Common use of Acting as Principal Clause in Contracts

Acting as Principal. In certain instances where we act as your broker or exercise discretion on your behalf, securities purchased for you may be bought from or sold to us, a party associated with us or, in the course of distribution, a Connected Party. Fairness Policy FMGL maintains standards directed to ensuring fairness for clients. The fairness policies of FMGL are set out below. Each director, officer and employee of FMGL will: • Ensure that orders for clients always have priority over orders for the Friedberg Professional Group, • Ensure that he/she deals fairly with all accounts when making investment recommendations, or taking investment action and must not favour some accounts over others, • Use his/her best efforts to mitigate any conflict of interest between himself/herself, FMGL and clients, and inform clients of any material conflict of interest relating to him/her that might impair his/her ability to render unbiased and objective advice with respect to investment opportunities, • In advising clients, exercise diligence, independence (including in the case of securities of Connected Issuers and Related Issuers, where additional conflict controls are in place), and thoroughness in analyzing investments, making investment recommendations and taking investment action, and • Strive towards a high standard of ethical business and personal conduct and professionalism. Privacy Agreement and Consent The Personal Information Protection and Electronic Documents Act (“PIPEDA”) sets out the rules for the collection, management, use and disclosure of personal information. It is supposed to balance an individual’s right to the privacy of personal information with the need of organizations to collect, use, or disclose personal information for legitimate business purposes. Client Privacy Is Xxxxxxxxx’x Priority Friedberg Mercantile Group Ltd. (“FMGL”) is committed to safeguarding the personal information that our customers provide us. This private policy describes how FMGL handles and protects personal information we collect about individuals who apply for or receive FMGL services. The provisions of this policy apply to former customers as well as current customers. What Does Friedberg Mercantile Group Ltd. Do With Your Personal Information When you submit the New Customer Application Forms and/or a Subscription Application for any of FMGL’s investment funds, we collect personal information about you for business purposes, such as processing your application, processing your requests and transactions, and thereafter maintain an account with FMGL informing you about new products and services that may be of interest to you, and providing customer service. The need to collect the information is required by the self-regulatory organizations that oversee our industry. The personal information we collect about you includes: • Information you provide to us on subscription documents, applications and other forms, such as your name, address, bank account, date of birth, social insurance number/social security number, occupation, assets and income. • Account statements and other information about your transactions with us. • Information we receive from consumer reporting agencies, such as your credit history and creditworthiness. • Information you provide to us to verify your identity, such as your drivers license or passport. • Information received from Canadian/US or foreign governments or other entities not affiliated with us. • Recorded conversations with brokers. How We Protect Personal Information We limit access to your personal information to those FMGL employees who need to know it in order to comply with regulatory requirements, service your account, and help you accomplish your financial objectives, by providing you with a broad range of products and services. Our employees are required to maintain and protect the confidentiality of your personal information and must follow established procedures to do so, including yearly risk and vulnerability assessments. We maintain physical, electronic and procedural safeguards to protect your personal information. We do not rent or sell your name or personal information to anyone. We protect our servers via strong firewalls, brokers and all personnel use 2 step verification access to their computers to safeguard your privacy. We constantly update our antivirus and spam filters for cyber security threats. Any breach of security safeguards that can cause significant harm to your private information will be reported to you and the Privacy Commissioner of Canada. We will keep records of breaches of security that affect your personal information for at least 2 years. Information that is not needed for the purpose of doing business with FMG Ltd. is destroyed/deleted. Sharing Information With Affiliates We may share personal information described above with our affiliates for business purposes, such as, but not limited to, servicing client accounts and informing clients about new products and services, or to aid in the trading activity of the company, its affiliates, or employees, and as permitted by applicable law. Our affiliates may include companies controlled or owned by us as well as companies that have an ownership interest in our company. The information we share with affiliates may include any of the information described above, such as your name, address, trading and account information. Our affiliates maintain the privacy of your information to the same extent FMGL does in accordance with this policy. Disclosure To Non-Affiliated Third Parties In order to support the financial products and services we provide to you, we may share the personal information described above with third-party service providers, including financial service institutions (e.g., dealers, brokers and banks), auditors, lawyers and the companies under contract to perform services for us or on our behalf, such as vendors that prepare and mail statements and transaction confirmations or provide data processing, computer software maintenance and development, transaction processing and services. These companies acting on our behalf are required to keep your personal information confidential. Except as described in this privacy policy, we will not use your personal information for any purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so. We want you to know that FMGL will not sell your personal information.

Acting as Principal. In certain instances where we act as your broker or exercise discretion on your behalf, securities purchased for you may be bought from or sold to us, a party associated with us or, in the course of distribution, a Connected Party. Fairness Policy FMGL maintains standards directed to ensuring fairness for clients. The fairness policies of FMGL are set out below. Each director, officer and employee of FMGL will: • Ensure that orders for clients always have priority over orders for the Friedberg Professional Group, • Ensure that he/she deals fairly with all accounts when making investment recommendations, or taking investment action and must not favour some accounts over others, • Use his/her best efforts to mitigate any conflict of interest between himself/herself, FMGL and clients, and inform clients of any material conflict of interest relating to him/her that might impair his/her ability to render unbiased and objective advice with respect to investment opportunities, • In advising clients, exercise diligence, independence (including in the case of securities of Connected Issuers and Related Issuers, where additional conflict controls are in place), and thoroughness in analyzing investments, making investment recommendations and taking investment action, and • Strive towards a high standard of ethical business and personal conduct and professionalism. Privacy Agreement and Consent The Personal Information Protection and Electronic Documents Act (“PIPEDA”) sets out the rules for the collection, management, use and disclosure of personal information. It is supposed to balance an individual’s right to the privacy of personal information with the need of organizations to collect, use, or disclose personal information for legitimate business purposes. Financial companies choose how they share your personal information. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. Client Privacy Is Xxxxxxxxx’x Priority Friedberg Mercantile Group Ltd. (“FMGL”) is committed to safeguarding the personal information that our customers provide us. This private policy describes how FMGL handles and protects personal information we collect about individuals who apply for or receive FMGL services. The provisions of this policy apply to former customers as well as current customers. What Does Friedberg Mercantile Group Ltd. Do With Your Personal Information When you submit the New Customer Application Forms and/or a Subscription Application for any of FMGL’s investment funds, we collect personal information about you for business purposes, such as processing your application, processing your requests and transactions, and thereafter maintain an account with FMGL informing you about new products and services that may be of interest to you, and providing customer service. The need to collect the information is required by the self-regulatory organizations that oversee our industry. The personal information we collect about you includes: • Information you provide to us on subscription documents, applications and other forms, such as your name, address, bank account, date of birth, social insurance number/social security number, occupation, assets and income. • Account statements and other information about your transactions with us. • Information we receive from consumer reporting agencies, such as your credit history and creditworthiness. • Information you provide to us to verify your identity, such as your drivers license or passport. • Information received from Canadian/US or foreign governments or other entities not affiliated with us. • Recorded conversations with brokers. How We Protect Personal Information We limit access to your personal information to those FMGL employees who need to know it in order to comply with regulatory requirements, service your account, and help you accomplish your financial objectives, by providing you with a broad range of products and services. Our employees are required to maintain and protect the confidentiality of your personal information and must follow established procedures to do so, including yearly risk and vulnerability assessments. We maintain physical, electronic and procedural safeguards to protect your personal information. We do not rent or sell your name or personal information to anyone. We protect our servers via strong firewalls, brokers and all personnel use 2 step verification access to their computers to safeguard your privacy. We constantly update our antivirus and spam filters for cyber security threats. Any breach of security safeguards that can cause significant harm to your private information will be reported to you and the Privacy Commissioner of Canada. We will keep records of breaches of security that affect your personal information for at least 2 years. Information that is not needed for the purpose of doing business with FMG Ltd. is destroyed/deleted. Sharing Information With Affiliates We may share personal information described above with our affiliates for business purposes, such as, but not limited to, servicing client accounts and informing clients about new products and services, or to aid in the trading activity of the company, its affiliates, or employees, and as permitted by applicable law. Our affiliates may include companies controlled or owned by us as well as companies that have an ownership interest in our company. The information we share with affiliates may include any of the information described above, such as your name, address, trading and account information. Our affiliates maintain the privacy of your information to the same extent FMGL does in accordance with this policy. Disclosure To Non-Affiliated Third Parties In order to support the financial products and services we provide to you, we may share the personal information described above with third-party service providers, including financial service institutions (e.g., dealers, brokers and banks), auditors, lawyers and the companies under contract to perform services for us or on our behalf, such as vendors that prepare and mail statements and transaction confirmations or provide data processing, computer software maintenance and development, transaction processing and services. These companies acting on our behalf are required to keep your personal information confidential. Except as described in this privacy policy, we will not use your personal information for any purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so. We want you to know that FMGL will not sell your personal information.

Acting as Principal. In certain instances where we act as your broker or exercise discretion on your behalf, securities purchased for you may be bought from or sold to us, a party associated with us or, in the course of distribution, a Connected Party. Fairness Policy FMGL maintains standards directed to ensuring fairness for clients. The fairness policies of FMGL are set out below. Each director, officer and employee of FMGL will: • Ensure that orders for clients always have priority over orders for the Friedberg Professional Group, • Ensure that he/she deals fairly with all accounts when making investment recommendations, or taking investment action and must not favour some accounts over others, • Use his/her best efforts to mitigate any conflict of interest between himself/herself, FMGL and clients, and inform clients of any material conflict of interest relating to him/her that might impair his/her ability to render unbiased and objective advice with respect to investment opportunities, • In advising clients, exercise diligence, independence (including in the case of securities of Connected Issuers and Related Issuers, where additional conflict controls are in place), and thoroughness in analyzing investments, making investment recommendations and taking investment action, and • Strive towards a high standard of ethical business and personal conduct and professionalism. Privacy Agreement and Consent The Personal Information Protection and Electronic Documents Act (“PIPEDA”) sets out the rules for the collection, management, use and disclosure of personal information. It is supposed to balance an individual’s right to the privacy of personal information with the need of organizations to collect, use, or disclose personal information for legitimate business purposes. Financial companies choose how they share your personal information. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. Client Privacy Is Xxxxxxxxx’x Priority Friedberg Mercantile Group Ltd. (“FMGL”) is committed to safeguarding the personal information that our customers provide us. This private policy describes how FMGL handles and protects personal information we collect about individuals who apply for or receive FMGL services. The provisions of this policy apply to former customers as well as current customers. What Does Friedberg Mercantile Group Ltd. Do With Your Personal Information When you submit the New Customer Application Forms and/or a Subscription Application for any of FMGL’s investment funds, we collect personal information about you for business purposes, such as processing your application, processing your requests and transactions, and thereafter maintain an account with FMGL informing you about new products and services that may be of interest to you, and providing customer service. The need to collect the information is required by the self-regulatory organizations that oversee our industry. The personal information we collect about you includes: • Information you provide to us on subscription documents, applications and other forms, such as your name, address, bank account, date of birth, social insurance number/number/ social security number, occupation, assets and income. • Account statements and other information about your transactions with us. • Information we receive from consumer reporting agencies, such as your credit history and creditworthiness. • Information you provide to us to verify your identity, such as your drivers license or passport. • Information received from Canadian/US or foreign governments or other entities not affiliated with us. • Recorded conversations with brokers. How We Protect Personal Information We limit access to your personal information to those FMGL employees who need to know it in order to comply with regulatory requirements, service your account, and help you accomplish your financial objectives, by providing you with a broad range of products and services. Our employees are required to maintain and protect the confidentiality of your personal information and must follow established procedures to do so, including yearly risk and vulnerability assessments, and privacy impact assessments (related to acquisition, development and redesign of information systems or electronic delivery project involving personal information). We maintain physical, electronic and procedural safeguards to protect your personal information. We do not rent or sell your name or personal information to anyone. We protect our servers via strong firewalls, brokers and all personnel use 2 step verification access to their computers to safeguard your privacy. We constantly update our antivirus and spam filters for cyber security threats. Any breach of security safeguards that can cause significant harm to your private information will be reported to you and the Privacy Commissioner of Canada, and if you are a Quebec resident, based on Quebec’s Bill 64, we will notify the Commission d’acces a L’information (CAI) and affected individual when a prescribed breach occurs. We will keep records of breaches of security that affect your personal information for at least 2 years. Information that is not needed for the purpose of doing business with FMG Ltd. is destroyed/deleted. Sharing Information With Affiliates We may share personal information described above with our affiliates for business purposes, such as, but not limited to, servicing client accounts and informing clients about new products and services, or to aid in the trading activity of the company, its affiliates, or employees, and as permitted by applicable law. Our affiliates may include companies controlled or owned by us as well as companies that have an ownership interest in our company, most of these companies are outside of Quebec. The information we share with affiliates may include any of the information described above, such as your name, address, trading and account information. Our affiliates maintain the privacy of your information to the same extent FMGL does in accordance with this policy. Disclosure To Non-Affiliated Third Parties In order to support the financial products and services we provide to you, we may share the personal information described above with third-party service providers, including financial service institutions (e.g., dealers, brokers and banks), auditors, lawyers and the companies under contract to perform services for us or on our behalf, such as vendors that prepare and mail statements and transaction confirmations or provide data processing, computer software maintenance and development, transaction processing and services. These companies acting on our behalf are required to keep your personal information confidential. Except as described in this privacy policy, we will not use your personal information for any purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so. We want you to know that FMGL will not sell your personal information.

Acting as Principal. In certain instances where we act as your broker or exercise discretion on your behalf, securities purchased for you may be bought from or sold to us, a party associated with us or, in the course of distribution, a Connected Party. Fairness Policy FMGL maintains standards directed to ensuring fairness for clients. The fairness policies of FMGL are set out below. Each director, officer and employee of FMGL will: • Ensure that orders for clients always have priority over orders for the Friedberg Professional Group, • Ensure that he/she deals fairly with all accounts when making investment recommendations, or taking investment action and must not favour some accounts over others, • Use his/her best efforts to mitigate any conflict of interest between himself/herself, FMGL and clients, and inform clients of any material conflict of interest relating to him/her that might impair his/her ability to render unbiased and objective advice with respect to investment opportunities, • In advising clients, exercise diligence, independence (including in the case of securities of Connected Issuers and Related Issuers, where additional conflict controls are in place), and thoroughness in analyzing investments, making investment recommendations and taking investment action, and • Strive towards a high standard of ethical business and personal conduct and professionalism. Privacy Agreement and Consent The Personal Information Protection and Electronic Documents Act (“PIPEDA”) sets out the rules for the collection, management, use and disclosure of personal information. It is supposed to balance an individual’s right to the privacy of personal information with the need of organizations to collect, use, or disclose personal information for legitimate business purposes. Client Privacy Is Xxxxxxxxx’x Priority Friedberg Mercantile Group Ltd. (“FMGL”) is committed to safeguarding the personal information that our customers provide us. This private policy describes how FMGL handles and protects personal information we collect about individuals who apply for or receive FMGL services. The provisions of this policy apply to former customers as well as current customers. What Does Friedberg Mercantile Group Ltd. Do With Your Personal Information When you submit the New Customer Application Forms and/or a Subscription Application for any of FMGL’s investment funds, we collect personal information about you for business purposes, such as processing your application, processing your requests and transactions, and thereafter maintain an account with FMGL informing you about new products and services that may be of interest to you, and providing customer service. The need to collect the information is required by the self-regulatory organizations that oversee our industry. The personal information we collect about you includes: • Information you provide to us on subscription documents, applications and other forms, such as your name, address, bank account, date of birth, social insurance number/social security number, occupation, assets and income. • Account statements and other information about your transactions with us. • Information we receive from consumer reporting agencies, such as your credit history and creditworthiness. • Information you provide to us to verify your identity, such as your drivers license or passport. • Information received from Canadian/US or foreign governments or other entities not affiliated with us. • Recorded conversations with brokers. How We Protect Personal Information We limit access to your personal information to those FMGL employees who need to know it in order to comply with regulatory requirements, service your account, and help you accomplish your financial objectives, by providing you with a broad range of products and services. Our employees are required to maintain and protect the confidentiality of your personal information and must follow established procedures to do so, including yearly risk and vulnerability assessments. We maintain physical, electronic and procedural safeguards to protect your personal information. We do not rent or sell your name or personal information to anyone. We protect our servers via strong firewalls, brokers and all personnel use 2 step verification access to their computers to safeguard your privacy. We constantly update our antivirus and spam filters for cyber security threats. Any breach of security safeguards that can cause significant harm to your private information will be reported to you and the Privacy Commissioner of Canada. We will keep records of breaches of security that affect your personal information for at least 2 years. Information that is not needed for the purpose of doing business with FMG Ltd. is destroyed/deleted. Sharing Information With Affiliates We may share personal information described above with our affiliates for business purposes, such as, but not limited to, servicing client accounts and informing clients about new products and services, or to aid in the trading activity of the company, its affiliates, or employees, and as permitted by applicable law. Our affiliates may include companies controlled or owned by us as well as companies that have an ownership interest in our company. The information we share with affiliates may include any of the information described above, such as your name, address, trading and account information. Our affiliates maintain the privacy of your information to the same extent FMGL does in accordance with this policy. Disclosure To Non-Affiliated Third Parties In order to support the financial products and services we provide to you, we may share the personal information described above with third-party service providers, including financial service institutions (e.g., dealers, brokers and banks), auditors, lawyers and the companies under contract to perform services for us or on our behalf, such as vendors that prepare and mail statements and transaction confirmations or provide data processing, computer software maintenance and development, transaction processing and services. These companies acting on our behalf are required to keep your personal information confidential. Except as described in this privacy policy, we will not use your personal information for any purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so. We want you to know that FMGL will not sell your personal information.