MEMO

To: All Walton Employees - Singapore,

From: Bill Doherty

Date: March 9, 2009

Re: Walton Malaysia – Bank Negara Investigation Response

Recently some Malaysian media have unfortunately carried reports regarding an

investigation which has involved our Company in Malaysia. I wish to respond to those

reports directly.

Always remember, Walton International is a successful international corporation, with 13

offices in seven countries around the world. We have been in business in North America for

30 years, and are proud to have been in Malaysia since 2002 as a respected member of

Malaysia's growing and important international business community.

Walton operates to the highest ethical and business standards in Malaysia and around the

world. We are committed to positive relationships with our clients and with the citizens and

governments of all countries in which we do business. We strive to comply with all

applicable laws in every country in which we operate. We have never consciously or

deliberately contravened any laws of the countries we operate in. We have full confidence in

the soundness, professionalism and integrity of our business operations.

We have and will continue to fully assist the government in its desire to ensure all business

is conducted in Malaysia to the highest standard. We are fully open and transparent in our

professional relationships with regulatory authorities, and responsive to requests for

information and cooperation.

Contrary to references in some media reports, we do not offer “deposit-taking schemes” nor

“Real Estate Investment Trusts.” The reason for our continued success is that we offer real

ownership of land in highly researched target areas within Canada and the United States.

Almost 50,000 Walton clients worldwide have purchased over 49,000 acres of land, a total

of nearly $2 billion worth of land.

(land), with properly held title and ownership.Our clients' holdings are safe and secure in real estate

The interests of our clients are always foremost in our minds. Our track record speaks for

itself. We are careful in the land we select and offer to clients, and have delivered consistent

returns to our clients in Malaysia and around the globe. In the last 3 years we have returned

over $500 million to Walton clients globally including Malaysian clients.

audited by independent, third-party accounting firms. To date, we are proud to say we

have delivered our clients a 15.88% median compound annual rate of return. This

success cannot be argued.Our returns are

Our business in Malaysia is very important to us, and our long-term commitment to our

Malaysian clients and clients around the world remains firm.

We can be proud of the lands that we offer, the world class service we provide as well as

the returns we have and will continue to generate for our clients. We all need to be active in

communicating this message with our clients and with each other.

Sincerely,

Bill Doherty