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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:


[tr][th]Conflict of interest[/th] [th]

How conflicts will be addressed

[tr][td]Liberty earns compensation through investment management fees charged to client accounts, which reduce returns available to the client accounts[/td] [td]

[tr][td]Allocation of investment opportunities among clients[/td] [td]

[tr][td]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.[/td] [td]

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

[tr][td]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.[/td] [td]