In addition to the disclosures listed here, Canaccord Genuity maintains the following policies and makes the following disclosures.
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ANTI-MONEY LAUNDERING (CUSTOMER IDENTIFICATION PROGRAM NOTICE) (Customers of Canaccord Genuity Corp.)Canaccord Genuity Corp. maintains policies equivalent to those described here, pursuant to the Federal Anti-Crime (Money Laundering) Anti-Terrorist Act and IIROC regulation 1300.1.
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National Instrument (NI) 24-101 RE: TRADE MATCHING AND SETTLEMENT Trade Matching Statement (Customers of Canaccord Genuity Corp). Please read our certification letter
We may collect non-public personal information about you from the following sources:
We have adopted polices and procedures that are reasonably designed to ensure the security and confidentiality of customer information which includes consumer report information. In addition, these policies and procedures are designed to prevent unauthorized access to or use of customer records or information that could result in substantial harm or inconvenience to any customer.
We use the information described above when administering your account. We may disclose non-public personal information in order to provide a service or complete a transaction that you request or authorize, or as otherwise required or permitted by the laws and industry standards that apply to us (i.e. anti-money laundering, regulatory requests).
We restrict access to non-public personal information about you to our employees who need to access the information to provide products and services to you. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information. We keep your information only as long as we need it for the products and services you are using, to offer you products and services when you are a client and for a reasonable time thereafter, or to meet any legal requirements. We have industry regulated retention standards, which we must also meet. We shred/destroy your information when it is no longer needed, or we remove your name from the information. Our privacy policies and procedures will continue to apply to your information even if your account is no longer active.
For your protection, we recommend that you do not provide your account information to anyone. If you become aware of any suspicious activity relating to your account, please contact us at firstname.lastname@example.org immediately.
It is important that your account information is accurate and complete as decisions are often made based on it. As a client, you can check the information held in our files to verify, update and correct it, and to have any obsolete information removed. We encourage you to amend inaccuracies and make corrections as often as necessary. Despite our best efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file(s), we will make the proper changes and provide you with a copy of the corrected information. Where appropriate, we will communicate these changes to other parties who may have unintentionally received incorrect information from us.
We will deal quickly with your request to see your information, and always respond to you within 30 days. If we need to extend the time, or we have to refuse your request, we will tell you why, subject to any legal restrictions, and we will notify you of the new deadline, the reasons for the extension, and your rights under applicable legislation respecting the extension.
You may receive notices of changes to our privacy policies and procedures or periodic updates of this notice, as required by law.
At Canaccord Genuity, we are proud of the trust and confidence we have earned from you. We will continue to earn that trust and confidence by keeping your non-public personal information secure and confidential.
Canaccord Genuity Corp. has a designated Privacy Officer who oversees privacy governance including policy, dispute resolution, education, and communications'. Findings are reported to our Board of Directors and Senior Management. The Privacy Officer/s can be contacted as follows:
In Canada contact our Privacy Officer, Bruce Maranda via email at email@example.com or in writing to Canaccord Financial Inc., P.O. Box 10337 Pacific Centre, 2200 - 609 Granville Street, Vancouver B.C. V7Y 1H2
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CANACCORD GENUITY CORP (CGC) CONFLICT OF INTEREST POLICYThis document summarises a policy which we have put in place to meet our obligations to maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps to identify, monitor and manage conflicts of interest. This document provides key information designed to enable you to understand the measures we are taking to safeguard your interests.
Conflicts management: systems and controls
Canaccord Genuity Corp. (“CGC”) is a Canadian IIROC dealer that may face actual and potential conflicts of interest. CGC is committed to treating its customers fairly and CGC will never knowingly put itself into a position where its own interests, or its responsibilities to another client, prevent them from undertaking their duties to their clients.
Definition of a conflict of interest
A conflict of interest is where a company such as CGC carries out activities, either for a client or for their own account, that may conflict, or appear to conflict, with the interests of another client if those activities aren’t appropriately organised or controlled.
Potential conflicts of interest to be avoided
The following is a list of examples of conflicts of interest that may occur within CGC and is not intended to be an exhaustive list.
• We may act for different clients with competing interests;• Providing investment research in relation to an entity or group to which it is also financial adviser or broker;• Dealing as principal for our own account by selling the investment to clients or buying it from clients;• Personal account dealing: Employees trading in corporations they are advising or have inside information on. • Being involved as an underwriter or in some other capacity in a takeover, a new issue or another transaction involving the investment or a related investment that you are buying or selling; or
• Use of confidential/non-public information: Using restricted information to benefit CGC or clients of CGC.• Acting in multiple roles: CGC’s activities in different areas could cause a possible conflict, for example we may act as corporate broker to a company and also trade its securities with our investor clients.
Policies and Procedures
CGC has internal policies and procedures specifically established to manage potential conflicts of interest which are subjected to ongoing monitoring and review processes. These include, but are not limited to, the following:
Information Barriers: Whereby exchange of information is controlled between our employees and/or parts of the business where the interests of one client may conflict with the interests of another client or our own interests. Our Information Barriers procedures are designed to manage confidential or price sensitive information and to prevent inappropriate transmission.
A Personal Account Dealing Policy that requires prior approval of all trades in designated instruments that could be conceivably perceived to be in conflict with CGC’s clients.
Research policies that ensure full IIROC compliance and that clients are not disadvantaged in any way.
Separate supervision & segregation of employees, where appropriate to ensure that interests of CGC and their clients and between CGC’s clients are not in conflict.
Where there is no, or insufficient, means of resolving an identified conflict, the conflict will be disclosed to the client to enable the client to make an informed decision as to whether they wish to continue the business relationship with CGC for this activity.
Declining to Act:
Where we consider we are not able to manage the conflict of interest in any other way we may decline to act for you.
Further information on these conflict management procedures is available from CGC’s compliance department.
Accessible Client Service Policy
Canaccord Genuity Corp. (“Canaccord”) is committed to excellence in serving all clients, including clients with disabilities, while bearing in mind the principles of independence, dignity, integration and equal opportunity.Assistive DevicesCanaccord will ensure that our employees and agents are trained and familiar with various assistive devices that may be used by clients with disabilities while accessing our services and facilities.Service AnimalsWe welcome clients with disabilities and their service animals. Service animals are allowed on the parts of our premises that are open to the public. Support PersonsA client with a disability who is accompanied by a support person will be allowed to have that person accompany them on our premises.Service DisruptionsCanaccord will provide clients with notice in the event of a planned or unexpected disruption in all the facilities or services used by clients. Notices will include information about the reason for the disruption, the anticipated duration of the disruption, and a description of alternative facilities or services, if available.Notices will be placed at all public entrances, service counters located on the premises, and if appropriate, Canaccord websites and outgoing telephone messages.TrainingCanaccord will provide training to all employees on our accessible client service policy. This training will include:
Employees will be trained as soon as practical following their date of hire, no more than 90 days after their start date, as well as when changes occur to applicable policies, procedures and practices. All documents required by the Accessibility Standards for Customer Service will be available upon request, subject to privacy protection laws. When providing such documents to a person with a disability, Canaccord personnel will provide the document, or the information contained in the document, in a format that takes into consideration the person's disability.Feedback processCanaccord is committed to providing high quality service to all of our clients. Feedback from clients about the delivery of services to persons with disabilities may be given in confidence by telephone, in person, in writing, in electronic format or through other methods.Email To: Canaccord HRMail or deliver to: Canaccord Genuity Corp.Human Resources2200 – 609 Granville StreetVancouver, BCV7Y 1H2Telephone:1-800-663-1899 (please ask for someone in Human Resources)
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