Augtust 30th, 2002

Dear Members of APERT

We, the Negotiating Committee, sincerely regret the lack of communication that we have been constrained to follow during the very protracted negotiation process. However, we have finally reached a settlement proposal as mentioned in the Press Release of 30 August 2002, copy enclosed.

These negotiations have been unbelievably complex. The interests of all members of the Pension Plan, be they pensioners, still actively employed, taking a deferred pension or having cashed in after December 1989 needed to be addressed and the settlement had to be structured to meet the anticipated requirements of the regulatory bodies and of the Courts - both Ontario and Quebec. The process is not over and during the coming months we will learn if the Settlement Proposal does indeed meet their requirements and yours as we approach everyone for approvals.

Unfortunately we continue to be constrained by the Courts as to the amount of information that we are able to communicate to you. As a member of APERT, you have a say in this matter and will be approached, when the Court permits, for your vote of approval of the settlement. To this end, we anticipate that a full disclosure package will be mailed to you early in 2003 which contains an overview of the settlement together with a personal statement of the benefit that you will receive under the agreement.

The Settlement Proposal, valued at over $52 million will provide benefits to all members of the Class Action suit, whether they joined APERT or not. Accordingly, in January we will need to hold information meetings at major centres across the Country to fully explain the Settlement. Those affected are all those members and former members of the Plan who had an entitlement under the Plan as at 31 December 1989, together with those members who became members of the Plan after 31 December 1989 and have maintained an entitlement as at 31 August 2002. As you will recall, it was in December 1989 that the Royal Trust Board of Directors closed the Pension Plan to any new participants.

We regret that we were not able to move the Bank on the issue of the pre-1994 medical/dental plan cap. It was deemed not to be a pension plan issue and therefore not on the table. Individuals may wish to approach the Bank on a "one on one" basis for consideration of a hardship case. The benefits negotiated in the form of increased pension and/or cash payments will we trust also help.

The success of this Class Action can in large part be attributed to those members who by cheque or monthly debit to their credit cards, contributed towards the costs of our legal fees. As promised, these monies will be refunded from legal fees awarded by the courts in due course. In the meantime, monthly payments will continue to be processed until such time as final approval of the Settlement has been reached. This is necessary to maintain the funding objective for the court case in the event that, for some unforeseen reason, the Settlement falls through. In addition, a small group of members committed to lend APERT sufficient funds to meet our funding requirement, which enabled us to proceed with the negotiation. The Negotiating Committee is not able to say enough in the way of appreciation to all these supporters. Thank You.

Whereas we on the Negotiating Committee are always willing to take your calls and emails, we will not be able to give you any help at this time as to how you personally will be affected by the settlement. This will have to wait until such time as you receive your disclosure package. However, we intend to update our Web Site to post any additional information that is permissible and we are able to provide - www.apert.net

In any negotiated settlement there is a compromise and you never get all that you would wish. However, we believe that you will be pleased with the results which will provide you with benefits at a time when you can use them as opposed to an uncertain decision at some distant time after the route through the courts.

We are most appreciative of the patience that you have shown and the support that you have given to your Committee over the past months and indeed years. It is that support which kept us pushing on your behalf.

Yours Truly

John Burleton Chairman - Negotiating Committee

June 30th, 2002

Great news, the proposed settlement with the Royal Bank / Royal Trust has been approved by the Courts!

Mr. Justice Haines of the Ontario Superior Court of Justice released his Judgment on May 30, 2003 and confirmed that the proposed settlement is fair and reasonable and in the best interests of the class. The full text of the Judgment and his reasons may be found on our website.

On June 10, 2003 Mr. Justice Tellier confirmed the settlement in Quebec. As a result, we are still on track with respect to our timeline and proposed payout for the summer of 2004.

Despite court approval, this settlement is still conditional upon certain conditions being met as outlined in the settlement proposal. These include approval by the regulatory authorities of certain aspects in connection with the New Pension Plan and that no more than 4% of the APERT entitlement group, Non-APERT entitlement group or a group of members with entitlements exceeding 4% of the total value of the pension plan “opt-out” of the settlement proposal. We remain confident that these cond itions will be met. Mr. Justice Haines was also required to review and approve the fees and disbursements incurred by the lawyers for the parties. He reviewed the contingency fee applied for by our solicitors Cohen Highley and in his Reasons for Judgment stated:

“It is apparent to me from the materials that that I have reviewed on the road to approving settlement of this matter that the interests of the class members have been well served by counsel. Counsel have demonstrated industry, diligence, persistence and creativity in achieving a commendable result…Having due regard to the substantial risk undertaken by counsel, the exemplary and extensive efforts made to keep potential class members informed and the favourable results achieved, I am of the view that a premium of $2,000,000.00 would be fair and reasonable in all the circumstances.”

This award is less than the $2,966,000.00 requested by Cohen Highley which will in most cases result in a reduced contribution by you from that previously described in your personal statement of benefits and an increase in the lump sum payment for each of you.

Your executive committee is and has been most appreciative of the efforts and skill which Cohen Highley and their staff have brought to this matter and echo the words of Mr. Justice Haines. We are also appreciative of the co-operation shown by RBC / Royal Trust once a preliminary agreement had been reached.

You may have seen the settlement reported in The Globe and Mail, Toronto Star or Lawyer’s Weekly during the weeks of June 9th and June 16th. While most of the information contained in those articles is correct, there was one error. Neither the maximum nor the average settlement is $24,000.00 per person. There are some people who are receiving in excess of $24,000.00 and there are many people receiving less than $24,000.00 in the class of 8,500 people.

Next Steps:

Those persons who do not wish to be included in the settlement have until July 31, 2003 to optout of the class action and this settlement by delivering, by registered mail, courier or facsimile, notice of desire to opt-out of the proceeding to Cohen Highly LLP at the following address:

One London Place 255 Queens Ave, 11th Floor London, ON N6A 5R8 Fax: (519) 672-5960
Additional information may be obtained from Cohen Highley by telephone at 1-888-225-1693.

There is still substantial work to be done before the distribution of benefits may be made. We need to:

a) Obtain approvals from the various regulatory bodies such as the Financial Services Commission of Ontario (FSCO);

b) Apply to the CCRA for rulings with respect to potentially beneficial tax treatment of the proposed benefits for certain members of the class;

c) Provide each eligible beneficiary with the tax options available and obtain their tax election;

d) Transfer the appropriate assets and liabilities of the Old Plan into the New Plan, including the appropriate share of the surplus.

When all of the above has been completed pension payments shall be adjusted for those individuals receiving an increase in their monthly pension, the settlement shall be distributed and those of our members who supported APERT financially shall be refunded their full contribution, including any membership fee paid.

You, the APERT members, are to be congratulated for staying the course and providing the solid moral and financial support that enabled the action to proceed to this very satisfactory result.

Have a great summer and we will be in touch to update you in the fall.

Yours Truly

John Burleton Chairman APERT Negotiating Committee

August 30th, 2003

Dear Members of APERT

I hope everybody has had a great summer. It is with great pleasure that I am writing to let you know that the condition regarding the maximum number of opt outs has been met. Only two individuals have decided to opt out of the settlement. One of these individuals left the pension plan prior to 1989 and is not entitled to any benefit under the settlement.

The remaining settlement condition is to obtain regulatory approval. Although this process may take some time, we are very optimistic regulatory approval will be obtained in due course.

We have also now contacted CCRA (formerly known as Revenue Canada) to try and obtain some tax relief for those individuals receiving $5,000.00 or greater pursuant to the settlement agreement. This process will also take some time.

However, we are on track with our timeline and still anticipate a pay out of the settlement by the summer of 2004.

We also wish to remind you that it is extremely important to keep RBC and APERT informed of any address changes until you have received your settlement pay out. Enjoy the rest of the summer and the fall. We will be in touch with you again during the winter months to update you on our progress.

Yours Truly

John Burleton Chairperson APERT Negotiating Committee

December 8th, 2003

In our last newsletter of August 20, 2003 we mentioned that the condition regarding the maximum number of opt outs had been met and that we were seeking regulatory approval.

An actuarial report on the transfer of the assets from the old plan into the new plan has recently been finalized. This report will be filed shortly with the Financial Services Commission of Ontario (which regulates the plan and the new plan) for approval of the asset transfer and the payout of the settlement benefits.

Regarding tax matters, we have been in contact with CCRA (formerly Revenue Canada) to seek certain tax relief for individuals who qualify.

The good news is that we have received an initial positive verbal response from CCRA to a proposal that would enable most members of the APERT group who are receiving a lump sum settlement of $5,000.00 or more to tax shelter at least some of their settlement through a transfer to an RRSP or RRIF. We are requesting that the payout be considered a return of contributions. The verbal response, although promising, does not guarantee that all such members of the APERT group will be able to tax shelter their settlement. We will only know for certain which APERT members will be permitted by CCRA to shelter at least some of their settlement after we have obtained written approval from CCRA. Once we receive written confirmation from CCRA of the tax sheltering options, an election form and updated estimate of your settlement benefits will be forwarded to you indicating your options with respect to how your share of the settlement monies may be received and what tax sheltering options are available to you. You may wish to speak to your personal tax advisor at that time.

You will be pleased to know that we are still on track for a payout of the settlement for the summer of 2004.

Seasons greetings and best wishes for a Merry Christmas and a Happy and Healthy New Year from each of us on the Negotiating Committee.

Yours Truly

John Burleton Chairperson APERT Negotiating Committee

April 1st, 2004

We are very pleased to be able to inform you that we are now at the stage where the Royal Bank is preparing to write to all beneficiaries who will benefit from the APERT Settlement. It has taken longer than we had originally hoped as we have had to wait longer than anticipated for confirmation from the CRA (Formerly CCRA) as to the tax treatment of certain portions of funds you will receive.

As we are sure you are aware, all monies received from the Settlement will be taxable. However we wished clarification as to which portions of the settlement monies would be eligible for tax sheltering and under what circumstances.

While a favourable tax ruling has been received with respect to most of the people affected, CRA has yet to determine whether surviving spouses will be eligible to receive the same beneficial tax treatment. Clarification as to this aspect, which affects about 125 people, has been requested but may take some months to obtain.

Rather than delay any further while waiting for this clarification, the RBC has decided to proceed with their mailing targeted for no later than the end of April. It is our understanding that each person will receive an explanatory letter together with an election form which must be returned within 60 days. This election form is used by you to direct the RBC as to the method of payment you elect. Surviving spouses may or may not be eligible for the special tax treatment but should return their election form in any event.

As we trust you will appreciate, tax related questions can be very complex and the answers will differ dramatically with each person as to their personal circumstances and benefits under the Settlement. Accordingly we will NOT be in a position to answer any telephone enquiries as to the tax treatment applicable but do ask that you wait for your letter from the RBC. Shortly after the election forms have been mailed, the asset transfer report regarding our pension plan will be filed with the Financial Services Commission of Ontario (FSCO). FSCO approval is expected to take 3-6 months.

For those of you who very generously supported our efforts with financial contributions towards our legal costs we are advised that Cohen Highley plan to refund those contributions at the same time as the RBC disburses the lump sum payments out of the Settlement.

This is all very good news indicating that we are still on target potentially for a summer payout. It may be fall, but what's another few months after such a long struggle. Your patience has been very much appreciated and we look forward to all your happy smiles.

Yours Truly

John Burleton Chairperson APERT Negotiating Committee

May 6th, 2004

In our April Newsletter we advised that the RBC had anticipated mailing a package of information to all participants by the end of April, 2004. We now understand that this mailing will probably happen by the end of May instead.

We have been advised that the Bank experienced some delays in the completion/drafting of the Election Form which would form a part of this package. This problem has now been resolved and the RBC is in a position to complete and mail the material to you shortly.

The other major hurdle that the RBC needs to clear before they can implement a "payout" is in obtaining the approval of the Financial Services Commission Office (formerly the Ontario Pension Commission). This approval could come relatively quickly or not depending on how the FSCO view it and their current work load.

Hopefully the "payout" will happen August to November this year. We appreciate your patience and understanding. The RBC does seem to be using their best efforts to expedite completion of this matter but with over 8,000 beneficiaries there are more complexities than had been anticipated.

It is our intention to post News Updates to this site as occasion demands so that you can be informed of any new developments.

Yours Truly

John Burleton Chairperson APERT Negotiating Committee

October 19th, 2004

We are writing to update you regarding the distribution of the settlement monies.

As you are aware, the settlement has been approved by the court but regulatory approval is required. An application to transfer the assets was filed with the Financial Services Commission of Ontario (FSCO) in the spring and we understood from them that the approval process usually took 90 days.

We at APERT are disappointed that we are not further along in the process of putting money in your hands from the settlement. It had been our hope that we would have had all regulatory approvals behind us at this stage and that the RBC would be busy preparing its mailing to you.

While we remain confident that FSCO will approve the settlement, we cannot be sure of the timing. While it is possible that distribution may still occur in November or December, it is possible the RBC will have difficulty in meeting its objective of the 2004 distribution unless they receive FSCO approval in the next couple of weeks – which may indeed happen. The RBC advises that they and Mercers, their actuary, will require approximately 60 days in which to complete their administrative process of preparing the distribution from the date of FSCO approval. This would include tasks such as the computation of the interest for each participant, preparation of new statements, calculation of each person's entitlement in relation to the elections they have made, and communication to you.

We ask, therefore, for your continued patience as we understand from the RBC's lawyers that they are aware of no reason why this last approval should not be forthcoming in due course.

Yours Truly

John Burleton Chairperson APERT Negotiating Committee

November 10th, 2004

We are pleased to announce that the Financial Services Commission of Ontario has approved the Pension Plan Asset Transfer.

This means the Royal Bank will be in a position to pay out the settlement funds very soon.

We are told by the bank that they are making the interest calculations currently and the expectation is that you will likely receive your settlement funds before the end of the year.

We thank you all for your encouragement and patience.

For all of the APERT members who contributed to the cause, Cohen Highley LLP will be in a position to refund your contributions on receipt of payment for their legal fees by the Royal Bank. Once again, this is anticipated to be prior to the end of this year.

Yours Truly

John Burleton Chairperson APERT Negotiating Committee

December 7th, 2004

Now that we have reached a conclusion to our Class Action Suit and settlement with RBC/Royal Trust, it is very important that we recognize some of the many people who deserve the plaudits.

First of all, our sincere thanks to all 429 APERT members who contributed to the cause and provided us with your support, both moral and financial. Without you, we would never have been able to get off the ground, let alone carry on.

An additional vote of thanks to the small group who accepted our late request to commit further funds to enable us to meet the necessary legal funding target and to those who helped in our public relations efforts with radio and newspaper interviews.

Ian Sneddon deserves great credit for raising the issue in the first place, obtaining the funds for the legal opinion, which, in turn, provided him with the encouragement to pursue the matter.

Ian formed and led the Steering Committee which included myself, Frank Boers, John Corbishley, John Crane, Richard Labrosse, Dan Marmash, Dave Mellor, Sandy Milligan, Gord Morrison, Ken Schofield, Shirley Sharpe, Sam Smythe and Hedi Stilwell, all of whom did a tremendous job of digging up names and addresses of former Royal Trusters across the country so that we could solicit the necessary members and funds to proceed. John Harley, George Houston and Don Ross were on the original Steering Committee, but later resigned. It is with deep regret that Sandy Milligan, Gord Morrison and Don Ross did not survive to see the result of their efforts.

When it became obvious that we needed a more compact group to drive forward, an Executive Committee of John Corbishley, Richard Labrosse , Dave Mellor, Ken Schofield and myself was established and initiated the Class Action Suit, which led to negotiations with RBC/RoyalTrust. Subsequently, this group and Ian Sneddon formed the Negotiating Committee. The Committee members were instrumental in directing and helping our legal and actuarial team. Each one made a major contribution to the outcome.

We were extremely fortunate in having Cohen Highley as our lawyers and they went out on a limb to take on our cause and stuck with us. They took a significant financial risk in accepting our business. Paul Vogel and Iain Sneddon of that firm did an excellent job for us and co-ordinated well with Blake, Cassels & Graydon, RBC/Royal Trust's lawyers. Our sincere thanks to Paul and Iain and their staff.

Our actuary, John Christie of Christie Consulting, Vancouver, was invaluable at resolving problems and working effectively with Mercers in Toronto, RBC/Royal Trust's actuaries. John has the gift for making numbers understandable and was a major player in helping APERT to arrive at a successful conclusion.

We also greatly appreciated the influence and experience of Mark Zigler of Koskie Minsky, our legal consultant, and Marcel Rivest of Rivest Schmidt, who represented us in Quebec.

Amber Chen set up and maintained the APERT website so that everyone could keep up with developments.

All these people made a huge contribution to our success in reaching a settlement with RBC/Royal Trust and we are greatly indebted to them. In addition, our thanks to RBC/Royal Trust personnel for their positive attitude and cooperation.

Again, our sincere thanks to all you APERT members and best wishes for a Merry Christmas and a happy and healthy holiday season and New Year.

Yours Truly

John Burleton Chairperson APERT Negotiating Committee

July 22nd, 2005

As many of you may recall, Mr. Justice Haines was the judge of the Ontario Superior Court of Justice who approved our settlement. The total settlement value is approximately $52.9 million from which more than 9100 people are eligible to benefit. To date, RBC has issued cheques to 97% of eligible settlement beneficiaries but has still to locate an additional 227 APERT Subclass members who are entitled to a total of $1.2 million in settlement funds. Our lawyers attended before Mr. Justice Haines on July 15, 2005 at which time he approved post-judgment costs to date. He also requested that our lawyers and the lawyers for RBC re-attend before him in early 2006 to report on the success of RBC’s continuing efforts to locate the remaining APERT Subclass members in order that the balance of settlement funds may be forwarded to them.

RBC is now using the National Research Unit, a government agency, which provides assistance in helping pension plan administrators locate persons who may be entitled to a pension or benefit under a pension plan.

Mr. Justice Haines also asked that we continue to maintain the APERT web site and the toll-free long distance telephone number in the hope this may assist individuals who have yet to receive their settlement.

The toll-free telephone number is 1-888-225-1693 and our web site is www.apert.net. The RBC toll-free telephone number is 1-800-545-2555.

If you are aware of any person who has not yet received their settlement, please direct them to our web site or one of the toll-free numbers.

Yours Truly

John Burleton Chairperson APERT Negotiating Committee