Conflict of Interest Disclosure

OneVest Management Inc. (“OneVest”) is a registered Portfolio Manager in each province and territory of Canada and an Investment Fund Manager in the provinces of Alberta, Ontario, Newfoundland and Labrador, and Quebec. Assets in your OneVest accounts are held with CI Investment Services, a registered investment dealer in each province and territory of Canada, a member of the Investment Industry Regulatory Organization of Canada (IIROC) and Canadian Investor Protection Fund (CIPF).

Canadian securities laws require OneVest to take reasonable steps to identify and respond to material conflicts of interest in your best interest and tell you about them, including how the conflicts might impact you and how OneVest addresses them in your best interest. These conflicts may be actual or perceived conflicts of interest. We seek to avoid actual or perceived favouritism or discrimination amongst clients and to ensure that no client receives preferential treatment over another in the operation and management of their account and execution of trades. It is important that you are fully informed regarding our conflicts, including how we address them in your best interests.

At OneVest, we have established policies and procedures designed to identify, disclose, manage and, where necessary, avoid material conflicts of interest in relation to our company, our clients and third parties. This Conflict of Interest Disclosure sets out important information regarding our potential material conflicts of interest that may arise as part of doing business with us. In general, we deal with and manage conflicts as follows:

• We avoid conflicts which are prohibited by law, as well as conflicts that we cannot effectively control in your best interest.
• We avoid any material conflict of interest between you and us where the conflict cannot otherwise be addressed in your best interest.
• We disclose information about conflicts material to you, to enable you to independently assess the significance of the conflicts.
• We will strive to keep you informed in a timely fashion if we identify any other material conflicts that would adversely affect your interests in the future.

OneVest (all products)

Employee outside business activities

Our employees may engage in approved outside business activities, such as serving on a board of directors, participating in community events, or pursuing personal business interests in which they may receive compensation. This may give rise to the perception that these activities influence an employee’s professional dealings with a client.

OneVest has internal policies and procedures in place to ensure that prior to engaging in an outside business activity, employees disclose and obtain approval. Employees may only engage in such outside business activities if approved by the compliance department pursuant to our policies. Outside business activities that give rise to a material conflict of interest are not permitted.

Related/connected issuers

In the course of our relationship with you, we may make available to you, products of “related” and “connected” issuers of OneVest. This may give rise to the perception that, when providing products to you, we will favour the business interests of these related/connected issuers.

OneVest manages this conflict in your best interest as follows:

• We are required by regulation to disclose this conflict when we make a recommendation to you.
• We inform you whenever a transaction involves a related or connected security on the trade confirmation and account statement.
• We make the recommendations based on our assessment of suitability of the investment for you.
• We conduct due diligence on such securities in the same ways as we do for other unrelated issuers’ securities.

Discretionary managed accounts investing in related or connected issuers

We may, on your behalf, buy or sell securities of related issuers or connected issuers. This may give rise to the perception that, when providing products to you, we will favour the business interests of these related or connected issuers.

OneVest provides discretionary investment management services to you, not to our related/connected issuers or their representatives. OneVest is not authorized to provide services on behalf of its related/connected issuers or to act for or bind them.

OneVest will only buy or sell the securities of related or connected issuers on behalf of its clients in accordance with applicable securities laws and based on its good faith determination of the best interest of its clients.

Proprietary products

We offer proprietary products. To address this material conflict of interest, OneVest ensures that there is no added incentive to sell proprietary products over other products.

OneVest will always disclose the nature of the products and services offered, to ensure you are fully informed. We also conduct Know-Your-Product (“KYP”) to make sure that we select the product that is most suitable and, in your best interest.

Compensation and fees

As a portfolio manager, we have a duty to act in your best interest and will make decisions based on what is right for you. We earn compensation by providing you services, for which you are charged management fees. Generally, the more money you invest with us, the more compensation we earn. This may give rise to the perception that, when providing products to you, we will favour our own business interests.

For services rendered by OneVest, including management, trading, and performance reporting, OneVest charges an annual total management fee calculated as a percentage of the fair value of your assets under management (“AUM”).

We endeavour to be fully transparent on fees and commissions and fully inform you of any increases in advance. Information about our fees and commissions can be found on our website and in your account opening documentation.

Referral arrangements

We may enter an arrangement where we receive or pay a fee for referrals. The terms of any referral arrangements are disclosed and operated in accordance with regulatory standards.

A referral fee may be paid or received, directly or indirectly, by OneVest. The amount of any referral fee paid or received for referral services will not affect the fees paid or payable by you.

Vendor selection/outsourcing arrangements

We select vendors for the purposes of outsourcing certain services. We have established policies that are reasonably designed to ensure OneVest mitigates risks associated with vendors including performance and security related risks.

Sharing of information with partners and affiliates

We may make information about you available to our partners and affiliates. This may give rise to the perception that, when providing products to you, we will favour the business interests of these partners and affiliates.

We have established policies that are reasonably designed to ensure that OneVest complies with applicable privacy laws and regulations with respect to handling of client information, including our Privacy Policy. A copy of our Privacy Policy can be found on our website.

Partner relationships

Assets in your OneVest accounts are held with CI Investment Services, a registered investment dealer in each province and territory of Canada, a member of the Investment Industry Regulatory Organization of Canada (IIROC) and Canadian Investor Protection Fund (CIPF).

CI Investment Services is the custodian that OneVest uses to hold your assets and execute trades, among other brokerage services used to support your OneVest Managed Investing account. That means that you are a client of both CI Investment Services and OneVest; however, CI Investment Services does not provide any investment advice.

CI Investment Services and OneVest are separate entities. Although they are separate entities, information about you and your account may be shared between CI Investment Services and OneVest to service your account.