable input in the fair value
estimate, would result in a loss of $49 or a gain of $44, respectively. As at February 28, 2017, the effect of an increase or a decrease of 5% of the
volatility  used,  which  is  the  significant  unobservable  input  in  the  fair  value  estimate,  would  result  in  a  loss  of  $45  (unaudited)  or  a  gain  of  $40
(unaudited), respectively.

22. Capital management:

Since inception, the Corporation’s objective in managing capital is to ensure sufficient liquidity to finance its research and development activities,
general and administrative expenses, expenses associated with intellectual property protection and its overall capital expenditures. The Corporation is
not exposed to external requirements by regulatory agencies or third parties regarding its capital, except for certain covenants included within the
convertible debentures (Note 11).

Since  the  beginning  of  its  operations,  the  Corporation  has  primarily  financed  its  liquidity  needs  from  funding  provided  through  public  offerings,
private placements, its parent corporation, from the exercise of warrants that were distributed to its parent corporation’s shareholders, from a rights
offering and from the issuance of options to employees. However, the Corporation attempts to optimize its liquidity needs with non-dilutive sources
whenever possible, including from research and development tax credits or government assistance.

The Corporation defines capital to include total shareholders’ equity, derivative warrant liabilities and unsecured convertible debentures.

The Corporation’s policy is to maintain a minimal level of debt.

The following table summarizes the cash and cash equivalents and short-term investments of the Corporation:

  Cash
  Cash equivalents
  Short-term investments

March 31, 2017

February 28, 2017

February 29, 2016 

6,778   
2,994   
—   
9,772   

(Unaudited)   

7,584   
2,989   
—   
10,573   

3,027  
—  
7,443  
10,470  

As at March 31, 2017 and February 28, 2017, cash equivalents consisting of two term deposits totaling $2,994 (US - $2,251) and $2,990 (US$2,251)
(unaudited), respectively, are being held with a Canadian financial institution having a high credit rating. The term deposits as at March 31, 2017
have maturity dates of April 11, 2017 and April 25, 2017, bearing an interest rate of 0.52% and 0.53% per annum, respectively, cashable at any time
at the discretion of the Corporation, under certain conditions. The term deposits as at February 28, 2017 have maturity dates of March 12, 2017 and
March  28,  2017,  bearing  an  interest  rate  of  0.46%  and  0.45%  per  annum,  respectively,  cashable  at  any  time  at  the  discretion  of  the  Corporation,
under certain conditions.

As at February 29, 2016, a short-term investment consisting of a term deposit totaling $7,443 (US - $5,500) was with a Canadian financial institution
having a high credit rating. The short-term investment had a maturity date of March 29, 2016, bearing an interest rate of 0.33% per annum, cashable
at any time at the discretion of the Corporation, under certain conditions.

F-39

 
 
 
 
 
 
 
  
  
   
 
  
 
 
 
  
 
 
 
  
 
 
 
 
  
 
 
 
 
Exhibit 2.3

ACASTI PHARMA INC.

as the Corporation

and

COMPUTERSHARE TRUST COMPANY OF CANADA

as the Warrant Agent

WARRANT INDENTURE
Providing for the Issue of Warrants

Dated as of February 21, 2017

 
 
 
 
TABLE OF CONTENTS

ARTICLE 1 INTERPRETATION

1.1   

1.2   

1.3   

1.4   

1.5   

1.6   

1.7   

Definitions.

Gender and Number.

Headings, Etc.

Day not a Business Day.

Time of the Essence.

Monetary References.

Applicable Law.

ARTICLE 2 ISSUE OF WARRANTS

2.1   

2.2   

2.3   

2.4   

2.5   

2.6   

2.7   

2.8   

2.9   

2.10  

2.11  

2.12  

2.13  

Creation and Issue of Warrants.

Terms of Warrants.

Warrantholder not a Shareholder.

Warrants to Rank Pari Passu.

Form of Warrants and Certificated Warrants.

Beneficial Holders of Warrants.

Warrant Certificate.

Legends.

Register of Warrants

Issue in Substitution for Warrant Certificates Lost, etc.

Exchange of Warrant Certificates.

Transfer and Ownership of Warrants.

Cancellation of Surrendered Warrants.

ARTICLE 3 EXERCISE OF WARRANTS

3.1   

3.2   

3.3   

3.4   

3.5   

3.6   

3.7   

3.8   

Right of Exercise.

Warrant Exercise.

Securities Restrictions.

Prohibition on Exercise by U.S. Persons; Legended Certificates

Transfer Fees and Taxes.

Warrant Agency.

Effect of Exercise of Warrant Certificates.

Partial Exercise of Warrants; Fractions.

    2 

    2 

    6 

    6 

    6 

    6 

    6 

    6 

    7 

    7 

    7 

    7 

    8 

    8 

    8 

   10 

   11 

   13 

   14 

   15 

   15 

   16 

   16 

   16 

   17 

   19 

   20 

   21 

   21 

   22 

   22 

 
- 2 -

3.9   

3.10  

Expiration of Warrants.

Accounting and Recording.

ARTICLE 4 ADJUSTMENT OF NUMBER OF COMMON SHARES AND EXERCISE PRICE

4.1   

4.2   

4.3   

4.4   

4.5   

4.6   

4.7   

4.8   

4.9   

4.10  

4.11  

Adjustment of Number of Common Shares and Exercise Price.

Entitlement to Common Shares on Exercise of Warrant.

No Adjustment for Certain Transactions.

Determination by Independent Firm.

Proceedings Prior to any Action Requiring Adjustment.

Certificate of Adjustment.

Notice of Special Matters.

No Action after Notice.

Other Action.

Protection of Warrant Agent.

Participation by Warrantholder.

ARTICLE 5 RIGHTS OF THE CORPORATION AND COVENANTS

5.1   

5.2   

5.3   

5.4   

5.5   

Optional Purchases by the Corporation.

General Covenants.

Warrant Agent’s Remuneration and Expenses.

Performance of Covenants by Warrant Agent.

Enforceability of Warrants.

ARTICLE 6 ENFORCEMENT

6.1   

6.2   

6.3   

6.4   

Suits by Registered Warrantholders.

Suits by the Corporation.

Immunity of Shareholders, etc.

Waiver of Default.

ARTICLE 7 MEETINGS OF REGISTERED WARRANTHOLDERS

7.1   

7.2   

7.3   

7.4   

7.5   

7.6   

Right to Convene Meetings.

Notice.

Chairman.

Quorum.

Power to Adjourn.

Show of Hands.

   23 

   23 

   23 

   23 

   27 

   27 

   28 

   28 

   28 

   28 

   28 

   29 

   29 

   29 

   30 

   30 

   30 

   31 

   31 

   31 

   32 

   32 

   32 

   32 

   32 

   33 

   33 

   33 

   33 

   33 

   34 

   34 

 
 
- 3 -

Poll and Voting.

Regulations.

Corporation and Warrant Agent May be Represented.

Powers Exercisable by Extraordinary Resolution.

Meaning of Extraordinary Resolution.

Powers Cumulative.

Minutes.

Instruments in Writing.

Binding Effect of Resolutions.

Holdings by Corporation Disregarded.

7.7   

7.8   

7.9   

7.10  

7.11  

7.12  

7.13  

7.14  

7.15  

7.16  

ARTICLE 8 SUPPLEMENTAL INDENTURES

8.1   

8.2   

Provision for Supplemental Indentures for Certain Purposes.

Successor Entities.

ARTICLE 9 CONCERNING THE WARRANT AGENT

9.1   

9.2   

9.3   

9.4   

9.5   

9.6   

9.7   

9.8   

9.9   

9.10  

9.11  

9.12  

9.13  

9.14  

9.15  

Trust Indenture Legislation.

Rights and Duties of Warrant Agent.

Evidence, Experts and Advisers.

Documents, Monies, etc. Held by Warrant Agent.

Actions by Warrant Agent to Protect Interest.

Warrant Agent Not Required to Give Security.

Protection of Warrant Agent.

Replacement of Warrant Agent; Successor by Merger.

Conflict of Interest.

Acceptance of Agency.

Warrant Agent Not to be Appointed Receiver.

Warrant Agent Not Required to Give Notice of Default.

Anti-Money Laundering.

Compliance with Privacy Code.

Securities Exchange Commission Certification.

ARTICLE 10 GENERAL

10.1  

10.2  

10.3  

Notice to the Corporation and the Warrant Agent.

Notice to Registered Warrantholders.

Ownership of Warrants.

   34 

   34 

   35 

   35 

   36 

   37 

   37 

   37 

   37 

   37 

   38 

   38 

   39 

   39 

   39 

   39 

   40 

   41 

   41 

   41 

   42 

   43 

   43 

   44 

   44 

   44 

   44 

   45 

   45 

   46 

   46 

   46 

   47 

 
 
- 4 -

Counterparts.

Satisfaction and Discharge of Indenture.

Provisions of Indenture and Warrants for the Sole Benefit of Parties and Registered
Warrantholders.

Common Shares or Warrants Owned by the Corporation or its Subsidiaries – Certificate to be
Provided.

Severability.

Force Majeure.

Assignment, Successors and Assigns.

Rights of Rescission and Withdrawal for Holders.

Language

10.4   

10.5   

10.6

10.7

10.8   

10.9   

10.10  

10.11  

10.12  

   47 

   47 

   48 

   48 

   48 

   49 

   49 

   49 

   49 

SCHEDULES
SCHEDULE “A” FORM OF WARRANT CERTIFICATE

SCHEDULE “B” FORM OF TRANSFER CERTIFICATE

SCHEDULE “C” EXERCISE FORM

SCHEDULE “D” FORM OF DECLARATION FOR REMOVAL OF LEGEND

SCHEDULE “E” FORM OF U.S. PURCHASER CERTIFICATION UPON EXERCISE OF
WARRANTS

 
 
  
  
THIS WARRANT INDENTURE is dated as of February 21, 2017.

WARRANT INDENTURE

BETWEEN:

ACASTI  PHARMA  INC. ,  a  corporation  incorporated  under  the  laws  of  the  Province  of  Québec  (the
“Corporation”),

- and -

COMPUTERSHARE TRUST COMPANY OF CANADA , a trust company existing under the laws of Canada
and authorized to carry on business in all provinces of Canada (the “Warrant Agent”),

WHEREAS in connection with its short form prospectus dated February 10, 2017 filed with the Canadian provincial
securities regulatory authorities in the provinces of Alberta, British Columbia, Manitoba, Ontario and Québec relating
to a Canadian public offering and a concurrent offering by way of private placements outside of Canada, including in
the United States in an offering to accredited investors exempt from the registration requirements of the U.S. Securities
Act (as defined herein), pursuant to Rule 501(a) of Regulation D thereunder, the Corporation proposes to issue and sell
3,930,518  units  (“Units”)  of  the  Corporation  (the  “ Offering”),  each  Unit  comprising  one  (1)  Common  Share  (as
defined herein) and one half of one (1/2) Warrant (as defined herein);

AND WHEREAS for the purpose of the Offering, the Corporation is proposing to issue 1,965,259 Warrants pursuant
to this Indenture;

AND  WHEREAS  each  whole  Warrant  shall,  subject  to  adjustment,  entitle  the  holder  thereof  to  acquire  one
(1)  Common  Share  upon  payment  of  the  Exercise  Price  (as  defined  below)  upon  the  terms  and  conditions  herein  set
forth;

AND WHEREAS all acts and deeds necessary have been done and performed to make the Warrants, when created and
issued as provided in this Indenture, legal, valid and binding upon the Corporation with the benefits and subject to the
terms of this Indenture;

AND WHEREAS the foregoing recitals are made as representations and statements of fact by the Corporation and not
by the Warrant Agent;

NOW THEREFORE, in consideration of the premises and mutual covenants hereinafter contained and other good and
valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the Corporation hereby appoints
the Warrant Agent as warrant agent to hold the rights, interests and benefits contained herein for and on behalf of those
persons who from time to time become the holders of Warrants issued pursuant to this Indenture and the parties hereto
agree as follows:

- 2 -

ARTICLE 1
INTERPRETATION

1.1 Definitions.

In this Indenture, including the recitals and schedules hereto, and in all indentures supplemental hereto:

“Acceleration  Notice”  means  the  notice  of  acceleration  deliverable  to  the  Warrantholders  upon  the  Corporation’s
exercise of the Acceleration Rights;

“Acceleration Right” means the right of the Corporation to accelerate the Expiry Date to a date that is not the less than
30 days following delivery of the Acceleration Notice if, at any time at least four months after the Effective Date, the
volume  weighted  average  trading  price  of  the  Common  Shares  equals  or  exceeds  CAD$2.65  for  a  period  of  20
consecutive trading dates on the TSXV;

“Adjustment Period” means the period from the Effective Date up to and including the Expiry Time;

“Applicable  Legislation”  means  any  statute  of  Canada  or  a  province  thereof,  and  the  regulations  under  any  such
named or other statute, relating to warrant indentures or to the rights, duties and obligations of warrant agents under
warrant indentures, to the extent that such provisions are at the time in force and applicable to this Indenture;

“Applicable Securities Laws” means the applicable securities laws, regulations, rules, rulings and orders, including the
applicable  federal  and  state  securities  laws  and  regulations  of  the  United  States,  including  the  U.S.  Securities Act,
together  with  all  related  rules,  policies,  notices,  blanket  rulings,  orders  and  all  other  regulatory  instruments  of  the
securities regulators in the Provinces of Quebec, Ontario, Manitoba, Alberta and British Columbia, and the policies of
the TSXV;

“Auditors” means a firm of chartered accountants duly appointed as auditors of the Corporation;

“Authenticated” means (a) with respect to the issuance of a Warrant Certificate, one which has been duly signed by
the Corporation and authenticated by manual signature of an authorized officer of the Warrant Agent, (b) with respect
to  the  issuance  of  an  Uncertificated  Warrant,  one  in  respect  of  which  the  Warrant Agent  has  completed  all  Internal
Procedures such that the particulars of such Uncertificated Warrant as required by Section 2.7 are entered in the register
of  holders  of  Warrants,  “Authenticate”,  “Authenticating”  and  “Authentication”  have  the  appropriate  correlative
meanings;

“Book Based Participants” means institutions that participate directly or indirectly in the Book Based System;

“Book Based System ” means the book-based securities registration and transfer system administered by the Depository
in accordance with its operating rules and procedures in force from time to time;

“Book Based Warrants” means Warrants that are to be held by or on behalf of the Depository;

 
 
 
- 3 -

“Business Day” means any day other than Saturday, Sunday or a statutory or civic holiday, or any other day on which
the banks or Warrant Agency are not open for business in Montreal, Québec or Toronto, Ontario and shall be a day on
which the TSXV is open for trading;

“CDS Global Warrants” means Warrants representing all or a portion of the aggregate number of Warrants issued in
the  name  of  the  Depository  represented  by  an  Uncertificated  Warrant,  or  if  requested  by  the  Depository  or  the
Corporation, by a Warrant Certificate;

“Certificated Warrant”  means  a  Warrant  evidenced  by  a  writing  or  writings  substantially  in  the  form  of  Schedule
“A”, attached hereto;

“Common Shares”  means,  subject  to Article  4,  fully  paid  and  non-assessable  Class A  shares  of  the  Corporation  as
presently constituted;

“Counsel” means a barrister or solicitor and/or a firm of barristers and/or solicitors retained by the Warrant Agent or
retained  by  the  Corporation  and  acceptable  to  the  Warrant  Agent,  which  may  or  may  not  be  counsel  for  the
Corporation;

“Current  Market  Price”  of  the  Common  Shares  at  any  date  means  the  weighted  average  of  the  trading  price  per
Common  Share  for  each  day  there  was  a  closing  price  for  the  twenty  consecutive  Trading  Days  ending  on  (and
including) the third Trading Day immediately prior to such date on the TSXV, or if on such date the Common Shares
are not listed on the TSXV, on such other stock exchange upon which such Common Shares are listed as the directors
of the Corporation may select for this purpose, or, if such Common Shares are not then listed on any stock exchange,
on any over-the-counter market on which the Common Shares are traded as the directors of the Corporation may select
for  this  purpose,  or  if  Common  Shares  are  not  then  traded  on  any  over-the-counter-market,  then  the  Current  Market
Price shall be determined by the directors of the Corporation, acting reasonably;

“Depository” means CDS Clearing and Depository Services Inc. or such other Person as is designated in writing by the
Corporation to act as depository in respect of the Warrants;

“Dividends” means any dividends paid by the Corporation;

“Effective Date” means the date of this Indenture;

“Exchange Rate” means the number of Common Shares subject to the right of purchase under each Warrant;

“Exercise Date” means, in relation to the Warrants, the Business Day on which such Warrant is validly exercised or
deemed to be validly exercised in accordance with Article 3 hereof;

“Exercise Notice” has the meaning set forth in Section 3.2(a);

“Exercise Price” at any time means the price at which a whole Common Share may be purchased by the exercise of a
whole  Warrant,  which  is  initially  CAD$2.15  per  Common  Share,  payable  in  immediately  available  Canadian  funds,
subject to adjustment in accordance with the provisions of Article 4;

 
 
“Expiry Date” means the earlier of (i) February 21, 2022; and (ii) thirty (30) days following the date of delivery of an
Acceleration Notice;

- 4 -

“Expiry Time” means 5:00 p.m. (Montreal time) on the Expiry Date;

“Extraordinary Resolution” has the meaning set forth in 7.11;

“Issue Date” means February 21, 2017;

“Internal Procedures” means in respect of the making of any one or more entries to, changes in or deletions of any
one or more entries in the register at any time (including without limitation, original issuance or registration of transfer
of ownership) the minimum number of the Warrant Agent’s internal procedures customary at such time for the entry,
change or deletion made to be complete under the operating procedures followed at the time by the Warrant Agent, it
being understood that neither preparation and issuance shall constitute part of such procedures for any purpose of this
definition;

“NASDAQ” means The Nasdaq Stock Market;

“person”  means  an  individual,  body  corporate,  partnership,  trust,  warrant  agent,  executor,  administrator,  legal
representative or any unincorporated organization;

“register” means the one set of records and accounts maintained by the Warrant Agent pursuant to Section 2.9;

“Registered Warrantholders” means the persons who are registered owners of Warrants as such names appear on the
register,  and  for  greater  certainty,  shall  include  the  Depository  as  well  as  the  holders  of  Uncertificated  Warrants
appearing on the register of the Warrant Agent;

“Regulation D” means Regulation D as promulgated by the SEC under the U.S. Securities Act;

“Regulation S” means Regulation S as promulgated by the SEC under the U.S. Securities Act;

“SEC” means the United States Securities and Exchange Commission;

“Shareholders” means the holders of Common Shares;

“Tax Act” means the Income Tax Act  (Canada) and the regulations thereunder;

“this Warrant Indenture ”, “this Indenture”, “this Agreement”, “hereto” “herein”, “hereby”, “hereof” and similar
expressions  mean  and  refer  to  this  indenture  and  any  indenture,  deed  or  instrument  supplemental  hereto;  and  the
expressions “Article”, “Section”, “subsection” and “paragraph” followed by a number, letter or both mean and refer
to the specified article, section, subsection or paragraph of this indenture;

“Trading  Day ”  means,  with  respect  to  the  TSXV,  a  day  on  which  such  exchange  is  open  for  the  transaction  of
business, and with respect to another exchange or an over-the-counter market, means a day on which such exchange is
open for the transaction of business;

 
 
- 5 -

“Transaction Instruction” means a written order signed by the holder or the Depository, entitled to request that one or
more  actions  be  taken,  or  such  other  form  as  may  be  reasonably  acceptable  to  the  Warrant Agent,  requesting  one  or
more such actions to be taken in respect of an Uncertificated Warrant;

“TSXV” means the TSX Venture Exchange;

“Uncertificated Warrant” means any Warrant which is not a Certificated Warrant, including uncertificated Warrants
issued through the Book-Based System;

“United States” means the United States of America, its territories and possessions, any state of the United States, and
the District of Columbia;

“U.S. Accredited Investor Certificate ” means the U.S. Accredited Investor Status Certificate attached as Schedule A
to the subscription agreement relating to the U.S. Placement;

“U.S. Person” has the meaning given to such term in Regulation S under the U.S. Securities Act;

“U.S. Placement” means the original private placement in the United States of the Warrants on the date hereof;

“U.S. Purchaser Letter” means the U.S. Purchaser letter in substantially the form attached hereto as Schedule “E”;

“U.S. Securities Act” means the United States  Securities Act of 1933 , as amended;

“U.S. Warrantholder” means any Warrantholder that is a U.S. Person, acquired Warrants in the United States or for
the account or benefit of any U.S. Person or Person in the United States;

“U.S. Warrant Legend” means the U.S. restrictive legends set forth in Section 2.8(a);

“Warrants”  means  the  Common  Share  purchase  warrants  created  by  and  authorized  by  and  issuable  under  this
Indenture, to be issued and countersigned hereunder in certificated form and/or held through the Book Based System on
a no certificate issued basis, entitling the holder thereof to purchase one Common Share (subject to adjustment as herein
provided)  at  the  Exercise  Price  prior  to  the  Expiry  Time  or  means  the  warrants  issued  and Authenticated  hereunder,
whether by way of Warrant Certificate or Uncertificated Warrant;

“Warrant Agency ”  means  the  principal  office  of  the  Warrant Agent  in  the  City  of  Montreal,  Québec,  the  City  of
Toronto, Ontario, or such other place as may be designated in accordance with Section 3.6;

“Warrant Agent” means Computershare Trust Company of Canada, in its capacity as warrant agent of the Warrants, or
its successors from time to time;

“Warrant Certificate” means a certificate, substantially in the form set forth in Schedule “A” hereto, to evidence those
Warrants that will be evidenced by a certificate;

“Warrantholders”,  or  “ holders”  without  reference  to  Warrants,  means  the  holders  of  Warrants  and  includes
Registered Warrantholders and owners of Warrants who beneficially hold securities

 
 
- 6 -

entitlements  in  respect  of  the  Warrants  through  a  Book  Based  Participant,  and  “ Warrantholder”  means  any  of  the
Warrantholders;

“Warrantholders’ Request ” means an instrument signed in one or more counterparts by Registered Warrantholders
entitled  to  acquire  in  the  aggregate  not  less  than  50%  of  the  aggregate  number  of  Common  Shares  which  could  be
acquired pursuant to all Warrants then unexercised and outstanding, requesting the Warrant Agent to take some action
or proceeding specified therein; and

“written order of the Corporation ”, “written request of the Corporation ”, “written consent of the Corporation ”
and “certificate of the Corporation ” mean, respectively, a written order, request, consent and certificate signed in the
name  of  the  Corporation  by  any  duly  authorized  signatory  of  the  Corporation  and  may  consist  of  one  or  more
instruments so executed.

1.2 Gender and Number.

Words  importing  the  singular  number  or  masculine  gender  shall  include  the  plural  number  or  the  feminine  or

neuter genders, and vice versa.

1.3 Headings, Etc.

The division of this Indenture into Articles and Sections, the provision of a Table of Contents and the insertion of
headings are for convenience of reference only and shall not affect the construction or interpretation of this Indenture or
of the Warrants.

1.4 Day not a Business Day.

If any day on or before which any action or notice is required to be taken or given hereunder is not a Business
Day,  then  such  action  or  notice  shall  be  required  to  be  taken  or  given  on  or  before  the  requisite  time  on  the  next
succeeding day that is a Business Day.

1.5 Time of the Essence.

Time shall be of the essence of this Indenture.

1.6 Monetary References.

Whenever any amounts of money are referred to herein, such amounts shall be deemed to be in lawful money of

Canada unless otherwise expressed. References to “CAD$” are references to Canadian dollars.

1.7 Applicable Law.

This  Indenture,  the  Warrants,  the  Warrant  Certificates  (including  all  documents  relating  thereto,  which  by
common  accord  have  been  and  will  be  drafted  in  English)  shall  be  construed  in  accordance  with  the  laws  of  the
Province  of  Québec  and  the  federal  laws  of  Canada  applicable  therein  and  shall  be  treated  in  all  respects  as  legally-
binding  contracts.  Each  of  the  parties  hereto,  which  shall  include  the  Warrantholders,  irrevocably  attorns  to  the
exclusive jurisdiction of the courts of the Province of Québec with respect to all matters arising out of this Indenture
and the transactions contemplated herein.

 
 
 
 
 
 
 
 
- 7 -

ARTICLE 2
ISSUE OF WARRANTS

2.1 Creation and Issue of Warrants.

A maximum of 1,965,259 Warrants (subject to adjustment as herein provided) are hereby created and authorized
to  be  issued  in  accordance  with  the  terms  and  conditions  hereof.  By  written  order  of  the  Corporation,  the  Warrant
Agent  shall  deliver  Warrant  Certificates  to  Registered  Warrantholders  and  record  the  name  of  the  Registered
Warrantholders on the Warrant register. Registration of interests in Warrants held by the Depository may be evidenced
by  a  position  appearing  on  the  register  for  Warrants  of  the  Warrant Agent  for  an  amount  representing  the  aggregate
number  of  such  Warrants  outstanding  from  time  to  time.  The  Warrant Agent  is  hereby  appointed  Warrant Agent  in
respect of the Warrants.

2.2 Terms of Warrants.

(a)

Subject  to  the  applicable  conditions  for  exercise  set  out  in  Article  3  having  been  satisfied  and  subject  to
adjustment in accordance with Article 4, each Warrant shall entitle each Warrantholder thereof, upon exercise at
any time after the Issue Date and prior to the Expiry Time, to acquire one Common Share upon payment of the
Exercise Price.

(b) No fractional Warrants shall be issued or otherwise provided for hereunder and Warrants may only be exercised
in a sufficient number to acquire whole numbers of Common Shares. If any fractional interest in such securities
would, except for the provisions of this Section, be deliverable hereunder, the number of Warrants or Common
Shares, as the case may be, issuable by the Corporation shall be rounded down to the nearest whole number of
Warrants or Common Shares, as the case may be, to be issued in accordance with this Indenture.

(c)

Each Warrant shall entitle the holder thereof to such other rights and privileges as are set forth in this Indenture.

(d) The  number  of  Common  Shares  which  may  be  purchased  pursuant  to  the  Warrants  and  the  Exercise  Price

therefor shall be adjusted upon the events and in the manner specified in Article 4.

(e)

If  at  any  time  at  least  four  months  after  the  Effective  Date,  the  volume  weighted  average  trading  price  of  the
Common Shares shall equal or exceed $2.65 for a period of twenty (20) consecutive trading days on TSXV, the
Corporation shall be entitled, at the option of the Corporation, to exercise the Acceleration Right by delivering an
Acceleration Notice to the Warrantholders. An Acceleration Notice shall be delivered to each Warrantholder in
the manner in Section 10.1.

2.3 Warrantholder not a Shareholder.

Except as may be specifically provided herein, nothing in this Indenture or in the holding of a Warrant Certificate,
entitlement to a Warrant or otherwise, shall, in itself, confer or be construed as conferring upon a Warrantholder any
right or interest whatsoever as a Shareholder, including, but not limited to, the right to vote at, to receive notice of, or to
attend, meetings of

 
 
 
 
 
 
 
 
 
 
- 8 -

Shareholders or any other proceedings of the Corporation, or the right to Dividends and other allocations.

2.4 Warrants to Rank Pari Passu.

All Warrants shall rank equally and without preference over each other, whatever may be the actual date of issue

thereof.

2.5 Form of Warrants and Certificated Warrants.

The Warrants may be issued in both certificated and uncertificated form. Each Warrant originally issued to a U.S.
Warrantholder will be evidenced in certificated form only and bear the applicable legends as set forth in Schedule “A”
hereto. All Warrants issued in certificated form shall be evidenced by one or more Warrant Certificates (including all
replacements issued in accordance with this Indenture), substantially in the form set out in Schedule “A” hereto, which
shall be dated as of the Issue Date, shall bear such distinguishing letters and numbers as the Corporation may, with the
approval of the Warrant Agent, prescribe, and shall be issuable in any denomination excluding fractions. All Warrants
issued to the Depository may be in either a certificated or uncertificated form, such uncertificated form being evidenced
by  a  book  position  on  the  register  of  Warrantholders  to  be  maintained  by  the  Warrant  Agent  in  accordance  with
Section 2.6.

Each Warrantholder, by purchasing Warrants, acknowledges and agrees that the terms and conditions set forth in
the  form  of  Warrant  Certificate  set  out  in  Schedule  “A”  hereto  shall  apply  to  all  Warrants  and  Warrantholders,
regardless of whether such Warrants are issued in certificated or uncertificated form, or whether such Warrantholders
are  Registered  Warrantholders  or  owners  of  Warrants  who  beneficially  hold  securities  entitlements  in  respect  of  the
Warrants through a Book Based Participant.

2.6 Beneficial Holders of Warrants.

(a)

The Warrants may be represented in the form of one or more CDS Global Warrants registered in the name of the
Depositary or its nominee and held by, or on behalf of, the Depositary, as depositary of the CDS Global Warrants
for the Book Based Participants, and any such CDS Global Warrant will bear, or be deemed to bear the legend
included in section 2.8(c) hereto.

(b) Registration  of  beneficial  interests  in  and  transfers  of  Warrants  held  by  the  Depository  shall  be  made  only
through the Book Based System and no Warrant Certificates shall be issued in respect of such Warrants except
where physical certificates evidencing ownership in such securities are required or as set out herein or as may be
requested  by  a  Depository,  as  determined  by  the  Corporation,  from  time  to  time.  Except  as  provided  in  this
Section  2.6,  owners  of  beneficial  interests  in  any  CDS  Global  Warrants  shall  not  be  entitled  to  have  Warrants
registered in their names and shall not receive or be entitled to receive Warrants in definitive form or to have their
names appear in the register referred to in Section 2.9 herein.

(c) Notwithstanding any other provision in this Indenture, no CDS Global Warrants may be exchanged in whole or in

part for registered Warrants, and no transfer of any CDS

 
 
 
 
 
 
 
 
- 9 -

Global Warrant in whole or in part may be registered, in the name of any Person other than the Depository for
such CDS Global Warrants or a nominee thereof unless:

(i)

(ii)

the  Depository  notifies  the  Corporation  that  it  is  unwilling  or  unable  to  continue  to  act  as  depository  in
connection with the Book Based Warrants and the Corporation is unable to locate a qualified successor;

the Corporation determines that the Depository is no longer willing, able or qualified to discharge properly
its responsibilities as holder of the CDS Global Warrants and the Corporation is unable to locate a qualified
successor;

(iii)

the Depository ceases to be a clearing agency or otherwise ceases to be eligible to be a depository and the
Corporation is unable to locate a qualified successor;

(iv)

the Corporation determines that the Warrants shall no longer be held as Book Based Warrants through the
Depository;

(v)

such right is required by Applicable Law, as determined by the Corporation and the Corporation’s Counsel;

(vi)

the Warrant is to be Authenticated to or for the account or benefit of a person in the United States or a U.S.
Person; or

(vii) such registration is effected in accordance with the Internal Procedures of the Depository and the Warrant

Agent,

following  which  Warrants  for  those  holders  requesting  the  same  shall  be  registered  and  issued  to  the  beneficial
owners of such Warrants or their nominees as directed by the holder. The Corporation shall provide an Officer’s
Certificate giving notice to the Warrant Agent of the occurrence of any event outlined in this Section 2.6(b)(i) and
(vi).

(d)

(e)

Subject to the provisions of this Section 2.6, any exchange of CDS Global Warrants for Warrants which are not
CDS Global Warrants may be made in whole or in part in accordance with the provisions of Section 2.11,  mutatis
mutandis.  All  such  Warrants  issued  in  exchange  for  a  CDS  Global  Warrant  or  any  portion  thereof  shall  be
registered in such names as the Depository for such CDS Global Warrants shall direct and shall be entitled to the
same  benefits  and  subject  to  the  same  terms  and  conditions  (except  insofar  as  they  relate  specifically  to  CDS
Global Warrants) as the CDS Global Warrants or portion thereof surrendered upon such exchange.

Every Warrant that is Authenticated upon registration or transfer of a CDS Global Warrant, or in exchange for or
in lieu of a CDS Global Warrant or any portion thereof, whether pursuant to this Section 2.6, or otherwise, shall
be Authenticated  in  the  form  of,  and  shall  be,  a  CDS  Global  Warrant,  unless  such  Warrant  is  registered  in  the
name of a person other than the Depository for such CDS Global Warrant or a nominee thereof.

(f) Notwithstanding anything to the contrary in this Indenture, subject to Applicable Law, the CDS Global Warrant
will  be  issued  as  an  Uncertificated  Warrant,  unless  otherwise  requested  in  writing  by  the  Depository  or  the
Corporation.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 10 -

(g) The rights of beneficial owners of Warrants who hold securities entitlements in respect of the Warrants through
the  Book  Based  System  shall  be  limited  to  those  established  by  applicable  law  and  agreements  between  the
Depository  and  the  Book  Based  Participants  and  between  such  Book  Based  Participants  and  the  beneficial
owners of Warrants who hold securities entitlements in respect of the Warrants through the Book Based System,
and such rights must be exercised through a Book Based Participant in accordance with the rules and procedures
of the Depository.

(h) Notwithstanding  anything  herein  to  the  contrary,  neither  the  Corporation  nor  the  Warrant Agent  nor  any  agent

thereof shall have any responsibility or liability for:

(i)

any  aspects  of  the  records  relating  to  any  beneficial  ownership  interests  or  any  other  interests  in  the
Warrants or the Book Based System, or payments made by the Depository or its nominee on account of any
beneficial  ownership  interest  or  any  other  interest  of  any  person  in  any  Warrant  represented  by  an
electronic position in the Book Based System;

(ii)

for maintaining, supervising or reviewing any records of the Depository or its nominee or any Book Based
Participant relating to any such interest; or

(iii) any advice or representation made or given by the Depository or those contained herein that relate to the
rules and regulations of the Depository or any action to be taken by the Depository on its own direction or
at the direction of any Book Based Participant.

(i)

The Corporation may terminate the application of this Section 2.6 in its sole discretion in which case all Warrants
shall be evidenced by Warrant Certificates registered in the name of a Person other than the Depository.

2.7 Warrant Certificate.

(a)

For Warrants issued in certificated form, the form of certificate representing Warrants shall be substantially as set
out  in  Schedule  “A”  hereto  or  such  other  form  as  is  authorized  from  time  to  time  by  the  Warrant Agent.  Each
Warrant  Certificate  shall  be Authenticated  manually  on  behalf  of  the  Warrant Agent.  Each  Warrant  Certificate
shall  be  signed  by  any  authorized  signatory  of  the  Corporation;  whose  signature  shall  appear  on  the  Warrant
Certificate  and  may  be  printed,  lithographed  or  otherwise  mechanically  reproduced  thereon  and,  in  such  event,
certificates  so  signed  are  as  valid  and  binding  upon  the  Corporation  as  if  it  had  been  signed  manually.  Any
Warrant Certificate which is signed by any authorized signatory of the Corporation as hereinbefore provided shall
be  valid  notwithstanding  that  one  or  more  of  the  person(s)  whose  signature  is  printed,  lithographed  or
mechanically  reproduced  no  longer  holds  office  at  the  date  of  issuance  of  such  certificate.  The  Warrant
Certificates may be engraved, printed or lithographed, or partly in one form and partly in another, as the Warrant
Agent may determine.

(b) The  Warrant  Agent  shall  Authenticate  Uncertificated  Warrants  (whether  upon  original  issuance,  exchange,
registration of transfer, partial payment or otherwise) by completing its Internal Procedures and the Corporation
shall,  and  hereby  acknowledges  that  it  shall,  thereupon  be  deemed  to  have  duly  and  validly  issued  such
Uncertificated Warrants

 
 
 
 
 
 
 
 
 
 
 
 
 
- 11 -

under this Indenture. Such Authentication shall be conclusive evidence that such Uncertificated Warrant has been
duly issued hereunder and that the holder or holders are entitled to the benefits of this Indenture. The register shall
be final and conclusive evidence as to all matters relating to Uncertificated Warrants with respect to which this
Indenture requires the Warrant Agent to maintain records or accounts. In case of differences between the register
at any time and any other time, the register at the later time shall be controlling, absent manifest error and such
Uncertificated Warrants are binding on the Corporation.

(c) Any Warrant Certificate validly issued in accordance with the terms of this Indenture in effect at the time of issue
of  such  Warrant  Certificate  shall,  subject  to  the  terms  of  this  Indenture  and  applicable  law,  validly  entitle  the
holder to acquire Common Shares, notwithstanding that the form of such Warrant Certificate may not be in the
form currently required by this Indenture.

(d) No Certificated Warrant shall be considered issued and Authenticated or, if Authenticated, shall be obligatory or
shall  entitle  the  holder  thereof  to  the  benefits  of  this  Indenture,  until  it  has  been  Authenticated  by  manual
signature by or on behalf of the Warrant Agent substantially in the form of the Warrant set out in Schedule “A”
hereto. Such Authentication on any such Certificated Warrant shall be conclusive evidence that such Certificated
Warrant  is  duly Authenticated  and  is  valid  and  a  binding  obligation  of  the  Corporation  and  that  the  holder  is
entitled to the benefits of this Indenture.

(e) No Uncertificated Warrant shall be considered issued and shall be obligatory or shall entitle the holder thereof to
the  benefits  of  this  Indenture,  until  it  has  been Authenticated  by  entry  on  the  register  of  the  particulars  of  the
Uncertificated  Warrant.  Such  entry  on  the  register  of  the  particulars  of  an  Uncertificated  Warrant  shall  be
conclusive evidence that such Uncertificated Warrant is a valid and binding obligation of the Corporation and that
the holder is entitled to the benefits of this Indenture.

(f)

The Authentication by the Warrant Agent of any Warrants by way of entry on the register shall not be construed
as  a  representation  or  warranty  by  the  Warrant Agent  as  to  the  validity  of  this  Indenture  or  of  such  Warrants
(except the due Authentication thereof) or as to the performance by the Corporation of its obligations under this
Indenture and the Warrant Agent shall in no respect be liable or answerable for the use made of the Warrants or
any of them or the proceeds thereof.

2.8 Legends.

(a) Neither  the  Warrants  nor  the  Common  Shares  issuable  upon  exercise  of  the  Warrants  have  been  or  will  be
registered  under  the  U.S.  Securities  Act  or  under  any  United  States  state  securities  laws.  If  applicable,  each
Warrant  Certificate  originally  issued  for  the  benefit  or  account  of  a  U.S.  Warrantholder  and  each  Warrant
Certificate  issued  in  exchange  therefor  or  in  substitution  thereof,  shall  bear  the  following  legends  or  such
variations thereof as the Corporation may prescribe from time to time:

THIS WARRANT AND THE SECURITIES DELIVERABLE UPON EXERCISE HEREOF HAVE NOT BEEN
REGISTERED  UNDER  THE  UNITED  STATES  SECURITIES  ACT  OF  1933,  AS  AMENDED  (THE  “ U.S.
SECURITIES ACT”), OR

 
 
 
 
 
 
 
 
 
- 12 -

ANY  STATE  SECURITIES  LAWS,  AND  MAY  BE  OFFERED,  SOLD,  PLEDGED  OR  OTHERWISE
TRANSFERRED,  DIRECTLY  OR  INDIRECTLY,  ONLY  (A)  TO  ACASTI  PHARMA  INC.  (THE
“CORPORATION”)  (B)  OUTSIDE  THE  UNITED  STATES  IN  COMPLIANCE  WITH  RULE  904  OF
REGULATION  S  UNDER  THE  U.S.  SECURITIES  ACT  AND  IN  COMPLIANCE  WITH  APPLICABLE
LOCAL LAWS AND REGULATIONS, (C) WITHIN THE UNITED STATES IN ACCORDANCE WITH THE
EXEMPTION FROM REGISTRATION UNDER THE U.S. SECURITIES ACT PROVIDED BY (1) RULE 144A
UNDER  THE  U.S.  SECURITIES ACT  OR  (2)  IF AVAILABLE,  RULE  144  UNDER  THE  U.S.  SECURITIES
ACT  AND,  IN  EACH  CASE,  IN  COMPLIANCE  WITH  APPLICABLE  STATE  SECURITIES  LAWS,  OR
(D) IN A TRANSACTION THAT DOES NOT REQUIRE REGISTRATION UNDER THE U.S. SECURITIES
ACT  OR  ANY  APPLICABLE  STATE  SECURITIES  LAWS,  PROVIDED  THAT  IN  THE  CASE  OF
TRANSFERS  PURSUANT  TO  (C)(2)  OR  (D)  ABOVE,  A  LEGAL  OPINION  SATISFACTORY  TO  THE
CORPORATION MUST FIRST BE PROVIDED TO COMPUTERSHARE TRUST COMPANY OF CANADA
TO  THE  EFFECT  THAT  SUCH  TRANSFER  MAY  BE  EFFECTED  WITHOUT  REGISTRATION  UNDER
THE  U.S.  SECURITIES  ACT  AND  APPLICABLE  STATE  SECURITIES  LAWS.  DELIVERY  OF  THIS
CERTIFICATE MAY NOT CONSTITUTE “GOOD DELIVERY” IN SETTLEMENT OF TRANSACTIONS ON
STOCK EXCHANGES IN CANADA.”

provided, that, if the Warrants are being sold outside the United States in accordance with Rule 904 of Regulation
S, and if the Corporation is a “foreign issuer” within the meaning of Regulation S at the time of sale, this legend
may  be  removed  by  the  transferor  providing  a  declaration  to  the  Warrant  Agent  in  the  form  set  forth  in  the
attached Warrant Certificate or as the Warrant Agent or the Corporation may prescribe from time to time, and if
required by the Warrant Agent, including an opinion of counsel, of recognized standing reasonably satisfactory to
the Corporation and the Warrant Agent, that such legend is no longer required under the U.S. Securities Act and
applicable state securities laws.

(b) Each Warrant Certificate and each Warrant Certificate issued in exchange therefor or in substitution thereof, shall

bear the following legends or such variations thereof as the Corporation may prescribe from time to time:

“THE  SECURITIES  EVIDENCED  HEREBY  AND  THE  SECURITIES  ISSUABLE  UPON  EXERCISE
HEREOF  HAVE  NOT  BEEN  REGISTERED  UNDER  THE  U.S.  SECURITIES  ACT  OR  U.S.  STATE
SECURITIES LAWS. THESE WARRANTS MAY NOT BE EXERCISED IN THE UNITED STATES OR BY
OR  ON  BEHALF  OF,  OR  FOR  THE  ACCOUNT  OR  BENEFIT  OF,  A  U.S.  PERSON  UNLESS  AN
EXEMPTION  FROM  REGISTRATION  UNDER  THE  U.S.  SECURITIES  ACT  AND  ANY  APPLICABLE
STATE  SECURITIES  LAWS  IS AVAILABLE AND  THE  CORPORATION  HAS  RECEIVED AN  OPINION
OF  COUNSEL  OF  RECOGNIZED  STANDING  TO  SUCH  EFFECT  IN  FORM  AND  SUBSTANCE
REASONABLY  SATISFACTORY  TO  THE  CORPORATION.  “UNITED  STATES”  AND  “U.S.  PERSON”
ARE AS  DEFINED  BY  REGULATION  S  UNDER  THE  U.S.  SECURITIES ACT.  IF  REQUESTED  BY  THE
CORPORATION, THE HOLDER AGREES TO

 
 
 
- 13 -

PROVIDE  THE  INFORMATION  NECESSARY  TO  DETERMINE  WHETHER  THE  TRANSFER  OR
EXERCISE OF THIS WARRANT IS PERMISSIBLE UNDER THE U.S. SECURITIES ACT.”

(c)

The  Warrant Agent  shall  be  entitled  to  request  any  other  documents  that  it  may  require  in  accordance  with  its
internal policies for the removal of the legend set forth above.

(d) Each  CDS  Global  Warrant  originally  issued  in  Canada  and  held  by  the  Depository,  and  each  CDS  Global
Warrant  issued  in  exchange  therefor  or  in  substitution  thereof  shall  bear  or  be  deemed  to  bear  the  following
legend or such variations thereof as the Corporation may prescribe from time to time:

“UNLESS  THIS  CERTIFICATE  IS  PRESENTED  BY  AN  AUTHORIZED  REPRESENTATIVE  OF  CDS
CLEARING AND DEPOSITORY SERVICES INC. (“ CDS”)  TO ACASTI  PHARMA  INC.  (THE  “ ISSUER”)
OR  ITS  AGENT  FOR  REGISTRATION  OF  TRANSFER,  EXCHANGE  OR  PAYMENT,  AND  ANY
CERTIFICATE  ISSUED  IN  RESPECT  THEREOF  IS  REGISTERED  IN  THE  NAME  OF  CDS  &  CO,  OR  IN
SUCH OTHER NAME AS IS REQUESTED BY AN AUTHORIZED REPRESENTATIVE OF CDS (AND ANY
PAYMENT  IS  MADE  TO  CDS  &  CO.  OR  TO  SUCH  OTHER  ENTITY  AS  IS  REQUESTED  BY  AN
AUTHORIZED REPRESENTATIVE OF CDS), ANY TRANSFER, PLEDGE OR OTHER USE HEREOF FOR
VALUE OR OTHERWISE BY OR TO ANY PERSON IS WRONGFUL SINCE THE REGISTERED HOLDER
HEREOF,  CDS  &  CO.,  HAS  A  PROPERTY  INTEREST  IN  THE  SECURITIES  REPRESENTED  BY  THIS
CERTIFICATE HEREIN AND IT IS A VIOLATION OF ITS RIGHTS FOR ANOTHER PERSON TO HOLD,
TRANSFER OR DEAL WITH THIS CERTIFICATE.”

(e) Notwithstanding  any  other  provisions  of  this  Indenture,  in  processing  and  registering  transfers  of  Warrants,  no
duty  or  responsibility  whatsoever  shall  rest  upon  the  Warrant  Agent  to  determine  the  compliance  by  any
transferor or transferee with the terms of the legend contained in subsections 2.8(a) or 2.8(c), or with the relevant
securities laws or regulations, including, without limitation, Regulation S, and the Warrant Agent shall be entitled
to assume that all transfers are legal and proper.

2.9 Register of Warrants

(a)

The  Warrant  Agent  shall  maintain  records  and  accounts  concerning  the  Warrants,  whether  certificated  or
uncertificated, which shall contain the information called for below with respect to each Warrant, together with
such  other  information  as  may  be  required  by  law  or  as  the  Warrant  Agent  may  elect  to  record.  All  such
information  shall  be  kept  in  one  set  of  accounts  and  records  which  the  Warrant Agent  shall  designate  (in  such
manner  as  shall  permit  it  to  be  so  identified  as  such  by  an  unaffiliated  party)  as  the  register  of  the  holders  of
Warrants.  The  information  to  be  entered  for  each  account  in  the  register  of  Warrants  at  any  time  shall  include
(without limitation):

(i)

the name and address of the holder of the Warrants, the date of Authentication thereof and the number of
Warrants;

 
 
 
 
 
 
 
 
 
- 14 -

(ii) whether such Warrant is a Certificated Warrant or an Uncertificated Warrant and, if a Warrant Certificate,
the  unique  number  or  code  assigned  to  and  imprinted  thereupon  and,  if  an  Uncertificated  Warrant,  the
unique number or code assigned thereto if any;

(iii) whether such Warrant has been cancelled; and

(iv)

a register of transfers in which all transfers of Warrants and the date and other particulars of each transfer
shall be entered.

The  register  shall  be  available  for  inspection  by  the  Corporation  and  or  any  Warrantholder  during  the  Warrant
Agent’s regular business hours on a Business Day and upon payment to the Warrant Agent of its reasonable fees.
Any  Warrantholder  exercising  such  right  of  inspection  shall  first  provide  an  affidavit  in  form  satisfactory  to  the
Corporation and the Warrant Agent stating the name and address of the Warrantholder and agreeing not to use the
information  therein  except  in  connection  with  an  effort  to  call  a  meeting  of  Warrantholders  or  to  influence  the
voting of Warrantholders at any meeting of Warrantholders.

(b) Once  an  Uncertificated  Warrant  has  been Authenticated,  the  information  set  forth  in  the  register  with  respect
thereto  at  the  time  of Authentication  may  be  altered,  modified,  amended,  supplemented  or  otherwise  changed
only to reflect exercise or proper instructions to the Warrant Agent from the holder as provided herein, except that
the Warrant Agent may act unilaterally to make purely administrative changes internal to the Warrant Agent and
changes  to  correct  errors.  Each  person  who  becomes  a  holder  of  an  Uncertificated  Warrant,  by  his,  her  or  its
acquisition thereof shall be deemed to have irrevocably consented to the foregoing authority of the Warrant Agent
to make such error corrections.

2.10 Issue in Substitution for Warrant Certificates Lost, etc.

(a)

If any Warrant Certificate becomes mutilated or is lost, destroyed or stolen, the Corporation, subject to applicable
law, shall issue and thereupon the Warrant Agent shall certify and deliver, a new Warrant Certificate of like tenor,
and bearing the same legend, if applicable, as the one mutilated, lost, destroyed or stolen in exchange for and in
place of and upon cancellation of such mutilated Warrant Certificate, or in lieu of and in substitution for such lost,
destroyed or stolen Warrant Certificate, and the substituted Warrant Certificate shall be in a form approved by the
Warrant Agent and the Warrants evidenced thereby shall be entitled to the benefits hereof and shall rank equally
in accordance with its terms with all other Warrants issued or to be issued hereunder.

(b) The applicant for the issue of a new Warrant Certificate pursuant to this Section 2.10 shall bear the cost of the
issue thereof and in case of loss, destruction or theft shall, as a condition precedent to the issuance thereof, furnish
to the Corporation and to the Warrant Agent such evidence of ownership and of the loss, destruction or theft of
the Warrant Certificate so lost, destroyed or stolen as shall be satisfactory to the Corporation and to the Warrant
Agent, in their sole discretion, and such applicant shall also be required to furnish an indemnity and surety bond
in amount and form satisfactory to the

 
 
 
 
 
 
 
 
 
 
 
- 15 -

Corporation  and  the  Warrant  Agent,  in  their  sole  discretion,  and  shall  pay  the  reasonable  charges  of  the
Corporation and the Warrant Agent in connection therewith.

2.11 Exchange of Warrant Certificates.

(a) Any  one  or  more  Warrant  Certificates  representing  any  number  of  Warrants  may,  upon  compliance  with  the
reasonable  requirements  of  the  Warrant  Agent  (including  compliance  with  Applicable  Securities  Laws),  be
exchanged for one or more other Warrant Certificates representing the same aggregate number of Warrants and
bearing  the  same  legend,  if  applicable,  as  represented  by  the  Warrant  Certificate  or  Warrant  Certificates  so
exchanged.

(b) Warrant Certificates may be exchanged only at the Warrant Agency or at any other place that is designated by the
Corporation  with  the  approval  of  the  Warrant  Agent.  Any  Warrant  Certificate  or  duly  executed  Transaction
Instruction from the holder (or such other instructions, in form satisfactory to the Warrant Agent), tendered for
exchange shall be surrendered to the Warrant Agency and cancelled by the Warrant Agent.

(c) Warrant Certificates exchanged for Warrant Certificates that bear a legend set forth in Section 2.8 shall bear the

same legend.

2.12 Transfer and Ownership of Warrants.

(a)

The Warrants may only be transferred on the register kept by the Warrant Agent at the Warrant Agency by the
holder or its legal representatives or its attorney duly appointed by an instrument in writing in form and execution
satisfactory to the Warrant Agent only upon (a) in the case of a Warrant Certificate, surrendering to the Warrant
Agent at the Warrant Agency the Warrant Certificate representing the Warrants to be transferred together with a
duly executed transfer form as set forth in Schedule “B”, (b) in the case of Book Based Warrants, in accordance
with  procedures  prescribed  by  the  Depository  under  the  Book  Based  System,  (c)  in  the  case  of  Uncertificated
Warrants,  surrendering  to  the  Warrant Agent  at  the  Warrant Agency,  a  duly  executed  Transaction  Instruction
from the holder (or such other instructions, in form satisfactory to the Warrant Agent), and (d) upon compliance
with:

(i)

the conditions herein;

(ii)

such reasonable requirements as the Warrant Agent may prescribe; and

(iii) all Applicable Securities Laws and requirements of regulatory authorities;

and  such  transfer  shall  be  duly  noted  in  such  register  by  the  Warrant  Agent.  Upon  compliance  with  such
requirements, the Warrant Agent shall issue to the transferee of a Certificated Warrant (or it shall Authenticate an
Uncertificated  Warrant  instead,  upon  request),  a  Warrant  Certificate,  and  to  the  transferee  of  an  Uncertificated
Warrant,  an  Uncertificated  Warrant  (or  it  shall  Authenticate  and  deliver  a  Certificated  Warrant  instead,  upon
request),  representing  the  Warrants  transferred  and  the  transferee  of  a  Book  Based  Warrant  shall  be  recorded
through the relevant Book Based Participant in accordance with the Book Based System as the entitlement holder
in respect of such

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 16 -

Warrants. Transfers within the Book Based System are not the responsibility of the Warrant Agent and will not be
noted on the register maintained by the Warrant Agent.

(b)

(c)

If a Warrant Certificate tendered for transfer bears the legend set forth in Section 2.8(a), the Warrant Agent shall
not register such transfer unless the transferor has provided the Warrant Agent with the Warrant Certificate and
(i) the transfer is made to the Corporation or (ii) a declaration to the effect set forth in Schedule C to this Warrant
Indenture, or in such other form as the Corporation may from time to time prescribe, is delivered to the Warrant
Agent,  and  if  required  by  the  Warrant  Agent,  the  transferor  provides  an  opinion  of  counsel  of  recognized
standing, reasonably satisfactory to the Corporation and the Warrant Agent that the transfer is in compliance with
applicable state laws and the U.S. Securities Act.

Subject to the provisions of this Indenture and Applicable Legislation, the Warrantholder shall be entitled to the
rights  and  privileges  attaching  to  the  Warrants,  and  the  issue  of  Common  Shares  by  the  Corporation  upon  the
exercise  of  Warrants  in  accordance  with  the  terms  and  conditions  herein  contained  shall  discharge  all
responsibilities  of  the  Corporation  and  the  Warrant  Agent  with  respect  to  such  Warrants  and  neither  the
Corporation nor the Warrant Agent shall be bound to inquire into the title of any such holder.

2.13 Cancellation of Surrendered Warrants.

All Warrant Certificates surrendered pursuant to Article 3 shall be cancelled by the Warrant Agent and upon such
circumstances all such Uncertificated Warrants shall be deemed cancelled and so noted on the register by the Warrant
Agent. Upon request by the Corporation, the Warrant Agent shall furnish to the Corporation a cancellation certificate
identifying the Warrant Certificates so cancelled, the number of Warrants evidenced thereby, the number of Common
Shares,  if  any,  issued  pursuant  to  such  Warrants  and  the  details  of  any  Warrant  Certificates  issued  in  substitution  or
exchange for such Warrant Certificates cancelled.

ARTICLE 3
EXERCISE OF WARRANTS

3.1 Right of Exercise.

Subject to the provisions hereof, each Registered Warrantholder may exercise the right conferred on such holder
to subscribe for and purchase one Common Share for each Warrant after the Issue Date and prior to the Expiry Time
and in accordance with the conditions herein.

Notwithstanding any provision to the contrary contained in this Indenture, no U.S. Warrantholder may exercise
any  Warrant  unless  an  exemption  from  the  registration  requirements  of  the  U.S.  Securities Act  is  available  and  such
holder provides evidence, including an opinion of counsel, of the availability of such exemption reasonably satisfactory
to the Corporation and the Warrant Agent;  provided, however, that a U.S. Warrantholder that is the original purchaser
of Warrants and delivered to the Corporation a U.S. Accredited Investor Certificate in connection with its purchase of
Units  pursuant  to  the  U.S.  Placement  will  not  be  required  to  deliver  an  opinion  of  counsel  in  connection  with  the
exercise of the Warrants, unless reasonably requested by the Corporation.

 
 
 
 
 
 
3.2 Warrant Exercise.

- 17 -

(a) Registered  Warrantholders  of  Warrant  Certificates  who  wish  to  exercise  the  Warrants  held  by  them  in  order  to
acquire Common Shares must complete a Transaction Instruction or the exercise form (the “Exercise  Notice”)
attached to the Warrant Certificate(s) in the form set forth in Schedule “C” hereto, which may be amended by the
Corporation with the consent of the Warrant Agent, if such amendment does not, in the reasonable opinion of the
Corporation  and  the  Warrant Agent,  which  may  be  based  on  the  advice  of  Counsel,  materially  and  adversely
affect the rights, entitlements and interests of the Warrantholders, and deliver such certificate(s), if applicable, the
executed  Exercise  Notice  and  a  certified  cheque,  bank  draft  or  money  order  payable  to  or  to  the  order  of  the
Corporation  for  the  aggregate  Exercise  Price  to  the  Warrant  Agent  at  the  Warrant  Agency.  The  Warrants
represented by a Warrant Certificate shall be deemed to be surrendered upon personal delivery of such certificate,
Exercise  Notice  and  aggregate  Exercise  Price  or,  if  such  documents  are  sent  by  mail  or  other  means  of
transmission, upon actual receipt thereof by the Warrant Agent at the office referred to above.

(b)

In addition to completing the Exercise Form attached to the Warrant Certificate(s), a U.S. Warrantholder, or any
other  person  requesting  delivery  of  the  Common  Shares  issuable  upon  exercise  of  the  Warrants  in  or  into  the
United States must (a) provide a completed and executed U.S. Purchaser Letter or (b) an opinion of counsel of
recognised standing in form and substance reasonably satisfactory to the Corporation and the Warrant Agent that
the exercise and delivery is exempt from the registration requirements of Applicable Securities Laws of any state
of  the  United  States  and  the  U.S.  Securities Act; provided,  however  a  U.S.  Warrantholder  that  is  the  original
purchaser of Warrants and who has delivered the U.S. Accredited Investor Certificate attached to the subscription
agreement of the Corporation in connection with its purchase of Units pursuant to the U.S. Placement, will not be
required to deliver a U.S. Purchaser Letter or an  opinion  of  counsel  in  connection  with  the  due  exercise  of  the
Warrant  at  a  time  when  the  representations,  warranties  and  covenants  made  by  the  Warrantholder  in  the  U.S.
Accredited Investor Certificate remain true and correct and the Warrantholder certifies to the Corporation as such.

(c) A  Registered  Warrantholder  of  Uncertificated  Warrants  evidenced  by  a  security  entitlement  in  respect  of
Warrants  must  complete  the  Exercise  Notice  and  deliver  the  executed  Exercise  Notice  and  a  certified  cheque,
bank draft or money order payable to or to the order of the Corporation for the aggregate Exercise Price to the
Warrant Agent  at  the  Warrant Agency.  The  Uncertificated  Warrants  shall  be  deemed  to  be  surrendered  upon
receipt of the duly completed and executed Exercise Notice and payment of the applicable Exercise Price or, if
such  documents  are  sent  by  mail  or  other  means  of  transmission,  upon  actual  receipt  thereof  by  the  Warrant
Agent at the office referred to above.

(d) A  beneficial  owner  of  Warrants  evidenced  by  a  security  entitlement  in  respect  of  Warrants  in  the  Book  Based
System who desires to exercise his or her Warrants must do so by causing a Book Based Participant to deliver to
the  Depository  on  behalf  of  the  entitlement  holder,  notice  of  the  owner’s  intention  to  exercise  Warrants  in  a
manner acceptable to the Depository. Forthwith upon receipt by the Depository of such notice,

 
 
 
 
 
 
- 18 -

as  well  as  payment  for  the  aggregate  Exercise  Price,  the  Depository  shall  deliver  to  the  Warrant  Agent
confirmation of its intention to exercise Warrants (“Confirmation”) in a manner acceptable to the Warrant Agent,
including by electronic means through a book based registration system, including CDSX. An electronic exercise
of  the  Warrants  initiated  by  the  Book  Based  Participant  through  a  book  based  registration  system,  including
CDSX, shall constitute a representation to both the Corporation and the Warrant Agent that the beneficial owner
at  the  time  of  exercise  of  such  Warrants  (a)  is  not  in  the  United  States;  (b)  is  not  a  U.S.  Person  and  is  not
exercising such Warrants on behalf of a U.S. Person or a person in the United States; and (c) did not execute or
deliver the notice of the owner’s intention to exercise such Warrants in the United States. If the CDS Participant
is not able to make or deliver the foregoing representation by initiating the electronic exercise of the Warrants,
then  such  Warrants  shall  be  withdrawn  from  the  book  based  registration  system,  including  CDSX  by  the  CDS
Participant  and  an  individually  registered  Warrant  Certificate  shall  be  issued  by  the  Warrant  Agent  to  such
Beneficial Owner or CDS Participant and the exercise procedures set forth in Section 3.2(a) shall be followed.

(e)

Payment representing the aggregate Exercise Price must be provided to the appropriate office of the Book Based
Participant in a manner acceptable to it. A notice in form acceptable to the Book Based Participant and payment
from  such  beneficial  holder  should  be  provided  to  the  Book  Based  Participant  sufficiently  in  advance  so  as  to
permit the Book Based Participant to deliver notice and payment to the Depository and for the Depository in turn
to  deliver  notice  and  payment  to  the  Warrant Agent  prior  to  the  Expiry  Time.  The  Depository  will  initiate  the
exercise  by  way  of  the  Confirmation  and  forward  the  aggregate  Exercise  Price  electronically  to  the  Warrant
Agent  and  the  Warrant Agent  will  execute  the  exercise  by  issuing  to  the  Depository  through  the  Book  Based
System  the  Common  Shares  to  which  the  exercising  Warrantholder  is  entitled  pursuant  to  the  exercise.  Any
expense  associated  with  the  exercise  process  will  be  for  the  account  of  the  entitlement  holder  exercising  the
Warrants and/or the Book Based Participant exercising the Warrants on its behalf.

(f)

By causing a Book Based Participant to deliver notice to the Depository, a Warrantholder shall be deemed to have
irrevocably surrendered his or her Warrants so exercised and appointed such Book Based Participant to act as his
or her exclusive settlement agent with respect to the exercise and the receipt of Common Shares in connection
with the obligations arising from such exercise.

(g) Any notice which the Depository determines to be incomplete, not in proper form or not duly executed shall for
all purposes be void and of no effect and the exercise to which it relates shall be considered for all purposes not to
have been exercised thereby. A failure by a Book Based Participant to exercise or to give effect to the settlement
thereof in accordance with the Warrantholder’s instructions will not give rise to any obligations or liability on the
part of the Corporation or Warrant Agent to the Book Based Participant or the Warrantholder.

(h) Any  exercise  form  or  Exercise  Notice  referred  to  in  this  Section  3.2  shall  be  signed  by  the  Registered
Warrantholder,  or  its  executors  or  administrators  or  other  legal  representatives  or  an  attorney  of  the  Registered
Warrantholder, duly appointed by an

 
 
 
 
 
 
 
- 19 -

instrument  in  writing  satisfactory  to  the  Warrant  Agent  but  such  exercise  form  need  not  be  executed  by  the
Depository.

(i) Any  exercise  referred  to  in  this  Section  3.2  shall  require  that  the  entire  Exercise  Price  for  Common  Shares
subscribed  must  be  paid  at  the  time  of  subscription  and  such  Exercise  Price  and  original  Exercise  Notice
executed  by  the  Registered  Warrantholder  or  the  Confirmation  from  the  Depository  must  be  received  by  the
Warrant Agent prior to the Expiry Time.

(j) Warrants may only be exercised pursuant to this Section 3.2 by or on behalf of a Registered Warrantholder, as
applicable, who makes the certifications set forth on the Exercise Notice set out in Schedule “C” or as provided
herein.

(k)

(l)

If the form of Exercise Notice set forth in the Warrant Certificate shall have been amended, the Corporation shall
cause the amended Exercise Notice to be forwarded to all Registered Warrantholders.

Exercise  Notices  and  Confirmations  must  be  delivered  to  the  Warrant Agent  at  any  time  during  the  Warrant
Agent’s  actual  business  hours  on  any  Business  Day  prior  to  the  Expiry  Time.  Any  Exercise  Notice  or
Confirmations  received  by  the  Warrant Agent  after  business  hours  on  any  Business  Day  other  than  the  Expiry
Date will be deemed to have been received by the Warrant Agent on the next following Business Day.

(m) Any  Warrant  with  respect  to  which  an  Exercise  Notice  or  Confirmation  is  not  received  by  the  Warrant Agent
before  the  Expiry  Time  shall  be  deemed  to  have  expired  and  become  void  and  all  rights  with  respect  to  such
Warrants shall terminate and be cancelled.

3.3

Securities Restrictions.

Notwithstanding anything herein contained, Common Shares will be issued upon exercise of a Warrant only in
compliance  with  the  securities  laws  of  any  applicable  jurisdiction,  including  without  limitation  the  Applicable
Securities Laws, and, without limiting the generality of the foregoing, the Corporation will direct the Warrant Agent to
legend  any  certificates  representing  the  Common  Shares  if,  in  the  opinion  of  counsel  to  the  Corporation  acting
reasonably,  such  legend  is  necessary  in  order  to  avoid  a  violation  of  such  securities  laws  or  to  comply  with  the
requirements  of  any  stock  exchange  on  which  the  Common  Shares  are  listed;  provided  that  if,  at  any  time,  in  the
opinion  of  counsel  to  the  Corporation,  acting  reasonably,  such  legends  are  no  longer  necessary  in  order  to  avoid  a
violation  of  any  such  laws,  or  the  holder  of  any  such  legended  certificate,  at  his  or  her  expense,  provides  the
Corporation  with  evidence  in  form  and  substance  reasonably  satisfactory  to  the  Corporation  (which  may  include  an
opinion  of  Counsel  of  recognized  standing  in  form  and  substance  reasonably  satisfactory  to  the  Corporation)  to  the
effect  that  such  holder  is  entitled  to  sell  or  otherwise  transfer  such  Common  Shares  in  a  transaction  in  which  such
legends are not required, such legended certificates may thereafter be surrendered to the Warrant Agent in exchange for
a certificate which does not bear such legends.

The Warrant Agent shall be entitled to assume that Common Shares may be issued pursuant to the exercise of any
Warrant  without  violating  any  Applicable  Securities  Laws  and  without  legending  the  certificate  representing  the
Common Shares unless the Warrant Agent has

 
 
 
 
 
 
 
 
 
- 20 -

received notice in writing from the Corporation stating otherwise and setting forth the restrictions on the exercise of the
Warrants and any legend the certificates representing the Common Shares should bear.

3.4 Prohibition on Exercise by U.S. Persons; Legended Certificates

(a)

Subject to Section 3.2(b) and Section 3.4(b), (i) Warrants may not be exercised within the United States or by or
on  behalf  of  any  U.S.  Warrantholders;  and  (ii)  no  Common  Shares  issued  upon  exercise  of  Warrants  may  be
delivered to any address in the United States.

(b) Notwithstanding  Section  3.4(a),  Warrants  which  bear  the  legend  set  forth  in  Section  2.8(a)  and  2.8(b)  may  be
exercised  in  the  United  States  or  by  or  on  behalf  of  a  U.S.  Warrantholder,  and  Common  Shares  issued  upon
exercise of any such Warrants may be delivered to an address in the United States, provided that (a) the Person
exercising  the  Warrants  (i)  is  an  original  U.S.  Purchaser  who  purchased  the  Warrants  directly  from  the
Corporation, (ii) is an institutional “accredited investor” that satisfies one or more of the criteria set forth in Rule
501(a)(1),  (2),  (3)  or  (7)  of  Regulation  D  and  (b)  delivers  a  completed  and  executed  U.S.  Purchaser  Letter  or
provides in form and substance satisfactory to the Corporation and Warrant Agent a legal opinion which confirms
that issuance of shares without registration under the U.S. Securities Act is in compliance with the applicable state
laws and the U.S. Securities Act; provided however  that in the case of a U.S. Warrantholder that is the original
purchaser  of  the  Warrants  and  who  delivered  the  U.S.  Accredited  Investor  Certificate  to  the  Corporation  in
connection with its purchase of Units pursuant to the U.S. Placement, such Warrantholder will not be required to
deliver a U.S. Purchaser Letter or an opinion of counsel in connection with the exercise of the Warrant at a time
when the representations, warranties and covenants made by the Warrantholder in the U.S. Accredited Investor
Certificate remain true and correct and the Warrantholder certifies to the Corporation as such.

(c) Certificates representing Common Shares issued upon the exercise of Warrants which bear the legend set forth in
Sections 2.8(a) and 2.8(b) and which are issued and delivered pursuant to Section 3.4(b) shall bear the following
legend:

“THE  SECURITIES  REPRESENTED  HEREBY  HAVE  NOT  BEEN  REGISTERED  UNDER  THE  UNITED
STATES  SECURITIES ACT  OF  1933, AS AMENDED  (THE  “ U.S. SECURITIES ACT ”),  OR ANY  STATE
SECURITIES  LAWS,  AND  MAY  BE  OFFERED,  SOLD,  PLEDGED  OR  OTHERWISE  TRANSFERRED,
DIRECTLY  OR  INDIRECTLY,  ONLY  (A)  TO  ACASTI  PHARMA  INC.  (THE  “ CORPORATION”)
(B)  OUTSIDE  THE  UNITED  STATES  IN  COMPLIANCE  WITH  RULE  904  OF  REGULATION  S  UNDER
THE  U.S.  SECURITIES  ACT  AND  IN  COMPLIANCE  WITH  APPLICABLE  LOCAL  LAWS  AND
REGULATIONS, (C) WITHIN THE UNITED STATES IN ACCORDANCE WITH THE EXEMPTION FROM
REGISTRATION UNDER THE U.S. SECURITIES ACT PROVIDED BY (1) RULE 144A UNDER THE U.S.
SECURITIES ACT OR (2) IF AVAILABLE, RULE 144 UNDER THE U.S. SECURITIES ACT AND, IN EACH
CASE, IN COMPLIANCE WITH APPLICABLE STATE SECURITIES LAWS, OR (D) IN A TRANSACTION
THAT  DOES  NOT  REQUIRE  REGISTRATION  UNDER  THE  U.S.  SECURITIES  ACT  OR  ANY
APPLICABLE STATE SECURITIES LAWS, PROVIDED THAT IN

 
 
 
 
 
 
- 21 -

THE CASE OF TRANSFERS PURSUANT TO (C)(2) OR (D) ABOVE, THE HOLDER MUST FURNISH TO
THE  CORPORATION  AN  OPINION  OF  COUNSEL  OF  RECOGNIZED  STANDING  IN  FORM  AND
SUBSTANCE  REASONABLY  SATISFACTORY  TO  THE  CORPORATION  TO  THE  EFFECT  THAT  THE
PROPOSED TRANSFER MAY BE EFFECTED WITHOUT REGISTRATION UNDER THE U.S. SECURITIES
ACT OR APPLICABLE STATE SECURITIES LAWS.

THE  SECURITIES  REPRESENTED  BY  THIS  CERTIFICATE  ARE  LISTED  ON  THE  TSX  VENTURE
EXCHANGE  (“TSXV”);  HOWEVER,  SUCH  SECURITIES  CANNOT  BE  TRADED  THROUGH  THE
FACILITIES OF THE TSXV SINCE THEY ARE NOT FREELY TRANSFERABLE, AND CONSEQUENTLY
DELIVERY OF ANY CERTIFICATE REPRESENTING SUCH SECURITIES IS NOT “GOOD DELIVERY” IN
SETTLEMENT  OF  TRANSACTIONS  ON  THE  TSXV.  PROVIDED  THAT  THE  CORPORATION  IS  A
“FOREIGN  ISSUER”  WITHIN  THE  MEANING  OF  REGULATION  S  AT  THE  TIME  OF  SALE,  A  NEW
CERTIFICATE,  BEARING  NO  LEGEND,  DELIVERY  OF  WHICH  WILL  CONSTITUTE  “GOOD
DELIVERY”  MAY  BE  OBTAINED  FROM  COMPUTERSHARE  INVESTOR  SERVICES  INC.,  AS
REGISTRAR AND TRANSFER AGENT, OR SUCH OTHER ORGANIZATION OR ENTITY PERFORMING
SUCH  FUNCTION  FOR  THE  CORPORATION  (THE  “TRANSFER AGENT”)  UPON  DELIVERY  OF  THIS
CERTIFICATE  AND  A  DULY  EXECUTED  DECLARATION,  IN  A  FORM  SATISFACTORY  TO  THE
TRANSFER  AGENT  AND  THE  CORPORATION,  TO  THE  EFFECT  THAT  THE  SALE  OF  THE
SECURITIES  REPRESENTED  HEREBY  IS  BEING  MADE  IN  COMPLIANCE  WITH  RULE  904  OF
REGULATION S UNDER THE SECURITIES ACT (AND IF REQUIRED BY THE TRANSFER AGENT OR
THE CORPORATION, AN OPINION OF COUNSEL REASONABLY SATISFACTORY TO THE TRANSFER
AGENT AND THE CORPORATION).”

3.5 Transfer Fees and Taxes.

If  any  of  the  Common  Shares  subscribed  for  are  to  be  issued  to  a  person  or  persons  other  than  the  Registered
Warrantholder, the Registered Warrantholder shall execute the form of transfer and will comply with such reasonable
requirements as the Warrant Agent may stipulate and will pay to the Corporation or the Warrant Agent on behalf of the
Corporation,  all  applicable  transfer  or  similar  taxes  and  the  Corporation  will  not  be  required  to  issue  or  deliver
certificates  evidencing  Common  Shares  or  issue  Common  Shares  in  uncertificated  form  unless  or  until  such
Warrantholder  shall  have  paid  to  the  Corporation  or  the  Warrant Agent  on  behalf  of  the  Corporation,  the  amount  of
such tax or shall have established to the satisfaction of the Corporation and the Warrant Agent that such tax has been
paid or that no tax is due.

3.6 Warrant Agency.

To facilitate the exchange, transfer or exercise of Warrants and compliance with such other terms and conditions
hereof as may be required, the Corporation has appointed the Warrant Agency, as the agency at which Warrants may
be surrendered for exchange or transfer or at which Warrants may be exercised and the Warrant Agent has accepted
such  appointment.  The  Corporation  may  from  time  to  time  designate  alternate  or  additional  places  as  the  Warrant
Agency  (subject  to  the  Warrant Agent’s  prior  approval)  and  will  give  notice  to  the  Warrant Agent  of  any  proposed
change of the Warrant Agency. Branch registers shall also be kept at such

 
 
 
 
- 22 -

other place or places, if any, as the Corporation, with the approval of the Warrant Agent, may designate. The Warrant
Agent  will  from  time  to  time  when  requested  to  do  so  by  the  Corporation  or  any  Registered  Warrantholder,  upon
payment  of  the  Warrant  Agent’s  reasonable  charges,  furnish  a  list  of  the  names  and  addresses  of  Registered
Warrantholders showing the number of Warrants held by each such Registered Warrantholder.

3.7 Effect of Exercise of Warrant Certificates.

(a) Upon  the  exercise  of  Warrants  pursuant  to  and  in  compliance  with  Section  3.2  and  subject  to  Section  3.3  and
Section 3.4, the Common Shares to be issued pursuant to the Warrants exercised shall be deemed to have been
issued and the person or persons to whom such Common Shares are to be issued shall be deemed to have become
the holder or holders of record of such Common Shares on the Exercise Date, unless the register shall be closed
on  such  date,  in  which  case  the  Common  Shares  subscribed  for  shall  be  deemed  to  have  been  issued  and  such
person or persons deemed to have become the holder or holders of record of such Common Shares, on the date on
which such register is reopened. It is hereby understood that in order for persons to whom Common Shares are to
be  issued,  to  become  holders  of  Common  Shares  of  record  on  the  Exercise  Date,  beneficial  holders  must
commence  the  exercise  process  sufficiently  in  advance  so  that  the  Warrant Agent  is  in  receipt  of  all  items  of
exercise at least one Business Day prior to such Exercise Date.

(b) As  soon  as  practicable,  but  in  any  event  within  five  Business  Days  after  the  Exercise  Date  with  respect  to  a
Warrant,  the  Warrant Agent  shall  cause  to  be  delivered  or  mailed  to  the  person  or  persons  in  whose  name  or
names the Warrant is registered or, if so specified in writing by the holder, cause to be delivered to such person
or persons at the Warrant Agency where the Warrant Certificate was surrendered, a certificate or certificates for
the appropriate number of Common Shares subscribed for, or any other appropriate evidence of the issuance of
Common Shares to such person or persons in respect of Common Shares issued under the Book Based System.

3.8 Partial Exercise of Warrants; Fractions.

(a)

The holder of any Warrants may exercise his right to acquire a number of whole Common Shares less than the
aggregate number which the holder is entitled to acquire. In the event of any exercise of a number of Warrants
less than the number which the holder is entitled to exercise, the holder of Warrants upon such exercise shall, in
addition, be entitled to receive, without charge therefor, a new Warrant Certificate(s), bearing the same legend, if
applicable,  or  other  appropriate  evidence  of  Warrants,  in  respect  of  the  balance  of  the  Warrants  held  by  such
holder and which were not then exercised.

(b) Notwithstanding anything herein contained including any adjustment provided for in Section 4.1, the Corporation
shall  not  be  required,  upon  the  exercise  of  any  Warrants,  to  issue  fractions  of  Common  Shares.  Warrants  may
only be exercised in a sufficient number to acquire whole numbers of Common Shares.

 
 
 
 
 
 
 
 
3.9 Expiration of Warrants.

- 23 -

Immediately  after  the  Expiry  Time,  all  rights  under  any  Warrant  in  respect  of  which  the  right  of  acquisition
provided for herein shall not have been exercised shall cease and terminate and each Warrant shall be void and of no
further force or effect.

3.10 Accounting and Recording.

(a)

The  Warrant  Agent  shall  promptly  account  to  the  Corporation  with  respect  to  Warrants  exercised,  and  shall
promptly  forward  to  the  Corporation  (or  into  an  account  or  accounts  of  the  Corporation  with  the  bank  or  trust
company  designated  by  the  Corporation  for  that  purpose),  all  monies  received  by  the  Warrant  Agent  on  the
subscription  of  Common  Shares  through  the  exercise  of  Warrants. All  such  monies  and  any  securities  or  other
instruments,  from  time  to  time  received  by  the  Warrant  Agent  shall  be  received  in  trust  for,  and  shall  be
segregated and kept apart by the Warrant Agent, the Warrantholders and the Corporation as their interests may
appear.

(b) The Warrant Agent shall record the particulars of Warrants exercised, which particulars shall include the names
and  addresses  of  the  persons  who  become  holders  of  Common  Shares  on  exercise  and  the  Exercise  Date,  in
respect  thereof.  The  Warrant  Agent  shall  provide  such  particulars  in  writing  to  the  Corporation  within  five
Business Days of any request by the Corporation therefor.

ARTICLE 4
ADJUSTMENT OF NUMBER OF COMMON SHARES AND EXERCISE PRICE

4.1 Adjustment of Number of Common Shares and Exercise Price.

The  subscription  rights  in  effect  under  the  Warrants  for  Common  Shares  issuable  upon  the  exercise  of  the
Warrants shall be subject to adjustment from time to time upon the occurrence of any of the events and in the manner
provided as follows:

(a)

If and whenever, at any time during the Adjustment Period, the Corporation shall:

(i)

subdivide, re-divide or change its Common Shares into a greater number of Common Shares;

(ii)

reduce, combine or consolidate its outstanding Common Shares into a lesser number of Common Shares; or

(iii)

issue  Common  Shares  or  securities  exchangeable  for,  or  convertible  into,  Common  Shares  to  all  or
substantially all of the holders of Common Shares by way of stock dividend or other distribution (other than
dividends paid in the ordinary course, and other than a distribution of Common Shares upon the exercise of
any outstanding warrants, options or other securities);

(any of such events in Section 4.1(a) (i) to (iii), a “ Common Share Reorganization”),  then  the  Exercise  Price
shall be adjusted with effect on the effective date of such subdivision, re-division, change, reduction, combination,
consolidation or on the record date of such distribution, as the case may be, shall in the case of the events referred
to in

 
 
 
 
 
 
 
 
 
 
 
 
 
- 24 -

(i)  or  (iii)  above  be  decreased  in  proportion  to  the  number  of  outstanding  Common  Shares  resulting  from  such
subdivision,  re-division,  change  or  distribution,  or  shall,  in  the  case  of  the  events  referred  to  in  (ii)  above,  be
increased in proportion to the number of outstanding Common Shares resulting from such reduction, combination
or consolidation by multiplying the Exercise Price in effect immediately prior to such effective date or record date
by a fraction, the numerator of which shall be the number of Common Shares outstanding on such effective date or
record date before giving effect to such Common Share Reorganization and the denominator of which shall be the
number of Common Shares outstanding as of the effective date or record date after giving effect to such Common
Shares  Reorganization  (including,  in  the  case  where  securities  exchangeable  for  or  convertible  into  Common
Shares are distributed, the number of Common Shares that would have been outstanding had such securities been
exchanged for or converted into Common Shares on such record date or effective date). Such adjustment shall be
made successively whenever any event referred to in this Section 4.1(a) shall occur. Upon any adjustment of the
Exercise Price pursuant to Section 4.1(a), the Exchange Rate shall be contemporaneously adjusted by multiplying
the number of Common Shares theretofore obtainable on the exercise thereof by a fraction of which the numerator
shall  be  the  Exercise  Price  in  effect  immediately  prior  to  such  adjustment  and  the  denominator  shall  be  the
Exercise Price resulting from such adjustment;

(b)

if  and  whenever  at  any  time  during  the  Adjustment  Period,  the  Corporation  shall  fix  a  record  date  for  the
issuance  of  rights,  options  or  warrants  to  all  or  substantially  all  the  holders  of  its  outstanding  Common  Shares
entitling them, for a period expiring not more than 45 days after such record date, to subscribe for or purchase
Common Shares (or securities convertible or exchangeable into Common Shares) at a price per Common Share
(or having a conversion or exchange price per Common Share) less than 95% of the Current Market Price on such
record date (a “Rights Offering”), the Exercise Price shall be adjusted immediately after such record date so that
it shall equal the amount determined by multiplying the Exercise Price in effect on such record date by a fraction,
of  which  the  numerator  shall  be  the  total  number  of  Common  Shares  outstanding  on  such  record  date  plus  a
number of Common Shares equal to the number arrived at by dividing the aggregate price of the total number of
additional Common Shares offered for subscription or purchase (or the aggregate conversion or exchange price of
the  convertible  or  exchangeable  securities  so  offered)  by  such  Current  Market  Price,  and  of  which  the
denominator shall be the total number of Common Shares outstanding on such record date plus the total number
of additional Common Shares offered for subscription or purchase or into which the convertible or exchangeable
securities so offered are convertible or exchangeable; any Common Shares owned by or held for the account of
the Corporation shall be deemed not to be outstanding for the purpose of any such computation; such adjustment
shall be made successively whenever such a record date is fixed; to the extent that no such rights or warrants are
exercised prior to the expiration thereof, the Exercise Price shall be readjusted to the Exercise Price which would
then  be  in  effect  if  such  record  date  had  not  been  fixed  or,  if  any  such  rights  or  warrants  are  exercised,  to  the
Exercise Price which would then be in effect based upon the number of Common Shares (or securities convertible
or exchangeable into Common Shares) actually issued upon the exercise of such rights or warrants, as the case
may be. Upon any adjustment of the Exercise Price pursuant to this Section 4.1(b), the Exchange Rate

 
 
 
- 25 -

will be adjusted immediately after such record date so that it will equal the rate determined by multiplying the
Exchange Rate in effect on such record date by a fraction, of which the numerator shall be the Exercise Price in
effect immediately prior to such adjustment and the denominator shall be the Exercise Price resulting from such
adjustment. Such adjustment will be made successively whenever such a record date is fixed, provided that if two
or more such record dates or record dates referred to in this Section 4.1(b) are fixed within a period of 25 Trading
Days, such adjustment will be made successively as if each of such record dates occurred on the earliest of such
record dates;

(c)

if and whenever at any time during the Adjustment Period the Corporation shall fix a record date for the making
of a distribution to all or substantially all the holders of its outstanding Common Shares of (i) securities of any
class, whether of the Corporation or any other entity (other than Common Shares), (ii) rights, options or warrants
to subscribe for or purchase Common Shares (or other securities convertible into or exchangeable for Common
Shares), other than pursuant to a Rights Offering; (iii) evidences of its indebtedness or (iv) any property or other
assets (other than cash dividends paid in the normal course) then, in each such case, the Exercise Price shall be
adjusted immediately after such record date so that it shall equal the price determined by multiplying the Exercise
Price in effect on such record date by a fraction, of which the numerator shall be the total number of Common
Shares  outstanding  on  such  record  date  multiplied  by  the  Current  Market  Price  on  such  record  date,  less  the
excess,  if  any,  of  the  fair  market  value  on  such  record  date,  as  determined  by  the  Corporation  (whose
determination shall be conclusive), of such securities or other assets so issued or distributed over the fair market
value of any consideration received therefor by the Corporation from the holders of the Common Shares, and of
which the denominator shall be the total number of Common Shares outstanding on such record date multiplied
by the Current Market Price on such record date; and Common Shares owned by or held for the account of the
Corporation  shall  be  deemed  not  to  be  outstanding  for  the  purpose  of  any  such  computation;  such  adjustment
shall  be  made  successively  whenever  such  a  record  date  is  fixed;  to  the  extent  that  such  distribution  is  not  so
made, the Exercise Price shall be readjusted to the Exercise Price which would then be in effect if such record
date had not been fixed. Upon any adjustment of the Exercise Price pursuant to this Section 4.1(c), the Exchange
Rate will be adjusted immediately after such record date so that it will equal the rate determined by multiplying
the Exchange Rate in effect on such record date by a fraction, of which the numerator shall be the Exercise Price
in  effect  immediately  prior  to  such  adjustment  and  the  denominator  shall  be  the  Exercise  Price  resulting  from
such adjustment;

(d)

if and whenever at any time during the Adjustment Period, there is a reclassification of the Common Shares or a
capital  reorganization  of  the  Corporation  other  than  as  described  in  Section  4.1(a)  or  a  consolidation,
amalgamation, arrangement or merger of the Corporation with or into any other body corporate, trust, partnership
or  other  entity  (other  than  consolidations,  amalgamations,  arrangements  or  mergers  which  do  not  result  in  any
reclassification  of  the  outstanding  Common  Shares  or  a  change  of  the  Common  Shares  into  other  shares),  or  a
sale or conveyance of the property and assets of the Corporation as an entirety or substantially as an entirety to
any other body corporate, trust, partnership or other entity, any Registered Warrantholder who has not exercised
its

 
 
 
 
 
- 26 -

right  of  acquisition  prior  to  the  effective  date  of  such  reclassification,  capital  reorganization,  consolidation,
amalgamation,  arrangement  or  merger,  sale  or  conveyance,  upon  the  exercise  of  such  right  thereafter,  shall  be
entitled to receive upon payment of the Exercise Price and shall accept, in lieu of the number of Common Shares
that prior to such effective date the Registered Warrantholder would have been entitled to receive, the number of
shares or other securities or property of the Corporation or of the body corporate, trust, partnership or other entity
resulting from such merger, amalgamation or consolidation, or to which such sale or conveyance may be made, as
the case may be, that such Registered Warrantholder would have been entitled to receive on such reclassification,
capital  reorganization,  consolidation,  amalgamation,  arrangement  or  merger,  sale  or  conveyance,  if,  on  the
effective  date  thereof,  as  the  case  may  be,  the  Registered  Warrantholder  had  been  the  registered  holder  of  the
number of Common Shares to which prior to such effective date it was entitled to acquire upon the exercise of the
Warrants. If determined appropriate by the Warrant Agent, relying on advice of Counsel, to give effect to or to
evidence the provisions of this Section 4.1(d), the Corporation, its successor, or such purchasing body corporate,
partnership,  trust  or  other  entity,  as  the  case  may  be,  shall,  prior  to  or  contemporaneously  with  any  such
reclassification,  capital  reorganization,  consolidation,  amalgamation,  arrangement,  merger,  sale  or  conveyance,
enter into an indenture which shall provide, to the extent possible, for the application of the provisions set forth in
this Indenture with respect to the rights and interests thereafter of the Registered Warrantholders to the end that
the  provisions  set  forth  in  this  Indenture  shall  thereafter  correspondingly  be  made  applicable,  as  nearly  as  may
reasonably  be,  with  respect  to  any  shares,  other  securities  or  property  to  which  a  Registered  Warrantholder  is
entitled  on  the  exercise  of  its  acquisition  rights  thereafter. Any  indenture  entered  into  between  the  Corporation
and the Warrant Agent pursuant to the provisions of this Section 4.1(d) shall be a supplemental indenture entered
into  pursuant  to  the  provisions  of Article  8  hereof. Any  indenture  entered  into  between  the  Corporation,  any
successor to the Corporation or such purchasing body corporate, partnership, trust or other entity and the Warrant
Agent shall provide for adjustments which shall be as nearly equivalent as may be practicable to the adjustments
provided  in  this  Section  4.1  and  which  shall  apply  to  successive  reclassifications,  capital  reorganizations,
amalgamations, consolidations, mergers, sales or conveyances;

(e)

in any case in which this Section 4.1 shall require that an adjustment shall become effective immediately after a
record date for an event referred to herein, the Corporation may defer, until the occurrence of such event, issuing
to  the  Registered  Warrantholder  of  any  Warrant  exercised  after  the  record  date  and  prior  to  the  completion  of
such  event  the  additional  Common  Shares  issuable  by  reason  of  the  adjustment  required  by  such  event  before
giving  effect  to  such  adjustment;  provided,  however,  that  the  Corporation  shall  deliver  to  such  Registered
Warrantholder  an  appropriate  instrument  evidencing  such  Registered  Warrantholder’s  right  to  receive  such
additional Common Shares upon the occurrence of the event requiring such adjustment and the right to receive
any distributions made on such additional Common Shares declared in favour of holders of record of Common
Shares on and after the relevant date of exercise or such later date as such Registered Warrantholder would, but
for  the  provisions  of  this  Section  4.1(e),  have  become  the  holder  of  record  of  such  additional  Common  Shares
pursuant to Section 4.1;

 
 
 
 
- 27 -

(f)

(g)

(h)

in any case in which Section 4.1(a)(iii), Section 4.1(b) or Section 4.1(c) require that an adjustment be made to the
Exercise Price, no such adjustment shall be made if the Registered Warrantholders of the outstanding Warrants
receive,  subject  to  any  required  stock  exchange  or  regulatory  approval,  the  rights  or  warrants  referred  to  in
Section  4.1(a)(iii),  Section  4.1(b)  or  the  shares,  rights,  options,  warrants,  evidences  of  indebtedness  or  assets
referred to in Section 4.1(c), as the case may be, in such kind and number as they would have received if they had
been holders of Common Shares on the applicable record date or effective date, as the case may be, by virtue of
their outstanding Warrant having then been exercised into Common Shares at the Exercise Price in effect on the
applicable record date or effective date, as the case may be;

the  adjustments  provided  for  in  this  Section  4.1  are  cumulative,  and  shall,  in  the  case  of  adjustments  to  the
Exercise  Price  be  computed  to  the  nearest  whole  cent  and  shall  apply  to  successive  subdivisions,  re-divisions,
reductions, combinations, consolidations, distributions, issues or other events resulting in any adjustment under
the  provisions  of  this  Section  4.1,  provided  that,  notwithstanding  any  other  provision  of  this  Section,  no
adjustment of the Exercise Price shall be required unless such adjustment would require an increase or decrease of
at least 1% in the Exercise Price then in effect; provided, however, that any adjustments which by reason of this
Section  4.1(g)  are  not  required  to  be  made  shall  be  carried  forward  and  taken  into  account  in  any  subsequent
adjustment; and

after any adjustment pursuant to this Section 4.1, the term “ Common Shares” where used in this Indenture shall
be  interpreted  to  mean  securities  of  any  class  or  classes  which,  as  a  result  of  such  adjustment  and  all  prior
adjustments pursuant to this Section 4.1, the Registered Warrantholder is entitled to receive upon the exercise of
his Warrants, and the number of Common Shares indicated by any exercise made pursuant to a Warrant shall be
interpreted to mean the number of Common Shares or other property or securities a Registered Warrantholder is
entitled to receive, as a result of such adjustment and all prior adjustments pursuant to this Section 4.1, upon the
full exercise of a Warrant.

4.2 Entitlement to Common Shares on Exercise of Warrant.

All Common Shares or shares of any class or other securities, which a Registered Warrantholder is at the time in
question entitled to receive on the exercise of its Warrant, whether or not as a result of adjustments made pursuant to
this Article 4, shall, for the purposes of the  interpretation  of  this  Indenture,  be  deemed  to  be  Common  Shares  which
such Registered Warrantholder is entitled to acquire pursuant to such Warrant.

4.3 No Adjustment for Certain Transactions.

Notwithstanding anything in this Article 4, no adjustment shall be made in the acquisition rights attached to the
Warrants if the issue of Common Shares is being made pursuant to this Indenture or in connection with (a) any share
incentive  plan  or  restricted  share  plan  or  share  purchase  plan  in  force  from  time  to  time  for  directors,  officers,
employees,  consultants  or  other  service  providers  of  the  Corporation;  or  (b)  the  satisfaction  of  existing  instruments
issued at the date hereof.

 
 
 
 
 
 
4.4 Determination by Independent Firm.

- 28 -

In the event of any question arising with respect to the adjustments provided for in this Article 4 such question
shall be conclusively determined by an independent firm of chartered accountants other than the Auditors, who shall
have access to all necessary records of the Corporation, and such determination shall be binding upon the Corporation,
the Warrant Agent, all holders and all other persons interested therein.

4.5 Proceedings Prior to any Action Requiring Adjustment.

As a condition precedent to the taking of any action which would require an adjustment in any of the acquisition
rights  pursuant  to  any  of  the  Warrants,  including  the  number  of  Common  Shares  which  are  to  be  received  upon  the
exercise thereof, the Corporation shall take any action which may, in the opinion of Counsel, be necessary in order that
the Corporation has unissued and reserved in its authorized capital and may validly and legally issue as fully paid and
non-assessable all the Common Shares which the holders of such Warrants are entitled to receive on the full exercise
thereof in accordance with the provisions hereof.

4.6 Certificate of Adjustment.

The  Corporation  shall  from  time  to  time  immediately  after  the  occurrence  of  any  event  which  requires  an
adjustment  or  readjustment  as  provided  in  Section  4.1,  deliver  a  certificate  of  the  Corporation  to  the  Warrant Agent
specifying  the  nature  of  the  event  requiring  the  same  and  the  amount  of  the  adjustment  or  readjustment  necessitated
thereby  and  setting  forth  in  reasonable  detail  the  method  of  calculation  and  the  facts  upon  which  such  calculation  is
based, which certificate shall be supported by a certificate of the Corporation’s Auditors verifying such calculation. The
Warrant  Agent  shall  rely,  and  shall  be  protected  in  so  doing,  upon  the  certificate  of  the  Corporation  or  of  the
Corporation’s Auditor and any other document filed by the Corporation pursuant to this Article 4 for all purposes.

4.7 Notice of Special Matters.

The Corporation covenants with the Warrant Agent that, so long as any Warrant remains outstanding, it will give
notice to the Warrant Agent and to the Registered Warrantholders of its intention to fix a record date that is prior to the
Expiry Date for any matter for which an adjustment may be required pursuant to Section 4.1. Such notice shall specify
the particulars of such event and the record date for such event, provided that the Corporation shall only be required to
specify  in  the  notice  such  particulars  of  the  event  as  shall  have  been  fixed  and  determined  on  the  date  on  which  the
notice  is  given.  The  notice  shall  be  given  in  each  case  not  less  than  14  days  prior  to  such  applicable  record  date.  If
notice has been given and the adjustment is not then determinable, the Corporation shall promptly, after the adjustment
is  determinable,  file  with  the  Warrant  Agent  a  computation  of  the  adjustment  and  give  notice  to  the  Registered
Warrantholders of such adjustment computation.

4.8 No Action after Notice.

The  Corporation  covenants  with  the  Warrant Agent  that  it  will  not  close  its  transfer  books  or  take  any  other

corporate action which might deprive the Registered Warrantholder of the

 
 
 
 
 
 
- 29 -

opportunity  to  exercise  its  right  of  acquisition  pursuant  thereto  during  the  period  of  14  days  after  the  giving  of  the
certificate or notices set forth in Section 4.6 and Section 4.7.

4.9 Other Action.

If  the  Corporation,  after  the  date  hereof,  shall  take  any  action  affecting  the  Common  Shares  other  than  action
described in Section 4.1, which in the reasonable opinion of the directors of the Corporation would materially affect the
rights of Registered Warrantholders, the Exercise Price and/or Exchange Rate, the number of Common Shares which
may  be  acquired  upon  exercise  of  the  Warrants  shall  be  adjusted  in  such  manner  and  at  such  time,  by  action  of  the
directors,  acting  reasonably  and  in  good  faith,  in  their  sole  discretion  as  they  may  determine  to  be  equitable  to  the
Registered  Warrantholders  in  the  circumstances,  provided  that  no  such  adjustment  will  be  made  unless  any  requisite
prior approval of any stock exchange on which the Common Shares are listed for trading has been obtained.

4.10 Protection of Warrant Agent.

The Warrant Agent shall not:

(i)

(ii)

at any time be under any duty or responsibility to any Registered Warrantholder to determine whether any
facts exist which may require any adjustment contemplated by Section 4.1, or with respect to the nature or
extent of any such adjustment when made, or with respect to the method employed in making the same;

be accountable with respect to the validity or value (or the kind or amount) of any Common Shares or of
any other securities or property which may at any time be issued or delivered upon the exercise of the rights
attaching to any Warrant;

(iii) be responsible for any failure of the Corporation to issue, transfer or deliver Common Shares or certificates
for the same upon the surrender of any Warrants for the purpose of the exercise of such rights or to comply
with any of the covenants contained in this Article 4; and

(iv)

incur  any  liability  or  be  in  any  way  responsible  for  the  consequences  of  any  breach  on  the  part  of  the
Corporation  of  any  of  the  representations,  warranties  or  covenants  herein  contained  or  of  any  acts  of  the
directors, officers, employees, agents or servants of the Corporation.

4.11 Participation by Warrantholder.

No adjustments shall be made pursuant to this Article 4 if the Registered Warrantholders are entitled to participate
in any event described in this Article 4 on the same terms, mutatis mutandis, as if the Registered Warrantholders had
exercised their Warrants prior to, or on the effective date or record date of, such event.

 
 
 
 
 
 
 
 
 
 
 
 
 
- 30 -

ARTICLE 5
RIGHTS OF THE CORPORATION AND COVENANTS

5.1 Optional Purchases by the Corporation.

Subject to compliance with Applicable Securities Laws and approval of applicable regulatory authorities and any
stock exchange on which the Common Shares are listed, the Corporation may from time to time purchase by private
contract or otherwise any of the Warrants. Any such purchase shall be made at the lowest price or prices at which, in
the opinion of the directors, such Warrants are then obtainable, plus reasonable costs of purchase, and may be made in
such manner, from such persons and on such other terms as the Corporation, in its sole discretion, may determine. In
the case of Certificated Warrants, Warrant Certificates representing the Warrants purchased pursuant to this Section 5.1
shall  forthwith  be  delivered  to  and  cancelled  by  the  Warrant  Agent  and  reflected  accordingly  on  the  register  of
Warrants. In the case of Uncertificated Warrants, the Warrants purchased pursuant to this Section 5.1 shall be reflected
accordingly  on  the  register  of  Warrants  and  in  accordance  with  procedures  prescribed  by  the  Depository  under  the
Book Based System. No Warrants shall be issued in replacement thereof.

5.2 General Covenants.

The Corporation covenants with the Warrant Agent that so long as any Warrants remain outstanding:

(a)

(b)

(c)

(d)

(a)

it will reserve and keep available a sufficient number of Common Shares for the purpose of enabling it to satisfy
its obligations to issue Common Shares upon the exercise of the Warrants;

it will cause the Common Shares from time to time acquired pursuant to the exercise of the Warrants to be duly
issued and delivered in accordance with the Warrants and the terms hereof;

all Common Shares which shall be issued upon exercise of the right to acquire provided for herein shall be fully
paid and non-assessable;

it  will  use  reasonable  commercial  efforts  to  maintain  its  corporate  existence  and  carry  on  its  business  in  the
ordinary course;

it will use reasonable commercial efforts to ensure that all Common Shares outstanding or issuable from time to
time (including without limitation the Common Shares issuable on the exercise of the Warrants) continue to be or
are  listed  and  posted  for  trading  on  the  TSXV  (or  such  other  Canadian  stock  exchange  acceptable  to  the
Corporation)  and  NASDAQ,  provided  that  this  clause  shall  not  be  construed  as  limiting  or  restricting  the
Corporation  from  completing  a  consolidation,  amalgamation,  arrangement  takeover  bid  or  merger  that  would
result in the Common Shares ceasing to be listed and posted for trading on the TSXV or NASDAQ, so long as the
holders of Common Shares receive securities of an entity which is listed on a stock exchange in Canada or the
United States, or cash, or the holders of the Common Shares have approved the transaction in

 
 
 
 
 
 
 
 
 
- 31 -

accordance with the requirements of applicable corporate and securities laws and the policies of the TSXV and, to
the extent applicable, NASDAQ;

(b)

it  will  make  all  requisite  filings  under  applicable  Canadian  securities  legislation  including  those  necessary  to
remain a reporting issuer not in default in each of the provinces and other Canadian jurisdictions where it is or
becomes a reporting issuer; and

(c)

generally, it will well and truly perform and carry out all of the acts or things to be done by it as provided in this
Indenture.

5.3 Warrant Agent’s Remuneration and Expenses.

The Corporation covenants that it will pay to the Warrant Agent from time to time reasonable remuneration for its
services  hereunder  and  will  pay  or  reimburse  the  Warrant  Agent  upon  its  request  for  all  reasonable  expenses,
disbursements  and  advances  incurred  or  made  by  the  Warrant Agent  in  the  administration  or  execution  of  the  trusts
hereby created (including the reasonable compensation and the disbursements of its Counsel and all other advisers and
assistants not regularly in its employ) both before any default hereunder and thereafter until all duties of the Warrant
Agent hereunder shall be finally and fully performed. Any amount owing hereunder and remaining unpaid after 30 days
from the invoice date will bear interest at the then current rate charged by the Warrant Agent against unpaid invoices
and  shall  be  payable  upon  demand.  This  Section  shall  survive  the  resignation  of  the  Warrant  Agent  and/  or  the
termination of this Indenture.

5.4 Performance of Covenants by Warrant Agent.

If the Corporation shall fail to perform any of its covenants contained in this Indenture, the Warrant Agent may
notify  the  Registered  Warrantholders  of  such  failure  on  the  part  of  the  Corporation  or  may  itself  perform  any  of  the
covenants  capable  of  being  performed  by  it  but,  subject  to  Section  9.2,  shall  be  under  no  obligation  to  perform  said
covenants or to notify the Registered Warrantholders of such performance by it. All sums expended or advanced by the
Warrant Agent in so doing shall be repayable as provided in Section 5.3. No such performance, expenditure or advance
by the Warrant Agent shall relieve the Corporation of any default hereunder or of its continuing obligations under the
covenants herein contained.

5.5 Enforceability of Warrants.

The  Corporation  covenants  and  agrees  that  it  is  duly  authorized  to  create  and  issue  the  Warrants  to  be  issued
hereunder  and  that  the  Warrants,  when  issued  and Authenticated  as  herein  provided,  will  be  valid  and  enforceable
against  the  Corporation  in  accordance  with  the  provisions  hereof  and  the  terms  hereof  and  that,  subject  to  the
provisions of this Indenture, the Corporation will cause the Common Shares from time to time acquired upon exercise
of Warrants issued under this Indenture to be duly issued and delivered in accordance with the terms of this Indenture.

 
 
 
 
 
 
 
 
- 32 -

ARTICLE 6
ENFORCEMENT

6.1

Suits by Registered Warrantholders.

All or any of the rights conferred upon any Registered Warrantholder by any of the terms of this Indenture may
be  enforced  by  the  Registered  Warrantholder  by  appropriate  proceedings  but  without  prejudice  to  the  right  which  is
hereby conferred upon the Warrant Agent to proceed in its own name to enforce each and all of the provisions herein
contained for the benefit of the Registered Warrantholders.

6.2

Suits by the Corporation.

The Corporation shall have the right to enforce full payment of the Exercise Price of all Common Shares issued
by the Warrant Agent to a Registered Warrantholder hereunder and shall be entitled to demand such payment from the
Registered Warrantholder or alternatively to instruct the Warrant Agent to cancel the share certificates and amend the
securities register accordingly.

6.3

Immunity of Shareholders, etc.

The Warrant Agent and the Warrantholders hereby waive and release any right, cause of action or remedy now or
hereafter  existing  in  any  jurisdiction  against  any  incorporator  or  any  past,  present  or  future  shareholder,  trustee,
employee or agent of the Corporation or any successor entity on any covenant, agreement, representation or warranty
by the Corporation herein.

6.4 Waiver of Default.

Upon the happening of any default hereunder:

(i)

(ii)

the Registered Warrantholders of not less than 51% of the Warrants then outstanding shall have power (in
addition  to  the  powers  exercisable  by  Extraordinary  Resolution)  by  requisition  in  writing  to  instruct  the
Warrant Agent  to  waive  any  default  hereunder  and  the  Warrant Agent  shall  thereupon  waive  the  default
upon such terms and conditions as shall be prescribed in such requisition; or

the Warrant Agent shall have power to waive any default hereunder upon such terms and conditions as the
Warrant Agent may deem advisable, on the advice of Counsel, if, in the Warrant Agent’s opinion, based on
the advice of Counsel, the same shall have been cured or adequate provision made therefor;

provided that no delay or omission of the Warrant Agent or of the Registered Warrantholders to exercise any right or
power accruing upon any default shall impair any such right or power or shall be construed to be a waiver of any such
default  or  acquiescence  therein  and  provided  further  that  no  act  or  omission  either  of  the  Warrant Agent  or  of  the
Registered  Warrantholders  in  the  premises  shall  extend  to  or  be  taken  in  any  manner  whatsoever  to  affect  any
subsequent default hereunder of the rights resulting therefrom.

 
 
 
 
 
 
 
 
 
 
- 33 -

ARTICLE 7
MEETINGS OF REGISTERED WARRANTHOLDERS

7.1 Right to Convene Meetings.

The  Warrant Agent  may  at  any  time  and  from  time  to  time,  and  shall  on  receipt  of  a  written  request  of  the
Corporation or of a Warrantholders’ Request and upon being indemnified and funded to its reasonable satisfaction by
the  Corporation  or  by  the  Registered  Warrantholders  signing  such  Warrantholders’  Request  against  the  costs  which
may  be  incurred  in  connection  with  the  calling  and  holding  of  such  meeting,  convene  a  meeting  of  the  Registered
Warrantholders. If the Warrant Agent fails to so call a meeting within seven days after receipt of such written request of
the Corporation or such Warrantholders’ Request and the indemnity and funding given as aforesaid, the Corporation or
such Registered Warrantholders, as the case may be, may convene such meeting. Every such meeting shall be held in
the City of Montreal, Québec or at such other place as may be approved or determined by the Warrant Agent.

7.2 Notice.

At  least  21  days’  prior  written  notice  of  any  meeting  of  Registered  Warrantholders  shall  be  given  to  the
Registered Warrantholders in the manner provided for in Section 10.2 and a copy of such notice shall be sent by mail to
the  Warrant  Agent  (unless  the  meeting  has  been  called  by  the  Warrant  Agent)  and  to  the  Corporation  (unless  the
meeting has been called by the Corporation). Such notice shall state the time when and the place where the meeting is
to  be  held,  shall  state  briefly  the  general  nature  of  the  business  to  be  transacted  thereat  and  shall  contain  such
information  as  is  reasonably  necessary  to  enable  the  Registered  Warrantholders  to  make  a  reasoned  decision  on  the
matter, but it shall not be necessary for any such notice to set out the terms of any resolution to be proposed or any of
the provisions of this Section 7.2.

7.3 Chairman.

An individual (who need not be a Registered Warrantholder) designated in writing by the Warrant Agent shall be
chairman of the meeting and if no individual is so designated, or if the individual so designated is not present within
fifteen minutes from the time fixed for the holding of the meeting, the Registered Warrantholders present in person or
by proxy shall choose an individual present to be chairman.

7.4 Quorum.

Subject to the provisions of Section 7.11, at any meeting of the Registered Warrantholders a quorum shall consist
of  Registered  Warrantholder(s)  present  in  person  or  by  proxy  and  entitled  to  purchase  at  least  20%  of  the  aggregate
number of Common Shares which could be acquired pursuant to all the then-outstanding Warrants. If a quorum of the
Registered Warrantholders shall not be present within thirty minutes from the time fixed for holding any meeting, the
meeting, if summoned by Registered Warrantholders or on a Warrantholders’ Request, shall be dissolved; but in any
other case the meeting shall be adjourned to the same day in the next week (unless such day is not a Business Day, in
which case it shall be adjourned to the next following Business Day) at the same time and place and no notice of the
adjournment need be given. Any business may be brought before or dealt with at an adjourned meeting which might
have been dealt with at the original meeting in accordance with the notice calling the

 
 
 
 
 
 
- 34 -

same. No business shall be transacted at any meeting unless a quorum be present at the commencement of business. At
the  adjourned  meeting  the  Registered  Warrantholders  present  in  person  or  by  proxy  shall  form  a  quorum  and  may
transact the business for which the meeting was originally convened, notwithstanding that they may not be entitled to
acquire  at  least  20%  of  the  aggregate  number  of  Common  Shares  which  may  be  acquired  pursuant  to  all  then
outstanding Warrants.

7.5 Power to Adjourn.

The  chairman  of  any  meeting  at  which  a  quorum  of  the  Registered  Warrantholders  is  present  may,  with  the
consent of the meeting, adjourn any such meeting, and no notice of such adjournment need be given except such notice,
if any, as the meeting may prescribe.

7.6

Show of Hands.

Every question submitted to a meeting shall be decided in the first place by a majority of the votes given on a
show of hands except that votes on an Extraordinary Resolution shall be given in the manner hereinafter provided. At
any such meeting, unless a poll is duly demanded as herein provided, a declaration by the chairman that a resolution has
been carried or carried unanimously or by a particular majority or lost or not carried by a particular majority shall be
conclusive evidence of the fact.

7.7 Poll and Voting.

(a) On every Extraordinary Resolution, and on any other question submitted to a meeting and after a vote by show of
hands when demanded by the chairman or by one or more of the Registered Warrantholders acting in person or
by proxy and entitled to acquire in the aggregate at least 5% of the aggregate number of Common Shares which
could  be  acquired  pursuant  to  all  the  Warrants  then  outstanding,  a  poll  shall  be  taken  in  such  manner  as  the
chairman shall direct. Questions other than those required to be determined by Extraordinary Resolution shall be
decided by a majority of the votes cast on the poll.

(b) On a show of hands, every person who is present and entitled to vote, whether as a Registered Warrantholder or
as  proxy  for  one  or  more  absent  Registered  Warrantholders,  or  both,  shall  have  one  vote.  On  a  poll,  each
Registered  Warrantholder  present  in  person  or  represented  by  a  proxy  duly  appointed  by  instrument  in  writing
shall  be  entitled  to  one  vote  in  respect  of  each  Warrant  then  held  or  represented  by  it. A  proxy  need  not  be  a
Registered Warrantholder. The chairman of any meeting shall be entitled, both on a show of hands and on a poll,
to vote in respect of the Warrants, if any, held or represented by him.

7.8 Regulations.

(a)

The Warrant Agent, or the Corporation with the approval of the Warrant Agent, may from time to time make and
from time to time vary such regulations as it shall think fit for the setting of the record date for a meeting for the
purpose of determining Registered Warrantholders entitled to receive notice of and to vote at the meeting.

 
 
 
 
 
 
 
 
 
- 35 -

(b) Any regulations so made shall be binding and effective and the votes given in accordance therewith shall be valid
and  shall  be  counted.  Save  as  such  regulations  may  provide,  the  only  persons  who  shall  be  recognized  at  any
meeting  as  a  Registered  Warrantholder,  or  be  entitled  to  vote  or  be  present  at  the  meeting  in  respect  thereof
(subject to Section 7.9), shall be Registered Warrantholders or proxies of Registered Warrantholders.

7.9 Corporation and Warrant Agent May be Represented.

The  Corporation  and  the  Warrant Agent,  by  their  respective  directors,  officers,  agents,  and  employees  and  the

Counsel for the Corporation and for the Warrant Agent may attend any meeting of the Registered Warrantholders.

7.10 Powers Exercisable by Extraordinary Resolution.

In  addition  to  all  other  powers  conferred  upon  them  by  any  other  provisions  of  this  Indenture  or  by  law,  the
Registered  Warrantholders  at  a  meeting  shall,  subject  to  the  provisions  of  Section  7.11,  have  the  power  exercisable
from time to time by Extraordinary Resolution:

(i)

to agree to any modification, abrogation, alteration, compromise or arrangement of the rights of Registered
Warrantholders  or  the  Warrant Agent  in  its  capacity  as  warrant  agent  hereunder  (subject  to  the  Warrant
Agent’s  prior  consent,  acting  reasonably)  or  on  behalf  of  the  Registered  Warrantholders  against  the
Corporation whether such rights arise under this Indenture or otherwise;

(ii)

to amend, alter or repeal any Extraordinary Resolution previously passed or sanctioned by the Registered
Warrantholders;

(iii)

(iv)

(v)

(vi)

to direct or to authorize the Warrant Agent, subject to Section 9.2(a) hereof, to enforce any of the covenants
on the part of the Corporation contained in this Indenture or to enforce any of the rights of the Registered
Warrantholders in any manner specified in such Extraordinary Resolution or to refrain from enforcing any
such covenant or right;

to waive, and to direct the Warrant Agent to waive, any default on the part of the Corporation in complying
with  any  provisions  of  this  Indenture  either  unconditionally  or  upon  any  conditions  specified  in  such
Extraordinary Resolution;

to restrain any Registered Warrantholder from taking or instituting any suit, action or proceeding against the
Corporation for the enforcement of any of the covenants on the part of the Corporation in this Indenture or
to enforce any of the rights of the Registered Warrantholders;

to direct any Registered Warrantholder who, as such, has brought any suit, action or proceeding to stay or to
discontinue or otherwise to deal with the same upon payment of the costs, charges and expenses reasonably
and properly incurred by such Registered Warrantholder in connection therewith;

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 36 -

(vii) to assent to any change in or omission from the provisions contained in this Indenture or any ancillary or
supplemental instrument which may be agreed to by the Corporation, and to authorize the Warrant Agent to
concur in and execute any ancillary or supplemental indenture embodying the change or omission;

(viii) with the consent of the Corporation, such consent not to be unreasonably withheld, to remove the Warrant
Agent or its successor in office and to appoint a new warrant agent or warrant agents to take the place of the
Warrant Agent so removed; and

(ix)

to  assent  to  any  compromise  or  arrangement  with  any  creditor  or  creditors  or  any  class  or  classes  of
creditors,  whether  secured  or  otherwise,  and  with  holders  of  any  shares  or  other  securities  of  the
Corporation.

7.11 Meaning of Extraordinary Resolution.

(a)

(b)

The expression “Extraordinary Resolution” when used in this Indenture means, subject as hereinafter provided
in this Section 7.11 and in Section 7.14, a resolution proposed at a meeting of Registered Warrantholders duly
convened for that purpose and held in accordance with the provisions of this Article 7 at which there are present
in  person  or  by  proxy  Registered  Warrantholders  holding  at  least  20%  of  the  aggregate  number  of  Common
Shares that could be acquired and passed by the affirmative votes of Registered Warrantholders holding not less
than 66 2⁄3% of the aggregate number of Common Shares that could be acquired at the meeting and voted on the
poll upon such resolution.

If, at the meeting at which an Extraordinary Resolution is to be considered, Registered Warrantholders holding at
least  20%  of  the  aggregate  number  of  Common  Shares  that  could  be  acquired  are  not  present  in  person  or  by
proxy within 30 minutes after the time appointed for the meeting, then the meeting, if convened by Registered
Warrantholders or on a Warrantholders’ Request, shall be dissolved; but in any other case it shall stand adjourned
to such day, being not less than 15 or more than 60 days later, and to such place and time as may be appointed by
the chairman. Not less than 14 days’ prior notice shall be given of the time and place of such adjourned meeting
in the manner provided for in Section 10.2. Such notice shall state that at the adjourned meeting the Registered
Warrantholders present in person or by proxy shall form a quorum but it shall not be necessary to set forth the
purposes  for  which  the  meeting  was  originally  called  or  any  other  particulars.  At  the  adjourned  meeting  the
Registered Warrantholders present in person or by proxy shall form a quorum and may transact the business for
which the meeting was originally convened and a resolution proposed at such adjourned meeting and passed by
the requisite vote as provided in Section 7.11(a) shall be an Extraordinary Resolution within the meaning of this
Indenture  notwithstanding  that  Registered  Warrantholders  entitled  to  acquire  at  least  20%  of  the  aggregate
number of Common Shares which may be acquired pursuant to all the then outstanding Warrants are not present
in person or by proxy at such adjourned meeting.

(c)

Subject to Section 7.14, votes on an Extraordinary Resolution shall always be given on a poll and no demand for
a poll on an Extraordinary Resolution shall be necessary.

 
 
 
 
 
 
 
 
 
 
 
7.12 Powers Cumulative.

- 37 -

Any one or more of the powers or any combination of the powers in this Indenture stated to be exercisable by the
Registered  Warrantholders  by  Extraordinary  Resolution  or  otherwise  may  be  exercised  from  time  to  time  and  the
exercise of any one or more of such powers or any combination of powers from time to time shall not be deemed to
exhaust the right of the Registered Warrantholders to exercise such power or powers or combination of powers then or
thereafter from time to time.

7.13 Minutes.

Minutes of all resolutions and proceedings at every meeting of Registered Warrantholders shall be made and duly
entered  in  books  to  be  provided  from  time  to  time  for  that  purpose  by  the  Warrant  Agent  at  the  expense  of  the
Corporation, and any such minutes as aforesaid, if signed by the chairman or the secretary of the meeting at which such
resolutions  were  passed  or  proceedings  had  shall  be  prima  facie  evidence  of  the  matters  therein  stated  and,  until  the
contrary is proved, every such meeting in respect of the proceedings of which minutes shall have been made shall be
deemed to have been duly convened and held, and all resolutions passed thereat or proceedings taken shall be deemed
to have been duly passed and taken.

7.14 Instruments in Writing.

All  actions  which  may  be  taken  and  all  powers  that  may  be  exercised  by  the  Registered  Warrantholders  at  a
meeting  held  as  provided  in  this Article  7  may  also  be  taken  and  exercised  by  Registered  Warrantholders  holding  at
least 66 2⁄3% of the aggregate number of all of the then outstanding Warrants by an instrument in writing signed in one
or  more  counterparts  by  such  Registered  Warrantholders  in  person  or  by  attorney  duly  appointed  in  writing,  and  the
expression “Extraordinary Resolution” when used in this Indenture shall include an instrument so signed.

7.15 Binding Effect of Resolutions.

Every resolution and every Extraordinary Resolution passed in accordance with the provisions of this Article 7 at
a meeting of Registered Warrantholders shall be binding upon all the Warrantholders, whether present at or absent from
such  meeting,  and  every  instrument  in  writing  signed  by  Registered  Warrantholders  in  accordance  with  Section  7.14
shall be binding upon all the Warrantholders, whether signatories thereto or not, and each and every Warrantholder and
the Warrant Agent (subject to the provisions for indemnity herein contained) shall be bound to give effect accordingly
to every such resolution and instrument in writing.

7.16 Holdings by Corporation Disregarded.

In  determining  whether  Registered  Warrantholders  holding  Warrants  evidencing  the  entitlement  to  acquire  the
required  number  of  Common  Shares  are  present  at  a  meeting  of  Registered  Warrantholders  for  the  purpose  of
determining a quorum or have concurred in any consent, waiver, Extraordinary Resolution, Warrantholders’ Request or
other  action  under  this  Indenture,  Warrants  owned  legally  or  beneficially  by  the  Corporation  shall  be  disregarded  in
accordance with the provisions of Section 10.7.

 
 
 
 
 
 
- 38 -

ARTICLE 8
SUPPLEMENTAL INDENTURES

8.1 Provision for Supplemental Indentures for Certain Purposes.

From  time  to  time,  the  Corporation  (when  authorized  by  action  of  the  directors)  and  the  Warrant Agent  may,
subject to the provisions hereof and they shall, when so directed in accordance with the provisions hereof, execute and
deliver by their proper officers, indentures or instruments supplemental hereto, which thereafter shall form part hereof,
for any one or more or all of the following purposes:

(i)

setting forth any adjustments resulting from the application of the provisions of Article 4;

(ii)

adding to the provisions hereof such additional covenants and enforcement provisions as, in the opinion of
Counsel,  are  necessary  or  advisable  in  the  premises,  provided  that  the  same  are  not  in  the  opinion  of  the
Warrant  Agent,  relying  on  the  advice  of  Counsel,  prejudicial  to  the  interests  of  the  Registered
Warrantholders;

(iii) giving effect to any Extraordinary Resolution passed as provided in Section 7.11;

(iv) making such provisions not inconsistent with this Indenture as may be necessary or desirable with respect to
matters or questions arising hereunder or for the purpose of obtaining a listing or quotation of the Warrants
on any stock exchange, provided that such provisions are not, in the opinion of the Warrant Agent, relying
on the advice of Counsel, prejudicial to the interests of the Registered Warrantholders;

(v)

adding to or altering the provisions hereof in respect of the transfer of Warrants, making provision for the
exchange of Warrants, and making any modification in the form of the Warrant Certificates which does not
affect the substance thereof;

(vi) modifying  any  of  the  provisions  of  this  Indenture,  including  relieving  the  Corporation  from  any  of  the
obligations, conditions or restrictions herein contained, provided that such modification or relief shall be or
become  operative  or  effective  only  if,  in  the  opinion  of  the  Warrant  Agent,  relying  on  the  advice  of
Counsel, such modification or relief in no way prejudices any of the rights of the Registered Warrantholders
or of the Warrant Agent, and provided further that the Warrant Agent may in its sole discretion decline to
enter into any such supplemental indenture which in its opinion may not afford adequate protection to the
Warrant Agent when the same shall become operative;

(vii) providing for the issuance of additional Warrants hereunder, including Warrants in excess of the number set
out  in  Section  2.1  and  any  consequential  amendments  hereto  as  may  be  required  by  the  Warrant Agent
relying on the advice of Counsel; and

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 39 -

(viii) for  any  other  purpose  not  inconsistent  with  the  terms  of  this  Indenture,  including  the  correction  or
rectification of any ambiguities, defective or inconsistent provisions, errors, mistakes or omissions herein,
provided  that  in  the  opinion  of  the  Warrant  Agent,  relying  on  the  advice  of  Counsel,  the  rights  of  the
Warrant Agent and of the Registered Warrantholders are in no way prejudiced thereby.

8.2

Successor Entities.

In the case of the consolidation, amalgamation, arrangement, merger or transfer of the undertaking or assets of the
Corporation as an entirety or substantially as an entirety to or with another entity (“successor entity”),  the  successor
entity resulting from such consolidation, amalgamation, arrangement, merger or transfer (if not the Corporation) shall
expressly assume, by supplemental indenture satisfactory in form to the Warrant Agent and executed and delivered to
the Warrant Agent, the due and punctual performance and observance of each and every covenant and condition of this
Indenture to be performed and observed by the Corporation.

ARTICLE 9
CONCERNING THE WARRANT AGENT

9.1 Trust Indenture Legislation.

(a)

If and to the extent that any provision of this Indenture limits, qualifies or conflicts with a mandatory requirement
of Applicable Legislation, such mandatory requirement shall prevail.

(b) The  Corporation  and  the  Warrant Agent  agree  that  each  will,  at  all  times  in  relation  to  this  Indenture  and  any

action to be taken hereunder, observe and comply with and be entitled to the benefits of Applicable Legislation.

9.2 Rights and Duties of Warrant Agent.

(a)

In the exercise of the rights and duties prescribed or conferred by the terms of this Indenture, the Warrant Agent
shall exercise that degree of care, diligence and skill that a reasonably prudent warrant agent would exercise in
comparable circumstances. No provision of this Indenture shall be construed to relieve the Warrant Agent from
liability for its own gross negligent action, wilful misconduct, bad faith or fraud under this Indenture.

(b) The obligation of the Warrant Agent to commence or continue any act, action or proceeding for the purpose of
enforcing any rights of the Warrant Agent or the Registered Warrantholders hereunder shall be conditional upon
the  Registered  Warrantholders  furnishing,  when  required  by  notice  by  the  Warrant Agent,  sufficient  funds  to
commence or to continue such act, action or proceeding and an indemnity reasonably satisfactory to the Warrant
Agent to protect and to hold harmless the Warrant Agent and its officers, directors, employees and agents, against
the costs, charges and expenses and liabilities to be incurred thereby and any loss and damage it may suffer by
reason thereof. None of the provisions contained in this Indenture shall require the Warrant Agent to expend or to
risk its own funds or otherwise to incur financial liability

 
 
 
 
 
 
 
 
 
 
- 40 -

in the performance of any of its duties or in the exercise of any of its rights or powers unless indemnified and
funded as aforesaid.

(c)

The  Warrant Agent  may,  before  commencing  or  at  any  time  during  the  continuance  of  any  such  act,  action  or
proceeding,  require  the  Registered  Warrantholders,  at  whose  instance  it  is  acting  to  deposit  with  the  Warrant
Agent the Warrants Certificates held by them, for which Warrants the Warrant Agent shall issue receipts.

(d) Every provision of this Indenture that by its terms relieves the Warrant Agent of liability or entitles it to rely upon

any evidence submitted to it is subject to the provisions of Applicable Legislation.

9.3 Evidence, Experts and Advisers.

(a)

(b)

In  addition  to  the  reports,  certificates,  opinions  and  other  evidence  required  by  this  Indenture,  the  Corporation
shall furnish to the Warrant Agent such additional evidence of compliance with any provision hereof, and in such
form, as may be prescribed by Applicable Legislation or as the Warrant Agent may reasonably require by written
notice to the Corporation.

In the exercise of its rights and duties hereunder, the Warrant Agent may, if it is acting in good faith, rely as to
the truth of the statements and the accuracy of the opinions expressed in statutory declarations, opinions, reports,
written  requests,  consents,  or  orders  of  the  Corporation,  certificates  of  the  Corporation  or  other  evidence
furnished to the Warrant Agent pursuant to a request of the Warrant Agent, provided that such evidence complies
with  Applicable  Legislation  and  that  the  Warrant  Agent  complies  with  Applicable  Legislation  and  that  the
Warrant Agent examines the same and determines that such evidence complies with the applicable requirements
of this Indenture.

(c) Whenever it is provided in this Indenture or under Applicable Legislation that the Corporation shall deposit with
the Warrant Agent resolutions, certificates, reports, opinions, requests, orders or other documents, it is intended
that the truth, accuracy and good faith on the effective date thereof and the facts and opinions stated in all such
documents so deposited shall, in each and every such case, be conditions precedent to the right of the Corporation
to have the Warrant Agent take the action to be based thereon.

(d) The Warrant Agent may employ or retain such Counsel, accountants, appraisers or other experts or advisers as it
may reasonably require for the purpose of discharging its duties hereunder and may pay reasonable remuneration
for  all  services  so  performed  by  any  of  them,  without  taxation  of  costs  of  any  Counsel,  and  shall  not  be
responsible  for  any  misconduct  or  negligence  on  the  part  of  any  such  experts  or  advisers  who  have  been
appointed with due care by the Warrant Agent.

(e)

The Warrant Agent may act and rely and shall be protected in acting and relying in good faith on the opinion or
advice of or information obtained from any Counsel, accountant, appraiser, engineer or other expert or adviser,
whether retained or employed by the

 
 
 
 
 
 
 
 
 
 
 
- 41 -

Corporation or by the Warrant Agent, in relation to any matter arising in the administration of the agency hereof.

9.4 Documents, Monies, etc. Held by Warrant Agent.

(a) Any  monies,  securities,  documents  of  title  or  other  instruments  that  may  at  any  time  be  held  by  the  Warrant
Agent  shall  be  placed  in  the  deposit  vaults  of  the  Warrant Agent  or  of  any  Canadian  chartered  bank  listed  in
Schedule I of the Bank Act (Canada), or deposited for safekeeping with any such bank. Any monies held pending
the  application  or  withdrawal  thereof  under  any  provisions  of  this  Indenture,  shall  be  held,  invested  and
reinvested  in  Permitted  Investments  as  directed  in  writing  by  the  Corporation.  Permitted  Investments  shall  be
treasury bills guaranteed by the Government of Canada having a term to maturity not to exceed ninety (90) days,
or term deposits or bankers’ acceptances of a Canadian chartered bank having a term to maturity not to exceed
ninety  (90)  days,  or  such  other  investments  that  is  in  accordance  with  the  Warrant Agent’s  standard  type  of
investments. Unless otherwise specifically provided herein, all interest or other income received by the Warrant
Agent in respect of such deposits and investments shall belong to the Corporation.

(b) Any written direction for the investment or release of funds received shall be received by the Warrant Agent by
9:00 a.m. (Montreal time) on the Business Day on which such investment or release is to be made, failing which
such direction will be handled on a commercially reasonable efforts basis and may result in funds being invested
or released on the next Business Day.

(c)

(d)

The Warrant Agent shall have no responsibility or liability for any diminution of any funds resulting from any
investment  made  in  accordance  with  this  Indenture,  including  any  losses  on  any  investment  liquidated  prior  to
maturity in order to make a payment required hereunder.

In  the  event  that  the  Warrant Agent  does  not  receive  a  direction  or  only  a  partial  direction,  the  Warrant Agent
may hold cash balances constituting part or all of such monies and may, but need not, invest same in its deposit
department,  the  deposit  department  of  one  of  its  affiliates,  or  the  deposit  department  of  a  Canadian  chartered
bank;  but  the  Warrant Agent,  its  affiliates  or  a  Canadian  chartered  bank  shall  not  be  liable  to  account  for  any
profit to any parties to this Indenture or to any other person or entity.

9.5 Actions by Warrant Agent to Protect Interest.

The Warrant Agent shall have power to institute and to maintain such actions and proceedings as it may consider

necessary or expedient to preserve, protect or enforce its interests and the interests of the Registered Warrantholders.

9.6 Warrant Agent Not Required to Give Security.

The Warrant Agent shall not be required to give any bond or security in respect of the execution of the agency

and powers of this Indenture or otherwise in respect of the premises.

 
 
 
 
 
 
 
 
 
 
9.7 Protection of Warrant Agent.

- 42 -

By way of supplement to the provisions of any law for the time being relating to the Warrant Agent it is expressly

declared and agreed as follows:

(i)

(ii)

the Warrant Agent shall not be liable for or by reason of any statements of fact or recitals in this Indenture
or in the Warrant Certificates (except the representation contained in Section 9.9 or in the authentication of
the Warrant Agent on the Warrant Certificates) or be required to verify the same, but all such statements or
recitals are and shall be deemed to be made by the Corporation;

nothing herein contained shall impose any obligation on the Warrant Agent to see to or to require evidence
of  the  registration  or  filing  (or  renewal  thereof)  of  this  Indenture  or  any  instrument  ancillary  or
supplemental hereto;

(iii)

the Warrant Agent shall not be bound to give notice to any person or persons of the execution hereof;

(iv)

(v)

the Warrant Agent shall not incur any liability or responsibility whatever or be in any way responsible for
the consequence of any breach on the part of the Corporation of any of its covenants herein contained or of
any acts of any directors, officers, employees, agents or servants of the Corporation;

the  Corporation  hereby  indemnifies  and  agrees  to  hold  harmless  the  Warrant  Agent,  its  affiliates,  their
officers, directors, employees, agents, successors and assigns from and against any and all liabilities, losses,
damages,  penalties,  claims,  actions,  suits,  costs,  expenses  and  disbursements,  including  legal  fees  and
disbursements of whatever kind and nature which may at any time be imposed on or incurred by or asserted
against  the  Warrant Agent,  whether  groundless  or  otherwise,  arising  from  or  out  of  any  act,  omission  or
error of the Warrant Agent, provided that the Corporation shall not be required to indemnify the Warrant
Agent in the event of the gross negligence or wilful misconduct of the Warrant Agent, and this provision
shall  survive  the  resignation  or  removal  of  the  Warrant  Agent  or  the  termination  or  discharge  of  this
Indenture; and

(vi) notwithstanding the foregoing or any other provision of this Indenture, any liability of the Warrant Agent
shall  be  limited,  in  the  aggregate,  to  the  amount  of  annual  retainer  fees  paid  by  the  Corporation  to  the
Warrant Agent  under  this  Indenture  in  the  twelve  (12)  months  immediately  prior  to  the  Warrant Agent
receiving the first notice of the claim. Notwithstanding any other provision of this Indenture, and whether
such losses or damages are foreseeable or unforeseeable, the Warrant Agent shall not be liable under any
circumstances  whatsoever  for  any:  (a)  breach  by  any  other  party  of Applicable  Securities  Laws;  (b)  lost
profits;  or  (c)  special,  indirect,  incidental,  consequential,  exemplary,  aggravated  or  punitive  losses  or
damages.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
9.8 Replacement of Warrant Agent; Successor by Merger.

- 43 -

(a)

The  Warrant Agent  may  resign  its  agency  and  be  discharged  from  all  further  duties  and  liabilities  hereunder,
subject  to  this  Section  9.8,  by  giving  to  the  Corporation  not  less  than  60  days’  prior  notice  in  writing  or  such
shorter prior notice as the Corporation may accept as sufficient. The Registered Warrantholders by Extraordinary
Resolution  shall  have  power  at  any  time  to  remove  the  existing  Warrant Agent  and  to  appoint  a  new  warrant
agent. In the event of the Warrant Agent resigning or being removed as aforesaid or being dissolved, becoming
bankrupt,  going  into  liquidation  or  otherwise  becoming  incapable  of  acting  hereunder,  the  Corporation  shall
forthwith  appoint  a  new  Warrant  Agent  unless  a  new  Warrant  Agent  has  already  been  appointed  by  the
Registered  Warrantholders;  failing  such  appointment  by  the  Corporation,  the  retiring  Warrant  Agent  or  any
Registered Warrantholder may apply to a judge of the Superior Court of the Province of Québec on such notice
as such judge may direct, for the appointment of a new Warrant Agent; but any new Warrant Agent so appointed
by  the  Corporation  or  by  the  Court  shall  be  subject  to  removal  as  aforesaid  by  the  Registered  Warrantholders.
Any new Warrant Agent appointed under any provision of this Section 9.8 shall be an entity authorized to carry
on the business of a trust company in the Province of Québec and, if required by the Applicable Legislation for
any other provinces, in such other provinces. On any such appointment the new warrant agent shall be vested with
the same powers, rights, duties and responsibilities as if it had been originally named herein as Warrant Agent
hereunder.

(b) Upon  the  appointment  of  a  successor  warrant  agent,  the  Corporation  shall  promptly  notify  the  Registered

Warrantholders thereof in the manner provided for in Section 10.2.

(c) Any  Warrant  Authenticated  but  not  delivered  by  a  predecessor  Warrant  Agent  may  be  Authenticated  by  the

successor Warrant Agent in the name of the predecessor or successor Warrant Agent.

(d) Any  corporation  into  which  the  Warrant  Agent  may  be  merged  or  consolidated  or  amalgamated,  or  any
corporation  resulting  therefrom  to  which  the  Warrant Agent  shall  be  a  party,  or  any  corporation  succeeding  to
substantially  the  corporate  trust  business  of  the  Warrant  Agent  shall  be  the  successor  to  the  Warrant  Agent
hereunder without any further act on its part or any of the parties hereto, provided that such corporation would be
eligible for appointment as successor Warrant Agent under Section 9.8(a).

9.9 Conflict of Interest.

(a)

The Warrant Agent represents to the Corporation that to the best of its knowledge, at the time of execution and
delivery hereof no material conflict of interest exists between its role as a Warrant Agent hereunder and its role in
any other capacity and agrees that in the event of a material conflict of interest arising hereafter it will, within 90
days after ascertaining that it has such material conflict of interest, either eliminate the same or assign its agency
hereunder to a successor Warrant Agent approved by the Corporation and meeting the requirements set forth in
Section 9.8(a). Notwithstanding the foregoing provisions of this Section 9.9(a), if any such material conflict of
interest exists or hereafter shall exist, the validity and enforceability of this Indenture and the Warrant

 
 
 
 
 
 
 
 
- 44 -

Certificate, if applicable, shall not be affected in any manner whatsoever by reason thereof.

(b)

Subject to Section 9.9(a), the Warrant Agent, in its personal or any other capacity, may buy, lend upon and deal
in  securities  of  the  Corporation  and  generally  may  contract  and  enter  into  financial  transactions  with  the
Corporation without being liable to account for any profit made thereby.

9.10 Acceptance of Agency.

The Warrant Agent hereby accepts the agency in this Indenture declared and provided for and agrees to perform

the same upon the terms and conditions herein set forth.

9.11 Warrant Agent Not to be Appointed Receiver.

The Warrant Agent and any person related to the Warrant Agent shall not be appointed a receiver, a receiver and

manager or liquidator of all or any part of the assets or undertaking of the Corporation.

9.12 Warrant Agent Not Required to Give Notice of Default.

The Warrant Agent shall not be bound to give any notice or do or take any act, action or proceeding by virtue of
the powers conferred on it hereby unless and until it shall have been required so to do under the terms hereof; nor shall
the  Warrant Agent  be  required  to  take  notice  of  any  default  hereunder,  unless  and  until  notified  in  writing  of  such
default, which notice shall distinctly specify the default desired to be brought to the attention of the Warrant Agent and
the  Warrant Agent  shall  promptly  provide  the  Warrantholders  with  any  such  notice  and  in  the  absence  of  any  such
notice the Warrant Agent may for all purposes of this Indenture conclusively assume that no default has been made in
the observance or performance of any of the representations, warranties, covenants, agreements or conditions contained
herein. Any such notice shall in no way limit any discretion herein given to the Warrant Agent to determine whether or
not the Warrant Agent shall take action with respect to any default.

9.13 Anti-Money Laundering.

(a)

Each  party  to  this Agreement  other  than  the  Warrant Agent  hereby  represents  to  the  Warrant Agent  that  any
account to be opened by, or interest to be held by the Warrant Agent in connection with this Agreement, for or to
the credit of such party, either (i) is not intended to be used by or on behalf of any third party; or (ii) is intended to
be used by or on behalf of a third party, in which case such party hereto agrees to complete and execute forthwith
a declaration in the Warrant Agent’s prescribed form as to the particulars of such third party.

(b) The Warrant Agent shall retain the right not to act and shall not be liable for refusing to act if, due to a lack of
information or for any other reason whatsoever, the Warrant Agent, in its sole judgment, determines that such act
might  cause  it  to  be  in  non-compliance  with  any  applicable  anti-money  laundering,  anti-terrorist  or  economic
sanctions legislation, regulation or guideline. Further, should the Warrant Agent, in its sole judgment, determine
at any time that its acting under this Indenture has resulted in

 
 
 
 
 
 
 
 
 
 
- 45 -

its  being  in  non-compliance  with  any  applicable  anti-money  laundering,  anti-terrorist  or  economic  sanctions
legislation,  regulation  or  guideline,  then  it  shall  have  the  right  to  resign  on  10  days  written  notice  to  the  other
parties to this Indenture, provided (i) that the Warrant Agent’s written notice shall describe the circumstances of
such non-compliance; (ii) that if such circumstances are rectified to the Warrant Agent’s satisfaction within such
10 day period, then such resignation shall not be effective.

9.14 Compliance with Privacy Code.

Each  party  to  this Agreement  acknowledges  that  the  Warrant Agent  may,  in  the  course  of  providing  services
hereunder, collect or receive financial and other personal information about such parties and/or their representatives, as
individuals, or about other individuals related to the subject matter hereof, and use such information for the following
purposes:

(i)

to provide the services required under this Indenture and other services that may be requested from time to
time;

(ii)

to help the Warrant Agent manage its servicing relationships with such individuals;

(iii)

to meet the Warrant Agent’s legal and regulatory requirements; and

(iv)

if Social Insurance Numbers are collected by the Warrant Agent, to perform tax reporting and to assist in
verification of an individual’s identity for security purposes.

Each  party  to  this Agreement  acknowledges  and  agrees  that  the  Warrant Agent  may  receive,  collect,  use  and
disclose  personal  information  provided  to  it  or  acquired  by  it  in  the  course  of  its  acting  as  agent  hereunder  for  the
purposes  described  above  and,  generally,  in  the  manner  and  on  the  terms  described  in  its  Privacy  Code,  which  the
Warrant Agent  shall  make  available  on  its  website  or  upon  request,  including  revisions  thereto.  The  Warrant Agent
may transfer personal information to other companies in or outside of Canada that provide data processing and storage
or other support in order to facilitate the service it provides.

Further, the Corporation agrees that it shall not provide or cause to be provided to the Warrant Agent any personal
information relating to an individual who is not a party to this Indenture unless the Corporation has assured itself that
such individual understands and has consented to the aforementioned uses and disclosures.

9.15 Securities Exchange Commission Certification.

The Corporation confirms that it has either (i) a class of securities registered pursuant to Section 12 of the U.S.
Securities Exchange Act of 1934, as amended (the “1934 Act”); or (ii) a reporting obligation pursuant to Section 15(d)
of the Act, and has provided the Warrant Agent with an Officers’ Certificate (in a form provided by the Warrant Agent)
certifying  such  reporting  obligation  and  other  information  as  requested  by  the  Warrant  Agent.  The  Corporation
covenants that in the event that any such registration or reporting obligation shall be terminated by the Corporation in
accordance with the 1934 Act, the Corporation shall promptly notify the Warrant Agent of such termination and such
other information as the Warrant Agent may require at the

 
 
 
 
 
 
 
 
 
 
 
 
 
time. The Corporation acknowledges that the Warrant Agent is relying upon the foregoing representation and covenants
in order to meet certain SEC obligations with respect to those clients who are filing with the SEC.

- 46 -

10.1 Notice to the Corporation and the Warrant Agent.

ARTICLE 10
GENERAL

(a) Unless herein otherwise expressly provided, any notice to be given hereunder to the Corporation or the Warrant

Agent shall be deemed to be validly given if delivered, sent by registered letter, postage prepaid or faxed:

(i)

If to the Corporation:

Acasti Pharma Inc.
545 Promenade du Centropolis, Suite 100, Laval, Québec, Canada, H7T 0A3
Attention: Chief Financial Officer
Telecopy: (450) 687-2272

(ii)

If to the Warrant Agent:

Computershare Trust Company of Canada
1500 boul. Robert-Bourassa, 7 th Floor, Montréal, Québec, Canada, H3A 3S8
Attention: General Manager, Corporate Trust
Telecopy: (514) 982-7677

and any such notice delivered in accordance with the foregoing shall be deemed to have been received and given
on  the  date  of  delivery  or,  if  mailed,  on  the  fifth  Business  Day  following  the  date  of  mailing  such  notice  or,  if
telecopied, on the next Business Day following the date of transmission.

(b) The Corporation or the Warrant Agent, as the case may be, may from time to time notify the other in the manner
provided in Section 10.1(a) of a change of address which, from the effective date of such notice and until changed
by like notice, shall be the address of the Corporation or the Warrant Agent, as the case may be, for all purposes
of this Indenture.

(c)

If, by reason of a strike, lockout or other work stoppage, actual or threatened, involving postal employees, any
notice to be given to the Warrant Agent or to the Corporation hereunder could reasonably be considered unlikely
to reach its destination, such notice shall be valid and effective only if it is delivered to the named officer of the
party to which it is addressed, as provided in Section 10.1(a), or given by facsimile or other means of prepaid,
transmitted and recorded communication.

10.2 Notice to Registered Warrantholders.

(a) Unless otherwise provided herein, notice to the Registered Warrantholders under the provisions of this Indenture
shall be valid and effective if delivered or sent by ordinary prepaid post addressed to such holders at their post
office addresses appearing on the

 
 
 
 
 
 
 
 
 
 
 
 
- 47 -

register hereinbefore mentioned and shall be deemed to have been effectively received and given on the date of
delivery  or,  if  mailed,  on  the  third  Business  Day  following  the  date  of  mailing  such  notice.  In  the  event  that
Warrants  are  held  in  the  name  of  the  Depository,  a  copy  of  such  notice  shall  also  be  sent  by  electronic
communication to the Depository and shall be deemed received and given on the next Business Day it is so sent.

(b)

If, by reason of a strike, lockout or other work stoppage, actual or threatened, involving postal employees, any
notice to be given to the Registered Warrantholders hereunder could reasonably be considered unlikely to reach
its destination, such notice shall be valid and effective only if it is delivered to such Registered Warrantholders to
the address for such Registered Warrantholders contained in the register maintained by the Warrant Agent or such
notice  may  be  given,  at  the  Corporation’s  expense,  by  means  of  publication  in  the  Globe  and  Mail,  National
Edition,  or  any  other  English  language  daily  newspaper  or  newspapers  of  general  circulation  in  Canada,  in  the
first such notice to be published within five business days of such event, each two successive weeks, and any so
notice published shall be deemed to have been received and given on the latest date the publication takes place.

10.3 Ownership of Warrants.

The Corporation and the Warrant Agent may deem and treat the Registered Warrantholders as the absolute owner
thereof for all purposes, and the Corporation and the Warrant Agent shall not be affected by any notice or knowledge
to the contrary except where the Corporation or the Warrant Agent is required to take notice by statute or by order of a
court of competent jurisdiction. The receipt of any such Registered Warrantholder of the Common Shares which may
be  acquired  pursuant  thereto  shall  be  a  good  discharge  to  the  Corporation  and  the  Warrant Agent  for  the  same  and
neither the Corporation nor the Warrant Agent shall be bound to inquire into the title of any such holder except where
the  Corporation  or  the  Warrant  Agent  is  required  to  take  notice  by  statute  or  by  order  of  a  court  of  competent
jurisdiction.

10.4 Counterparts.

This Indenture may be executed in several counterparts, each of which when so executed shall be deemed to be
an original and such counterparts together shall constitute one and the same instrument and notwithstanding their date
of execution they shall be deemed to be dated as of the date hereof. Delivery of an executed copy of the Indenture by
electronic facsimile transmission or other means of electronic communication capable of producing a printed copy will
be deemed to be execution and delivery of this Indenture as of the date hereof.

10.5 Satisfaction and Discharge of Indenture.

Upon the earlier of:

(i)

the  date  by  which  there  shall  have  been  delivered  to  the  Warrant Agent  for  exercise  or  cancellation  all
Warrants  theretofore  Authenticated  hereunder,  in  the  case  of  Certificated  Warrants,  or  by  way  of  a
Transaction Instruction (or such other instructions, in a form satisfactory to the Warrant Agent), in the case
of

 
 
 
 
 
 
 
 
 
- 48 -

Uncertificated Warrants, or by way of standard processing through the Book Based System in the case of a
CDS Global Warrant; and

(ii)

the Expiry Time;

and if all certificates or other entry on the register representing Common Shares required to be issued in compliance
with the provisions hereof have been issued and delivered hereunder or to the Warrant Agent in accordance with such
provisions, this Indenture shall cease to be of further effect and the Warrant Agent, on demand of and at the cost and
expense of the Corporation and upon delivery to the Warrant Agent of a certificate of the Corporation stating that all
conditions precedent to the satisfaction and discharge of this Indenture have been complied with, shall execute proper
instruments  acknowledging  satisfaction  of  and  discharging  this  Indenture.  Notwithstanding  the  foregoing,  the
indemnities  provided  to  the  Warrant Agent  by  the  Corporation  hereunder  shall  remain  in  full  force  and  effect  and
survive the termination of this Indenture.

10.6 Provisions of Indenture and Warrants for the Sole Benefit of Parties and Registered Warrantholders.

Nothing  in  this  Indenture  or  in  the  Warrants,  expressed  or  implied,  shall  give  or  be  construed  to  give  to  any
person other than the parties hereto and the Registered Warrantholders, as the case may be, any legal or equitable right,
remedy or claim under this Indenture, or under any covenant or provision herein or therein contained, all such covenants
and provisions being for the sole benefit of the parties hereto and the Registered Warrantholders.

10.7 Common Shares or Warrants Owned by the Corporation or its Subsidiaries – Certificate to be Provided.

For the purpose of disregarding any Warrants owned legally or beneficially by the Corporation in Section 7.16,
the Corporation shall provide to the Warrant Agent, from time to time, a certificate of the Corporation setting forth as at
the date of such certificate:

(i)

the  names  (other  than  the  name  of  the  Corporation)  of  the  Registered  Warrantholders  which,  to  the
knowledge  of  the  Corporation,  hold  Warrants  which  are  owned  by  or  held  for  the  account  of  the
Corporation; and

(ii)

the number of Warrants owned legally or beneficially by the Corporation,

and the Warrant Agent, in making the computations in Section 7.16, shall be entitled to rely on such certificate without
any additional evidence.

10.8 Severability.

If, in any jurisdiction, any provision of this Indenture or its application to any party or circumstance is restricted,
prohibited  or  unenforceable,  such  provision  will,  as  to  such  jurisdiction,  be  ineffective  only  to  the  extent  of  such
restriction, prohibition or unenforceability without invalidating the remaining provisions of this Indenture and without
affecting the validity or enforceability of such provision in any other jurisdiction or without affecting its application to
other parties or circumstances.

 
 
 
 
 
 
 
 
 
 
 
 
10.9 Force Majeure.

- 49 -

No party shall be liable to the other, or held in breach of this Indenture, if prevented, hindered, or delayed in the
performance  or  observance  of  any  provision  contained  herein  by  reason  of  act  of  God,  riots,  terrorism,  acts  of  war,
epidemics, governmental action or judicial order, earthquakes, or any other similar causes (including, but not limited to,
mechanical, electronic or communication interruptions, disruptions or failures). Performance times under this Indenture
shall  be  extended  for  a  period  of  time  equivalent  to  the  time  lost  because  of  any  delay  that  is  excusable  under  this
Section.

10.10  Assignment, Successors and Assigns.

Neither  of  the  parties  hereto  may  assign  its  rights  or  interest  under  this  Indenture,  except  as  provided  in
Section  9.8  in  the  case  of  the  Warrant Agent,  or  as  provided  in  Section  8.2  in  the  case  of  the  Corporation.  Subject
thereto,  this  Indenture  shall  enure  to  the  benefit  of  and  be  binding  upon  the  parties  hereto  and  their  respective
successors and permitted assigns.

10.11  Rights of Rescission and Withdrawal for Holders.

Should a holder of Warrants exercise any legal, statutory, contractual or other right of withdrawal or rescission
that  may  be  available  to  it,  and  the  holder’s  funds  which  were  paid  on  exercise  have  already  been  released  to  the
Corporation by the Warrant Agent, the Warrant Agent shall not be responsible for ensuring the exercise is cancelled
and a refund is paid back to the holder. In such cases, the holder shall seek a refund directly from the Corporation and
subsequently,  the  Corporation,  upon  surrender  to  the  Corporation  or  the  Warrant Agent  of  any  Common  Shares  that
may have been issued, or such other procedure as agreed to by the parties hereto, shall instruct the Warrant Agent in
writing, to cancel the exercise transaction and any such Common Shares on the register, which may have already been
issued  upon  the  Warrant  exercise.  In  the  event  that  any  payment  is  received  from  the  Corporation  by  virtue  of  the
holder being a shareholder for such Warrants that were subsequently rescinded, such payment must be returned by the
Corporation to such holder. The Warrant Agent shall not be under any duty or obligation to take any steps to ensure or
enforce that the funds are returned pursuant to this section, nor shall the Warrant Agent be in any other way responsible
in the event that any payment is not delivered or received pursuant to this section. Notwithstanding the foregoing, in
the  event  that  the  Corporation  provides  the  refund  to  the  Warrant Agent  for  distribution  to  the  holder,  the  Warrant
Agent shall return such funds to the holder as soon as reasonably practicable, and in so doing, the Warrant Agent shall
incur no liability with respect to the delivery or non-delivery of any such funds.

10.12  Language

The  parties  hereto  confirm  their  express  wish  that  this  Indenture  and  all  documents  and  agreements  directly  or
indirectly relating thereto be drawn up in the English language. Notwithstanding such express wish, the parties agree
that any such document or agreement, or any part thereof or of this Indenture, may be drawn up in the French language.
Les parties aux présentes confirment leur volonté expresse que la présente convention ainsi que tous les documents et
conventions s’y rattachant directement ou indirectement soient rédigés en anglais. Nonobstant cette volonté expresse,
les parties aux présentes conviennent que la présente

 
 
 
 
 
- 50 -

convention ainsi que tous les documents et conventions s’y rattachant directement ou indirectement, ou toute partie de
ceux-ci, puissent être rédigés en français.

[Signature page follows]

 
 
IN WITNESS WHEREOF  the parties hereto have executed this Indenture under the hands of their proper officers in
that behalf as of the date first written above.

ACASTI PHARMA INC.

By:

Name: Jan D’Alvise
Title: President and Chief Executive Officer

COMPUTERSHARE TRUST COMPANY
OF CANADA

By:

Name:
Title:

By:

Name:
Title:

 
 
A-1

SCHEDULE “A”
FORM OF WARRANT CERTIFICATE

[For  all  Warrants  sold  outside  the  United  States  and  registered  in  the  name  of  the  Depository,  include  the
following legend:]

UNLESS  THIS  CERTIFICATE  IS  PRESENTED  BY  AN  AUTHORIZED  REPRESENTATIVE  OF  CDS
CLEARING AND DEPOSITORY SERVICES INC. (“ CDS”)  TO ACASTI  PHARMA  INC.  (THE  “ ISSUER”)
OR  ITS  AGENT  FOR  REGISTRATION  OF  TRANSFER,  EXCHANGE  OR  PAYMENT,  AND  ANY
CERTIFICATE  ISSUED  IN  RESPECT  THEREOF  IS  REGISTERED  IN  THE  NAME  OF  CDS  &  CO.,  OR
SUCH OTHER NAME AS IS REQUESTED BY AN AUTHORIZED REPRESENTATIVE OF CDS (AND ANY
PAYMENT  IS  MADE  TO  CDS  &  CO.  OR  TO  SUCH  OTHER  ENTITY  AS  IS  REQUESTED  BY  AN
AUTHORIZED REPRESENTATIVE OF CDS), ANY TRANSFER, PLEDGE OR OTHER USE HEREOF FOR
VALUE OR OTHERWISE BY OR TO ANY PERSON IS WRONGFUL SINCE THE REGISTERED HOLDER
HEREOF,  CDS  &  CO.,  HAS  A  PROPERTY  INTEREST  IN  THE  SECURITIES  REPRESENTED  BY  THIS
CERTIFICATE HEREIN AND IT IS A VIOLATION OF ITS RIGHTS FOR ANOTHER PERSON TO HOLD,
TRANSFER OR DEAL WITH THIS CERTIFICATE.

[If applicable, each Warrant Certificate originally issued for the benefit or account of a U.S. Warrantholder and
each Warrant Certificate issued in exchange therefor or in substitution thereof, shall bear the following legends or
such  variations  thereof  as  the  Corporation  may  prescribe:]  THIS  WARRANT  AND  THE  SECURITIES
DELIVERABLE UPON EXERCISE HEREOF HAVE NOT BEEN REGISTERED UNDER THE UNITED
STATES SECURITIES ACT OF 1933, AS AMENDED (THE “U.S. SECURITIES ACT”), OR ANY STATE
SECURITIES LAWS, AND MAY BE OFFERED, SOLD, PLEDGED OR OTHERWISE TRANSFERRED,
DIRECTLY  OR  INDIRECTLY,  ONLY  (A)  TO  ACASTI  PHARMA  INC.  (THE  “CORPORATION”)
(B)  OUTSIDE  THE  UNITED  STATES  IN  COMPLIANCE  WITH  RULE  904  OF  REGULATION  S
UNDER  THE  U.S.  SECURITIES ACT AND  IN  COMPLIANCE  WITH APPLICABLE  LOCAL  LAWS
AND  REGULATIONS,  (C)  WITHIN  THE  UNITED  STATES  IN  ACCORDANCE  WITH  THE
EXEMPTION FROM REGISTRATION UNDER THE U.S. SECURITIES ACT PROVIDED BY (1) RULE
144A  UNDER  THE  U.S.  SECURITIES  ACT  OR  (2)  IF  AVAILABLE,  RULE  144  UNDER  THE  U.S.
SECURITIES  ACT  AND,  IN  EACH  CASE,  IN  COMPLIANCE  WITH  APPLICABLE  STATE
SECURITIES  LAWS,  OR  (D)  IN A  TRANSACTION  THAT  DOES  NOT  REQUIRE  REGISTRATION
UNDER  THE  U.S.  SECURITIES  ACT  OR  ANY  APPLICABLE  STATE  SECURITIES  LAWS,
PROVIDED THAT IN THE CASE OF TRANSFERS PURSUANT TO (C)(2) OR (D) ABOVE, A LEGAL
OPINION  SATISFACTORY  TO  THE  CORPORATION  MUST  FIRST  BE  PROVIDED  TO
COMPUTERSHARE  TRUST  COMPANY  OF  CANADA  TO  THE  EFFECT  THAT  SUCH  TRANSFER
MAY  BE  EFFECTED  WITHOUT  REGISTRATION  UNDER  THE  U.S.  SECURITIES  ACT  AND
APPLICABLE  STATE  SECURITIES  LAWS.  DELIVERY  OF  THIS  CERTIFICATE  MAY  NOT
CONSTITUTE “GOOD

 
 
A-2

DELIVERY” IN SETTLEMENT OF TRANSACTIONS ON STOCK EXCHANGES IN CANADA.

THE  SECURITIES  EVIDENCED  HEREBY  AND  THE  SECURITIES  ISSUABLE  UPON  EXERCISE
HEREOF  HAVE  NOT  BEEN  REGISTERED  UNDER  THE  U.S.  SECURITIES  ACT  OR  U.S.  STATE
SECURITIES LAWS. THESE WARRANTS MAY NOT BE EXERCISED IN THE UNITED STATES OR
BY  OR  ON  BEHALF  OF,  OR  FOR  THE ACCOUNT  OR  BENEFIT  OF, A  U.S.  PERSON  UNLESS AN
EXEMPTION FROM REGISTRATION UNDER THE U.S. SECURITIES ACT AND ANY APPLICABLE
STATE  SECURITIES  LAWS  IS  AVAILABLE  AND  THE  CORPORATION  HAS  RECEIVED  AN
OPINION  OF  COUNSEL  OF  RECOGNIZED  STANDING  TO  SUCH  EFFECT  IN  FORM  AND
SUBSTANCE  REASONABLY  SATISFACTORY  TO  THE  CORPORATION.  “UNITED  STATES” AND
“U.S.  PERSON”  ARE  AS  DEFINED  BY  REGULATION  S  UNDER  THE  U.S.  SECURITIES  ACT.  IF
REQUESTED BY THE CORPORATION, THE HOLDER AGREES TO PROVIDE THE INFORMATION
NECESSARY TO DETERMINE WHETHER THE TRANSFER OR EXERCISE OF THIS WARRANT IS
PERMISSIBLE UNDER THE U.S. SECURITIES ACT.”]

SUBJECT  TO  THE  CORPORATION’S  ACCELERATION  RIGHT,  THE  WARRANTS  EVIDENCED
HEREBY ARE EXERCISABLE AT OR BEFORE 5:00 P.M. (MONTREAL TIME) ON FEBRUARY 21, 2022,
AFTER WHICH TIME THE WARRANTS EVIDENCED HEREBY SHALL BE DEEMED TO BE VOID AND
OF NO FURTHER FORCE OR EFFECT.

WARRANT

To acquire Common Shares of

ACASTI PHARMA INC.

(incorporated pursuant to the laws of the Province of Québec)

Warrant
Certificate No. ●                  

 Certificate for

Warrants, each entitling the holder to acquire one (1) Common Share subject to adjustment
in accordance with the terms of the Warrant Indenture

CUSIP: ●

ISIN: ●

THIS IS TO CERTIFY THAT , for value received,

 
 
 
  
 
      
 
 
 
 
A-3

(the “Warrantholder”) is the registered holder of the number of common share purchase warrants (the “ Warrants”)
of Acasti  Pharma  Inc.  (the  “Corporation”)  specified  above,  and  is  entitled,  on  exercise  of  these  Warrants  upon  and
subject to the terms and conditions set forth herein and in the Warrant Indenture hereinafter referred to, to purchase at
any time before 5:00 p.m. (Montreal time) (the “Expiry Time”) on February 21, 2022 (the “ Expiry Date”), subject to
the  Acceleration  Right,  one  fully  paid  and  non-assessable  common  share  without  par  value  in  the  capital  of  the
Corporation  as  constituted  on  the  date  hereof  (a  “Common  Share”)  for  each  Warrant  subject  to  adjustment  in
accordance with the terms of the Warrant Indenture.

For  the  purpose  of  this  Warrant  Certificate  and  the  Warrant  Indenture,  “Acceleration  Right”  means  the  right  of  the
Company to accelerate the Expiry Date to a date that is not the less than 30 days following delivery of the Acceleration
Notice if, at any time at least four months following the Effective Date, the volume weighted average trading price of
the Common Shares equals or exceeds $2.65 for a period of 20 consecutive trading dates on the TSXV.

The  Warrants  evidenced  hereby  are  exercisable  at  or  before  5:00  p.m.  (Montreal  time)  on  February  21,  2022  after
which time the warrants evidenced hereby shall be deemed to be void and of no further force or effect.

The right to purchase Common Shares may only be exercised by the Warrantholder within the time set forth above by:

(a)

duly completing and executing the exercise form (the “ Exercise Form”) attached hereto; and

(b)

surrendering this warrant certificate (the “ Warrant Certificate ”), with the Exercise Form to the Warrant
Agent at the principal office of the Warrant Agent, in the city of Montreal, Québec, together with a certified
cheque,  bank  draft  or  money  order  in  the  lawful  money  of  Canada  payable  to  or  to  the  order  of  the
Corporation in an amount equal to the aggregate Exercise Price (as defined herein) for the Common Shares
so subscribed for.

The surrender of this Warrant Certificate, the duly completed Exercise Form and payment as provided above will be
deemed to have been effected only on personal delivery thereof to, or if sent by mail or other means of transmission on
actual receipt thereof by, the Warrant Agent at its principal office as set out above.

Subject to adjustment thereof in the events and in the manner set forth in the Warrant Indenture hereinafter referred to,
the exercise price payable for each Common Share upon the exercise of the Warrants shall be CAD$2.15 per Common
Share (the “Exercise Price”) .

Certificates for the Common Shares subscribed for will be mailed to the persons specified in the Exercise Form at their
respective addresses specified therein or, if so specified in the Exercise Form, delivered to such persons at the office
where  this  Warrant  Certificate  is  surrendered.  If  fewer  Common  Shares  are  purchased  than  the  number  that  can  be
purchased  pursuant  to  this  Warrant  Certificate,  the  holder  hereof  will  be  entitled  to  receive  without  charge  a  new
Warrant Certificate in respect of the balance of the Common Shares not so purchased. No fractional Common Shares
will be issued upon exercise of any Warrant.

 
 
 
 
 
 
A-4

This  Warrant  Certificate  evidences  Warrants  of  the  Corporation  issued  or  issuable  under  the  provisions  of  a  warrant
indenture (which indenture together with all other instruments supplemental or ancillary thereto is herein referred to as
the “Warrant Indenture”) dated as of February 21, 2017 between the Corporation and Computershare Trust Company
of Canada, as Warrant Agent, to which Warrant Indenture reference is hereby made for particulars of the rights of the
holders of Warrants, the Corporation and the Warrant Agent in respect thereof and the terms and conditions on which
the Warrants are issued and held, all to the same effect as if the provisions of the Warrant Indenture were herein set
forth, to all of which the holder, by acceptance hereof, assents. The Corporation will furnish to the holder, on request
and without charge, a copy of the Warrant Indenture.

The  Warrants  evidenced  hereby  shall  not  be  exercised  by  any  U.S.  Warrantholder,  or  any  other  person  requesting
delivery of the Common Shares issuable upon exercise of the Warrants in or into the United States must (a) provide a
completed  and  executed  U.S.  Purchaser  Letter  or  (b)  an  opinion  of  counsel  of  recognised  standing  in  form  and
substance  reasonably  satisfactory  to  the  Corporation  and  the  Warrant Agent  that  the  exercise  and  delivery  is  exempt
from the registration requirements of applicable securities laws of any state of the United States and the U.S. Securities
Act; provided, however a U.S. Warrantholder that is the original purchaser of Warrants and who has delivered the U.S.
Accredited  Investor  Certificate  attached  to  the  subscription  agreement  of  the  Corporation  in  connection  with  its
purchase of Units pursuant to the U.S. Placement, will not be required to deliver a U.S. Purchaser Letter or an opinion
of  counsel  in  connection  with  the  due  exercise  of  the  Warrant  at  a  time  when  the  representations,  warranties  and
covenants  made  by  the  Warrantholder  in  the  U.S.  Accredited  Investor  Certificate  remain  true  and  correct  and  the
Warrantholder represents to the Corporation as such.

On presentation at the principal office of the Warrant Agent as set out above, subject to the provisions of the Warrant
Indenture and on compliance with the reasonable requirements of the Warrant Agent, one or more Warrant Certificates
may  be  exchanged  for  one  or  more  Warrant  Certificates  entitling  the  holder  thereof  to  purchase  in  the  aggregate  an
equal number of Common Shares as are purchasable under the Warrant Certificate(s) so exchanged.

The  Warrant  Indenture  contains  provisions  for  the  adjustment  of  the  Exercise  Price  per  Common  Share  upon  the
exercise of Warrants and the number of Common Shares issuable upon the exercise of Warrants in the events and in
the manner set forth therein.

The  Warrant  Indenture  also  contains  provisions  making  binding  on  all  holders  of  Warrants  outstanding  thereunder
resolutions passed at meetings of holders of Warrants held in accordance with the provisions of the Warrant Indenture
and instruments in writing signed by Warrantholders entitled to purchase a specific majority of the Common Shares that
can be purchased pursuant to such Warrants.

Nothing contained in this Warrant Certificate, the Warrant Indenture or elsewhere shall be construed as conferring upon
the holder hereof any right or interest whatsoever as a holder of Common Shares or any other right or interest except as
herein and in the Warrant Indenture expressly provided. In the event of any discrepancy between anything contained in
this Warrant Certificate and the terms and conditions of the Warrant Indenture, the terms and conditions of the Warrant
Indenture shall govern.

 
 
A-5

Warrants may only be transferred in compliance with the conditions of the Warrant Indenture on the register to be kept
by the Warrant Agent in Montreal, Québec, or such other registrar as the Corporation, with the approval of the Warrant
Agent,  may  appoint  at  such  other  place  or  places,  if  any,  as  may  be  designated,  upon  surrender  of  this  Warrant
Certificate  to  the  Warrant  Agent  or  other  registrar  accompanied  by  a  written  instrument  of  transfer  in  form  and
execution satisfactory to the Warrant Agent or other registrar and upon compliance with the conditions prescribed in
the Warrant Indenture and with such reasonable requirements as the Warrant Agent or other registrar may prescribe and
upon the transfer being duly noted thereon by the Warrant Agent or other registrar. Time is of the essence hereof.

This Warrant Certificate will not be valid for any purpose until it has been countersigned by or on behalf of the Warrant
Agent from time to time under the Warrant Indenture.

The parties hereto have declared that they have required that these presents and all other documents related hereto be in
the English language. Les parties aux présentes déclarent qu’elles ont exigé que la présente convention, de même que
tous les documents s’y rapportant, soient rédigés en anglais.

[Signature page follows]

 
 
IN  WITNESS  WHEREOF   the  Corporation  has  caused  this  Warrant  Certificate  to  be  duly  executed  as  of
                                        ,                 .

A-6

ACASTI PHARMA INC.

By:  

 Authorized Signatory

Countersigned and Registered by:

COMPUTERSHARE TRUST
COMPANY OF CANADA

By:

  Authorized Signatory

Date:    

 
 
 
 
   
C-1

SCHEDULE “B”

FORM OF TRANSFER CERTIFICATE

To: Computershare Trust Company of Canada

RE: Transfer of Warrants under the Warrant Indenture (the “ Warrant Indenture ”),  dated  as  of  February  21,  2017,
between Acasti Pharma Inc. (the “Corporation”) and Computershare Trust Company of Canada, as Warrant Agent

FOR VALUE RECEIVED the undersigned hereby sells, assigns and transfers to

(print name and address) the Warrants represented by this Warrants Certificate and hereby irrevocable constitutes and
appoints                                     
 as its attorney with full power of substitution to transfer the said securities on the
appropriate register of the Warrant Agent. Capitalized terms used herein and not otherwise defined have the meanings
set forth in the Warrant Indenture.

In the case of a warrant certificate that contains a U.S. Warrant Legend, the undersigned hereby represents, warrants
and certifies that (one (only) of the following must be checked):

☐

☐

☐

(A)     the transfer is being made only to the Corporation;

(B)     the transfer is being made outside the United States in accordance with Rule 904 of
Regulation  S  under  the  U.S.  Securities  Act,  and  in  compliance  with  any  applicable  local
securities  laws  and  regulations  and  the  holder  has  provided  herewith  the  Declaration  for
Removal of Legend attached as Schedule “D” to the Warrant Indenture, or

(C)     the transfer is being made within the United States or to, or for the account or benefit
of, U.S. Persons, in accordance in accordance with the exemption from registration under the
U.S. Securities Act provided by (i) Rule 144A under the U.S. Securities Act, (ii) if available,
Rule 144 under the U.S. Securities Act and, in each case, in compliance with applicable state
securities  laws,  or  (iii)  in  a  transaction  that  does  not  require  registration  under  the  U.S.
Securities Act  or  any  applicable  state  securities  laws,  and  the  undersigned  has  furnished  to
the Corporation and the Warrant Agent an opinion of counsel of recognized standing in form
and  substance  reasonably  satisfactory  to  the  Corporation  and  the  Warrant  Agent  to  such
effect.

In  the  case  of  a  warrant  certificate  that  does  not  contain  a  U.S.  Warrant  Legend,  if  the  proposed
transfer is to, or for the account or benefit of a U.S. Warrantholder or to a person in the United States, the undersigned
hereby represents, warrants and certifies that the transfer of the Warrants is being completed pursuant to an exemption
from the registration requirements of the U.S. Securities Act and any applicable state securities laws, in which case the
undersigned has furnished to the Corporation and the Warrant Agent an opinion of counsel of recognized

 
 
 
 
 
 
 
 
 
 
 
 
standing in form and substance reasonably satisfactory to the Corporation and the Warrant Agent to such effect.

C-2

☐

If transfer is to a U.S. Person, check this box.

DATED this          day of                        , 20        .

SPACE FOR GUARANTEES OF
SIGNATURES (BELOW)

Guarantor’s Signature/Stamp

)
)
)
)
)
)
)

  Signature of Transferor

Name of Transferor

REASON FOR TRANSFER – For US Residents only (where the individual(s) or corporation receiving the securities is
a US resident). Please select only one (see instructions below).

☐ Gift                  ☐ Estate              ☐ Private Sale              ☐ Other (or no change in ownership)

Date of Event (Date of gift, death or sale):                  Value per Warrant on the date of event:

/      /

   $                         .

   ☐ CAD OR ☐ USD

CERTAIN REQUIREMENTS RELATING TO TRANSFERS – READ CAREFULLY

The signature(s) of the transferor(s) must correspond with the name(s) as written upon the face of this certificate(s), in
every  particular,  without  alteration  or  enlargement,  or  any  change  whatsoever.  All  securityholders  or  a  legally
authorized representative must sign this form. The signature(s) on this form must be guaranteed in accordance with the
transfer agent’s then current guidelines and requirements at the time of transfer. Notarized or witnessed signatures are
not  acceptable  as  guaranteed  signatures. As  at  the  time  of  closing,  you  may  choose  one  of  the  following  methods
(although subject to change in accordance with industry practice and standards):

•

  Canada  and  the  USA:   A  Medallion  Signature  Guarantee  obtained  from  a  member  of  an  acceptable
Medallion Signature Guarantee Program (STAMP, SEMP, NYSE, MSP). Many commercial banks, savings
banks,  credit  unions,  and  all  broker  dealers  participate  in  a  Medallion  Signature  Guarantee  Program.  The
Guarantor  must  affix  a  stamp  bearing  the  actual  words  “Medallion  Guaranteed”,  with  the  correct  prefix
covering the face value of the certificate.

 
 
 
 
 
   
 
 
 
 
 
   
 
 
 
 
 
  
 
  
  
 
 
C-3

•

•

  Canada: A Signature Guarantee obtained from an authorized officer of the Royal Bank of Canada, Scotia
Bank  or  TD  Canada  Trust.  The  Guarantor  must  affix  a  stamp  bearing  the  actual  words  “Signature
Guaranteed”,  sign  and  print  their  full  name  and  alpha  numeric  signing  number.  Signature  Guarantees  are
not  accepted  from  Treasury  Branches,  Credit  Unions  or  Caisse  Populaires  unless  they  are  members  of  a
Medallion  Signature  Guarantee  Program.  For  corporate  holders,  corporate  signing  resolutions,  including
certificate  of  incumbency,  are  also  required  to  accompany  the  transfer,  unless  there  is  a  “Signature  &
Authority to Sign Guarantee” Stamp affixed to the transfer (as opposed to a “Signature Guaranteed” Stamp)
obtained  from  an  authorized  officer  of  the  Royal  Bank  of  Canada,  Scotia  Bank  or  TD  Canada  Trust  or  a
Medallion Signature Guarantee with the correct prefix covering the face value of the certificate.

  Outside  North America:   For  holders  located  outside  North  America,  present  the  certificates(s)  and/or
document(s)  that  require  a  guarantee  to  a  local  financial  institution  that  has  a  corresponding  Canadian  or
American  affiliate  which  is  a  member  of  an  acceptable  Medallion  Signature  Guarantee  Program.  The
corresponding affiliate will arrange for the signature to be over-guaranteed.

OR

The signature(s) of the transferor(s) must correspond with the name(s) as written upon the face of this certificate(s), in
every particular, without alteration or enlargement, or any change whatsoever. The signature(s) on this form must be
guaranteed  by  an  authorized  officer  of  Royal  Bank  of  Canada,  Scotia  Bank  or  TD  Canada  Trust  whose  sample
signature(s)  are  on  file  with  the  transfer  agent,  or  by  a  member  of  an  acceptable  Medallion  Signature  Guarantee
Program  (STAMP,  SEMP,  NYSE,  MSP).  Notarized  or  witnessed  signatures  are  not  acceptable  as  guaranteed
signatures.  The  Guarantor  must  affix  a  stamp  bearing  the  actual  words:  “SIGNATURE  GUARANTEED”,
“MEDALLION GUARANTEED” OR “SIGNATURE & AUTHORITY TO SIGN GUARANTEE”, all in accordance
with  the  transfer  agent’s  then  current  guidelines  and  requirements  at  the  time  of  transfer.  For  corporate  holders,
corporate  signing  resolutions,  including  certificate  of  incumbency,  will  also  be  required  to  accompany  the  transfer
unless  there  is  a  “SIGNATURE  & AUTHORITY  TO  SIGN  GUARANTEE”  Stamp  affixed  to  the  Form  of  Transfer
obtained  from  an  authorized  officer  of  the  Royal  Bank  of  Canada,  Scotia  Bank  or  TD  Canada  Trust  or  a
“MEDALLION  GUARANTEED”  Stamp  affixed  to  the  Form  of  Transfer,  with  the  correct  prefix  covering  the  face
value of the certificate.

REASON FOR TRANSFER – FOR US RESIDENTS ONLY

Consistent  with  US  IRS  regulations,  Computershare  is  required  to  request  cost  basis  information  from  US
securityholders. Please indicate the reason for requesting the transfer as well as the date of event relating to the reason.
The event date is not the day in which the transfer is finalized, but rather the date of the event which led to the transfer
request (i.e. date of gift, date of death of the securityholder, or the date the private sale took place).

 
 
 
 
 
D-1

SCHEDULE “C”

EXERCISE FORM

TO: Acasti Pharma Inc.

AND TO:

Computershare Trust Company of Canada
c/o of Corporate Trust Services
1500 Robert Bourassa Street, Suite 700
Montréal, Québec H3A 3S8
Attention: Manager, Corporate Trust

OR TO:

Computershare Trust Company of Canada
c/o of Corporate Trust Services
100 University Avenue, Suite 800
Toronto, ON M5J 2Y1
Attention: Manager, Corporate Trust

The undersigned hereby exercises the right of such holder to be issued, and hereby subscribes for, Common Shares that
are  issuable  pursuant  to  the  exercise  of  such  Warrants  on  the  terms  specified  in  such  Warrant  Certificate  and  in  the
Warrant Indenture dated February 21, 2017 between Computershare Trust Company of Canada and Acasti Pharma Inc.
(the “Warrant Indenture”).

The  undersigned  holder  of  the  Warrants  evidenced  by  this  Warrant  Certificate  hereby  exercises  the  right  to  acquire
  Common  Shares  of  Acasti  Pharma  Inc.  for  an  aggregate  purchase  price  of

CAD$                                .

❑

Please check if this Exercise Form is being exercised by or on behalf of a U.S. Warrantholder, or in connection
with a request for delivery of the Common Shares issuable upon exercise of the Warrants in or into the United
States (in which case, additional documentation and certifications may be required).

Exercise  Price  Payable: equals  CAD$2.15  for  each  Common  Share,  subject  to  adjustment  in  accordance  with  the
Warrant Indenture.

Capitalized terms used herein have the meaning ascribed to them in the Warrant Indenture.

The undersigned hereby irrevocably directs that the said Common Shares be issued, registered and delivered as
follows:

Name(s) in Full

Address(es)

Number of
Common Shares

 
 
 
 
 
 
 
 
 
                                
 
  
 
   
 
     
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
D-2

Please print full name in which certificates representing the Common Shares are to be issued. If any Common Shares
are to be issued to a person or persons other than the registered holder, the registered holder must pay to the Warrant
Agent all exigible transfer taxes or other government charges, if any, and the Form of Transfer must be duly executed.

Once  completed  and  executed,  this  Exercise  Form  must  be  mailed  or  delivered  to  Computershare  Trust  Company  of
Canada, c/o Corporate Trust Services, 1500 Robert Bourassa Street, Suite 700, Montréal, Quebec H3A 3S8.

It is understood that the Corporation and Computershare Trust Company of Canada may require evidence to verify the
foregoing representation.

DATED _______________________, 20__.

Witness

Signature of Warrantholder, to be the same as appears
on the face of this Warrant Certificate

  Name of Registered Warrantholder

❑

Please  check  if  the  certificates  representing  the  Common  Shares  are  to  be  delivered  at  the  office  where  this
Warrant  Certificate  is  surrendered,  failing  which  such  certificates  will  be  mailed  to  the  address  set  out  above.
Certificates will be delivered or mailed as soon as practicable after the surrender of this Warrant Certificate to
the Warrant Agent.

 
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
   
 
 
 
   
 
 
 
 
 
 
   
 
 
 
 
 
 
   
 
 
 
  
D-3

SCHEDULE “D”

FORM OF DECLARATION FOR REMOVAL OF LEGEND

TO: Computershare Trust Company of Canada

Computershare  Investor  Services  Ltd.,  as  registrar  and  transfer  agent  for  the  Warrants  and  Common  Shares
issuable upon exercise of the Warrants of Acasti Pharma Inc.

The  undersigned  (a)  acknowledges  that  the  sale  of  the  securities  of Acasti  Pharma  Inc.  (the  “ Corporation”)  to  which  this  declaration
relates  is  being  made  in  reliance  on  Rule  904  of  Regulation  S  under  the  United  States  Securities Act  of  1933,  as  amended  (the  “ U.S.
Securities Act”) and (b) certifies that (1) the undersigned is not (i) an “affiliate” of the Corporation (as that term is defined in Rule 405
under the U.S. Securities Act), (ii) a “distributor” as defined in Regulation S under the U.S. Securities Actor (iii) an affiliate of a distributor,
(2) the offer of such securities was not made to a person in the United States and either (A) at the time the buy order was originated, the
buyer was outside the United States, or the seller and any person acting on its behalf reasonably believed that the buyer was outside the
United States, or (B) the transaction was executed in, on or through the facilities of a designated offshore securities market (such as the
TSX Venture Exchange or the Toronto Stock Exchange) and neither the seller nor any person acting on its behalf knows that the transaction
has been prearranged with a buyer in the United States or a U.S. person, (3) neither the seller nor any affiliate of the seller nor any person
acting on any of their behalf has engaged or will engage in any directed selling efforts in the United States in connection with the offer and
sale  of  such  securities,  (4)  the  sale  is  bona  fide  and  not  for  the  purpose  of  “washing  off”  the  resale  restrictions  imposed  because  the
securities are “restricted securities” (as such term is defined in Rule 144(a)(3) under the U.S. Securities Act), (5) the seller does not intend
to  replace  the  securities  sold  in  reliance  on  Rule  904  of  the  U.S.  Securities  Act  with  fungible  unrestricted  securities  and  (6)  the
contemplated sale is not a transaction, or part of a series of transactions which, although in technical compliance with Regulation S, is part
of a plan or scheme to evade the registration provisions of the U.S. Securities Act. Terms used herein have the meanings given to them by
Regulation S.

DATED this _____ day of __________, 20__.

(Name of Seller)

By:  

   Name:         [*]
   Title:           [*]

Affirmation By Seller’s Broker-Dealer (required for sales in accordance with Section (b)(2)(B) above)

We have read the foregoing representations of our customer,                                        (the “Seller”) dated                                  , with regard
to our sale, for such Seller’s account, of the securities of the Corporation described therein, and on behalf of ourselves we certify and affirm
that  (A)  we  have  no  knowledge  that  the  transaction  had  been  prearranged  with  a  buyer  in  the  United  States,  (B)  the  transaction  was
executed on or through the facilities of designated offshore securities market, (C) neither we, nor any person acting on our behalf, engaged
in  any  directed  selling  efforts  in  connection  with  the  offer  and  sale  of  such  securities,  and  (D)  no  selling  concession,  fee  or  other
remuneration is being paid to us in connection with this offer and sale other than the usual and customary broker’s commission that would
be received by a person executing such transaction as agent. Terms used herein have the meanings given to them by Regulation S under the
U.S. Securities Act.

Name of Firm

By:

  Authorized officer

Date:   __________

 
 
 
  
 
 
  
 
 
 
   
 
   
FORM OF U.S. PURCHASER CERTIFICATION UPON EXERCISE OF WARRANTS

SCHEDULE “E”

Acasti Pharma Inc.
545 Promenade du Centropolis, Suite 100, Laval, Québec, Canada, H7T 0A3
Attention: Chief Financial Officer

- and to -
Computershare Trust Company of Canada.
as Warrant Agent

Dear Sirs:
We are delivering this letter in connection with the purchase of common shares (the “ Common Shares”)  of Acasti
Pharma  Inc.,  a  corporation  incorporated  under  the  laws  of  the  Province  of  Québec  (the  “Corporation”)  upon  the
exercise  of  warrants  of  the  Corporation  (“Warrants”),  issued  under  the  warrant  indenture  dated  as  of  February  21,
2017 between the Corporation and Computershare Trust Company of Canada.

We hereby confirm that:

(a) we are an institutional “ accredited investor” (satisfying one or more of the criteria set forth in Rule 501 (a)
(1),(2),(3)  or  (7)  of  Regulation  D  under  the  United  States  Securities Act  of  1933  (the  “U.S.  Securities
Act”)) who is also a “ Qualified Purchaser” (as defined in Section 2(a) (51) of, and related rules under, the
United States Investment Company Act of 1940 , as amended (the “1940 Act”));

(b) we are purchasing the Common Shares for our own account;

(c) we have such knowledge and experience in financial and business matters that we are capable of evaluating

the merits and risks of purchasing the Common Shares;

(d) we are not acquiring the Common Shares with a view to distribution thereof or with any present intention of
offering or selling any of the Common Shares, except (A) to the Corporation, (B) outside the United States
in  accordance  with  Rule  904  under  the  U.S.  Securities Act  or  (C)  inside  the  United  States  in  accordance
with Rule 144 under the U.S. Securities Act, if applicable, and in compliance with applicable state securities
laws;

(e) we acknowledge that we have had access to such financial and other information as we deem necessary in

connection with our decision to exercise the Warrants and purchase the Common Shares; and

(f) we acknowledge that we are not purchasing the Common Shares as a result of any general solicitation or
general  advertising,  including  advertisements,  articles,  notices  or  other  communications  published  in  any
newspaper, magazine or similar media or broadcast over radio, television, or any seminar or meeting whose
attendees have been invited by general solicitation or general advertising.

 
 
 
 
 
 
 
 
 
 
 
 
- 2 -

We understand that the Common Shares are being offered in a transaction not involving any public offering within the
United States within the meaning of the U.S. Securities Act and that the Common Shares have not been and will not be
registered under the U.S. Securities Act.

We further understand that any Common Shares acquired by us will be in the form of definitive physical certificates
and that such certificates will bear a legend reflecting the fact that we will not offer, sell or otherwise transfer any of the
Common Shares, directly or indirectly, unless (i) the sale is to the Corporation; (ii) the sale is made outside the United
States in compliance with the requirements of Rule 904 of Regulation S under the U.S. Securities Act; or (iii) the sale is
made  in  the  United  States  pursuant  to  an  exemption  from  registration  under  the  U.S.  Securities  Act  provided  by
(A) Rule 144A under the U.S. Securities Act or (2) if available, Rule 144 under the U.S. Securities Act and, in each
case, in compliance with applicable state securities laws, or (iv) in a transaction that does not require registration under
the U.S. Securities Act or any applicable state securities laws; and, in the case of clause (iii)(B) or clause (iv), and, prior
to such sale or transfer, the seller has furnished to the Corporation and the Corporation’s transfer agent an opinion of
counsel  of  recognized  standing  in  form  and  substance  reasonably  satisfactory  to  the  Corporation  and  such  Transfer
Agent  to  the  effect  that  the  proposed  transfer  may  be  effected  without  registration  under  the  U.S.  Securities Act  or
applicable state securities laws.

We acknowledge that you will rely upon our confirmations, acknowledgements and agreements set forth herein, and we
agree  to  notify  you  promptly  in  writing  if  any  of  our  representations  or  warranties  herein  ceases  to  be  accurate  or
complete.

DATED this _____ day of ______, 20__.

(Name of U.S. Purchaser)

By:  

   Name:         [*]
   Title:           [*]

 
 
 
Exhibit 4.2

ACASTI PHARMA INC.

EQUITY INCENTIVE PLAN
JUNE 27, 2013

LASTLY AMENDED JUNE 8, 2017

 
Acasti Pharma Inc.

Equity Incentive Plan

ARTICLE 1
PURPOSE

1.1 Purpose

The purpose of this Plan is to provide the Corporation with a share-related mechanism to attract, retain and motivate
qualified  Directors,  Employees  and  Consultants  of  the  Corporation  and  its  Subsidiaries,  to  reward  such  of  those
Directors, Employees and Consultants as may be granted Awards under this Plan by the Board from time to time for
their  contributions  toward  the  long  term  goals  and  success  of  the  Corporation  and  to  enable  and  encourage  such
Directors,  Employees  and  Consultants  to  acquire  Shares  as  long  term  investments  and  proprietary  interests  in  the
Corporation.

ARTICLE 2
INTERPRETATION

2.1 Definitions

When used herein, unless the context otherwise requires, the following terms have the indicated meanings,
respectively:

“Affiliate” has the meaning set forth in the Securities Act;

“Associate” has the meaning ascribed to it in the Securities Act;

“Award” means any Bonus Share, Restricted Share Unit, Performance Share Unit, Deferred Share Unit, Restricted
Share or Other Share-Based Award granted under this Plan;

“Award Agreement” means a signed, written agreement between a Participant and the Corporation, substantially
in the form attached as Schedule A, subject to any amendments or additions thereto as may, in the discretion of the
Board, be necessary or advisable, evidencing the terms and conditions on which an Award has been granted under
this Plan;

“Award Value”  means such percentage of annual base salary or such other amount as may be determined from
time  to  time  by  the  Board  as  the  original  value  of  the Award  to  be  paid  to  a  Participant  and  specified  in  the
Participant’s Award Agreement;

“Board” means the board of directors of the Corporation;

 
 
- 2 -

“Business Day” means a day, other than a Saturday or Sunday, on which the principal commercial banks in the
City of Montréal are open for commercial business during normal banking hours;

“Bonus Share” means Shares issued to a Participant under the terms of this Plan;

“Cause” means, with respect to a particular Employee:

(a)

(b)

“cause”  as  such  term  is  defined  in  the  written  employment  agreement  between  the  Corporation  and  the
Employee; or

in  the  event  there  is  no  written  employment  agreement  between  the  Corporation  and  the  Employee  or
“cause”  is  not  defined  in  the  written  employment  agreement  between  the  Corporation  and  the  Employee,
the usual meaning of “cause” under the laws of the Province of Québec.

“Change in Control”  means the occurrence of any one or more of the following events:

(a)

(b)

a  consolidation,  merger,  amalgamation,  arrangement  or  other  reorganization  or  acquisition  involving  the
Corporation or any of its Affiliates and another corporation or other entity, as a result of which the holders
of  Shares  prior  to  the  completion  of  the  transaction  hold  less  than  50%  of  the  outstanding  shares  of  the
successor corporation after completion of the transaction;

the sale, lease, exchange or other disposition, in a single transaction or a series of related transactions, of
assets, rights or properties of the Corporation and/or any of its Subsidiaries which have an aggregate book
value  greater  than  30%  of  the  book  value  of  the  assets,  rights  and  properties  of  the  Corporation  and  its
Subsidiaries  on  a  consolidated  basis  to  any  other  person  or  entity,  other  than  a  disposition  to  a  wholly-
owned subsidiary of the Corporation in the course of a reorganization of the assets of the Corporation and
its subsidiaries;

(c)

a resolution is adopted to wind-up, dissolve or liquidate the Corporation;

(d)

any person, entity or group of persons or entities acting jointly or in concert (an “ Acquiror”) acquires or
acquires control (including, without limitation, the right to vote or direct the voting) of Voting Securities of
the  Corporation  which,  when  added  to  the  Voting  Securities  owned  of  record  or  beneficially  by  the
Acquiror or which the Acquiror has the right to vote or in respect of which the Acquiror has the right to
direct the voting, would entitle the Acquiror and/or Associates and/or Affiliates of the Acquiror to cast or to
direct  the  casting  of  20%  or  more  of  the  votes  attached  to  all  of  the  Corporation’s  outstanding  Voting
Securities which may be cast to elect directors of the Corporation or the successor corporation (regardless
of whether a meeting has been called to elect directors);

(e)

as a result of or in connection with: (A) a contested election of directors, or; (B) a consolidation, merger,
amalgamation, arrangement or other reorganization or acquisitions involving the Corporation or any of its
affiliates and another corporation or other entity, the nominees named in the most recent Management

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 3 -

Information  Circular  of  the  Corporation  for  election  to  the  Board  shall  not  constitute  a  majority  of  the
Board; or

(f)

the  Board  adopts  a  resolution  to  the  effect  that  a  Change  of  Control  as  defined  herein  has  occurred  or  is
imminent.

For the purposes of the foregoing,  “Voting Securities” means Shares and any other shares entitled to vote for the
election of directors and shall include any security, whether or not issued by the Corporation, which are not shares
entitled to vote for the election of directors but are convertible into or exchangeable for shares which are entitled to
vote for the election of directors including any options or rights to purchase such shares or securities.

Notwithstanding the foregoing definition, for Awards that are non-qualified deferred compensation held by a U.S.
Taxpayer,  any  Change  in  Control  must  also  meet  the  requirements  for  a  “change  in  control”  or  “change  in
ownership” under Section 409A;

“Code”  means  the  U.S.  Internal  Revenue  Code  of  1986,  as  amended  from  time  to  time,  and  the  regulations
promulgated under it;

“Committee” has the meaning set forth in Section 3.2;

“Corporation” means Acasti Pharma Inc.;

“Consultant”  means  an  individual  or  Consultant  Company,  other  than  an  Employee  or  a  Director  of  the
Corporation, that:

(a)

(b)

(c)

(d)

is engaged to provide on a ongoing  bona fide basis, consulting, technical, management or other services to
the Corporation or an Affiliate of the Corporation, other than services provided in relation to a Distribution;

provides  the  services  under  a  written  contract  between  the  Corporation  or  an Affiliate  of  the  Corporation
and the individual or the Consultant Company;

in  the  reasonable  opinion  of  the  Corporation,  spends  or  will  spend  a  significant  amount  of  time  and
attention on the affairs and business of the Corporation or an Affiliate of the Corporation; and

has a relationship with the Corporation or an Affiliate of the Corporation that enables the individual to be
knowledgeable about the business and affairs of the Corporation;

“Consultant Company” means for an individual consultant, a company or partnership of which the individual is
an employee, shareholder or partner;

“Date of Grant”  means, for any Award, the date specified by the Board at the time it grants the Award (which,
for greater certainty, shall be no earlier than the date on which the Board meets for the purpose of granting such
Award) or if no such date is specified, the date upon which the Award was granted;

 
 
 
 
 
 
 
 
 
 
 
 
 
- 4 -

“Deferred  Share  Unit”  or  “DSU”  means  a  unit  equivalent  in  value  to  a  Share,  credited  by  means  of  a
bookkeeping entry in the books of the Corporation in accordance with ARTICLE 7;

“Director” means a director of the Corporation who is not an employee of the Corporation or a Subsidiary;

“Disabled” or “Disability” means the permanent and total incapacity of a Participant as determined in accordance
with procedures established by the Board for purposes of this Plan;

“Distribution” has the meaning set forth in the Securities Act;

“Effective Date” means the effective date of this Plan, being June 27, 2013;

“Employee” means an individual who:

(a)

is considered an employee of the Corporation or a Subsidiary of the Corporation under the  Income Tax Act
(Canada) (i.e., for whom income tax, employment insurance and CPP deductions must be made at source);

(b) works  full-time  for  the  Corporation  or  a  Subsidiary  of  the  Corporation  providing  services  normally
provided  by  an  employee  and  who  is  subject  to  the  same  control  and  direction  by  the  Corporation  or  a
Subsidiary of the Corporation over the details and methods of work as an employee of the Corporation, but
for whom income tax deductions are not made at source; or

(c) works  for  the  Corporation  or  a  Subsidiary  of  the  Corporation  on  a  continuing  and  regular  basis  for  a
minimum  amount  of  time  per  week  providing  services  normally  provided  by  an  employee  and  who  is
subject  to  the  same  control  and  direction  by  the  Corporation  or  a  Subsidiary  of  the  Corporation  over  the
details and methods of work as an employee of the Corporation, but for whom income tax deductions are
not made at source.

“Exchange” means such stock exchange or other organized market on which the Shares are or may be listed or
posted for trading from time to time, including as applicable the TSX-V or the TSX;

“Exchange Act” means the United States Securities Exchange Act of 1934, as amended from time to time;

“Insider” means an “insider” as defined by the Exchange from time to time in its rules and regulations;

“Investor  Relations Activities”   means  any  activities,  by  or  on  behalf  of  the  Corporation  or  shareholder  of  the
Corporation,  that  promote  or  reasonably  could  be  expected  to  promote  the  purchase  or  sale  of  securities  of  the
Corporation, but does not include:

 
 
 
 
 
 
 
 
(a)

the  dissemination  of  information  provided,  or  records  prepared,  in  the  ordinary  course  of  business  of  the
Corporation

- 5 -

(i)

to promote the sale of products or services of the Corporation, or

(ii)

to raise public awareness of the Corporation,

(b)

that cannot reasonably be considered to promote the purchase or sale of securities of the Corporation;

(c)

activities or communications necessary to comply with the requirements of:

(i)

applicable Securities Laws;

(ii) Exchange  requirements  or  the  by-laws,  rules  or  other  regulatory  instruments  of  any  other  self

regulatory body or exchange having jurisdiction over the Corporation;

(d)

communications  by  a  publisher  of,  or  writer  for,  a  newspaper,  magazine  or  business  or  financial
publication, that is of general and regular paid circulation, distributed only to subscribers to it for value or to
purchasers of it, if:

(i)

the communication is only through the newspaper, magazine or publication, and

(ii)

the  publisher  or  writer  receives  no  commission  or  other  consideration  other  than  for  acting  in  the
capacity of publisher or writer; or

activities or communications that may be otherwise specified by the Exchange.

“Market Price”  at  any  date  in  respect  of  the  Shares  shall  be  the  closing  price  of  such  Shares  on  the  Exchange
(and if listed on more than one stock exchange, then the highest of such closing prices) on the last Business Day
prior to the relevant date. In the event that such Shares did not trade on such Business Day, the Market Price shall
be  the  average  of  the  bid  and  asked  prices  in  respect  of  such  Shares  at  the  close  of  trading  on  such  date.  In  the
event that such Shares are not listed and posted for trading on any stock exchange, the Market Price shall be the
fair market value of such Shares as determined by the Board in its sole discretion;

“NI  45-106”  means  National  Instrument  45-106  Prospectus  and  Registration  Exemptions  of  the  Canadian
Securities Administrators, as amended from time to time;

“Other Share-Based Award”  means any right granted under Section 8.1;

“Participant” means an Employee, Consultant or Director to whom an Award has been granted under this Plan;

“Participant’s Employer” means the Corporation or such Subsidiary as is or, if the Participant has ceased to be
employed by the Corporation or such Subsidiary, was the Participant’s Employer;

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 6 -

“Performance Goals” means performance goals expressed in terms of attaining a specified level of the particular
criteria or the attainment of a percentage increase or decrease in the particular criteria, and may be applied to one
or  more  of  the  Corporation,  a  Subsidiary,  or  a  division  or  strategic  business  unit  of  the  Corporation,  or  may  be
applied  to  the  performance  of  the  Corporation  relative  to  a  market  index,  a  group  of  other  companies  or  a
combination thereof, all as determined by the Board;

“Performance Share Unit” or “PSU” means any right granted under Section 5.1 of the Plan;

“Permitted Assign” has the meaning assigned to that term in NI 45-106;

“Person”  includes  an  individual,  sole  proprietorship,  partnership,  unincorporated  association,  unincorporated
syndicate, unincorporated organization, trust, body corporate, and a natural person in his or her capacity as trustee,
executor, administrator or other legal representative;

“Plan” means this Acasti Pharma Inc. Equity Incentive Plan, as may be amended from time to time;

“QBCA” means the  Business Corporations Act (Québec), as amended, or such other successor legislation which
may be enacted, from time to time;

“Regulatory  Authorities”   means  the  Exchange  and  any  other  organized  trading  facilities  on  which  the
Corporation’s  Shares  are  listed  and  all  securities  commissions  or  similar  securities  regulatory  bodies  having
jurisdiction over the Corporation;

“Restricted Period” means the period during which Restricted Shares are subject to restrictions as set out in the
Award Agreement;

“Restricted Shares”  means  Shares  granted  to  a  Participant  under  Section  6.1  hereof  that  are  subject  to  certain
restrictions and to a risk of forfeiture;

“Restricted Share Unit” or “RSU” means a right to receive a Share or a Restricted Share granted, as determined
by the Board, under Section 4.1;

“Securities Act”  means  the  Securities Act (Québec), as amended, or such other successor legislation  as  may  be
enacted, from time to time;

“Securities  Laws”  means  securities  legislation,  securities  regulation  and  securities  rules,  as  amended,  and  the
policies,  notices,  instruments  and  blanket  orders  in  force  from  time  to  time  that  govern  or  are  applicable  to  the
Corporation or to which it is subject, including, without limitation, the Securities Act;

“Share” means one (1) common share without par value in the capital stock of the Corporation as constituted on
the Effective Date or, in the event of an adjustment contemplated by ARTICLE 12, such other shares or securities
to which the holder of an Award may be entitled as a result of such adjustment;

 
 
- 7 -

“Stock Option Plan” means the Corporation’s stock option plan in effect from time to time;

“Termination Date” means, in the case of a Participant whose employment or term of office or engagement with
the Corporation or an Affiliate terminates:

(i)

(ii)

in the case of the resignation of the Participant as an Employee of the Corporation, the date that the
Participant  provides  notice  of  his  or  her  resignation  as  an  Employee  of  the  Corporation  to  the
Corporation;

in the case of the termination of the Participant as an Employee of the Corporation by the Corporation
for any reason other than death, the effective date of termination set out in the Corporation’s notice of
termination of the Participant as an Employee of the Corporation to the Participant;

(iii)

in  the  case  of  the  termination  of  the  written  contract  of  the  Consultant  Participant  to  provide
consulting services to the Corporation, the effective date of termination set out in any notice provided
by one of the parties to the written contract to the other party; or

(iv)

the effective date of termination of a Director, Employee or Consultant pursuant to an order made by
any Regulatory Authority having jurisdiction to so order;

provided that in the case of termination by reason of voluntary resignation by the Participant, such date shall not
be earlier than the date that notice of resignation was received from such Participant, and “Termination Date” in
any  such  case  specifically  does  not  mean  the  date  on  which  any  period  of  contractual  notice,  reasonable  notice,
salary  continuation  or  deemed  employment  that  the  Corporation  or  the  Affiliate,  as  the  case  may  be,  may  be
required at law to provide to a Participant would expire;

“TSX-V” means the TSX Venture Exchange;

“TSX” means the Toronto Stock Exchange; and

“U.S. Taxpayer” shall mean a Participant who is a U.S. citizen, U.S. permanent resident or individual providing
services to the Corporation or its Subsidiaries in the U.S.

2.2

Interpretation

(a) Whenever the Board or, where applicable, the Committee is to exercise discretion in the administration of
this Plan, the term “discretion” means the sole and absolute discretion of the Board or the Committee, as
the case may be.

(b) As used herein, the terms “Article”, “Section”, “Subsection” and “clause” mean and refer to the specified

Article, Section, Subsection and clause of this Plan, respectively.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 8 -

(c) Words  importing  the  singular  include  the  plural  and  vice  versa  and  words  importing  any  gender  include

any other gender.

(d) Whenever any payment is to be made or action is to be taken on a day which is not a Business Day, such

payment shall be made or such action shall be taken on the next following Business Day.

(e)

In this Plan, a Person is considered to be a  “Subsidiary” of another Person if:

(i)

it is controlled by,

(A)

that other, or

(B)

that other and one or more Persons, each of which is controlled by that other, or

(C)

two or more Persons, each of which is controlled by that other; or

(ii)

it is a Subsidiary of a Person that is that other’s Subsidiary.

(f)

In this Plan, a Person is considered to be  “controlled” by a Person if:

(i)

in the case of a Person,

(A)

voting  securities  of  the  first-mentioned  Person  carrying  more  than  50%  of  the  votes  for  the
election of directors are held, directly or indirectly, otherwise than by way of security only, by
or for the benefit of the other Person; and

(B)

the votes carried by the securities are entitled, if exercised, to elect a majority of the directors
of the first-mentioned Person;

(ii)

in  the  case  of  a  partnership  that  does  not  have  directors,  other  than  a  limited  partnership,  the
second-mentioned Person holds more than 50% of the interests in the partnership; or

(iii)

in the case of a limited partnership, the general partner is the  second-mentioned Person.

(g) Unless otherwise specified, all references to money amounts are to Canadian currency.

(h) This  Plan  is  established  under  and  the  provisions  of  this  Plan  will  be  subject  to  and  interpreted  and

construed in accordance with the laws of the Province of Québec.

(i)

The headings used herein are for convenience only and are not to affect the interpretation of this Plan.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 9 -

ARTICLE 3
ADMINISTRATION

3.1 Administration

Subject to Section 3.2, this Plan will be administered by the Board and the Board has sole and complete authority, in its
discretion, to:

(a)

determine the individuals to whom grants under the Plan may be made;

(b) make  grants  of Awards  under  the  Plan  relating  to  the  issuance  of  Shares  (including  any  combination  of
Bonus Shares, Restricted Share Units, Performance Share Units, Deferred Share Units, Restricted Shares or
Other Share-Based Awards) in such amounts, to such Persons and, subject to the provisions of this Plan, on
such terms and conditions as it determines including without limitation:

(i)

the time or times at which Awards may be granted;

(ii)

the conditions under which:

(A)

Awards may be granted to Participants; or

(B)

Awards may be forfeited to the Corporation,

including any conditions relating to the attainment of specified Performance Goals;

(iii)

the price, if any, to be paid by a Participant in connection with the granting of Awards;

(iv) whether  restrictions  or  limitations  are  to  be  imposed  on  the  Shares  issuable  pursuant  to  grants  of

Awards, and the nature of such restrictions or limitations, if any; and

(v)

any acceleration of exercisability or vesting or Restricted Period, or waiver of termination regarding
any Award, based on such factors as the Board may determine;

(c)

interpret this Plan and adopt, amend and rescind administrative guidelines and other rules and regulations
relating to this Plan; and

(d) make all other determinations and take all other actions necessary or advisable for the implementation and

administration of this Plan.

The  Board’s  determinations  and  actions  within  its  authority  under  this  Plan  are  conclusive  and  binding  on  the
Corporation  and  all  other  persons.  The  day-to-day  administration  of  the  Plan  may  be  delegated  to  such  officers  and
employees of the Corporation or of a Subsidiary as the Board determines.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3.2 Delegation to Committee

- 10 -

To the extent permitted by applicable law and the Corporation’s articles, the Board may, from time to time, delegate to
a  committee  (the  “Committee”)  of  the  Board,  all  or  any  of  the  powers  conferred  on  the  Board  under  the  Plan.  In
connection with such delegation, the Committee will exercise the powers delegated to it by the Board in the manner and
on  the  terms  authorized  by  the  Board.  Any  decision  made  or  action  taken  by  the  Committee  arising  out  of  or  in
connection with the administration or interpretation of this Plan in this context is final and conclusive. Notwithstanding
any such delegation or any reference to the Committee in this Plan, the Board may also take any action and exercise
any powers that the Committee is authorized to take or has power to exercise under this Plan.

3.3 Eligibility

All  Employees,  Consultants  and  Directors  are  eligible  to  participate  in  the  Plan,  subject  to  subsections  10.11(c)  and
10.2(g). Eligibility to participate does not confer upon any Employee, Consultant or Director any right to receive any
grant of an Award pursuant to the Plan. The extent to which any Employee, Consultant or Director is entitled to receive
a grant of an Award pursuant to the Plan will be determined in the sole and absolute discretion of the Board.

3.4 Board Requirements

Any  Award  granted  under  this  Plan  shall  be  subject  to  the  requirement  that,  if  at  any  time  the  Corporation  shall
determine  that  the  listing,  registration  or  qualification  of  the  Shares  issuable  pursuant  to  such  Award  upon  any
securities  exchange  or  under  any  Securities  Laws  of  any  jurisdiction,  or  the  consent  or  approval  of  Regulatory
Authority, is necessary as a condition of, or in connection with, the grant or exercise of such Award or the issuance or
purchase of Shares thereunder, such Award may not be accepted or exercised in whole or in part unless such listing,
registration,  qualification,  consent  or  approval  shall  have  been  effected  or  obtained  on  conditions  acceptable  to  the
Board.  Nothing  herein  shall  be  deemed  to  require  the  Corporation  to  apply  for  or  to  obtain  such  listing,  registration,
qualification, consent or approval.

3.5 Participation

The  Board  may  only  grant  Awards  to  an  Employee  or  Consultant  if  such  Employee  or  Consultant  is  a  bona  fide
Employee or Consultant of the Corporation or a Subsidiary of the Corporation, as the case may be. The Board may, in
its sole discretion, grant the majority of the Awards to Insiders of the Corporation. The number of Shares that may be
purchased  under  any Award  or  the  amount  of  any Award  that  shall  be  granted  in  any  form  that  may  result  in  the
issuance of Shares will be determined and fixed by the Board at the date of grant, provided that:

(i)

(ii)

no more than 2% of the issued and outstanding Shares may be granted to any one Consultant in any
12 month period; and

no  more  than  an  aggregate  of  2%  of  the  issued  and  outstanding  Shares  may  be  granted  to  all
Participants conducting Investor Relations Activities in any 12 month period.

 
 
 
 
 
 
 
 
 
3.6 Number of Shares Reserved

- 11 -

Subject  to  adjustment  as  provided  for  in ARTICLE  12  and  any  subsequent  amendment  to  this  Plan,  the  number  of
Shares reserved for issuance and which will be available for issuance pursuant to Awards granted under this Plan will
be equal to a number that:

(a)

if, and for so long as the Common Shares are listed on the TSXV, shall not exceed the lower of (i) 367,563
Common  Shares,  and  (ii)  20%  of  the  issued  and  outstanding  Common  Shares  as  of  March  31,  2017,
representing 2,940,511 Common Shares, which number shall include Common Shares issuable pursuant to
options issued under the Stock Option Plan.

(b)

if, and for so long as the Shares are listed on the TSX, shall not exceed 2.5% of the issued and outstanding
Shares of the Corporation from time to time.

The aggregate maximum number of Shares available under the Plan may be used for any type of Award. Subject to the
provisions and restrictions of this Plan, if any Award is exercised, cancelled, expired or otherwise terminated for any
reason  whatsoever,  the  number  of  Shares  in  respect  of  which  Award  is  exercised,  cancelled,  expired  or  otherwise
terminated for any reason whatsoever, as the case may be, will ipso facto again be immediately available for purchase
pursuant to Awards granted under this Plan.

All grants of Awards under this Plan will be evidenced by Award Agreements. Award Agreements will be subject to
the  applicable  provisions  of  this  Plan  and  will  contain  such  provisions  as  are  required  by  this  Plan  and  any  other
provisions that the Board may direct. Any one officer of the Corporation is authorized and empowered to execute and
deliver, for and on behalf of the Corporation, an Award Agreement to each Participant granted an Award pursuant to
this Plan.

3.7 Non-transferability of Awards

No  assignment  or  transfer  of Awards,  whether  voluntary,  involuntary,  by  operation  of  law  or  otherwise,  vests  any
interest or right in such Awards whatsoever in any assignee or transferee (except that, if, and for so long as the Shares
are listed on the TSX, a Participant may transfer Awards to Permitted Assigns in a manner consistent with applicable
tax  and  securities  laws)  and  immediately  upon  any  assignment  or  transfer,  or  any  attempt  to  make  the  same,  such
Awards will terminate and be of no further force or effect. If any Participant has transferred Awards to a corporation
pursuant to this Section 3.7, such Awards will terminate and be of no further force or effect if at any time the transferor
should cease to own all of the issued shares of such corporation.

3.8 Dividend Equivalents

(a) RSUs, PSUs and DSUs shall be credited with dividend equivalents in the form of additional RSUs, PSUs
and DSUs as of each dividend payment date in respect of which normal cash dividends are paid on Shares.
Such  dividend  equivalents  shall  be  computed  by  dividing:  (a)  the  amount  obtained  by  multiplying  the
amount of the dividend declared and paid per Share by the number of RSUs, PSUs and DSUs held by the
Participant on the record date for the payment of such dividend,

 
 
 
 
 
 
 
 
 
 
- 12 -

by  (b)  the  Market  Price  at  the  close  of  the  first  business  day  immediately  following  the  dividend  record
date,  with  fractions  computed  to  three  decimal  places.  Dividend  equivalents  credited  to  a  Participant’s
accounts shall vest in proportion to the RSUs, PSUs and DSUs to which they relate.

(b) The Board may in its discretion include in an Award Agreement applicable to an Other Share-Based Award
a dividend equivalent right entitling the Participant to receive amounts equal to the normal cash dividends
that would be paid, during the time such Award is outstanding and unexercised, on the Shares covered by
such Award if such Shares were then outstanding and may decide whether such payments shall be made in
cash,  in  Shares  or  in  another  form,  whether  they  shall  be  conditioned  upon  the  vesting  of  the Award  to
which they relate, the time or times at which they shall be made, and such other terms and conditions as the
Board shall deem appropriate.

(c)

The foregoing does not obligate the Corporation to make dividends on Shares and nothing in this Plan shall
be interpreted as creating such an obligation.

3.9 Permitted Assigns

If,  and  for  so  long  as  the  Shares  are  listed  on  the  TSX,  grants  of  Awards  may  be  made  to  Permitted  Assigns  of
Employees, Directors and Consultants and may be transferred by Employees, Directors and Consultants to a Permitted
Assign  of  an  Employee,  Director  or  Consultant  as  applicable,  except  for  U.S.  Taxpayers,  if  transfer  to  a  Permitted
Assign would be prohibited by Section 409A of the Code. In any such case, the provisions of ARTICLE 10 shall apply
to the Award as if the Award was held by the Employee, Director or Consultant rather than such person’s Permitted
Assign.

In  the  event  of  the  death  of  the  Permitted  Assign,  the  Award  shall  be  automatically  transferred  to  the  Employee,
Director or Consultant who effected the transfer of the Award to the deceased Permitted Assign.

ARTICLE 4
GRANT OF RESTRICTED SHARE UNITS

4.1 Grant of RSUs

If, and for so long as (i) the Corporation is a Tier 1 issuer on the TSXV, (ii) the Shares are listed on the Toronto Stock
Exchange, or (iii) the prior approval of the of the stock exchange on which the Shares are listed for trading is obtained,
the  Board  may,  from  time  to  time,  subject  to  the  provisions  of  this  Plan  and  such  other  terms  and  conditions  as  the
Board may prescribe, grant RSUs to any Participant. The number of RSUs to be credited to each Participant’s account
shall  be  computed  by  dividing  (a)  the  Award  Value,  by  (b)  the  Market  Price  of  a  Share  on  the  day  immediately
preceding the Grant Date, with fractions rounded down to the nearest whole number.

4.2 Terms of RSUs

The Board shall have the authority to condition the grant of RSUs upon the attainment of

 
 
 
 
 
 
 
 
 
 
- 13 -

specified  Performance  Goals,  or  such  other  factors  (which  may  vary  as  between  awards  of  RSUs)  as  the  Board  may
determine in its sole discretion.

4.3 Vesting of RSUs

The Board shall have the authority to determine at the time of grant, in its sole discretion, the duration of the vesting
period and other vesting terms applicable to the grant of RSUs, provided that no RSU granted shall vest and be payable
after December 31 of the third calendar year following the year of service for which the RSU was granted.

4.4 Delivery of Shares

Unless  otherwise  specified  in  the Award Agreement,  as  soon  as  practicable  following  the  expiry  of  the  applicable
vesting period, or at such later date as may be determined by the Board in its sole discretion at the time of grant, a share
certificate representing the Shares issuable pursuant to the RSUs shall be registered in the name of the Participant or as
the Participant may direct, subject to applicable securities laws.

ARTICLE 5
PERFORMANCE SHARE UNITS

5.1 Grant of PSUs

If, and for so long as (i) the Corporation is a Tier 1 issuer on the TSXV, (ii) the Shares are listed on the Toronto Stock
Exchange, or (iii) the prior approval of the of the stock exchange on which the Shares are listed for trading is obtained,
the  Board  may,  from  time  to  time,  subject  to  the  provisions  of  this  Plan  and  such  other  terms  and  conditions  as  the
Board  may  prescribe,  grant  PSUs  to  any  Participant.  Each  PSU  will  consist  of  a  right  to  receive  a  Share  upon  the
achievement of such Performance Goals during such performance periods as the Board will establish. The number of
PSUs  to  be  credited  to  each  Participant’s  account  shall  be  computed  by  dividing  (a)  the Award  Value,  by  (b)  the
Market Price of a Share on the day immediately preceding the Grant Date, with fractions rounded down to the nearest
whole number.

5.2 Terms of PSUs

Subject to the terms of the Plan, the Performance Goals to be achieved during any performance period, the length of
any performance period, the amount of any PSU granted, the termination of a Participant’s employment and the amount
of any payment or transfer to be made pursuant to any PSU will be determined by the Board and by the other terms and
conditions of any PSU, all as set forth in the applicable Award Agreement.

5.3 Performance Goals

The  Board  will  issue  Performance  Goals  prior  to  the  commencement  of  the  performance  period  to  which  such
Performance  Goals  pertain.  The  Performance  Goals  may  be  based  upon  the  achievement  of  corporation-wide,
divisional  or  individual  goals,  or  any  other  basis  determined  by  the  Board.  The  Board  may  modify  the  Performance
Goals as necessary to align them with the Corporation’s corporate objectives if there is a subsequent material change in
the Corporation’s business, operations or capital or corporate structure. The Performance Goals may include a

 
 
 
 
 
 
 
- 14 -

threshold level of performance below which no payment will be made (or no vesting will occur), levels of performance
at which specified payments will be made (or specified vesting will occur), and a maximum level of performance above
which no additional payment will be made (or at which full vesting will occur).

5.4 Delivery of Shares

Unless  otherwise  specified  in  the Award Agreement,  as  soon  as  practicable  following  the  expiry  of  the  applicable
vesting period, or at such later date as may be determined by the Board in its sole discretion at the time of grant, a share
certificate representing the Shares issuable pursuant to the PSUs shall be registered in the name of the Participant or as
the Participant may direct, subject to applicable securities laws.

ARTICLE 6
RESTRICTED SHARES

6.1 Grant of Restricted Shares

If, and for so long as (i) the Corporation is a Tier 1 issuer on the TSXV, (ii) the Shares are listed on the Toronto Stock
Exchange, or (iii) the prior approval of the of the stock exchange on which the Shares are listed for trading is obtained,
the  Board  may,  from  time  to  time,  subject  to  the  provisions  of  this  Plan  and  such  other  terms  and  conditions  as  the
Board  may  prescribe,  grant  Restricted  Shares  to  any  Participant.  The  terms  and  conditions  of  each  Restricted  Shares
grant shall be evidenced by an Award Agreement, which agreements need not be identical. The number of Restricted
Shares  to  be  credited  to  each  Participant’s  account  shall  be  computed  by  dividing  (a)  the Award  Value,  by  (b)  the
Market Price of a Share on the day immediately preceding the Grant Date, with fractions rounded down to the nearest
whole number.

Subject to the restrictions set forth in Section 10.2, except as otherwise set forth in the applicable Award Agreement,
the Participant shall generally have the rights and privileges of a shareholder as to such Restricted Shares, including the
right to vote such Restricted Shares. Unless otherwise set forth in a Participant’s Award Agreement, cash dividends and
stock dividends, if any, with respect to the Restricted Shares shall be withheld by the Corporation for the Participant’s
account, and shall be subject to forfeiture until released, in each case, to be released at the same time and in the same
proportion  as  the  lapse  of  restrictions  on  the  Restricted  Shares  to  which  such  dividends  relate.  Except  as  otherwise
determined by the Board, no interest will accrue or be paid on the amount of any dividends withheld.

6.2 Restrictions on Transfer

In  addition  to  any  other  restrictions  set  forth  in  a  Participant’s Award Agreement,  until  such  time  that  the  Restricted
Period for the Restricted Shares has lapsed pursuant to the terms of the Award Agreement, which Restricted Period the
Board may in its sole discretion accelerate at any time, the Participant shall not be permitted to sell, transfer, pledge, or
otherwise encumber the Restricted Shares. Notwithstanding anything contained herein to the contrary, the Board shall
have the authority to remove any or all of the restrictions on the Restricted Shares whenever it may determine that, by
reason of changes in applicable laws or other changes in circumstances arising after the date of the Restricted Shares
Award, such action is appropriate.

 
 
 
 
 
6.3

Separation of Service

- 15 -

Except as may otherwise be provided by applicable laws and regulations or in the applicable Award Agreement, in the
event  of  a  Participant’s  “separation  from  service”  (within  the  meaning  of  Section  409A  of  the  Code)  with  the
Corporation or any of the Subsidiaries for any reason prior to the time that the Restricted Period for the Participant’s
Restricted  Shares  has  lapsed,  as  soon  as  practicable  following  such  Separation  from  Service,  the  Corporation  shall
repurchase from the Participant, and the Participant shall sell, all of such Participant’s Restricted Shares for which the
Restricted  Period  has  not  lapsed  at  a  purchase  price  equal  to  the  cash  amount,  if  any,  paid  by  the  Participant  for  the
Restricted Shares, or if no cash amount was paid by the Participant for the Restricted Shares, such Restricted Shares
shall  be  forfeited  by  the  Participant  to  the  Corporation  for  no  consideration  as  of  the  date  of  such  separation  from
service.

ARTICLE 7
GRANT OF DEFERRED SHARE UNITS

7.1 Number of Deferred Share Units

If, and for so long as (i) the Corporation is a Tier 1 issuer on the TSXV, (ii) the Shares are listed on the Toronto Stock
Exchange, or (iii) the prior approval of the of the stock exchange on which the Shares are listed for trading is obtained,
the  Board  may,  from  time  to  time,  subject  to  the  provisions  of  this  Plan  and  such  other  terms  and  conditions  as  the
Board  may  prescribe,  grant  Deferred  Share  Units  to  any  Participant;  provided,  however,  to  the  extent  required  by
applicable  law  (including,  but  not  limited  to,  Section  409A  of  the  Code),  if  any  Participant  is  allowed  an  election  to
receive  DSUs  in  lieu  of  other  compensation,  such  election  must  be  made  in  writing  prior  to  the  start  of  the  calendar
year  during  which  services  will  be  performed  for  which  the  compensation  relates,  or  such  later  date  as  permitted  in
accordance with applicable law, including, but not limited to, Section 409A of the Code and the regulations thereunder.
The number of DSUs to be credited to each Participant’s account shall be computed by dividing (a) the Award Value,
by (b) the Market Price of a Share on the day immediately preceding the Grant Date, with fractions rounded down to
the nearest whole number.

All Deferred Share Units received by a Participant shall be credited to an account maintained for the Participant on the
books  of  the  Corporation,  as  of  the  Date  of  Grant.  The  award  of  Deferred  Share  Units  for  a  calendar  year  to  a
Participant shall be evidenced by an Award Agreement.

7.2

Issuance of Shares

DSUs shall be settled on the date established in the Award Agreement (the “ Settlement Date”);  provided,  however
that in no event shall a DSU Award be settled prior to the date of the applicable Participant’s Separation from Service.
If the Award Agreement does not establish a date for the settlement of the DSUs, then the Settlement Date shall be the
date of Separation from Service, subject to the delay that may be required under Section 13.9 below. On the Settlement
Date for any DSU:

(a)

the Participant shall deliver a cheque payable to the Corporation (or payment by such other method as may
be acceptable to the Corporation) representing payment of any amounts required by the Corporation to be
withheld in connection with such settlement as contemplated by Section 13.3; and

 
 
 
 
 
 
(b)

the  Corporation  shall  issue  to  the  Participant  one  fully  paid  and  non-assessable  Share  in  respect  of  each
Vested DSU being paid on such date.

- 16 -

ARTICLE 8
OTHER SHARE-BASED AWARDS

8.1 Other Share-Based Awards

The Board may, from time to time, subject to the prior approval of the TSX-V, if applicable, the provisions of this Plan
and such other terms and conditions as the Board may prescribe, grant Other Share-Based Awards to any Participant.
Each Other Share-Based Award will consist of a right (1) which is other than an Award or right described in Article 4,
5, 6 or 7 above and (2) which is denominated or payable in, valued in whole or in part by reference to, or otherwise
based on or related to, Shares (including, without limitation, securities convertible into Shares) as are deemed by the
Board to be consistent with the purposes of the Plan; provided, however, that such right will comply with applicable
law.  Subject  to  the  terms  of  the  Plan  and  any  applicable Award Agreement,  the  Board  will  determine  the  terms  and
conditions of Other Share-Based Awards. Shares or other securities delivered pursuant to a purchase right granted under
this Section 8.1 will be purchased for such consideration, which may be paid by such method or methods and in such
form  or  forms,  including,  without  limitation,  cash,  Shares,  other  securities,  other  Awards,  other  property,  or  any
combination thereof, as the Board will determine.

ARTICLE 9
BONUS SHARES

9.1 Bonus Shares

The Board may, from time to time, subject to the provisions of this Plan and such other terms and conditions as the
Board may prescribe, grant fully paid and non-assessable Bonus Shares to any Participant. The allocation of the Bonus
Shares  among  the  Participants  shall  be  determined  by  the  Board  of  Directors  at  the  time  that  the  Bonus  Shares  are
qualified for issuance and shall be evidenced by an Award Agreement.

ARTICLE 10
TERMINATION OF EMPLOYMENT OR SERVICES

10.1 Death or Disability

If a Participant dies or becomes Disabled while an Employee, Director or Consultant:

(a)

a  portion  of  the  next  instalment  of  any Awards  due  to  vest  (or  for  which  the  Restricted  Period  is  due  to
lapse) shall immediately vest (or cease to be restricted) such portion to equal to the number of Awards next
due to vest (or cease to be restricted) multiplied by a fraction the numerator of which is the number of days
elapsed since the date of vesting (or lapse of Restricted Period) of the last instalment of the Awards (or if
none have vested or have ceased to be restricted, the Date of Grant) to the date of Disability or death and
the denominator of which is the number of days between the date of vesting (or lapse of Restricted Period)
of the last instalment of the Awards (or if none have vested or have ceased to be

 
 
 
 
 
 
 
 
- 17 -

restricted, the Date of Grant) and the date of vesting (or lapse of Restricted Period) of the next instalment of
the Awards;

(b)

unless otherwise determined by the Board and set forth in an Award Agreement and subject to subsection
(c), any Awards held by the Participant that are not yet vested (or for which the Restricted Period has not
lapsed)  at  the  date  of  Disability  or  death  are  immediately  forfeited  to  the  Corporation  on  the  date  of
Disability or death; and

(c)

such Participant’s or Director’s eligibility to receive further grants of Awards under the Plan ceases as of
the date of Disability or death.

10.2 Termination of Employment or Services

(a) Where  a  Participant’s  employment  or  term  of  office  or  engagement  with  the  Corporation  or  an Affiliate
terminates by reason of the Participant’s death or Disability, then the provisions of Section 10.1 will apply.

(b) Unless  otherwise  determined  by  the  Board  and  set  forth  in  an Award Agreement,  where  a  Participant’s
employment or term of office or engagement terminates by reason of a Participant’s resignation or, in the
case  of  a  Consultant,  by  reason  of  the  termination  by  the  Consultant  of  the  Consultant’s  engagement  in
accordance  with  the  terms  of  such  engagement,  then  any Awards  held  by  the  Participant  that  are  not  yet
vested (or for which the Restricted Period has not lapsed) at the Termination Date are immediately forfeited
to the Corporation on the Termination Date.

(c) Unless  otherwise  determined  by  the  Board  and  set  forth  in  an Award Agreement,  where  a  Participant’s
employment or term of office or engagement terminates by reason of termination by the Corporation or an
Affiliate  without  cause  in  the  case  of  an  Employee,  without  breach  of  a  Director’s  fiduciary  duties  or
without breach of contract by a Consultant, as applicable (in each case as determined by the Board in its
sole  discretion)  (whether  such  termination  occurs  with  or  without  any  or  adequate  notice  or  reasonable
notice, or with or without any or adequate compensation in lieu of such notice), then any Awards held by
the Participant that are not yet vested (or for which the Restricted Period has not lapsed) at the Termination
Date are immediately forfeited to the Corporation on the Termination Date.

(d) Where an Employee Participant’s or Consultant Participant’s employment or engagement is terminated by
the Corporation or an Affiliate for cause (as determined by the Board in its sole discretion), or, in the case
of a Consultant, for breach of contract (as determined by the Board in its sole discretion), then any Awards
held  by  the  Participant  at  the  Termination  Date  (whether  or  not  then  vested  or  subject  to  a  Restricted
Period) are immediately forfeited to the Corporation on the Termination Date.

(e) Where a Director’s term of office is terminated by the Corporation for breach by the Director of his or her

fiduciary duty to the Corporation (as determined by the

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 18 -

Board in its sole discretion), then any Awards held by the Director at the Termination Date (whether or not
vested or subject to a Restricted Period) are immediately forfeited to the Corporation on the Termination
Date.

(f) Where a Director’s term of office terminates for any reason other than death or Disability of the Director or
a breach by the Director of his or her fiduciary duty to the Corporation (as determined by the Board in its
sole  discretion),  the  Board  may,  in  its  sole  discretion,  at  any  time  prior  to  or  following  the  Termination
Date,  provide  for  the  vesting  (or  lapse  of  restrictions)  of  any  or  all  Awards  held  by  a  Director  on  the
Termination Date.

(g) The  eligibility  of  a  Participant  to  receive  further  grants  under  the  Plan  ceases  as  of  the  date  that  the
Corporation or an Affiliate, as the case may be, provides the Participant with written notification that the
Participant’s employment or term of service is terminated, notwithstanding that such date may be prior to
the Termination Date.

(h) Unless the Board, in its sole discretion, otherwise determines, at any time and from time to time, Awards
are not affected by a change of employment arrangement within or among the Corporation or a Subsidiary
for  so  long  as  the  Participant  continues  to  be  an  employee  of  the  Corporation  or  a  Subsidiary,  including
without  limitation  a  change  in  the  employment  arrangement  of  a  Participant  whereby  such  Participant
becomes a Director.

10.3 Discretion to Permit Acceleration

Notwithstanding  the  provisions  of  Sections  10.1  and  10.2,  the  Board  may,  in  its  discretion,  at  any  time  prior  to  or
following the events contemplated in such Sections, permit the acceleration of vesting (or Restricted Period) of any or
all Awards, all in the manner and on the terms as may be authorized by the Board.

ARTICLE 11
CHANGE IN CONTROL

11.1 Change in Control

The  Board  shall  have  the  right  to  determine  that  any  unvested  or  unearned  Bonus  Shares,  Restricted  Share  Units,
Deferred  Share  Units,  Performance  Share  Units  or  Other  Share-Based  Awards  or  Restricted  Shares  subject  to  a
Restricted Period outstanding immediately prior to the occurrence of a Change in Control shall become fully vested or
earned or free of restriction upon the occurrence of such Change in Control. The Board may also determine that any
vested or earned Bonus Shares, Restricted Share Units, Deferred Share Units, Performance Share Units or Other Share-
Based  Awards  shall  be  cashed  out  at  the  Market  Price  as  of  the  date  such  Change  in  Control  is  deemed  to  have
occurred, or as of such other date as the Board may determine prior to the Change in Control. Further, the Board shall
have the right to provide for the conversion or exchange of any Bonus Shares, Restricted Share Unit, Deferred Share
Unit,  Performance  Share  Unit  or  Other  Share-Based  Award  into  or  for  rights  or  other  securities  in  any  entity
participating in or resulting from the Change in Control.

 
 
 
 
 
 
 
 
 
 
 
- 19 -

ARTICLE 12
SHARE CAPITAL ADJUSTMENTS

12.1 General

The existence of any Awards does not affect in any way the right or power of the Corporation or its shareholders to
make, authorize or determine any adjustment, recapitalization, reorganization or any other change in the Corporation’s
capital structure or its business, or any amalgamation, combination, arrangement, merger or consolidation involving the
Corporation, to create or issue any bonds, debentures, Shares or other securities of the Corporation or to determine the
rights and conditions attaching thereto, to effect the dissolution or liquidation of the Corporation or any sale or transfer
of  all  or  any  part  of  its  assets  or  business,  or  to  effect  any  other  corporate  act  or  proceeding,  whether  of  a  similar
character or otherwise, whether or not any such action referred to in this Section would have an adverse effect on this
Plan or on any Award granted hereunder.

12.2 Reorganization of Corporation’s Capital

Should  the  Corporation  effect  a  subdivision  or  consolidation  of  Shares  or  any  similar  capital  reorganization  or  a
payment of a stock dividend (other than a stock dividend that is in lieu of a cash dividend), or should any other change
be made in the capitalization of the Corporation that does not constitute a Change in Control and that would warrant the
amendment or replacement of any existing Awards in order to adjust the number of Shares that may be acquired on the
vesting  of  outstanding  Awards  and/or  the  terms  of  any  Award  in  order  to  preserve  proportionately  the  rights  and
obligations  of  the  Participants  holding  such Awards,  the  Board  will,  subject  to  the  prior  approval  of  the  Exchange,
authorize such steps to be taken as it may consider to be equitable and appropriate to that end.

12.3 Other Events Affecting the Corporation

In the event of an amalgamation, combination, arrangement, merger or other transaction or reorganization involving the
Corporation  and  occurring  by  exchange  of  Shares,  by  sale  or  lease  of  assets  or  otherwise,  that  does  not  constitute  a
Change in Control and that warrants the amendment or replacement of any existing Awards in order to adjust: (a) the
number  of  Shares  that  may  be  acquired  on  the  vesting  of  outstanding Awards  and/or  (b)  the  terms  of  any Award  in
order  to  preserve  proportionately  the  rights  and  obligations  of  the  Participants  holding  such Awards,  the  Board  will,
subject to the prior approval of the Exchange, authorize such steps to be taken as it may consider to be equitable and
appropriate to that end.

12.4 Immediate Acceleration of Awards

Where the Board determines that the steps provided in Sections 12.2 and 12.3 would not preserve proportionately the
rights, value and obligations of the Participants holding such Awards in the circumstances or otherwise determines that
it  is  appropriate  the  Board  may  permit  the  immediate  vesting  of  any  unvested Awards  and  immediate  lapse  of  any
Restricted Period.

12.5 Issue by Corporation of Additional Shares

Except  as  expressly  provided  in  this ARTICLE  12,  neither  the  issue  by  the  Corporation  of  shares  of  any  class  or
securities convertible into or exchangeable for shares of any class, nor the

 
 
 
 
 
 
 
- 20 -

conversion or exchange of such shares or securities, affects, and no adjustment by reason thereof is to be made with
respect to the number of Shares that may be acquired as a result of a grant of Awards.

12.6 Fractions

No  fractional  Shares  will  be  issued  pursuant  to  an  Award.  Accordingly,  if,  as  a  result  of  any  adjustment  under
Section 12.2, 12.3 or dividend equivalent, a Participant would become entitled to a fractional Share, the Participant has
the  right  to  acquire  only  the  adjusted  number  of  full  Shares  and  no  payment  or  other  adjustment  will  be  made  with
respect to the fractional Shares, which shall be disregarded.

ARTICLE 13
MISCELLANEOUS PROVISIONS

13.1 Legal Requirement

The Corporation is not obligated to grant any Awards, issue any Shares or other securities, make any payments or take
any  other  action  if,  in  the  opinion  of  the  Board,  in  its  sole  discretion,  such  action  would  constitute  a  violation  by  a
Participant,  Director  or  the  Corporation  of  any  provision  of  any  applicable  statutory  or  regulatory  enactment  of  any
government  or  government  agency  or  the  requirements  of  any  stock  exchange  upon  which  the  Shares  may  then  be
listed.

13.2 Participants’ Entitlement

Except as otherwise provided in this Plan, Awards previously granted under this Plan are not affected by any change in
the relationship between, or ownership of, the Corporation and an Affiliate. For greater certainty, all grants of Awards
remain are not affected by reason only that, at any time, an Affiliate ceases to be an Affiliate.

13.3 Withholding Taxes

The granting or vesting or lapse of the Restricted Period of each Award under this Plan is subject to the condition that if
at  any  time  the  Board  determines,  in  its  discretion,  that  the  satisfaction  of  withholding  tax  or  other  withholding
liabilities is necessary or desirable in respect of such grant, vesting or lapse of the Restricted Period, such action is not
effective unless such withholding has been effected to the satisfaction of the Board. In such circumstances, the Board
may require that a Participant pay to the Corporation such amount as the Corporation or an Affiliate is obliged to remit
to the relevant taxing authority in respect of the granting or vesting or lapse of the Restricted Period of the Award. Any
such additional payment is due no later than the date on which any amount with respect to the Award is required to be
remitted to the relevant tax authority by the Corporation or an Affiliate, as the case may be.

13.4 Rights of Participant

No Participant has any claim or right to be granted an Award and the granting of any Award is not to be construed as
giving  a  Participant  a  right  to  remain  as  an  employee,  consultant  or  director  of  the  Corporation  or  an Affiliate.  No
Participant has any rights as a shareholder of the

 
 
 
 
 
 
 
- 21 -

Corporation in respect of Shares issuable pursuant to any Award until the allotment and issuance to such Participant, or
as such Participant may direct, of certificates representing such Shares.

13.5 Other Incentive Awards

The  Board  shall  have  the  right  to  grant  other  incentive  awards  based  upon  Shares  under  this  Plan  to  Participants  in
accordance  with  applicable  laws  and  regulations  and  subject  to  regulatory  approval,  including  without  limitation  the
approval of the Exchange (to the extent the Corporation has any securities listed on the particular exchange), having
such  terms  and  conditions  as  the  Board  may  determine,  including  without  limitation  the  grant  of  Shares  based  upon
certain conditions and the grant of securities convertible into Shares.

13.6 Blackout Period

If an Award expires during, or within five business days after, a trading black-out period imposed by the Corporation to
restrict trades in the Corporation’s securities, then, notwithstanding any other provision of this Plan, the Award shall
expire ten business days after the trading black-out period is lifted by the Corporation.

13.7 Termination

The Board may, without notice or shareholder approval, terminate the Plan on or after the date upon which no Awards
remain outstanding.

13.8 Amendment

(a)

Subject to the rules and policies of any stock Exchange on which the Shares are listed and applicable law,
the Board may, without notice or shareholder approval, at any time or from time to time, amend the Plan for
the purposes of:

(i) making any amendments to the general vesting provisions or Restricted Period of each Award;

(ii) making any amendments to the provisions set out in ARTICLE 10;

(iii) making any amendments to add covenants of the Corporation for the protection of Participants, as the
case may be, provided that the Board shall be of the good faith opinion that such additions will not be
prejudicial to the rights or interests of the Participants, as the case may be;

(iv) making any amendments not inconsistent with the Plan as may be necessary or desirable with respect
to matters or questions which, in the good faith opinion of the Board, having in mind the best interests
of  the  Participants  and  Directors,  it  may  be  expedient  to  make,  including  amendments  that  are
desirable as a result of changes in law in any jurisdiction where a Participant resides, provided that the
Board shall be of the opinion that such amendments and modifications will not be prejudicial to the
interests of the Participants and Directors; or

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 22 -

(v) making such changes or corrections which, on the advice of counsel to the Corporation, are required
for the purpose of curing or correcting any ambiguity or defect or inconsistent provision or clerical
omission  or  mistake  or  manifest  error,  provided  that  the  Board  shall  be  of  the  opinion  that  such
changes or corrections will not be prejudicial to the rights and interests of the Participants.

(b)

Subject to Section 11.1, the Board shall not materially adversely alter or impair any rights or increase any
obligations  with  respect  to  an  Award  previously  granted  under  the  Plan  without  the  consent  of  the
Participant, as the case may be.

(c) Notwithstanding any other provision of this Plan, none of the following amendments shall be made to this
Plan  without  approval  of  the  Exchange  (to  the  extent  the  Corporation  has  any  securities  listed  on  the
particular  Exchange)  and  the  approval  of  shareholders  in  accordance  with  the  requirements  of  such
Exchange(s):

(i)

(ii)

amendments to the Plan which would increase the number of Shares issuable under the Plan, except
as otherwise provided pursuant to the provisions in the Plan, including Sections 12.2 and 12.3, which
permit  the  Board  to  make  adjustments  in  the  event  of  transactions  affecting  the  Corporation  or  its
capital;

amendments  to  the  Plan  which  would  increase  the  number  of  Shares  issuable  to  Insiders,  except  as
otherwise  provided  pursuant  to  the  provisions  in  the  Plan,  including  Sections  12.2  and  12.3,  which
permit  the  Board  to  make  adjustments  in  the  event  of  transactions  affecting  the  Corporation  or  its
capital; and

(iii) amendments to this Section 13.8.

Any amendment that would cause an Award held by a U.S. Taxpayer to fail to comply with Section 409A of the Code
shall be null and void ab initio.

13.9 Section 409A of the Code

This Plan will be construed and interpreted to be exempt from, or where not so exempt, to comply with Section 409A of
the Code to the extent required to preserve the intended tax consequences of this Plan. The Corporation reserves the
right  to  amend  this  Plan  to  the  extent  it  reasonably  determines  is  necessary  in  order  to  preserve  the  intended  tax
consequences of this Plan in light of Section 409A of the Code and any regulations or guidance under that section. In
no  event  will  the  Corporation  be  responsible  if Awards  under  this  Plan  result  in  adverse  tax  consequences  to  a  U.S.
Taxpayer under Section 409A of the Code. Notwithstanding any provisions of the Plan to the contrary, in the case of
any  “specified  employee”  within  the  meaning  of  Section  409A  of  the  Code  who  is  a  U.S.  Taxpayer,  distributions  of
non-qualified  deferred  compensation  under  Section  409A  of  the  Code  made  in  connection  with  a  “separation  from
service” within the meaning set forth in Section 409A of the Code may not be made prior to the date which is 6 months
after the date of separation from service (or, if earlier, the date of death of the U.S. Taxpayer). Any amounts subject to
a delay in payment pursuant to the

 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 23 -

preceding  sentence  shall  be  paid  as  soon  practicable  following  such  6-month  anniversary  of  such  separation  from
service.

13.10 Requirement of Notification of Election Under Section 83(b) of the Code

If a Participant, in connection with the acquisition of Restricted Shares under the Plan, is permitted under the terms of
the Award Agreement to make the election permitted under Section 83(b) of the Code (i.e., an election to include in
gross income in the year of transfer the amounts specified in Section 83(b) of the Code notwithstanding the continuing
transfer  restrictions)  and  the  Participant  makes  such  an  election,  the  Participant  shall  notify  the  Corporation  of  such
election within ten (10) days of filing notice of the election with the Internal Revenue Service, in addition to any filing
and notification required pursuant to regulations issued under Section 83(b) of the Code.

13.11 Indemnification

Every member of the Board will at all times be indemnified and saved harmless by the Corporation from and against all
costs, charges and expenses whatsoever including any income tax liability arising from any such indemnification, that
such member may sustain or incur by reason of any action, suit or proceeding, taken or threatened against the member,
otherwise than by the Corporation, for or in respect of any act done or omitted by the member in respect of this Plan,
such costs, charges and expenses to include any amount paid to settle such action, suit or proceeding or in satisfaction
of any judgment rendered therein.

13.12 Participation in the Plan

The participation of any Participant in the Plan is entirely voluntary and not obligatory and shall not be interpreted as
conferring upon such Participant any rights or privileges other than those rights and privileges expressly provided in the
Plan.  In  particular,  participation  in  the  Plan  does  not  constitute  a  condition  of  employment  or  engagement  nor  a
commitment on the part of the Corporation to ensure the continued employment or engagement of such Participant. The
Plan  does  not  provide  any  guarantee  against  any  loss  which  may  result  from  fluctuations  in  the  market  value  of  the
Shares. The Corporation does not assume responsibility for the income or other tax consequences for the Participants
and Directors and they are advised to consult with their own tax advisors.

13.13 International Participants

With  respect  to  Participants  who  reside  or  work  outside  Canada  and  the  United  States,  the  Board  may,  in  its  sole
discretion, amend, or otherwise modify, without shareholder approval, the terms of the Plan or Awards with respect to
such  Participants  in  order  to  conform  such  terms  with  the  provisions  of  local  law,  and  the  Board  may,  where
appropriate, establish one or more sub-plans to reflect such amended or otherwise modified provisions.

13.14 Effective Date

This Plan becomes effective on June 27, 2013, being the date on which the Plan was approved by the shareholders of
the Corporation.

 
 
 
 
 
 
 
13.15 Governing Law

- 24 -

This Plan and all matters to which reference is made herein shall be governed by and interpreted in accordance with the
laws of the Province of Québec and the federal laws of Canada applicable therein.

Lastly adopted by the Board on June 8, 2017

Lastly approved by Shareholders on July 12, 2016

 
 
SCHEDULE A

Award Agreement

Acasti Pharma Inc. (“ Us” or “Our”) hereby grants the following Award(s) to you subject to the terms and conditions of
this Award Agreement (the “ Agreement”), together with the provisions of Our Equity Incentive Plan (the “ Plan”) in
which you become a “Participant”, dated ●, 2013, all the terms of which are hereby incorporated into this Agreement:

Name and Address of Participant:

Date of Grant:

Type of Award:

Total Number Granted:

Vesting Date(s):

1.

2.

3.

The  terms  and  conditions  of  the  Plan  are  hereby  incorporated  by  reference  as  terms  and  conditions  of  this
Award  Notice  and  all  capitalized  terms  used  herein,  unless  expressly  defined  in  a  different  manner,  have  the
meanings ascribed thereto in the Plan.

Each  notice  relating  to  the Award  must  be  in  writing  and  signed  by  the  Participant  or  the  Participant’s  legal
representative.  All  notices  to  US  must  be  delivered  personally  or  by  prepaid  registered  mail  and  must  be
addressed to Our Corporate Secretary. All notices to the Participant will be addressed to the principal address of
the Participant on file with US. Either the Participant or US may designate a different address by written notice
to  the  other.  Any  notice  given  by  either  the  Participant  or  US  is  not  binding  on  the  recipient  thereof  until
received.

Nothing in the Plan, in this Agreement, or as a result of the grant of an Award to you, will affect Our right, or
that of any Affiliate of Ours, to terminate your employment or term of office or engagement at any time for any
reason whatsoever. Upon such termination, your rights to exercise Award will be subject to restrictions and time
limits, complete details of which are set out in the Plan.

[4.

Add a fixed payment date or permitted event for payment, for U.S. taxpayers .]

ACASTI PHARMA INC.

By:  

 Authorized Signatory

I  have  read  the  foregoing Agreement  and  hereby  accept  the Award  in  accordance  with  and  subject  to  the  terms  and
conditions of the Agreement and the Plan. [I understand that I may review the complete text of the Plan on line at
[●], or by contacting either my Human

 
   
 
   
 
   
 
   
 
   
 
 
 
 
 
Resources  representative  or  the  Office  of  the  Corporate  Secretary.]   I  agree  to  be  bound  by  the  terms  and
conditions of the Plan governing the Award.

- 2 -

Date Accepted

  Signature

 
 
 
 
 
 
 
   
 
 
Exhibit 4.3

ACASTI PHARMA INC.

STOCK OPTION PLAN
AS AMENDED JUNE 8, 2017

 
 
ACASTI PHARMA INC.

STOCK OPTION PLAN

THIS PLAN adopted October 8, 2008, amended on April 29, 2009, March 1, 2011, May 22, 2013, October 5, 2015, May 11,
2016 and June 8, 2017.

ARTICLE 1
DEFINITIONS AND INTERPRETATION

1.1                            Definitions. Where used in this Plan, unless there is something in the subject matter or context inconsistent
therewith, the following terms will have the meanings set forth below:

(a)

(b)

“Associate” has the meaning ascribed to it in the Securities Act.

“Board” means the board of directors of the Corporation, or any duly appointed committee thereof to which the
board of directors of the Corporation has delegated the power to administer and grant Options under this Plan, as
constituted from time to time.

(c)

“Cause” means, with respect to a particular Employee:

(i)

(ii)

“cause” as such term is defined in the written employment agreement between the Corporation and the
Employee; or

in  the  event  there  is  no  written  employment  agreement  between  the  Corporation  and  the  Employee  or
“cause” is not defined in the written employment agreement between the Corporation and the Employee,
the usual meaning of cause under the laws of the Province of Québec.

(d)

“Change of Control” means:

(i)

a  consolidation,  reorganization,  amalgamation,  merger,  acquisition  or  other  business  combination  (or  a
plan of arrangement in connection with any of the foregoing), other than solely involving the Corporation
and any one or more of its Associates, with respect to which all or substantially all of the Persons who
were the beneficial owners of the Shares and other securities of the Corporation immediately prior to such
consolidation,  reorganization,  amalgamation,  merger,  acquisition,  business  combination  or  plan  of
arrangement  do  not,  following  the  completion  of  such  consolidation,  reorganization,  amalgamation,
merger, acquisition, business combination or plan of arrangement, beneficially own, directly or indirectly,
more than 50% of the resulting voting rights (on a fully-diluted basis) of the Corporation or its successor;

(ii)

a resolution is adopted to wind-up, dissolve or liquidate the Corporation;

(iii)

(iv)

the  sale,  exchange  or  other  disposition  to  a  person  other  than  an Affiliate  of  the  Corporation  of  all  or
substantially all of the Corporation’s assets; or

a  change  in  the  composition  of  the  Board,  which  occurs  at  a  single  meeting  of  the  shareholders  of  the
Corporation or upon the execution of a shareholders’

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 2 -

resolution,  such  that  individuals  who  are  members  of  the  Board  immediately  prior  to  such  meeting  or
resolution cease to constitute a majority of the Board, without the Board, as constituted immediately prior
to such meeting or resolution, having approved of such change;

(e)

(f)

“Code” has the meaning given in Section 7.1 of this Plan.

“Company”  means,  unless  specifically  indicated  otherwise,  a  corporation,  incorporated  association  or
organization, body corporate, partnership, trust, association, or other entity other than an individual.

(g)

“Consultant” means a person, other than an Employee or Director of the Corporation, or a Company, who:

(i)

(ii)

(iii)

(iv)

provides on a bona fide basis consulting, technical, management or other services to the Corporation or a
Subsidiary of the Corporation under a written contract;

possesses technical, business, management or other expertise of value to the Corporation or a Subsidiary
of the Corporation;

in  the  reasonable  opinion  of  the  Corporation,  spends  or  will  spend  a  significant  amount  of  time  and
attention on the business and affairs of the Corporation or a Subsidiary of the Corporation; and

has a relationship with the Corporation or a Subsidiary of the Corporation that enables the individual to be
knowledgeable about the business and affairs of the Corporation.

(h)

“Corporation” means Acasti Pharma Inc., and includes any successor corporation thereto.

(i)

“Director” means a member of the board of directors of the Corporation or a member of the board of directors of
a  Subsidiary  of  the  Corporation  to  whom  stock  options  may  be  granted  in  reliance  on  a  prospectus  exemption
under applicable Securities Laws.

(j)

“Effective Date” means the effective date of this Plan, as amended, being October 8, 2008.

(k)

“Employee” means an individual who:

(i)

(ii)

is considered an employee of the Corporation or a Subsidiary of the Corporation under the Income  Tax
Act  (Canada)  (i.e.,  for  whom  income  tax,  employment  insurance  and  CPP  deductions  must  be  made  at
source);

works  full-time  for  the  Corporation  or  a  Subsidiary  of  the  Corporation  providing  services  normally
provided by an employee and who is subject to the same control and direction by the Corporation or a
Subsidiary of the Corporation over the details and methods of work as an employee of the Corporation,
but for whom income tax deductions are not made at source; or

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 3 -

(iii)

works  for  the  Corporation  or  a  Subsidiary  of  the  Corporation  on  a  continuing  and  regular  basis  for  a
minimum  amount  of  time  per  week  providing  services  normally  provided  by  an  employee  and  who  is
subject to the same control and direction by the Corporation or a Subsidiary of the Corporation over the
details and methods of work as an employee of the Corporation, but for whom income tax deductions are
not made at source.

(l)

(m)

(n)

(o)

(p)

“Exchange” means the TSX Venture Exchange and, where the context permits, any other exchange on which the
Shares are or may be listed from time to time.

“Exercise  Notice”  means  the  notice  respecting  the  exercise  of  an  Option,  in  the  form  set  out  in  the  Option
Agreement, duly executed by the Option Holder.

“Exercise Period” means the period during which a particular Option may be exercised and, subject to  earlier
termination in accordance with the terms hereof, is the period from and including the Grant Date through to and
including the Expiry Date.

“Exercise Price”  means  the  price  per  Share  at  which  Shares  may  be  purchased  under  an  Option  duly  granted
under  this  Plan,  as  determined  in  accordance  with  Section  4.3  of  this  Plan  and,  if  applicable,  adjusted  in
accordance with Section 3.5 of this Plan.

“Expiry Date” means the date determined in accordance with Section 4.2 of this Plan and after which a particular
Option cannot be exercised and is deemed to be null and void and of no further force or effect.

(q)

“Grant Date” means the date on which the Board grants a particular Option.

(r)

(s)

(t)

(u)

(v)

“Insider” means an “insider” as defined by the Exchange from time to time in its rules and regulations.

“ISOs” has the meaning given in Section 7.1 of this Plan.

“Market Price” at any date in respect of the Shares shall be the closing price of such Shares on the Exchange
(and if listed on more than one stock exchange, then the highest of such closing prices) on the last Business Day
prior  to  the  Grant  Date  (or,  if  such  Shares  are  not  then  listed  and  posted  for  trading  on  the  Exchange,  on  such
stock  exchange  in  Canada  on  which  the  Shares  are  listed  and  posted  for  trading  as  may  be  selected  for  such
purpose by the Board). In the event that such Shares did not trade on such Business Day, the Market Price shall
be the average of the bid and asked prices in respect of such Shares at the close of trading on such date. In the
event that such Shares are not listed and posted for trading on any stock exchange, the Market Price shall be the
fair market value of such Shares as determined by the Board in its sole discretion;

“Option” means an option to acquire Shares granted to a Director, Employee or Consultant of the Corporation, or
any Subsidiary of the Corporation pursuant to this Plan.

“Option Agreement”  means  an  agreement,  in  the  form  substantially  similar  as  that  set  out  in  Schedule  “A”
hereto, evidencing an Option granted under this Plan.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(w)

(x)

(y)

(z)

(aa)

(bb)

- 4 -

“Option Holder”  means  a  Director,  Employee  or  Consultant  or  former  Director,  Employee  or  Consultant,  to
whom  an  Option  has  been  granted  and  who  continues  to  hold  an  unexercised  and  unexpired  Option  or,  where
applicable, the Personal Representative of such person.

“Plan” means this stock option plan, as may be amended from time to time.

“Person” means a Company or an individual.

“Personal Representative” means:

(i)

(ii)

in the case of a deceased Option Holder, the executor or administrator of the deceased duly appointed by
a court or public authority having jurisdiction to do so; and

in the case of an Option Holder who, for any reason, is unable to manage his or her affairs, the individual
entitled by law to act on behalf of such Option Holder.

“QBCA” means the Business Corporations Act (Québec), as amended, or such other successor legislation which
may be enacted, from time to time.

“Regulatory  Authorities”  means  the  Exchange  and  any  other  organized  trading  facilities  on  which  the
Corporation’s  Shares  are  listed  and  all  securities  commissions  or  similar  securities  regulatory  bodies  having
jurisdiction over the Corporation.

(cc)

“Re-Organization Event” has the meaning given in Section 3.5 of this Plan.

(dd)

(ee)

(ff)

“Securities Act”  means  the Securities Act (Québec), as amended, or such other successor legislation as may be
enacted, from time to time.

“Securities Laws”  means  securities  legislation,  securities  regulation  and  securities  rules,  as  amended,  and  the
policies, notices, instruments and blanket orders in force from time to time that govern or are applicable to the
Corporation or to which it is subject, including, without limitation, the Securities Act.

“Share” means one (1) common share without par value in the capital stock of the Corporation as constituted on
the Effective Date or, in the event of an adjustment contemplated by Section 3.5 of this Plan, such other shares or
securities  to  which  an  Option  Holder  may  be  entitled  upon  the  due  exercise  of  an  Option  as  a  result  of  such
adjustment.

(gg)

“Subsidiary” means a subsidiary as defined in the QBCA.

(hh)

“Termination Date” means:

(i)

in the case of the resignation of the Option Holder as an Employee of the Corporation, the date that the
Option  Holder  provides  notice  of  his  or  her  resignation  as  an  Employee  of  the  Corporation  to  the
Corporation;

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 5 -

(ii)

(iii)

in the case of the termination of the Option Holder as an Employee of the Corporation by the Corporation
for  any  reason  other  than  death,  the  effective  date  of  termination  set  out  in  the  Corporation’s  notice  of
termination of the Option Holder as an Employee of the Corporation to the Option Holder;

in the case of the termination of the written contract of the Option Holder to provide consulting services to
the Corporation, the effective date of termination set out in any notice provided by one of the parties to
the written contract to the other party; or

(iv)

the effective date of termination of a Director, Employee or Consultant pursuant to an order made by any
Regulatory Authority having jurisdiction to so order.

(ii)

“U.S. Taxpayer” has the meaning given in Section 7.1 of this Plan.

1.2                            Choice of Law. This Plan is established under and the provisions of this Plan will be subject to and
interpreted and construed in accordance with the laws of the Province of Québec.

1.3                            Headings. The headings used herein are for convenience only and are not to affect the interpretation of this
Plan.

ARTICLE 2
PURPOSE AND ADMINISTRATION

2.1                            Purpose. The purpose of this Plan is to provide the Corporation with a share-related mechanism to attract,
retain and motivate qualified Directors, Employees and Consultants of the Corporation, and any Subsidiary of the Corporation,
to reward such of those Directors, Employees and Consultants as may be granted Options under this Plan by the Board from time
to  time  for  their  contributions  toward  the  long  term  goals  and  success  of  the  Corporation  and  to  enable  and  encourage  such
Directors, Employees and Consultants to acquire Shares as long term investments and proprietary interests in the Corporation.

2.2                            Administration. This Plan will be administered by the Board. The Board may make, amend and repeal at
any time and from time to time such regulations not inconsistent with this Plan as it may deem necessary or advisable for the
proper administration and operation of this Plan and such regulations will form part of this Plan. The Board may delegate to any
director or other senior officer or employee of the Corporation such administrative duties and powers as it may see fit.

2.3                            Board Powers. The Board shall have the power, where consistent with the general purpose and intent of this
Plan and subject to the specific provisions of this Plan to, amongst other things:

(a)

(b)

establish policies and to adopt rules and regulations for carrying out the purposes, provisions and administration
of this Plan;

interpret and construe this Plan and to determine all questions arising out of this Plan or any Option, and any such
interpretation,  construction  or  determination  made  by  the  Board  shall  be  final,  binding  and  conclusive  for  all
purposes;

(c)

determine the number of Shares reserved for issuance by each Option;

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
determine the Exercise Price of each Option;

- 6 -

determine the time or times when Options will be granted and exercisable;

determine  if  the  Shares  which  are  issuable  on  the  due  exercise  of  an  Option  will  be  subject  to  any  restrictions
upon the due exercise of such Option; and

(d)

(e)

(f)

(g)

prescribe the form of the instruments and certificates relating to the grant, exercise and other terms of Options.

2.4                            Board Discretion. The Board may, in its discretion, require as conditions to the grant or exercise of any
Option that the Option Holder shall have:

(a)

represented, warranted and agreed in form and substance satisfactory to the Corporation that the Option Holder is
acquiring and will acquire such Option and the Shares to be issued upon the exercise thereof for his, her or its
own account, for investment and not with a view to or in connection with any distribution, that the Option Holder
has had access to such information as is necessary to enable him, her or it to evaluate the merits and risks of such
investment and that the Option Holder is able to bear the economic risk of holding such Shares for an indefinite
period;

(b)

agreed to restrictions on transfer in form and substance satisfactory to the Corporation and to an endorsement on
any option agreement or certificate representing the Shares making appropriate reference to such restrictions; and

(c)

agreed to indemnify the Corporation in connection with the foregoing.

2.5                            Board Requirements. Any Option granted under this Plan shall be subject to the requirement that, if at any
time  counsel  to  the  Corporation  shall  determine  that  the  listing,  registration  or  qualification  of  the  Shares  issuable  upon  due
exercise  of  such  Option  upon  any  securities  exchange  or  under  any  Securities  Laws  of  any  jurisdiction,  or  the  consent  or
approval of Regulatory Authority, is necessary as a condition of, or in connection with, the grant or exercise of such Option or
the  issuance  or  purchase  of  Shares  thereunder,  such  Option  may  not  be  accepted  or  exercised  in  whole  or  in  part  unless  such
listing, registration, qualification, consent or approval shall have been effected or obtained on conditions acceptable to the Board.
Nothing  herein  shall  be  deemed  to  require  the  Corporation  to  apply  for  or  to  obtain  such  listing,  registration,  qualification,
consent or approval.

2.6                            Interpretation. The interpretation by the Board of any of the provisions of this Plan and any determination
by it pursuant thereto will be final and conclusive and will not be subject to any dispute by any Option Holder. No member of the
Board or any individual acting pursuant to authority delegated by it hereunder will be liable for any action or determination in
connection with this Plan made or taken in good faith and each member of the Board and each such individual will be entitled to
indemnification with respect to any such action or determination in the manner provided for by the Corporation.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 7 -

ARTICLE 3
GRANT OF OPTIONS

3.1                            Board to Issue Shares. The Shares to be issued to Option Holders upon the exercise of Options will be
previously authorized but unissued Shares in the capital stock of the Corporation.

3.2                            Participation. The Board will, from time to time and in its sole discretion, determine (i) those Directors,
Employees, Consultants (and, when applicable, to a Company wholly owned by any such Director, Employee or Consultant), if
any, to whom Options are to be granted based upon certain participation criteria, which criteria include but are not limited to
functions within the Corporation, or any Subsidiary of the Corporation, seniority or actual and future contributions to the success
of  to  the  Corporation,  or  any  Subsidiary  of  the  Corporation,  and  (ii)  the  number  of  Options  to  be  granted  to  such  Directors,
Employees or Consultants. The Board may only grant options to an Employee or Consultant if such Employee or Consultant is a
bona fide Employee or Consultant of the Corporation or a Subsidiary of the Corporation, as the case may be. The Board may, in
its sole discretion, grant the majority of the Options to Insiders of the Corporation. However, in no case will the grant of Options
under this Plan, together with any proposed or previously existing security based compensation arrangement, result in (in each
case, as determined on the Grant Date):

(a)

(b)

the  grant  to  any  one  Consultant  of  the  Corporation,  or  any  Subsidiary  of  the  Corporation,  within  any  twelve
(12) month period, of Options reserving for issuance a number of Shares exceeding in the aggregate two percent
(2%) of the Corporation’s issued and outstanding Shares (on a non-diluted basis); or

the grant to any one Employee of the Corporation or any Subsidiary of the Corporation, which provides investor
relations  services,  within  any  twelve  (12)  month  period,  of  Options  reserving  for  issuance  a  number  of  Shares
exceeding in the aggregate two percent (2%) of the Corporation’s issued and outstanding Shares (on a non-diluted
basis).

3.3                            Number of Shares Reserved. Subject to adjustment as provided for in Section 3.4 of this Plan and any
subsequent  amendment  to  this  Plan,  the  number  of  Shares  reserved  for  issuance  and  which  will  be  available  for  purchase
pursuant  to  Options  granted  under  this  Plan,  together  with  any  proposed  or  previously  existing  security  based  compensation
arrangement, will equal to 2,940,511, representing 20% of the issued and outstanding Shares of the Corporation as of March 31,
2017. Subject to the provisions and restrictions of this Plan, if any Option is cancelled, expired or otherwise terminated for any
reason whatsoever, the number of Shares in respect of which Option is cancelled, expired or otherwise terminated for any reason
whatsoever, as the case may be, will ipso facto again be immediately available for purchase pursuant to Options granted under
this Plan.

3.4                            Adjustments. If, prior to the complete exercise of an Option, the Shares are consolidated, subdivided,
converted, exchanged or reclassified or in any way substituted for (collectively, a “ Re-Organization Event”), an Option, to the
extent that it has not been exercised, will be adjusted by the Board in accordance with such Re-Organization Event in the manner
the Board deems appropriate and equitable. No fractional Shares will be issued upon the exercise of the Options and accordingly,
if as a result of the Re-Organization Event, an Option Holder would become entitled to a fractional Share, such Option Holder
will have the right to purchase only the next lowest whole number of Shares and no payment or other adjustment will be made
with respect to the fractional interest so disregarded.

3.5                            Notification of Grant. Following the approval by the Board of the granting of an Option, the Board will
notify the Option Holder in writing of the award and will enclose with such notice the Option Agreement representing the Option
so granted.

 
 
 
 
 
 
- 8 -

3.6                            Copy of Plan. Each Option Holder, concurrently with the notice of the award of the Option, will, upon
written request, be provided with a copy of this Plan, and a copy of any amendment to this Plan will be promptly provided by the
Board to each Option Holder.

3.7                            Limitation. This Plan does not give any Option Holder that is a Director the right to serve or continue to
serve as a Director of the Corporation, does not give any Option Holder that is an Employee the right to be or to continue to be
employed by the Corporation and does not give any Option Holder that is a Consultant the right to be or continue to be retained
or engaged by the Corporation as a consultant for the Corporation.

ARTICLE 4
TERMS AND CONDITIONS OF OPTIONS

4.1                            Term of Option. Subject to Section 4.2, the Expiry Date of an Option will be the date so fixed by the Board
at the time the particular Option is granted, provided that such date will be no later than the tenth (10th) anniversary of the Grant
Date of such Option.

4.2                            Termination of Option. Subject to such other terms or conditions that may be attached to Options granted
hereunder, an Option Holder may exercise an Option in whole or in part at any time or from time to time during the Exercise
Period. Any Option or part thereof not exercised within the Exercise Period will terminate and become null, void and of no effect
as of 5:00 p.m. (Montréal time) on the Expiry Date. The Expiry Date of an Option will be the earlier of the date so fixed by the
Board at the time the Option is granted and the date established, if applicable, in subsections (a) to (c) below:

(a)

Death, Disability or Retirement of Option Holder

In the event that the Option Holder should die, become disable or retire from the Corporation while he or she is still an
Employee (if he or she holds his or her Option as an Employee) or in the event that the Option Holder should die or become disable while
he or she is still a Director (if he or she holds his or her Option as a Director) or a Consultant (if he or she holds his or her Option as a
Consultant), the Expiry Date will be the first anniversary of the Option Holder’s date of death, disability or retirement, as applicable.

(b)

Ceasing to Hold Office

In the event that the Option Holder holds his or her Option as a Director of the Corporation and such Option Holder ceases
to be a Director of the Corporation other than by reason of death or disability the Expiry Date of the Option will not exceed the sixtieth
(60th) day following the date the Option Holder ceases to be a Director of the Corporation unless the Option Holder ceases to be a Director
of the Corporation as a result of:

(i)

(ii)

ceasing to meet the qualifications of a director set forth the QBCA; or

an ordinary resolution having been passed by the shareholders of the Corporation pursuant to the QBCA;
or

(iii)

an order made by any Regulatory Authority having jurisdiction to so order,

in which case the Expiry Date will be the date the Option Holder ceases to be a Director of the Corporation.

 
 
 
 
 
 
 
 
 
 
 
 
(c)

Ceasing to be an Employee or Consultant

- 9 -

In the event that the Option Holder holds his or her Option as an Employee or Consultant of the Corporation and such Option
Holder  ceases  to  be  an  Employee  or  Consultant  of  the  Corporation  other  than  by  reason  of  death,  disability  or  retirement,  as
applicable in accordance with Section 4.2(a), the Expiry Date of the Option will not exceed the sixtieth (60th) day following the
Termination Date or, if the Employee or Consultant provides investor relations services, the thirtieth (30th) day following the
Termination Date, unless the Option Holder::

(i)

(ii)

ceases to be an Employee of the Corporation as a result of termination for Cause; or

ceases  to  be  an  Employee  or  Consultant  of  the  Corporation  as  a  result  of  an  order  made  by  any  Regulatory
Authority having jurisdiction to so order,

in which case the Expiry Date will be the Termination Date.

(d)

Bankruptcy

In  the  event  that  an  Option  Holder  commits  an  act  of  bankruptcy  or  any  proceeding  is  commenced  against  an  Option  Holder
under the Bankruptcy and Insolvency Act (Canada) or other applicable bankruptcy or insolvency legislation in force at the time
of such bankruptcy or insolvency, the Expiry Date of the Option will be the date immediately preceding the date on which such
Option Holder commits such act of bankruptcy.

Notwithstanding anything contained in this Plan, with the exception of Section 5.5, in no case will an Option be exercisable after
the tenth (10th) anniversary of the Grant Date of the Option.

4.3                            Exercise Price. The price at which an Option Holder may purchase a Share upon the exercise of an Option
(the “Exercise Price”) will be determined by the Board and set forth in the Option Agreement issued in respect of such Option
and,  in  any  event,  will  not  be  less  than  the  Market  Price  of  the  Corporation’s  Shares  calculated  as  of  the  Grant  Date.
Notwithstanding anything else contained in this Plan, in no case will the Market Price be less than the minimum prescribed by
each of the organized trading facilities as would apply to the Grant Date in question.

4.4                            Vesting. The date or dates on and after which a particular Option, or part thereof, may be exercised will be
determined by the Board and set forth in the Option Agreement issued in respect of such Option. In any event, all Options will be
vested gradually and evenly over a period of at least eighteen (18) months, on a quarterly basis.

4.5                            Additional Terms. Subject to all applicable Securities Laws of all applicable Regulatory Authorities, the
Board may attach other terms and conditions to the grant of a particular Option, such terms and conditions to be referred to in the
Option Agreement at the time of grant. These terms and conditions may include, but are not necessarily limited to, the following:

(a)

(b)

providing that an Option expires on a date other than as provided for herein;

providing  that  a  portion  or  portions  of  an  Option  vest  after  certain  periods  of  time  or  upon  the  occurrence  of
certain events, or expire after certain periods of time or upon the occurrence of certain events;

(c)

providing that an Option be exercisable immediately, in full, notwithstanding that it has vesting

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 10 -

provisions, upon the occurrence of certain events, such as a friendly or hostile take-over bid for the Corporation;
and

(d)

providing that an Option issued to, held by or exercised by an Option Holder who is a citizen or resident of the
United  Sates  of America,  and  otherwise  meeting  the  statutory  requirements,  be  treated  as  an  “Incentive  Stock
Option” as that term is defined for purposes of the United States of America Internal Revenue Code of 1986, as
amended.

4.6                            Non-Transferability of Options. The Options granted hereunder are not assignable, transferable or
negotiable  (whether  by  operation  of  law  or  otherwise)  and  may  not  be  assigned  or  transferred,  provided  however  that  the
Personal Representative of an Option Holder may, to the extent permitted by Section 5.1 of this Plan, exercise the Option within
the Exercise Period. Upon any attempt to assign, transfer, negotiate, pledge, hypothecate or otherwise dispose of or transfer an
Option contrary to this Section 4.6 of this Plan, or upon the levy of any attachment or similar process upon an Option, the Option
and all rights, benefits and privileges arising thereunder or therefrom, at the sole discretion and election of the Board, shall cease
and terminate and be of no further force or affect whatsoever.

4.7                            No Rights as Shareholders. An Option Holder shall not have any rights as a shareholder of the Corporation
with  respect  to  any  of  the  Shares  covered  by  such  Option  until  the  date  of  issuance  of  a  certificate  for  Shares  upon  the  due
exercise of such Option, in full or in part, and then only with respect to the Shares represented by such certificate or certificates.
Without in any way limiting the generality of the foregoing, no adjustment shall be made for dividends or other rights for which
the record date is prior to the date such share certificate is issued.

ARTICLE 5
EXERCISE OF OPTION

5.1                            Exercise of Option. An Option may be exercised only by the Option Holder or the Personal Representative
of the Option Holder. Subject to the provisions of this Plan, an Option Holder or the Personal Representative of an Option Holder
may exercise an Option in whole or in part at any time or from time to time during the Exercise Period up to 5:00 p.m. (Montréal
time) on the Expiry Date by delivering to the Secretary of the Corporation an Exercise Notice indicating the number of Shares to
be  purchased  pursuant  to  the  exercise  of  the  Option,  the  applicable  Option Agreement  and  a  certified  cheque  or  bank  draft
payable to “Acasti Pharma Inc.” in an amount equal to the aggregate Exercise Price of the Shares to be purchased pursuant to the
exercise of the Option.

5.2                            Withholding Taxes. In addition to the other conditions on exercise set forth in this Plan, the exercise of
each  Option  granted  under  this  Plan  is  subject  to  the  satisfaction  of  all  applicable  withholding  taxes  or  other  withholding
liabilities as the Corporation may determine to be necessary or desirable in respect of such exercise. The Corporation will require
that an Option Holder pay to the Corporation, in addition to, and in the same manner as, the Exercise Price, such amount as the
Corporation is obliged to remit to the relevant taxing authority in respect of the exercise of the Option.

5.3                            Issue of Share Certificates. As soon as practicable following the receipt of (i) the Exercise Notice and the
certified cheque or bank draft referred to in Section 5.1, and (ii) any amounts payable under Section 5.2, the Board will cause to
be  delivered  to  the  Option  Holder  the  Shares  so  purchased  in  certificated  or  uncertificated  form.  If  the  number  of  Shares  so
purchased  is  less  than  the  number  of  Shares  subject  to  the  Option Agreement,  the  Option  Holder  will  surrender  the  Option
Agreement to the Corporation and the Board will forward a new Option Agreement to the Option Holder

 
 
 
 
 
- 11 -

concurrently with delivery of the Shares for the balance of Shares available under the Option.

5.4                            Condition of Issue. The Options and the issue of Shares by the Corporation pursuant to the exercise of
Options  are  subject  to  the  terms  and  conditions  of  this  Plan  and  compliance  with  the  rules  and  policies  of  all  applicable
Regulatory Authorities to the granting of such Options and to the issuance and distribution of such Shares, and to all applicable
Securities Laws. The Option Holder agrees to comply with all such laws, regulations, rules and policies and agrees to furnish to
the Corporation any information, reports or undertakings required to comply with and to fully cooperate with the Corporation in
complying with such laws, regulations, rules and policies. Notwithstanding any of the provisions contained in this Plan or in any
Option, the Corporation’s obligation to issue Shares to an Option Holder pursuant to the exercise of any Option granted under the
Plan shall be subject to:

(a)

(b)

(c)

completion  of  such  registration  or  other  qualification  of  such  Shares  or  obtaining  approval  of  such  Regulatory
Authority as the Corporation shall determine to be necessary or advisable in connection with the authorization,
issuance or sale thereof;

the admission of such Shares to listing on any stock exchange on which the Shares may then be listed;

the  receipt  from  the  Option  Holder  of  such  representations,  warranties,  agreements  and  undertakings,  as  the
Corporation determines to be necessary or advisable in order to safeguard against the violation of the Securities
Laws of any jurisdiction; and

(d)

the satisfaction of any conditions on exercise prescribed pursuant to this Plan.

5.5                            Blackout Period. If an Option expires during, or within five business days after, a trading black-out period
imposed  by  the  Corporation  to  restrict  trades  in  the  Corporation’s  securities,  then,  notwithstanding  any  other  provision  of  the
Plan,  the  Option  shall  expire  ten  business  days  after  the  trading  black-out  period  is  lifted  by  the  Corporation,  subject  to  the
maximum period of time during which an Option is exercisable under Sections 7.3 of this Plan.

ARTICLE 6
AMENDMENT AND TERMINATION

6.1                            Amendment Without Shareholder Approval . Subject to the prior approval of the Exchange, The Board
may amend, suspend or discontinue the Plan, and amend or discontinue any Options granted under the Plan, at any time without
shareholder approval. Without limiting the foregoing, the Board is specifically authorized to amend the terms of the Plan, and the
terms of any Options granted under the Plan, without obtaining shareholder approval, to:

(a)

(b)

(c)

amend the vesting provisions to the extent permitted under the rules and regulations of the Exchange;

amend the termination provisions, except as otherwise provided in Section 6.3 (b) hereof;

amend  the  eligibility  requirements  of  eligible  Directors,  Employees  or  Consultants  which  would  have  the
potential of broadening or increasing Insider participation;

(d)

add any form of financial assistance;

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 12 -

(e)

(f)

(g)

amend a financial assistance provision which is more favorable to Directors, Employees or Consultants;

add a deferred or restricted share unit or any other provision which results in Directors, Employees or Consultants
receiving securities while no cash consideration is received by the Corporation; and

make  other  amendments  of  a  housekeeping  nature  or  to  comply  with  the  requirements  of  any  Regulatory
Authority.

6.2                            Amendment with Shareholder Approval. Notwithstanding Section 6.1, no amendments to the Plan to:

(a)

(b)

(c)

(d)

increase the number of Shares reserved for issuance under the Plan (including a change from a fixed maximum
number of shares to a fixed maximum percentage of Shares);

change the manner of determining the Exercise Price; or

amend the amending provisions of Sections 6.1 to 6.3 of this Plan; or

change the employees (or class of employees) eligible to receive options under this Plan

shall be made without obtaining approval of the shareholders in accordance with the requirements of the Exchange.

6.3                            Amendment of Insider Options. Notwithstanding Section 6.1, no amendments to granted Options to:

(a)

(b)

reduce the Exercise Price for the benefit of Insiders; or

extend the termination date for the benefit of Insiders, other than in accordance with Section 5.4 hereof;

shall  be  made  without  obtaining  approval  of  the  shareholders,  or  approval  of  the  disinterested  shareholders  for  amendments
under Section 6.3(a), in accordance with the requirements of the Exchange; and no action shall be taken with respect to granted
Options  without  the  consent  of  the  Option  Holder,  unless  the  Board  determines  that  such  action  does  not  materially  alter  or
impair such Option.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
- 13 -

6.4                            Options Granted Prior to Termination. No amendment, suspension or discontinuance of the Plan or of
any granted Option may contravene the requirements of the Exchange or any securities commission or regulatory body to which
the Plan or the Corporation is now or may hereafter be subject to. Termination of the Plan shall not affect the ability of the Board
to exercise the powers granted to it hereunder with respect to Options granted under the Plan prior to the date of such termination.

6.5                            Retrospective Amendment. The Board may from time to time retrospectively amend this Plan and, with the
consent of the affected Option Holders, retrospectively amend the terms and conditions of any Options that have been previously
granted.

6.6                            Change of Control. Notwithstanding anything contained to the contrary in this Plan or in any resolution of
the Board in implementation thereof:

(a)

in  the  event  of  a  proposed  Change  of  Control  of  the  Corporation,  the  Corporation  shall  have  the  right,  upon
written notice thereof to each Option Holder holding Options under the Plan, to permit the exercise of all such
Options within the twenty (20) day period next following the date of such notice and to determine that upon the
expiration of such twenty (20) day period, all rights of the Option Holders to such Options or to exercise same (to
the  extent  not  theretofore  exercised)  shall ipso  facto  terminate  and  cease  to  have  further  force  or  effect
whatsoever;

(b)

in the event of a Change of Control of the Corporation where a notice by the Corporation was not sent to Option
Holders in accordance with Section 6.6(a),

(i)

(ii)

all  of  the  Option  Holder’s  Options  will  immediately  vest  on  the  date  of  such  event.  In  such  event,  all
Options  so  vested  will  be  exercisable  from  such  date  until  their  respective  expiry  dates,  subject  to  the
terms of any employment agreement or other contractual arrangement between the Option Holder and the
Corporation.  For  greater  certainty,  upon  a  Change  of  Control,  Option  Holders  shall  not  be  treated  any
more favourably than holders of Shares with respect to the consideration that the Option Holders would
be entitled to receive for their Shares; and

if  the  Option  Holder  elects  to  exercise  its  Options  following  a  Change  of  Control,  such  Option  Holder
shall be entitled to receive, and shall accept, in lieu of the number of Shares which such Option Holder
was  entitled  upon  such  exercise,  the  kind  and  amount  of  shares  and  other  securities,  property  or  cash
which such Option Holder could have been entitled to receive as a result of such Change of Control, on
the effective date thereof, had such Option Holder been the registered holder of the number of Shares to
which such Option Holder was entitled to purchase upon exercise of such Options.

6.7                            Extension of Expiration Date, Non-Applicability of Termination of Employment Provisions. Subject to
the rules of any relevant Regulatory Authority and Securities Laws, the Board may, by resolution:

(a)

extend the Expiration Date of any Option, but shall not, in the event of any such advancement or extension, be
under any obligation to advance or extend the date on or by which Options may be exercised by any other Option
Holder; and

 
 
 
 
 
 
 
 
 
 
 
 
- 14 -

(b)

decide that any of the provisions hereof concerning the effect of termination of the Option Holder’s employment
shall not apply to any Option Holder for any reason acceptable to the Board.

                                  Notwithstanding the provisions of Sections 6.6 and 6.7, should changes be required to the Plan by any
Regulatory Authority of any jurisdiction to which this Plan or the Corporation now is or hereafter becomes subject, such changes
shall be made to the Plan as are necessary to conform with such requirements and, if such changes are approved by the Board, the
Plan, as amended, shall be filed with the records of the Corporation and shall remain in full force and effect in its amended form
as of and from the date of its adoption by the Board.

6.8                            Regulatory Authority Approval . This Plan and any amendments hereto are subject to all necessary
approvals of the applicable Regulatory Authorities.

6.9                            Agreement . The Corporation and every Option granted hereunder will be bound by and subject to the terms
and  conditions  of  this  Plan.  By  accepting  an  Option  granted  hereunder,  the  Option  Holder  has  expressly  agreed  with  the
Corporation to be bound by the terms and conditions of this Plan.

6.10                         Effective Date of Plan. Upon approval by the shareholders of the Corporation in accordance with the
QBCA, and by acceptance by the Exchange (if the Shares are listed or posted on an Exchange and such acceptance is required),
the  amendments  to  this  Plan  made  on  May  11,  2016  shall  be  deemed  to  be  effective  as  of  the  Effective  Date. Any  Options
granted  prior  to  such  approval  and  acceptance(s),  that  exceed  the  previous  number  of  Options  available  for  grant,  shall  be
conditional upon such approval and acceptance(s) being given and no such Options may be exercised unless such approval and
acceptance is given.

6.11                         Governing Law. This Plan and all matters to which reference is made herein shall be governed by and
interpreted in accordance with the laws of the Province of Québec and the federal laws of Canada applicable therein.

ARTICLE 7
U.S. TAXPAYERS

7.1                            Provisions for U.S. Taxpayers. Options granted under this Plan to U.S. Taxpayers may be nonqualified
stock options or incentive stock options intended to qualify under Section 422 (“ISOs”) of the United States Internal Revenue
Code of 1986 and the applicable authority thereunder (the “Code”). Each Option shall be designated in the Option Agreement as
either an ISO or a non-qualified stock option. “U.S. Taxpayer” means a Person who is a U.S. citizen, U.S. permanent resident or
U.S. tax resident for the purposes of the Code whose purchase of Shares under this Plan would be subject to U.S. taxation under
the Code. Such Person shall be considered a U.S. Taxpayer solely with respect to such options. Options may be granted as ISOs
only  to  individuals  who  are  employees  of  the  Corporation  or  any  present  or  future  “subsidiary  corporation”  or  “parent
corporation” as those terms are defined in Section 424(e) and (f) of the Code, and shall not be granted to non-employee Directors
or independent contractors. If an Option Holder ceases to be employed by the Corporation and/or all “subsidiary corporations” or
“parent corporations” as those terms are defined in Section 424(e) and (f) of the Code, other than by reason of death or disability
(meaning “permanent and total disability” as defined in Section 22(e)(3) of the Code), Options shall be eligible for treatment as
ISOs only if exercised no later than three months following such termination of employment.

7 . 2                            ISOs. The maximum number of Options that may be granted as ISOs is equal to the maximum number of
Shares issuable under Section 3.3. The terms and conditions of any ISOs granted

 
 
 
- 15 -

hereunder, including the eligible recipients of ISOs, shall be subject to the provisions of Section 422 of the Code, and the terms,
conditions, limitations and administrative procedures established by the Board from time to time in accordance with this Plan. At
the discretion of the Board, ISOs may be granted to any Employee of the Corporation, its “parent corporation” or any “subsidiary
corporation“ of the Corporation, as such terms are defined in Sections 424(e) and (f) of the Code.

.

3                            ISO Grants to 10% Shareholders. Notwithstanding anything to the contrary in this Plan, if an ISO is
7
granted  to  a  Person  who  owns  shares  representing  more  than  ten  percent  of  the  voting  power  of  all  classes  of  shares  of  the
Corporation or of a “subsidiary corporation” or “parent corporation”, as such terms are defined in Section 424(e) and (f) of the
Code, the term of the Option shall not exceed five years from the time of grant of such Option and the Exercise Price shall be at
least 110 percent (110%) of the Market Price (at the time of grant) of the Shares subject to the Option.

7.4                             $100,000 Per Year Limitation for ISOs. To the extent the aggregate Market Price (determined at the time
of grant) of the Shares for which ISOs are exercisable for the first time by any Person during any calendar year (under all plans
of the Corporation) exceeds $100,000, such excess ISOs shall be treated as nonqualified stock options.

7.5                            Disqualifying Dispositions. Each Person awarded an ISO under this Plan shall notify the Corporation in
writing immediately after the date he or she makes a disqualifying disposition of any Shares acquired pursuant to the exercise of
such ISO. A disqualifying disposition is any disposition (including any sale) of Shares before the later of (i) two years after the
time of grant of the ISO or (ii) one year after the date the Person acquired the Shares by exercising the ISO. The Corporation
may, if determined by the Board and in accordance with procedures established by it, retain possession of any Shares acquired
pursuant  to  the  exercise  of  an  ISO  as  agent  for  the  applicable  Person  until  the  end  of  the  period  described  in  the  preceding
sentence, subject to complying with any instructions from such Person as to the sale of such Share.

.

7
6                            Section  409A. Any Options granted to U.S. Taxpayers shall be limited to Employees or Consultants
providing services to the Corporation or to an affiliate which is an “eligible issuer”, as defined in final Treas. Reg. 1.409A-1(b)
(iii) (this includes corporate subsidiaries in which the Corporation has a controlling interest).

(a)

(b)

No  extension  of  term  of  an  Option  shall  extend  beyond  the  latest  date  that  the  right  could  have  expired  by  its
original terms.

Any replacement options issued under Section 3.5 or 6.6 of this Plan shall comply with U.S. Treas. Reg. 1.424-1
as if the Option were a incentive stock option (ISO) so that the ratio of the Exercise Price to the fair market value
of  Shares  subject  to  the  Options  immediately  after  the  replacement  may  not  be  greater  than  the  ratio  of  the
Exercise Price to the fair market value of Shares subject to the Options immediately before the replacement.

7.7                             Transferability. Notwithstanding any other provision in this Plan, an ISO is not transferable except by will
or  by  the  laws  of  descent  and  distribution,  and  may  be  exercised,  during  the  Option  Holder’s  lifetime,  only  by  such  Option
Holder.

 
 
 
 
 
 
Adopted  by  the  Board  on  October  8,  2008,  as  amended  on  April  29,  2009,  March  1,  2011,  May  22,  2013,  October  5,
2015, May 11, 2016 and June 8, 2017 and lastly approved by the shareholders on July 12, 2016.

- 16 -

 
 
I, Janelle D’Alvise, certify that:

SECTION 302 CERTIFICATION

Exhibit 12.1

1.

2.

3.

4.

I have reviewed this annual report on Form 20-F of Acasti Pharma Inc.;

Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact
necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading
with respect to the period covered by this report;

Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all
material  respects  the  financial  condition,  results  of  operations  and  cash  flows  of  the  registrant  as  of,  and  for,  the  periods
presented in this report;

The  registrant’s  other  certifying  officer  and  I  are  responsible  for  establishing  and  maintaining  disclosure  controls  and
procedures  (as  defined  in  Exchange Act  Rules  13a-15(e)  and 15d-15(e))  and  internal  control  over  financial  reporting  (as
defined in Exchange Act Rules 13a-15(f) and 15d–15(f)) for the company and have:

a)

b)

c)

d)

Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed
under  our  supervision,  to  ensure  that  material  information  relating  to  the  company,  including  its  consolidated
subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is
being prepared;

Designed such internal control over financial reporting, or caused such internal control over financial reporting to be
designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and
the  preparation  of  financial  statements  for  external  purposes  in  accordance  with  generally  accepted  accounting
principles;

Evaluated  the  effectiveness  of  the  company’s  disclosure  controls  and  procedures  and  presented  in  this  report  our
conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period covered by
this report based on such evaluation; and

Disclosed in this report any change in the company’s internal control over financial reporting that occurred during the
period  covered  by  the  annual  report  that  has  materially  affected,  or  is  reasonably  likely  to  materially  affect,  the
company’s internal control over financial reporting; and

5.

The  company’s  other  certifying  officer  and  I  have  disclosed,  based  on  our  most  recent  evaluation  of  internal  control  over
financial  reporting,  to  the  company’s  auditors  and  the  audit  committee  of  the  company’s  board  of  directors  (or  persons
performing the equivalent functions):

a)

b)

All  significant  deficiencies  and  material  weaknesses  in  the  design  or  operation  of  internal  control  over  financial
reporting  which  are  reasonably  likely  to  adversely  affect  the  registrant’s  ability  to  record,  process,  summarize  and
report financial information; and

Any fraud, whether or not material, that involves management or other employees who have a significant role in the
company’s internal control over financial reporting.

/s/ Janelle D’Alvise
Name: Janelle D’Alvise
Title: Principal Executive Officer

Date: June 27, 2017

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
I, Linda P. O’Keefe, certify that:

SECTION 302 CERTIFICATION

Exhibit 12.2

1.

2.

3.

4.

I have reviewed this annual report on Form 20-F of Acasti Pharma Inc.;

Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact
necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading
with respect to the period covered by this report;

Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all
material  respects  the  financial  condition,  results  of  operations  and  cash  flows  of  the  registrant  as  of,  and  for,  the  periods
presented in this report;

The  registrant’s  other  certifying  officer  and  I  are  responsible  for  establishing  and  maintaining  disclosure  controls  and
procedures  (as  defined  in  Exchange Act  Rules  13a-15(e)  and 15d-15(e))  and  internal  control  over  financial  reporting  (as
defined in Exchange Act Rules 13a-15(f) and 15d–15(f)) for the company and have:

a)

b)

c)

d)

Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed
under  our  supervision,  to  ensure  that  material  information  relating  to  the  registrant,  including  its  consolidated
subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is
being prepared;

Designed such internal control over financial reporting, or caused such internal control over financial reporting to be
designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and
the  preparation  of  financial  statements  for  external  purposes  in  accordance  with  generally  accepted  accounting
principles;

Evaluated  the  effectiveness  of  the  registrant’s  disclosure  controls  and  procedures  and  presented  in  this  report  our
conclusions about the effectiveness of the disclosure controls and procedures, as of the end of the period covered by
this report based on such evaluation; and

Disclosed in this report any change in the company’s internal control over financial reporting that occurred during the
period  covered  by  the  annual  report  that  has  materially  affected,  or  is  reasonably  likely  to  materially  affect,  the
company’s internal control over financial reporting; and

5.

The  registrant’s  other  certifying  officer  and  I  have  disclosed,  based  on  our  most  recent  evaluation  of  internal  control  over
financial  reporting,  to  the  company’s  auditors  and  the  audit  committee  of  the  company’s  board  of  directors  (or  persons
performing the equivalent functions):

a)

b)

All  significant  deficiencies  and  material  weaknesses  in  the  design  or  operation  of  internal  control  over  financial
reporting  which  are  reasonably  likely  to  adversely  affect  the  company’s  ability  to  record,  process,  summarize  and
report financial information; and

Any fraud, whether or not material, that involves management or other employees who have a significant role in the
company’s internal control over financial reporting.

/s/ Linda P. O’Keefe
Name: Linda P. O’Keefe
Title: Principal Financial Officer

Date: June 27, 2017

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CERTIFICATION PURSUANT TO 18 U.S.C. SECTION 1350
AS ADOPTED PURSUANT TO
SECTION 906 OF THE SARBANES–OXLEY ACT OF 2002

In connection with the Annual Report on Form  20-F of Acasti Pharma Inc. (the “Company”) for the fiscal year ended March 31, 2017, as
filed with the Securities and Exchange Commission on the date hereof (the “Report”), I, Janelle D’Alvise, Principal Executive Officer of
the Company certify pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, that:

1.

2.

The Report fully complies with the requirements of section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended; and

The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of
the Company.

Exhibit 13.1

Date: June 27, 2017

/s/ Janelle D’Alvise
Name: Janelle D’Alvise
Title: Principal Executive Officer

 
 
 
 
 
 
CERTIFICATION PURSUANT TO 18 U.S.C. SECTION 1350
AS ADOPTED PURSUANT TO
SECTION 906 OF THE SARBANES–OXLEY ACT OF 2002

In connection with the Annual Report on Form  20-F of Acasti Pharma Inc. (the “Company”) for the fiscal year ended March 31, 2017, as
filed with the Securities and Exchange Commission on the date hereof (the “Report”), I, Linda P. O’Keefe, Principal Financial Officer of
the Company certify pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, that:

1.

2.

The Report fully complies with the requirements of section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended; and

The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of
the Company.

Exhibit 13.2

Date: June 27, 2017

/s/ Linda P. O’Keefe
Name: Linda P. O’Keefe
Title: Principal Financial Officer