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Conflict of Interest Policy: 


There is a possibility that a conflict of interest may arise in connection with the business that CWMI conducts for you. Securities laws of Canada require investment dealers and other advisers to take reasonable steps to identify disclose and address existing and potential material conflicts that might reasonably arise between you and your Advisor. If a conflict arises, CWMI will take reasonable steps to advise you of the conflict in writing in a timely manner and will ensure that the conflict is addressed in a way that is in your best interest.


CWMI has adopted policies and procedures to assist in identifying, addressing, and minimizing any conflict of interest that CWMI, or its employees or CWMI Advisors may face when working on your behalf. Our employees and CWMI Advisors are required to address any conflict of interest by exercising responsible business judgment, influenced only by the best interests of the client; employees and CWMI Advisors are encouraged to bring any conflict of interest to the attention of clients as soon as they become aware of them.


Every CWMI employee and CWMI Advisor is subject to a code of conduct, which includes, among other things, policies to address many common types of conflict-of-interest situations. For example, we have adopted policies to prohibit Advisors from borrowing from or lending money to clients or investing with clients. We have also adopted policies that prohibit an CWMI Advisor from acting as a power of attorney, except in the case of immediate family members. Advisors are also required to obtain preapproval related to any outside business activity to ensure that such activities do not create potential conflict of interest or interfere with their ability to service clients.


In general, we deal with and manage relevant conflicts as follows:

Avoidance: This includes avoiding conflicts that are prohibited by law as well as conflicts that cannot effectively be addressed.

Control: We manage acceptable conflicts through means such as physically separating different business functions and limiting the internal exchange of information.

Disclosure: By providing you with information about conflicts, you can assess independently their significance when evaluating our recommendations and any actions we take.


Under certain circumstances, CWMI may deal with you or for you in securities transactions where the issuer of those securities or the other party to the transaction is CWMI or a party having an ownership or business relationship with CWMI.


Since these transactions may create a conflict between CWMI and you, we are required by securities law to disclose to your certain relevant matters relating to the transactions which are contained in the following sections entitled “Related Registrant” and “Related and Connected Issuers”.


Important Concepts

Related Issuer:

A related issuer is a person or company that is related in any way to CWMI such as:

  • the person or company issuing securities is an influential security holder of CWMI;

  • when CWMI is an influential security holder of the person or company issuing securities; or

  • when CWMI and the person or company issuing securities, are a related issuer of the same third person or company.

Connected Issuer:

A connected issuer means an issuer or selling security holder distributing securities where the issuer or selling security holder, or a related issuer of the issuer or selling security holder, has a relationship with any of the following persons or companies that may lead a reasonable prospective purchaser of the securities to question if IPCSC and the issuer are independent of each other for the purpose of distribution:

  • CWMI.

  • a related issuer of CWMI.

  • a director, officer, or partner of CWMI; or

  • a director, officer, or partner of a related issuer of CWMI.

Further in this document is a list of Related Issuers and Connected Issuers of CWMI, together with a summary statement of the relationship between them and CWMI.

Required Disclosure

When CWMI acts as your dealer or advises you with respect to securities issued by CWMI, or by a related issuer, or during distribution by a Connected Issuer, CWMI must disclose the nature and extent of its relationship with the issuer of the securities, or that CWMI is the issuer. CWMI will also disclose to you where CWMI knows or should know, that if because of CWMI acting as your dealer or advisor, or of CWMI exercising discretion on your behalf, securities will be purchased from or sold to CWMI, a related issuer, in the course of an initial distribution, from a connected issuer.

The following is a list of the timeline and way these disclosures must be made:

  • Where CWMI buys securities for your account or advises you with respect to the purchase of securities, the disclosure must be made prior to the purchase or the giving of the advice, either through the receipt of this disclosure or otherwise.

CWMI may, from time to time, be deemed to be related or connected to one or more issuers for purposes of disclosure and other rules of the securities laws. CWMI may have acted and is prepared to continue to act where permitted by law, as an advisor or dealer with respect to securities of such related and connected issuers and to provide the full range of services customarily provided by CWMI in respect of securities of other issuers. CWMI shall carry out such services in the ordinary course of its business in accordance with our usual practices and procedures and in accordance with all applicable disclosure and other regulatory requirements.


The following information is intended to assist you in understanding and assessing material, potential and actual conflicts of interest, including how we address them. This is an overview of a complex subject. Despite that, we believe the simplest control is the most effective – your continued satisfaction and patronage. If you ever have any questions or concerns, whether they involve conflicts of interest or anything else, you should never hesitate to say so and ask your advisor for an explanation and more information.


Possible Conflicts and How They Are Managed

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