Disclosures

Here is a copy of our Conflict of Interest Policy

Directors, and employees of the company must never permit their personal interests to conflict with the interests of the company or its clients. This includes, but is not limited to:

Directly or indirectly benefiting financially from recommendations which incur a cost to the client and is not part of our mandate with the client;

Receiving any non-cash incentives from affecting any predetermined transaction and / or product.

Effecting a transaction and / or product that may result in a benefit to another party other than the directors and employees must be particularly careful to avoid representing the company in any transaction with others with whom there is any outside business affiliation or relationship. Directors and employees shall avoid using their company contacts to advance their private business or personal interests at the expense of the company, its clients or affiliates.

Officers, directors and employees will refrain from gathering competitor intelligence by illegitimate means and refrain from acting on knowledge which has been gathered in such a manner. The officers, directors and employees of the company will seek to avoid exaggerating or disparaging comparisons of the services and competence of their competitors.

Violation of this Code can result in disciplinary action being taken against the person, including possible termination of services. The degree of discipline relates in part to whether there was a voluntary disclosure of any ethical violation and whether or not the violator cooperated in any subsequent investigation.