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Conflict of Interest Disclosure – June 2021

Securities legislation in Canada requires that Liberty International Investment Management (“Liberty”) take reasonable steps to identify and deal with actual, potential, or perceived conflicts of interest. It also requires that we advise you of any important conflicts of interest and how we address these conflicts in your best interest.

What is a conflict of interest under Canadian securities laws?

A conflict of interest arises when the interests of different parties are inconsistent or divergent.

The types of conflict that can arise include:

As part of Liberty’s policies and procedures, we use three methods to deal with conflicts of interest:

Our goal is to deal with a conflict of interest in a fair, equitable and transparent manner, while exercising responsible business judgment influenced only by your best interests.

In the table below, we have outlined material conflicts of interest and how we manage them:

Conflict of interest

How conflicts will be addressed

Liberty earns compensation through investment management fees charged to client accounts, which reduce returns available to the client accounts

  • All such fees are fully disclosed to our clients

Allocation of investment opportunities among clients

  • Liberty has adopted trading policies to ensure the fair allocation of investment opportunities amongst clients.
  • Details regarding the allocation of investments opportunities is provided in Schedule B of the Investment Management Agreement

Directors, officers, or other employees of Liberty may serve on a board of directors or take on other activities that could take time or attention away from your account.

  • Securities legislation prohibits a registered individual from serving as a director of another registered firm.
  • The pre-approval of Liberty’s Chief Compliance Officer must be obtained prior to Liberty personnel joining a board of directors or taking on other activities.
  • Liberty has implemented internal policies and procedures to monitor closely those other activities.

Directors, officers, or other employees of Liberty may receive or give gifts or entertainment opportunities from third parties and clients.

  • Employees are required to obtain pre-approval from the Chief Compliance Officer before accepting any gifts or entertainment
    opportunities with a value over $200.
  • Employees may not give or accept cash gifts or cash equivalents gifts to or from a client, prospective client or any third party that
    does or seeks business with Liberty.

Directors, officers, or other employees of Liberty may trade in the same securities as a client in their personal investment accounts held
outside of the firm.

  • Liberty has adopted a Code of Ethics which includes a personal trading policy. The Code of Ethics is directed at preventing Liberty personnel (and their family members and close associates) from using any information they may have about trading in a client account for personal benefit to the detriment of the client.
  • Liberty has implemented internal policies and procedures to monitor closely all activities in personal accounts held outside of the firm.