Regulatory Disclosures

Transcription

1 Regulatory Disclosures STATEMENT OF PRINCIPLES ON CONFLICTS OF INTEREST WHAT YOU SHOULD KNOW ABOUT COMPLAINT HANDLING AT DESJARDINS GLOBAL ASSET MANAGEMENT FAIRNESS POLICY DECLARATION OF RISK

2 INTRODUCTION This document is intended to provide clients with all the informa on they would consider important about their rela onship with Desjardins Global Asset Management Inc. ("the Company"), as required by sec on 14.2 of Regula on respec ng Registra on Requirements, Exemp ons and Ongoing Registrant Obliga ons. The Company is a wholly owned subsidiary of Desjardins Financial Corpora on Inc., itself an indirect wholly owned subsidiary of the Fédéra on des caisses Desjardins du Québec (the "Federa on"). Its head office is located in Montreal, in the province of Quebec, where it is registered in accordance with Canadian securi es legisla on as a por olio manager, an investment fund manager, an exempt market dealer and a deriva ves por olio manager. The Company is also registered, with non-resident status, as a por olio manager and/or an investment fund manager in the following provinces: Alberta, Bri sh Columbia, Manitoba, Nova Sco a and Saskatchewan. In Ontario, the Company is registered as a por olio manager, an investment fund manager, an exempt market dealer and a commodity trading manager. The Company is regulated by the Autorité des marchés financiers du Québec (the "AMF"), within the meaning of "regulator" set out in Regula on The Company offers its clients investment advisory services under discre onary por olio management agreements in the following sectors: Management of managers: selec on and monitoring of external managers for specific mandates Financial strategy and asset alloca on: management of equity investments according to effec ve systema c protocols Securi es investments: management of fixed-income security por olios Asset management through the Company Funds (the "Funds"): a family of six private funds sold under a prospectus exemp on exclusively to qualified investors The Company also offers the following services: Real estate investments: acquisi on, development and sale of real estate assets Mortgage investments and ins tu onal financing: management of mortgage asset por olios The Company wishes to assure its clients that it scrupulously preserves confiden ality and protects personal informa on. Moreover, it takes all necessary measures to ensure and preserve the accuracy, confiden ality, security and privacy of its clients personal informa on. This document will be updated as necessary and will be available on the Company website at You can always request a copy from the company representa ve you deal with, and we will mail you a copy free of charge. 2 Regulatory Disclosures - Desjardins Global Asset Management

3 DESJARDINS GLOBAL ASSET MANAGEMENT INC. STATEMENT OF PRINCIPLES ON CONFLICTS OF INTEREST 1. OBJECTIVE OF THIS DOCUMENT Desjardins Global Asset Management Inc. ("the Company") complies scrupulously with the regula ons that apply to its ac vi es. The primary objec ves of these regula ons are to protect clients and the integrity of financial markets. It is important to the Company that its clients be informed about exis ng or poten al conflicts of interest that could arise in the course of its ac vi es. A conflict of interest arises when the interests of different persons, namely those of a client and those of the Company or one of its representa ves (directors, officers, partners, employees or agents) are Incompa ble or divergent. The ac vi es of the Company and its representa ves are governed by a Code of Ethics and a Compliance Handbook which its representa ves must read every year and cer fy that they have done so. The Company is registered as a por olio manager, an investment fund manager, an exempt market dealer and a deriva ves por olio manager with the Autorité des marchés financiers ("AMF"). The Company is also registered, with non-resident status, as a por olio manager and/or an investment fund manager in the following provinces: Alberta, Bri sh Columbia, Manitoba, Nova Sco a and Saskatchewan. In Ontario, the Company is registered as a por olio manager, an investment fund manager, an exempt market dealer and a commodity trading manager. As part of the management of its clients discre onary accounts, the Company may retain the services of other dealers or advisors to which it is related or connected. In addi on, the Company may buy or sell or make recommenda ons in respect of: a) Securi es which it or a person of its group owns b) Securi es for which the Company or a person of its group par cipates in the placement c) Securi es of a related or connected issuer d) Securi es of an issuer that has a director, officer, partner, employee or agent of the Company or Desjardins Group as its director, officer, partner, employee or agent The Company will do so in accordance with the regula ons applicable to such transac ons and always in the best interest of its clients. In the case indicated in point (d) above, the Company will not carry out a transac on involving such issuer, unless the client concerned has been informed in advance and has expressly authorized the transac on in wri ng. In this document, the Company informs you of the nature and scope of the conflicts of interest that may affect the services it offers you. 2. DEFINITIONS For the purposes hereof, the following terms have the following meanings: "Related issuer" means, in rela on to the Company, an issuer that has a decisive influence on the Company or that is subject to the decisive influence of the Company or that has a decisive influence on an issuer connected to the Company. "Influence" in this context means the power to have a decisive influence on the management and policies of the Company, alone or together with other persons or companies, through the ownership of vo ng stock or any other means. "Connected issuer" means, in rela on to the Company, an issuer, or any issuer connected thereto, that is in a situa on of indebtedness to (i) the Company, (ii) an issuer connected to the Company, (iii) a director or an officer of the Company, or (iv) a director or officer of an issuer connected to the Company. Regulatory Disclosures - Desjardins Global Asset Management 3

4 This also means, in rela on to the Company, an issuer, or any issuer connected thereto, that is found to be in another rela onship with the abovemen oned persons such other rela onship cons tu ng important informa on for the poten al underwriter of such securi es in a placement of securi es of such an issuer. Thus, an issuer is a connected issuer of the Company if, given a situa on of indebtedness or other type of rela onship, a poten al underwriter of securi es of the connected issuer could challenge the independence of the Company vis-à-vis such issuer. 3. ISSUERS RELATED OR CONNECTED TO DESJARDINS GLOBAL ASSET MANAGEMENT The Company is a wholly owned subsidiary of Desjardins Financial Corporation Inc., itself an indirect wholly owned subsidiary of the Fédération des caisses Desjardins du Québec (the "Federation"). The entities listed below may be considered issuers related or connected to the Company. In addition, the Company may offer its discretionary management services to these related or connected issuers, or use their services. Caisse centrale Desjardins A financial services coopera ve owned by Desjardins caisses through the Federa on. Caisse centrale Desjardins is the treasurer for Desjardins Group and acts as its financial agent in the Canadian and interna onal markets. It offers financing, banking and interna onal services to ins tu ons and to large and medium-sized businesses. Capital Desjardins Inc. A wholly owned subsidiary of the Federa on, this company is responsible for issuing its own securi es on capital markets and inves ng the proceeds in securi es issued by Desjardins caisses. Capital régional et coopéra f Desjardins Inc. ("CRCD") A public company whose por olio manager is Desjardins Venture Capital Inc., itself a wholly owned subsidiary of the Federa on. CRCD raises development capital by means of public offerings and injects the funds into coopera ves and businesses. Fiera Capital Corpora on A public company in which Desjardins Financial Corpora on Inc., itself an indirect wholly owned subsidiary of the Federa on, holds an interest. Fiera Capital Corpora on is registered as a por olio manager and investment fund manager. Fiera Capital Corpora on acts as a por olio sub-manager for certain Desjardins Funds. Fiera Capital Mutual Funds: A family of mutual funds for which Fiera Capital Corpora on is investment fund manager and por olio manager. Fiera Capital Mutual Funds are repor ng issuers. Desjardins Funds A family of mutual funds for which Desjardins Investment Corpora on is the investment fund manager and promoter. Desjardins Funds are repor ng issuers. Desjardins Trust Inc. is the trustee and custodian of Desjardins Funds. The Company is the por olio manager of Desjardins Funds. Desjardins Investments Inc. ( DI ): A wholly owned subsidiary of Desjardins Financial Corpora on Inc., itself an indirect wholly owned subsidiary of the Federa on. DI is registered as an investment fund manager. 4 Regulatory Disclosures - Desjardins Global Asset Management

5 Desjardins Trust Inc. A wholly owned subsidiary of the Federa on, this company is a deposit ins tu on. DGIA Funds A family of investment funds dedicated to ins tu onal clients, for which the Company is the investment fund manager and por olio manager. The Company Funds are not repor ng issuers. Desjardins Trust is the trustee and custodian of the Company Funds. DGIA Emerging Market Equity Fund DIM Private Funds ("DIM Funds") Mutual fund for which the Company is the por olio manager and promoter. This Fund is not a repor ng issuer. A family of mutual funds for which Desjardins Investment Management is the investment fund manager and promoter. DIM Funds are not repor ng issuers. Desjardins Investment Management ("DIM"): A wholly owned subsidiary of Desjardins Financial Corpora on Inc., itself an indirect wholly owned subsidiary of the Federa on. DIM is registered as a por olio manager and investment fund manager. TMX Group Inc. A public company in which Desjardins Financial Corpora on Inc., a wholly owned subsidiary of the Federa on, has an interest. TMX Group Inc. operates cash and deriva ves markets for mul ple asset classes Including equi es, fixed Income and energy. NEI Funds A family of mutual funds for which Northwest & Ethical Investments is the investment fund manager and por olio manager. NEI Funds are repor ng issuers. Desjardins Trust is the custodian of NEI Funds. Northwest & Ethical Investments ("NEI Investments"): A 50% owned subsidiary of Desjardins Financial Corpora on Inc., itself an indirect wholly owned subsidiary loaf the Federa on. NEI Investments is a mutual fund company registered as an investment fund manager and por olio manager and it acts as such for NEI Funds. Desjardins Securi es ("DS") A wholly owned subsidiary of Desjardins Financial Corpora on Inc., itself an indirect wholly owned subsidiary of the Federa on. DS is registered as a securi es dealer and offers a full range of securi es brokerage products and services. Disnat is an online brokerage held by DS. Desjardins Securi es Interna onal Inc. ("DSI"), a DS subsidiary, is a brokerage registered with the Financial Industry Regulatory Authority ("FINRA") and the Securi es and Exchange Commission ("SEC"). Western Financial Group Inc. ("WFGI") A wholly owned subsidiary of Desjardins Financial Corporation Inc., itself an indirect wholly owned subsidiary of the Federation. Western Financial Group Inc. offers financial services such as insurance as well as banking and investment services to individuals and businesses in Western Canada. Regulatory Disclosures - Desjardins Global Asset Management 5

6 4. SEPARATE COMPANIES Poten al conflicts of interest are minimized by the fact that, although Desjardins Group has an interest in the above-men oned issuers, they all have separate opera ons, a separate management and a separate board of directors that is formed independently. 5. ISSUERS UNRELATED TO THE COMPANY Conflicts of interest may also arise in the rela onships between the Company and other issuers that are neither related nor connected to it, for example, trusts, partnerships, special purpose vehicles or conduits that issue asset-backed commercial paper. In such a situa on, the prac ces and procedures in effect and in accordance with regula ons will be applied. Shared premises with Desjardins Group en es The Company is a separate en ty from the Fédéra on des caisses Desjardins du Québec, the Fédéra on des caisses populaires de l Ontario Inc., and their caisses. In some cases, the premises of these en es are located at the same address and in the same offices. The Company representa ves perform their du es solely on behalf of the Company. In addi on, unless the Company informs the client otherwise, the securi es bought through the Company have the following features: a) They are not guaranteed by a government deposit insurer. b) They are not guaranteed by the caisses. c) Their value may fluctuate. The Company representa ves In carrying out their usual du es, the Company representa ves may find themselves in situa ons where their personal interests are in conflict with those of a client. The Company representa ves must disclose to the clients concerned any conflict of interest and any personal interest in a security or other investment that can be expected to affect their ability to advise such clients objec vely and impar ally. The Company representa ves must also disclose to their employer any situa on that can be reasonably expected to hinder them in their duty toward their employer or in their ability to provide objec ve and impar al advice. 6. PROCEDURES TO REDUCE CONFLICTS OF INTEREST The Company takes reasonable measures to iden fy all material conflicts of interest that exist or that can be reasonably expected to arise. It assesses the level of risk associated with each conflict and avoids any situa on involving a serious conflict of interest or a risk that is too great for its clients or the integrity of markets. In any other conflict of interest situa on, the Company ensures that appropriate measures are put in place to effec vely control the conflict. the Company ensures that fair and reasonable policies exist and are implemented to manage conflicts of interest specific to its management ac vi es, such as fair alloca on of securi es, use of vo ng rights, compensa on and expense alloca on prac ces, confiden ality of informa on, trade alloca on and best execu on. 6 Regulatory Disclosures - Desjardins Global Asset Management

7 The Company s Code of Ethics and Compliance Handbook establish, as a fundamental principle, standards that guide the conduct of the Company representa ves and that prohibit them, for example, from: Using the confiden al informa on acquired in the course of or in carrying out their du es, or taking advantage of a situa on so as to obtain a benefit of any kind Giving or accep ng gi s, entertainment or compensa on that could influence decisions to be made in carrying out their du es Engaging in outside ac vi es that could interfere or conflict with their du es at the Company Entering into financial transac ons with the Company clients on a personal basis Giving trade orders that knowingly conflict with the interests of the Company clients Engaging in any ac vity or holding an interest in any business or par cipa ng in any partnership that could hinder or appear to hinder their independence in judging what is in the Company clients best interest The Company representa ves must disclose to the clients concerned any conflict of interest and any personal interest in a security or other investment that can be expected to affect their ability to advise such clients objec vely and impar ally. The Company representa ves must disclose to their employer any situa on that can be reasonably expected to interfere with their duty toward their employer or their ability to provide objec ve and impar al advice. The Company ensures that its employee compensa on prac ces are not incompa ble with its obliga ons to its clients. Other conflicts of interest Other real or poten al conflicts of interest may arise at any me. The Company undertakes to take the necessary steps to iden fy and deal with such situa ons in a fair and reasonable manner. Regulatory Disclosures - Desjardins Global Asset Management 7

8 WHAT YOU SHOULD KNOW ABOUT COMPLAINT HANDLING AT DESJARDINS GLOBAL ASSET MANAGEMENT Desjardins Global Asset Management Inc. ("the Company"), in coopera on with the Desjardins Group Ombudsman, has set up a complaint-handling mechanism in accordance with good business prac ces and legal and regulatory requirements. If you are dissa sfied about a ma er or have comments to make in the course of your business rela onship with the Company, let your usual company representa ve know. That person will pinpoint your needs and make every effort to ensure that your expecta ons are met. To file a complaint with the Company If the ma er remains unresolved despite the steps you have taken with your company representa ve and you wish to file a complaint, you should mail or fax your complaint in wri ng to: Desjardins Global Asset Management Chief Compliance Officer Corporate Services Compliance Department 1, Complexe Desjardins Tour Sud, 19 e étage, C.P. 34 Montréal (Québec) H5B 1E4 Fax: Your le er of complaint should include: Your grievance with the company A descrip on of the actual or poten al prejudice that will or could be suffered The correc ve measure requested If you have difficulty formula ng your complaint, we suggest that you visit the Autorité des marchés financiers ("AMF") website, which offers consumers tools to help them with the process, at h p:// A er you file a complaint, i) You will be sent an acknowledgment of receipt within five business days following receipt of all the informa on required to review the file. ii) If your complaint is Incomplete, you will be sent a request for addi onal informa on and you must respond within 30 business days, failing which your complaint will be considered to be withdrawn. iii) The Chief Compliance Officer will review your complaint and inves gate the ma er. iv) You will be mailed a detailed response to your complaint as soon as possible, and no later than 90 business days following receipt of all the required informa on. The response will include a summary of the complaint, the results of the inves ga on and the final decision, with an explana on. v) If the Chief Compliance Officer is not able to provide a detailed response within the 90-day period, he or she will contact you to inform you of the reasons for the delay and the new response me an cipated. Other recourse available to you If you are not sa sfied with the review of your complaint, other recourse is available to you: i) You can request that the Chief Compliance Officer forward a copy of your file to the Desjardins Group Ombudsman, who will serve as your final recourse within Desjardins Group. The Ombudsman will review your file within about 60 days following receipt of all the necessary informa on. You can also send your file directly to the Ombudsman at the following address: 8 Regulatory Disclosures - Desjardins Global Asset Management

9 Ombudsman Fédéra on des caisses Desjardins du Québec 1, Complexe Desjardins C.P. 7, Succ. Desjardins Montréal (Québec) H5B 1B2 ii) You can request, at any me, that the Chief Compliance Officer forward a copy of your file to the Autorité des marchés financiers. You can also send your file directly to the AMF at the following address: Québec: Autorité des marchés financiers 800, Square Victoria, 22 e étage C.P. 246, tour de la Bourse Montréal (Québec) H4Z 1G3 No ce to clients residing outside Québec Clients residing in provinces other than Québec may file their complaint with one of the following the Company agents: Alberta: Borden Ladner Gervais LLP Centennial Place, East Tower 1900, rd Avenue S.W. Calgary, Alberta T2P 0R3 Bri sh Columbia: T.W. Business Law Corp / Falko Wong 470 Granville Street, # 218 Vancouver, Bri sh Columbia V6C 1V5 Manitoba: Fillmore Riley LLP Main Street Winnipeg, Manitoba R3C 3Z3 Nova Sco a: Stewart McKelvey LLP Upper Water Street P.O. Box 997 Halifax, Nova Sco a B3J 2X2 Ontario: Borden Ladner Gervais LLP Sco a Plaza, 40 King Street West Toronto, Ontario M5H 3Y4 Saskatchewan: McDougal Gauley LLP 701 Broadway Avenue Saskatoon, Saskatchewan S7N 1B3 Regulatory Disclosures - Desjardins Global Asset Management 9

10 FAIRNESS POLICY The Company undertakes to ensure that the transac ons carried out on behalf of its clients are executed under the best condi ons with brokers and in a fair and equitable manner for all its clients, in accordance with their investment policy. Transac ons carried out for a number of clients on the primary and/or secondary market are allocated on a pro rata basis determined in advance. Orders are then executed using the average price and average commission rate. When orders are par ally executed or the quan ty is deemed negligible, the por olio manager assigned to the account may, with the director s approval, reallocate the alloca on to another client or remit it to the broker. In the execu on process, the Company considers other factors that can influence the choice of broker for a transac on, such as service quality, commission rate, reputa on, financial responsibility and speed of execu on. A periodic review is conducted of each of the brokers with whom the Company deals. In the execu on of orders, the Company considers all factors that can affect execu on me as well as the way in which certain factors, such as market vola lity and available liquidity, can affect order processing. The Company strives to obtain the best possible result for its clients when execu ng orders and forwarding orders to be executed. This policy may be revised from me to me to reflect changes in regulatory requirements and industry prac ces. DECLARATION OF RISK Introduc on According to Regula on , the manager is required to describe the types of risks the client should take into account when establishing a new business rela onship with Desjardins Global Asset Management ("the Company"). The manager is also required to disclose the nature and scope of the specific investment-related risks about which a reasonable investor would expect to be informed. This document outlines the investment-related risks iden fied by the manager; the informa on is not exhaus ve, but rather intended strictly for informa on purposes. Nature of risks The main risks associated with por olio management, whether the investments are held directly or through a mutual fund ("fund"), are described below. Any investment in securi es may result in a capital loss by virtue of its specula ve nature. The risks associated with the strategies and methods used can Increase during periods of specula ve ac vity or unusual market vola lity. General risks related to markets and returns There is no guarantee that the investment approach used will be effec ve or that the investment objec ves will be achieved. Nor is there any guarantee that the investments in your por olio or the fund will generate Income or added value. Although the diversifica on and selec on process used by the Company is expected to mi gate risks, the por olio or the fund may sustain considerable losses rather than gains because of the risks described in this document. The return generated by the por olio/fund also depends on the manager s investment management skills. 10 Regulatory Disclosures - Desjardins Global Asset Management

11 The value of your por olio, like the net asset value of a fund, will fluctuate with general condi ons prevailing on debt, equity and commodity markets, as well as with exchange rates and various poli cal, economic and social situa ons, capital market instability and the financial performance of issuers of the securi es that cons tute or underlie the investments held by the por olio/fund. The success of any investment ac vity depends on the general economic situa on, which can influence interest rates and vola lity; it also depends on the volume of transac ons and the me investors choose to invest in equity and other markets. Unexpected vola lity or illiquidity on markets in which the Company holds an interest could hinder its ability to achieve its objec ves or cause it to sustain losses. Despite the significant volume of transac ons in securi es and other financial instruments, markets for certain financial instruments have limited transparency and liquidity, which can be a disadvantage for the Company in terms of obtaining the listed price and execu ng trades at the desired price. If your assets are invested in the Company Funds, it is important for you to know that these funds must comply with certain regulatory requirements, but are not subject to all the disclosure obliga ons or regula ons applicable to public mutual funds. Income tax considera ons The a er-tax return of an investment in a fund for an investor required to pay tax in Canada will depend in part on the composi on of the distribu ons paid by the fund (which can be wholly or par ally taxable or, in certain cases, cons tute a non-taxable capital refund). The composi on can vary over me, which influences the a er-tax yield of your investments. The taxa on rates applicable to the different types of Income could also change following amendments to government policies. Dividends and other distribu ons, Including deemed disposi ons, from securi es in the por olio may be taxable; the investor may not necessarily deduct all or a por on of such tax from his or her local Income or apply it to a foreign tax credit on his or her local tax expense. Borrowing The Company may temporarily borrow money on behalf of the Company Funds and clients, to meet redemp on demands or se le por olio opera ons. If the market declines before the securi es can be sold to raise the liquidity to reimburse the loans, the net asset value of the por olio/fund will decrease and the other investors will feel the impact. Based on your investment policy, the Company has the right to contract debts backed by its assets and intends to exercise this right. Illiquidity Some securi es may be illiquid because they are infrequently traded; as a result, there is no guarantee that the por olio/fund will be able to liquidate such investments. Currency If your investment policy so permits, the Company can use futures and foreign currency op ons as hedges against currency fluctua ons. However, the Company is not required to do so, and there is no guarantee that such hedges will be effec ve under the circumstances. Risks related to margin transac ons and counterparty risk The por olio/fund may be exposed to the risk of default by the counterpar es with which the transac ons are carried out. If the securi es provided to a broker to guarantee margin transac ons lose value, the broker will issue a margin call; the Company will then be required to deposit addi onal assets with the broker or another counterparty, or the securi es given as a guarantee may have to be liquidated to offset the loss. In the event of a sudden drop in the value of its assets, the por olio/fund may be unable to liquidate the assets quickly enough to reimburse the margin debt. Short sale If your investment policy so permits, the Company may engage in short selling, i.e., in selling a security not held by the por olio/fund in the hope of subsequently Regulatory Disclosures - Desjardins Global Asset Management 11

12 buying the same security (or an exchangeable security) back at a lower price. To deliver the security to the buyer, the por olio/fund must borrow the security then buy it back at a later date to return it to the lender. Short selling involves the risk of a theore cally unlimited Increase in the price of a security. Suspension of trading Stock markets generally have the right to suspend or limit trading in any financial instrument. In the event of such a suspension, the financial instrument in ques on might not be liquidated and the por olio/fund could thus sustain losses. Financial leverage If your investment policy so permits, the Company can use financial leverage. Although financial leverage improves the chance of achieving a be er return, it also Increases the risk of loss. The risks associated with leveraging vary for each buyer according to his or her specific situa on. The Company is not a lending ins tu on and consequently does not grant its clients loans. Deriva ves If your investment policy so permits, the Company can invest in deriva ves intended to hedge its interest in underlying markets so as to modify or reproduce the return of securi es, commodi es, interest rates, indices or specific markets with or without leverage. Deriva ves generally involve counterparty risk or the risk of losing all or part of the value of the investment, in par cular because of the vola lity of interest rates and credit risks, economic factors and ac vi es on domes c and global markets. Deriva ves can include substan al leverage that could considerably worsen the repercussions of market fluctua ons and result in losses greater than the value of the investment. Deriva ve transac ons are some mes carried out over the counter or between dealers. Par cipants in these markets are generally not subject to regulatory oversight like par cipants in regulated stock markets. Unless otherwise indicated by your investment policy, nothing prevents the Company from dealing with a par cular counterparty or carrying out all its transac ons with a single counterparty. Limited ability to liquidate investments in DGIA Funds Investors in a DGIA Fund do not have any public market for the shares offered hereunder and no market is expected to be created for that purpose. To redeem shares, the investor must complete and sign the redemp on form and forward it to the Company. The Company Fund shares may not be transferred or resold. In addi on, under the specific excep onal circumstances described in the Declara on of Trust, share redemp on could be suspended for a certain period. Poten al effects of share redemp on Requests to redeem a significant volume of shares could require the fund to liquidate its investments more quickly than desirable in order to raise the amounts required to fund the redemp ons and achieve a market posi on that faithfully reflects a lower asset base. A drop in the value of the redeemed shares and outstanding shares could ensue. Amendments to laws There is no guarantee that Canadian or foreign laws, in par cular legisla on governing securi es, investments and taxa on, as well as the administra ve policies and prac ces of governments and regulatory agencies will not be amended in a way that could adversely affect your investments. 12 Regulatory Disclosures - Desjardins Global Asset Management

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14 Desjardins Global Asset Management Inc (Montréal area)