Serebra's disclosure policies cover disclosure to the investment community, the press, industry consultants and other audiences. The purpose of this policy is to govern the disclosure of material, non-public information in a manner designed to provide broad, non-exclusionary distribution of information so that the public has equal access to the information.

Another purpose of the policy is to ensure that Serebra Learning Corporation complies with applicable laws, including any recent changes, adjustments and additions to the rules and regulations governing disclosure of material and non-public material information to the investment community.

Material Information

Any information concerning the company is considered material if there is a substantial likelihood that a reasonable investor would consider it important in determining whether to buy, sell, hold, or engage in other transactions concerning the company's securities. Although not intended to be a comprehensive list, the following are examples of information that could be material depending on its scale and magnitude:

Disclosures to the Investment Community

Disclosures of material, non-public information to the investment community will be coordinated with Serebra's Chief Financial Officer and shall be made in one or more of the following methods:

Authorized Spokespersons for
Disclosures to the Investment Community

Only the following authorized spokespersons may discuss material information with the institutional and individual investment community:

Other employees may be designated by either of the above-authorized spokespersons for a limited, specific communication only, including but not limited to an investor conference, a group meeting or a one-on-one meeting. Following the occurrence of the limited, specific communication, the employee's designation shall expire.

Employees and company representatives (other than the above authorized spokespersons) receiving any inquires from the investment community shall not respond to such inquiries other than to refer the inquirer to the President of Serebra Learning Corporation.

All Serebra meetings with members of the investment community shall be attended by at least one of the following:

Exceptions to this policy may be authorized only by an authorized spokesperson.

Disclosures to Audiences
other than the Investment Community

Disclosures of material, non-public information to audiences other than the investment community, including the press and industry consultants, shall be consistent with disclosures to the investment community and shall be discussed only by one or more of the following:

Disclosure of Material Non-Public
Information in Advance of Public Announcement

Any disclosure of material non-public information by an authorized spokesperson, which is made in advance of the public announcement of such information, shall only be made pursuant to an appropriate confidentiality arrangement or to a person who owes a duty of trust and confidence to the company, such as a lawyer, investment banker or accountant retained by the company.

Review of Financial Models

Financial models may be reviewed and commented upon only by the authorized spokespersons for disclosures to the investment community. Company comments on these models will be limited to the following:

Information not to be Disclosed

Our policy at Serebra is not to disclose any information that could be:

Communication and Disclosure of this Policy

The company has posted this policy on the Serebra corporate web site for reference by the investment community and the general public.