INSIDER TRADING POLICY





FOR




















Copyright/permission
to reproduce








Materials
in this document were produced or compiled by The Governance Box
(GBX) for the purpose of providing Public Companies with governance
information and outlining their corporate and public market
obligations to shareholders in accordance with the applicable laws
and policies of the Securities and Exchange Commission and relevant
stock market exchanges of the United States of
America.








The
materials in this manual are covered by the provisions of the
Copyright Act, by other US laws, policies, regulations, and by
international agreements. Such provisions serve to identify the
information source and, in specific instances, to prohibit
reproduction of materials without written permission.








Adopted
by Electrameccanica Vehicles Corp. Board of Directors on this ____
day of December 2017.














Electrameccanica Vehicles Corp.





The
purpose of this policy is to govern activities concerning employee
trading in securities. It is the policy of Electrameccanica
Vehicles Corp. (the “Company”) that its directors,
officers, employees (full time, part-time, contract and temporary)
and associates including those of all subsidiary companies
(collectively, the “Company Employees”), and all others
who act on the Company’s behalf, observe the spirit and
letter of all laws governing the Company’s operations, and
conduct the Company’s affairs in keeping with the highest
legal and ethical standards.





This
policy, which has been approved by the Audit Committee of the
Company’s Board of Directors, has been designed to assist
Company Employees in understanding and complying with the
Company’s policies and The Securities and Exchange Commission
rules and regulation with respect to the trading of the
Company’s securities. The policies set forth below may not
cover every situation. If there is ever any doubt as to a proper
course of action, Company Employees should consult with the
Company’s Chief Executive Officer, the Company’s
Corporate Secretary, or the Chief Financial Officer (each, a
“Senior Officer”).





1.1 Summary





1.
 This policy is
intended to ensure that Company Employees comply with the
Company’s policies and The Securities and Exchange Commission
rules and regulation with respect to the trading of the
Company’s securities.





2.
 If Company
Employees have undisclosed Material Information (as defined below)
concerning the Company, neither that person nor any related person
may buy or sell securities of the Company or engage in any other
action that takes advantage of such information or pass such
information on to others.





3.
 Insiders of the
Company and related persons are prohibited from trading in
securities of the Company from and including the day on which
written notification is delivered prohibiting trading until 24
hours after the date and time that the public release announcing
the Company’s material news is disseminated by the
Company’s news service, or in the case of financial
statements, (interim financial statements and annual audited
financial statements) to the day on which the financial results of
the Company for such periods are released. The Company will post
the dates of proposed release of its interim and audited year-end
financial statements, by e-mail, well in advance of the release
dates.





1.2 Application of the Policy





1.
 This policy applies
to all Company Employees and related persons. “Related
persons” include all associates and affiliates of Company
Employees (which includes, but is not limited to, spouses of
Company Employees, relatives of Company Employees residing with
them and personal holding companies of Company
Employees).





2.
 This policy covers
all investment activities over which such persons have control or
direction, whether for their personal account or in a fiduciary
capacity, as in the case of a partnership, trusteeship, or
executorship.





3.
 Where there is any
doubt as to whether this policy is applicable to a given person,
Company Employees should consult with a Senior Officer or the
Company’s legal counsel.





1.3 Material Information





1.
 “Material
Information” is any information concerning the business and
affairs of the Company that results in or would reasonably be
expected to result in a significant change in the market price or
value of the Company’s securities. Additionally, if it is
information that a reasonable investor would want to know before
making an investment decision.





2.
 The following types
of information regarding the Company should be presumed to be
material:





(a)
 Changes in share
ownership that may affect control of the Company;





(b)
 Take-over bids or
issuer bids;





(c)
 Changes in
corporate structure, such as amalgamations, arrangements,
reorganizations, dissolutions, etc.;





(d)
 Major corporate
acquisitions or dispositions;





(e)
 Changes in capital
structure;





(f)
 Increases or
decreases in dividends;





(g)
 Decisions to effect
or make stock splits or stock dividends;





(h)
 proposed issuance
of additional securities, whether public or private;





(i)
 proposed
redemptions or other repurchases of the Company’s
securities;





(j)
 Potential
initiation of a proxy battle;





(k)
 Changes in earnings
or financial forecasts or estimates, especially near-term earnings
prospects;





(l)
 Significant change
in operations;





(m)
 Entering or loss of
significant contracts, particularly with customers or
suppliers;





(n)
 Developments
affecting the Company’s resources, technology, or
market;





(o)
 Extraordinary or
otherwise significant borrowings;





(p)
 Major litigation
and developments in same;





(q)
 Changes in capital
investment plans or corporate objectives;





(r)
 Problems with
financial liquidity or with other commitments;





(s)
 Significant
management changes;





(t)
 Major alterations
in asset value or make-up;





(u)
 Major labor
disputes or disputes with major contractors, customers, or
suppliers;





(v)
 Major changes in
operating and financial facts, such as reduction of cash flow or
write-offs;





(w)
 Events of default
under financing or other agreements; and





(x)
 Insolvency or
bankruptcy.





3.
 The foregoing
examples of “material information” are by no means
exhaustive.





4.
 The source of any
material information is, for purposes of this policy, irrelevant.
Disclosure of material information to the public will only be
understood to have occurred once an official announcement has been
made and the public has had sufficient opportunity to evaluate it
(which will usually be considered to require at least one whole
trading day). When in doubt, any information should be presumed to
be material information and not to have been disclosed to the
public. Disclosure of material information to the public will only
be made by or with the prior approval of a “Senior
Officer”.





1.4 Definition of Insider





1.
 “Insiders”
of the Company include all directors and officers of the Company,
or of any subsidiary of the Company, and any person or company
(e.g. a personal holding company) who, directly or indirectly, owns
or controls more than 10% of the voting shares of the
Company.





1.5 Trading Prohibitions





1.
 If Company
Employees possess undisclosed material information concerning the
Company, such Company Employees and related persons may not,
directly or indirectly (i.e. via private holding company,
registered retirement savings plans, or otherwise):





a.
 Buy or sell
securities of the Company;





b.
 Buy or sell
securities whose price or value may reasonably be expected to be
affected by changes in price of the Company’s
securities;





c.
 Exercise Company
stock options or similar employee compensation mechanisms;
or





d.
 Buy or sell
securities of another company in which the Company proposes to
invest or where the individual, due to his position with the
Company, becomes aware of undisclosed material information
concerning that other company.





2.
 Company Employees
are prohibited from engaging in any other action to take advantage
of undisclosed material information concerning the Company or
undisclosed material information concerning another company, and
from passing such information on to others (i.e.
“tipping”).





3.
 The prohibitions of
this policy also apply to trading by individuals (e.g. spouses,
friends, business associates, relatives, etc. of Company Employees)
who learn of undisclosed material information concerning the
Company or undisclosed material information concerning another
company from Company Employees, who for the purposes of this policy
are responsible for the trading by such individuals. It should be
noted that trading by such individuals would also likely constitute
a violation by them of applicable securities law relating to
insider trading.





1.6 Material and Financial Blackout Periods





1.
 All directors and
officers of Electrameccanica Vehicles Corp. and all employees who
receive notice from the ECCTF Corporate Secretary that they are
designated blacked-out employees (“Designated Blacked-out
Employees”) in respect of a given blackout period shall be
subject to blackout periods surrounding the release ofElectrameccanica
Vehicles Corp. material or financial results. The Office of the
Chief Financial Officer shall determine the Designated Blacked-out
Employees in respect of each blackout period.





2.
 No trades shall be
carried out by directors, officers (or equivalent) or Designated
Blacked-out Employees during the period beginning on the first day
on which the NASDAQ Capital Market is open for trading following
the report of said material information have been disclosed by the
Company by way of press release.





3.
 Trading blackout
periods will also apply to all other employees with access to
material undisclosed information, such as during periods when
financial statements are being prepared but results have not yet
been publicly disclosed. Notice of such blackout may or may not be
communicated by issuance of a formal notice.





1.7 Regulatory Reporting Requirements





1.
 Insiders must file
in a timely manner with the Securities Exchange Commission or
relevant regulator(s) an Insider Report whenever such Insider
purchases or sells securities of the Company. Insider Reports are
required to be filed on or before the fifth day following the date
on which the purchase or sale of securities occurs.





2.
 A copy of any
Insider Report must be provided to the Company at the time of
filing. While Insiders are responsible for filing their own Insider
Reports, the Company will, upon request, assist.





Insiders in the filing of Insider Reports.





1.8 Sanctions





1.
 Failure to comply
with this Policy will result in the Company taking appropriate
disciplinary action, which may include termination of
employment.





2.
 U.S securities laws
provide that breach of the prohibition against trading in
securities with knowledge of undisclosed material information or
providing undisclosed material information to others, in addition
to civil liability for damages, may result in imprisonment and/or a
fine.





3.
 Penalties may also
be levied by U.S. securities regulatory authorities for not
complying with the requirements to file Insider
Reports.





1.9 Company Contact Person





1.
 Company Employees
who are unsure whether they may trade in a given circumstance are
advised to contact a Senior Officer for specific guidance or the
Company’s outside legal counsel.