Regulatory Disclosures

Transcription

1 STATEMENT OF PRINCIPLES ON CONFLICTS OF INTEREST DESJARDINS INVESTMENT MANAGEMENT INC. POLICY ON PROTECTION OF PERSONAL INFORMATION WHAT YOU SHOULD KNOW ABOUT DESJARDINS INVESTMENT MANAGEMENT INC. AND ITS COMPLAINTS HANDLING PROCESS FAIRNESS POLICY RISKS OF USING BORROWED MONEY TO FINANCE THE PURCHASE OF A SECURITY

2 Statement of Principles on Conflicts of Interest Discretionary portfolio management is offered by Desjardins Wealth Management, Private Wealth Management and is provided by Desjardins Investment Management Inc. ( DIM ), a wholly-owned subsidiary of the Fédération des caisses Desjardins du Québec. DIM s head office is located in the province of Québec where it is registered as a portfolio manager. DIM is also registered to that effect, as a non-resident firm, in the following provinces and territory: Alberta, British Columbia, New Brunswick, Ontario and Yukon. It is also registered as an investment fund manager in Québec and Ontario as part of the management of DIM Private Funds, which are available in the provinces where DIM is registered as a portfolio manager. DIM is subject to all regulations applicable to these two statuses. Where requirements differ, DIM applies the stricter rule. Within the meaning of Regulation respecting registration requirements and exemptions, the regulator of DIM is the Autorité des marchés financiers du Québec (AMF). It is important to DIM that its clients be informed of existing or potential conflicts of interest which could arise in the course of its activities. A conflict of interest arises when the interests of different persons, e.g. those of a client and those of DIM or one of its representatives are incompatible or divergent. DIM takes reasonable measures to identify any material conflicts of interest that exist or that it can reasonably expect to arise. It assesses the level of risk associated with each conflict and avoids any circumstances that involve a serious conflict of interest or that present too great a risk thereof for its clients. In any other situation involving a conflict of interest, DIM ensures that appropriate measures are put in place to effectively control the conflict. The activities of DIM and its representatives (directors, officers, partners, employees) are governed by a Code of Ethics and Conduct and by a Compliance Handbook, which its representatives must certify having read each year. CONFLICTS OF INTEREST DIM hereby informs you of the nature and scope of the conflicts of interest that could affect the services it offers you. Issuers related or connected to DIM As mentioned above, DIM is a wholly-owned subsidiary of the Fédération des caisses Desjardins du Québec. 2

3 The entities listed below may be considered issuers related or connected to DIM: Desjardins caisses Capital Desjardins Inc. Capital régional et coopératif Desjardins inc. (CRCD) Desjardins Funds NEI Funds Caisse centrale Desjardins du Québec Desjardins Trust Inc. Fiera Capital Corporation Fiera Sceptre Mutual Funds Western Financial Group Inc. TMX Group Limited Members of the Fédération des caisses Desjardins du Québec (the Fédération). A wholly-owned subsidiary of the Fédération, Capital Desjardins purpose is to offer its own securities in the financial markets and to invest the proceeds in securities issued by Desjardins caisses. An investment fund whose portfolio manager is Desjardins Venture Capital Inc. (which itself is a wholly-owned subsidiary of the Fédération), CRCD raises development capital by means of public offerings and injects these funds into cooperatives and small- and medium-sized businesses. Family of mutual funds for which the trustee and custodian is Desjardins Trust Inc., which is a wholly-owned subsidiary of the Fédération. Desjardins Investments Inc., which is a wholly-owned subsidiary of the Fédération, is the management company and sponsor of Desjardins Funds. Desjardins Global Asset Management Inc. (DGAM) is their portfolio manager. DGAM is a wholly-owned subsidiary of Desjardins Asset Management Inc., which itself is a wholly-owned subsidiary of the Fédération. Family of mutual funds for which Northwest & Ethical Investments L.P. is the trustee and manager. Northwest & Ethical Investments L.P. also acts as portfolio manager for specific funds. The Fédération has a 50% interest in Northwest & Ethical Investments L.P. Desjardins Trust Inc. is the custodian of these funds. A cooperative that belongs to the Desjardins caisses, Caisse centrale Desjardins is the treasurer of Desjardins Group and acts as its financial agent in the Canadian and international markets. It offers financing, banking and international services to institutions and to large- and medium-sized businesses. A wholly-owned subsidiary of the Fédération, this company is a deposit institution. Public company in which Desjardins Asset Management Inc., a wholly-owned subsidiary of the Fédération, has a significant indirect interest. Family of mutual funds for which Fiera Capital Corporation, a company in which Desjardins Asset Management Inc., a wholly-owned subsidiary of the Fédération, has a significant indirect interest, is the manager and the promoter. Fiera Capital Corporation is a registered portfolio manager and acts in this capacity for the Fiera Sceptre Mutual Funds. A wholly-owned subsidiary of Desjardins Financial Corporation Inc. (DSoF), which itself is a wholly-owned subsidiary of the Fédération. Western Financial, a financial services company, was amalgamated with a wholly-owned subsidiary of DSoF. The Fédération owns all the outstanding common shares of the amalgamated company. A public company in which Desjardins Financial Group, a wholly-owned subsidiary of the Fédération, has an ownership interest. TMX Group Limited operates cash and derivatives markets for multiple asset classes, including equities, fixed income and energy. 3

4 Meritas SRI Funds and OceanRock Funds Family of mutual funds for which OceanRock Investments Inc., a company in which Desjardins Financial Corporation Inc., a wholly-owned subsidiary of the Fédération, has a significant indirect interest, is the manager and the promoter. OceanRock Investments Inc. is a registered portfolio manager and acts in this capacity for the Meritas SRI Funds and OceanRock Funds. OceanRock Investments Inc. also acts as the trustee of the Funds. The list of these issuers related or connected to DIM is updated on the DIM website at gestionpriveedesjardins.com As part of the management of its clients discretionary accounts, DIM may buy or sell, or make recommendations with respect to: a) securities of an issuer which it or a person of its group owns; b) securities for which it or a person of its group participates in the placement; c) securities of a related or connected issuer; d) securities of an issuer that has as an employee, agent, partner, director or officer of DIM or of Desjardins. DIM will do so in accordance with the regulations applicable to such transactions and always in the best interest of its clients. In the case described in point (d) above, DIM will not make any transaction involving such issuer, unless the client concerned has been informed of this fact beforehand and has expressly authorized such transaction in writing. DIM ensures that fair and reasonable policies exist and are implemented for the management of conflicts of interest specific to portfolio management activities, such as fair allocation of securities, soft-dollar payments, proxy voting, compensation and expense allocation practices, error correction, confidentiality of information, trade allocation and best execution. Issuers unrelated to DIM Conflicts may also arise in the relationships between DIM 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 situation, the practices and procedures in force and in accordance with regulations will be applied. Other companies related to DIM Desjardins Group The complete organization chart of the companies belonging to Desjardins Group is available on the Internet at: Shared premises with Desjardins Group entities DIM is a separate entity from the Fédération des caisses Desjardins du Québec, the Fédération des caisses populaires de l Ontario inc., and their caisses. In some cases, the premises of those entities are at the same address and in the same offices. DIM representatives perform their duties solely on behalf of DIM. Moreover, unless DIM informed the client otherwise, securities bought through DIM have the following features: a) they are not guaranteed by a deposit insurer; b) they are not guaranteed by the caisses; c) their value may fluctuate. 4

5 DIM representatives In the normal course of performing their duties, DIM s officers and representatives may find themselves in situations where their personal interests are in conflict with those of a client. DIM representatives must then 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 capacity to advise them objectively and impartially. DIM representatives must also disclose to their employer any situation that can be reasonably expected to hinder them»in the performance of their duties or in their capacity to give objective and impartial advice. The Code of Ethics and Conduct and the Compliance Handbook of DIM set forth standards that guide the conduct of its representatives. These standards prohibit them from: using confidential information acquired in the course of or in connection with their duties, or exploiting a situation, for the purpose of obtaining an advantage of any kind; accepting or giving gifts, entertainment and compensation that could influence decisions to be taken in the course of performing their duties; engaging in outside activities that could interfere or conflict with their duties at DIM; entering into financial transactions on a personal basis with clients of DIM; giving trade orders which they know conflict with the interests of clients of DIM; engaging in any activity or holding an interest in any business or participating in any partnership that may hinder or appear to hinder their independence of judgment in the best interest of clients of DIM. DIM ensures that its employee compensation practices are not inconsistent with its obligations to its clients. Referral arrangements In the course of its activities, DIM has entered into fee-sharing agreements with Desjardins subsidiaries or with the following business partners: member caisses of the Fédération des caisses Desjardins du Québec; member caisses of the Fédération des caisses populaires de l Ontario inc.; Desjardins Financial Security (DFS); Desjardins General Insurance (DGI); Banque Transatlantique (BT). All these entities are members of the same financial group, Desjardins Group, except for BT which is an external business partner. The caisses mentioned above provide banking services inside Canada, while BT provides similar services abroad. DFS provides life and health insurance services and DGI provides property and casualty insurance services. According to the referral arrangements entered into between DIM and these groups, employees from the caisses and BT may refer clients to DIM for an access to all the discretionary portfolio management services. DIM s representatives may refer clients to DSF and DGI for insurance products and to BT for banking services outside Canada. As mentioned previously, DIM is registered with the Canadian Securities Administrators as a portfolio manager in the following provinces and territory: Alberta, British Columbia, New Brunswick, Ontario, Québec and Yukon. Services requiring a specific registration and originating from one of the referral arrangements shall be rendered by the registered group or individual receiving the referral. DIM or any of its employees shall not trade securities or give advice on securities other than those for which they have the registration or permit required under applicable securities legislation. 5

6 Details of Referral Agreements Currently in Force 1. CLIENT REFERRALS TO DIM BY THE FÉDÉRATION DES CAISSES In consideration for client referrals to DIM, the caisses receive, as intermediaries, a compensation according to the percentages indicated in the table below. Value market of accounts % of remuneration for the caisses (ongoing) > $500,000 20% of the fees charged to the client 2. CLIENT REFERRALS TO DFS BY DIM In consideration for client referrals to DFS, DIM receives in the first year of the conclusion of a new insurance contract, as an intermediary, a percentage of the remuneration of DFS based on the type of products or services and according with the percentages indicated in the table below. Remuneration First year From DFS to: DIM Insurance premium % of remuneration $0 to $999 15% $1,000 to $4,999 25% $5,000 and more 40% When a client is referred by the caisse to DIM and then referred by DIM to a financial security advisor from DFS, the remuneration paid by DFS for the sale of an insurance contract shall be separated between DIM (80%) and the caisse (20%) during the first year of the signature of the new contract. The table above indicates compensation received for the top-selling insurance and savings products. The table is not comprehensive. Different types of compensation apply to other accessorial products/services provided by DFS, such as group insurance, life insurance for people 50 years old and older, travel insurance, accident insurance or wellness insurance, guaranteed investment funds contracts, individual retirement annuities (life annuity and annuity certain), individual pension plans (IPPs), group plans (group RRSPs, defined contribution pension plans, deferred profit-sharing plans (DPSP), others), group annuities and others. 3. CLIENT REFERRALS TO DGI BY DIM In consideration for client referrals to DGI, DIM receives a remuneration that is 15% or less of the insurance premium subscribed to for personal services and limited to a maximum of $2,000 for business services. 4. CLIENT REFERRALS TO BT BY DIM In consideration for client referrals to BT, DIM receives, as intermediary, compensation based on the nature of the transaction, according to the percentages indicated in the table below. Banking products and services tied to financial savings collection Administrative management fees for life insurance contracts Credit files fees (costs for loans) 20% of net banking income 20% 50% 6

7 5. CLIENT REFERRALS TO DIM BY BT In consideration for client referrals in favour of DIM, BT receives, as intermediary, an annual amount equivalent to 20% of discretionary management fees generated for clients referred by BT and who have retained DIM services. Other referral arrangements DIM may enter into arrangements not described in the present document whereby it pays or receives compensation for client referrals. At all events, the following information is communicated to the client in writing before the opening of the client s account or, if the provision of services to the client by the person to whom the client is referred occurs earlier, before such provision of services: the name of each party to the referral arrangement; the purpose and material terms of the referral arrangement, including the nature of the services to be provided by each party; any conflicts of interest resulting from the relationship between the parties to the referral arrangement and from any other element of the referral arrangement; the method of calculating the referral fee and, to the extent possible, the amount of the fee; the category of registration of each registrant that is a party to the agreement, with a description of the activities that the registrant is authorized to engage in under that category and, giving consideration to the nature of the referral, the activities that the registrant is not permitted to engage in; if a referral is made to a registrant, a statement that all activity requiring registration resulting from the referral arrangement will be provided by the registrant receiving the referral; any other information that a reasonable client would consider important in evaluating the referral arrangement. If there is a change to the information set out above, DIM must ensure that written disclosure of that change is provided to each client affected by the change as soon as possible and no later than the 30th day before the date on which a referral fee is next paid or received. The client can enquire about specific products to his or her investment advisor. Other conflicts of interest Other potential or actual conflicts of interest may arise at any time. DIM undertakes to continue taking the necessary steps to identify and respond to such situations fairly and reasonably. There is a potential conflict of interest in any arrangement on the indication of clients including a fee because the person who refers has a financial interest to refer the client to another party. DIM addresses any potential conflict of interest by adopting a respectful business judgment and ethical standards related exclusively to the pursuit of your interests. This Statement of Principles on Conflicts of Interest will be updated if new conflict of interest situations arise. The most recent version of this Statement is available at all times on the DIM website at 7

8 Desjardins Investment Management Inc. Policy on Protection of Personal Information 1. DESCRIPTION The policy of Desjardins Investment Management Inc. ( DIM ) concerning the protection of personal information establishes DIM s orientations and rules to ensure the confidentiality and protection of all personal information collected, held, used or conveyed by DIM regarding its clients. This policy explains how DIM protects its clients personal information in the context of providing financial services. It also describes the principles applied to protect its clients respective personal information in the exercise of its activities in Canada, both on an intra-provincial or inter-provincial basis. 2. PURPOSE In addition to the fact that DIM is concerned with respecting the law, it takes all matters related to protection of personal information very seriously, and it is committed to taking the necessary measures to ensure and preserve the accuracy, confidentiality, security and privacy of its clients personal information. Adoption of and compliance with a policy on the protection of personal information demonstrates this interest and should result in a greater sense of client confidence in DIM. 3. SCOPE All employees, officers and directors of DIM must comply with the present policy and respect the protection of personal information process established by DIM. 4. TERMINOLOGY For purposes of applying this policy, the following words and expressions shall mean: 4.1 Consent Free and informed acquiescence obtained in accordance with applicable laws. A client may express his or her consent verbally, in writing or electronically. 4.2 Name list A list of names, addresses or telephone numbers of physical persons, whether or not constituted from a common denominator. 4.3 Direct marketing Promotions targeting clients whose personal information reveals that a financial product or service is likely to interest them. Direct marketing includes telemarketing initiatives and mailings by post or but excludes regularly issued statements, inserts enclosed with statements, messages at Desjardins automatic teller machines, or advertising on electronic bulletin boards or websites. 4.4 Client A person who uses or intends to use a DIM financial product or service. 4.5 Desjardins Group All components of the Desjardins Group taken collectively. 4.6 Financial products and services Encompass, but are not limited to, personal financial services, brokerage and securities advisory services, as well as discretionary portfolio management services. 4.7 Personal information Any information concerning a client that this client provides to DIM that has been collected from a third party in compliance with this policy and applicable laws or generated by a component of the Desjardins Group. 4.8 Third party An individual or organization other than a component of the Desjardins Group. 8

9 5. COLLECTION, USE AND COMMUNICATION 5.1 Subject to requirements set out in applicable laws, DIM collects, uses and conveys personal information on clients for the following purposes only: a) understanding a client s needs; b) determining if financial products and services to which clients subscribe suit their needs; c) offering financial products and services that meet clients needs better; d) establishing and managing financial products and services to meet these needs; e) providing clients with current financial products and services; f) meeting the requirements of laws and regulations; g) performing direct marketing activities. 5.2 DIM may use information related to a client s deposits, investments, credit and other personal information it holds with respect to him or her, including how the client uses financial products and services of Desjardins Group, for the purpose of informing him or her further on the said financial products and services of Desjardins Group. 5.3 Subject to legal or contractual restrictions and Article 10 of this policy, DIM may share personal information on a client with other components of the Desjardins Group so as to be able to inform him or her directly on their financial products and services. This exchange of personal information will occur, however, only if the client has signed the Desjardins consent form and has read the accompanying leaflet entitled Desjardins consent: I benefit! 6. CONSERVATION 6.1 DIM may, subject to applicable laws, conserve in its files a client s personal information as long as required for the above-mentioned purposes, even if an individual ceases to be a client. 7. CONSENT 7.1 Subject to exceptions found in or permitted by applicable laws, DIM does not collect, use or pass on personal information on its clients for the purposes set out in Article 5.1 or for any other purpose, except with each client s prior consent. This consent is given by clients at various times when a financial service is provided. 7.2 If DIM collects personal information from third parties (e.g. credit bureaus or other agencies, employers, hospitals, etc.) or contacts them to verify or complete personal information, it does so, subject to applicable laws, only with the client s prior consent. 7.3 Except in the below mentioned cases, each time DIM passes on any information in compliance with this policy, it keeps in its records, where it is reasonable to do so, the nature of this information, the date on which it was sent and the identity of the third party or Desjardins Group component to which it was provided. Exceptions to this rule are personal information passed on for current operations, such as sending information to companies acting as proxies for DIM, as well as the production of statements and other documents intended for Revenu Québec, the Customs Agency and the Canada Revenue Agency, and the updating of data with the authority concerned, or communications with third parties for non-sufficient-fund cheques. 7.4 Subject to legal and contractual obligations, clients may refuse their consent for the collection, use or conveyance of their personal information or may withdraw consent at any time. If clients do not want DIM to collect, use or convey their personal information for any purpose at all or to communicate with them by mail or by phone, clients may take the necessary measures to this effect with DIM. If clients refuse or withdraw such consent, however, DIM may not be able to provide or continue to provide them with certain products, services or information that is likely to interest them or that they have requested. 9

10 8. NAME LISTS Components of the Desjardins Group may establish and pass on to third parties or to other components of the Desjardins Group name lists of their respective members/clients for purposes of commercial or philanthropic prospecting. DIM s clients may at any time ask DIM to strike them from DIM s name lists. 9. SUBCONTRACTORS AND SERVICE PROVIDERS A client s personal information may be passed on to DIM agents or subcontractors, or to service providers, for services such as data processing, cheque or credit card printing, statement preparation and mailing, credit collection or the processing of claims. In such circumstances, DIM prohibits use of this information for purposes other than providing the service in question. These subcontractors and service providers must also agree to take all necessary measures to protect personal information when services are being provided. These obligations are valid both during and after the time the services are provided. 10. DELETED INFORMATION DIM may use and convey information on a client for purposes of statistical study, market analysis or segmentation, provided the client can in no way be identified and no link can be established between the client and the information used or conveyed. 11. ACCURACY OF INFORMATION 11.1 DIM makes every reasonable effort to ensure the updating, accuracy and integrity of personal information it holds on its clients. It is, however, the responsibility of each client to inform DIM promptly of any change of name or address or of any other pertinent modification to be made to the personal information on the client If a client believes that any personal information on him or her is inaccurate or erroneous, DIM encourages the client to seek access to his or her file and check the accuracy of this information. This provides the opportunity to make any corrections or updates that may be required. 12. RIGHTS OF ACCESS AND CORRECTION 12.1 Subject to applicable legal restrictions, a client may at any time ask to be informed of the existence, use or conveyance of his or her personal information. For a client to gain access to his or her own personal information, the client needs only to contact or write to DIM. For security purposes, a client must provide proof of identity before gaining access to his or her personal information Upon receiving a request for access, DIM will convey to the client the information it holds on him or her within thirty (30) days of receiving the request, unless a further delay is granted in compliance with applicable laws as required. If fees are required for seeking information, the client is advised beforehand and may, if he or she wishes, withdraw the request or challenge whether the fees are reasonable Any client with a sensory disability may have access, upon request to DIM, to his or her personal information in a format enabling this information to be read or heard, if such a format is available. If such a format is not available, DIM will convert the pertinent personal information into the required format if it is reasonable to do so If a client s request for access is denied, DIM must, subject to applicable legislative restrictions, inform the client of the reasons for denying the request. 10

11 13. PROTECTIVE MEASURES 13.1 Again with the aim of maintaining client confidence, DIM has established measures to ensure and maintain the confidentiality, security and privacy of its clients personal information DIM employees must read this policy and agree to comply with it and to respect the privacy of personal information on clients. In addition to this policy, they must obey the Code of Ethics and Conduct applicable to them As mentioned above, subcontractors and service providers dealing with DIM must agree to protect the confidentiality and privacy of personal information conveyed to them for purposes of the services they provide DIM has also established substantial security measures to protect its data systems. Only staff members authorized by DIM have access to the internal facilities where personal information is received, processed or maintained. Moreover, data systems and data handling procedures are subject to appropriate security measures such as passwords, data encryption, access controls to applications and databanks, firewalls, anti-virus systems and intrusion detection systems, continuously revised to guarantee the security of operations and the confidentiality of processed data. Further information on precise protective measures related to trading services and online application forms may be found at When DIM considers that it no longer needs personal information for the purposes for which it was collected, it destroys or erases the information, subject to applicable laws and in compliance with DIM s policies on conservation and internal destruction. 14. QUESTIONS / COMPLAINTS / RECOURSE 14.1 Clients may address DIM directly with any question, suggestion, dissatisfaction or comment they consider important. More particularly, DIM has designated a person in charge of answering questions from clients regarding any of their personal information that DIM may hold or concerning the firm s compliance with this policy. This person is also in charge of informing clients of the settlement procedure for applicable complaints If a client is not satisfied with results obtained from DIM or, as a final recourse, from the Desjardins Group ombudsman, he/she may contact the government authority responsible for the protection of personal information in his or her place of residence. 11

12 What you Should Know about Desjardins Investment Management Inc. and its Complaints Handling Process Desjardins Investment Management Inc. ( DIM ), in cooperation with Desjardins Group s Ombudsman, has established efficient measures for handling client complaints, in order to comply with the quality standards set out by the applicable regulations. These complaints handling procedures allow clients who allege they suffered potential or actual prejudice, or were victims of misconduct, to appeal to an impartial review and investigation service for dispute settlements with DIM. FILING A COMPLAINT WITH DIM Complaints may be sent by mail at the following address: Compliance Department Complaints and Litigation Desjardins Investment Management Inc Peel Street, Suite 300 Montreal, Quebec H3B 0A9 The client who wishes to file a complaint must do so in writing and the request must include the following three elements: 1. Details of the grievance; 2. A description of the alleged potential or actual prejudice; 3. The requested corrective measure. If you are having difficulties in formulating your complaint, you can refer to the Autorité des marchés financiers (AMF) website for tools to help you with your process: STEPS FOLLOWING THE RECEIPT OF A COMPLAINT A member of the Compliance, Complaints and Litigation department will be appointed to your file. An acknowledgement of receipt will be forwarded to you within five business days following the receipt of your complaint unless your complaint is settled within said delay of five days. The person responsible for your file proceeds to his or her review and conducts an investigation. His or her contact information is available on the acknowledgement receipt. A detailed response to your complaint will be sent by mail as soon as possible and no later than 90 calendar days from the receipt of the complaint. The answer includes a summary of the complaint, the results of the investigation and the final decision, with an explanation thereof. The letter also provides you with other options for seeking compensation, if you are not satisfied with the response. In the event that the Compliance, Complaints and Litigation department is not able to provide you with a response within the set delay of 90 days, they will contact you within that timeframe to inform you of the reasons for the delay and of the new expected response time. OTHER OPTIONS AVAILABLE If you are not satisfied with the conclusion reached by DIM s Compliance, Complaints and Litigation department, the following options are also available. 12

13 Desjardins Group s Ombudsman Upon a written request, Desjardins Investment Management s Compliance, Complaints and Litigation department can forward a copy of your file to Desjardins Group s Ombudsman, which will serve as your final recourse within Desjardins Group. Once it has received all necessary information, Desjardins Group s Ombudsman will review your file within 60 days. You may also forward them your file directly, at the following address: Ombudsman Fédération des caisses Desjardins du Québec 1, Complexe Desjardins P.O. Box 7, Desjardins Station Montreal, Quebec H5B 1B2 Autorité des marchés financiers (AMF) Upon a written request, Desjardins Investment Management s Compliance, Complaints and Litigation department can forward a copy of your file to the Autorité des marchés financiers. You may also forward them your file directly, at the following address: Autorité des marchés financiers 800, Square Victoria, 22nd floor P.O. Box 246, Tour de la Bourse Montreal, Quebec H4Z 1G3 Ombudsman for Banking Services and Investments (OBSI) Service for resolving banking services and investment disputes (clients residing outside Quebec) The Service for resolving banking services and investment disputes offered by OBSI is exclusively for the benefit of clients residing outside the province of Quebec. OBSI is a national and independent service available to individuals and small businesses that did not succeed to satisfactorily settle a disagreement with their banking services or investments firm. In order to send your complaint to the OBSI, a complaint form is available at the following address: To contact the OBSI: Ombudsman for Banking Services and Investments (OBSI) 401, rue Bay Suite 1505, P.O. Box 5 Toronto, Ontario M5H 2Y4 ombudsman@obsi.ca Toll-free Telephone:

14 Notice to Clients Residing outside Quebec Clients residing in provinces other than Quebec may forward their complaints by mail to one of DIM s following agents: ALBERTA Mr. Graham Wetter Credit Union Central 8500 MacLeod Trail, SE Calgary, Alberta T2H 2N1 NEW BRUNSWICK M. Marc Roy Fédération des caisses populaires Acadiennes Édifice Martin-J.-Légère 295 West St-Pierre Blvd, P.O. Box 5554 Caraquet, New Brunswick E1W 1B7 YUKON Mr. Grant Macdonald Macdonald & Company, Lawyers Suite 200 Financial Plaza 204 Lambert Street Whitehorse, Yukon Y1A 3T2 BRITISH COLUMBIA Mr. Richard J. Thomas Credit Union Central of British Columbia 1441 Creekside Drive Vancouver, British Columbia V6J 4S7 ONTARIO Desjardins Trust Inc. 220 Laurier West Avenue, Suite 1650 Ottawa, Ontario K1P 5Z9 DIM insists on the fact that clients residing outside Quebec will incur no risk concerning the respect of their rights in the treatment of their complaints in said provinces. Fairness Policy Desjardins Investment Management Inc. ( DIM ) endorses, enforces and complies with the Code of Ethics and Standards of Professional Conducted by the CFA Institute (formerly AIMR). Without limitation to the foregoing and with regard to transactions executed for its clients, DIM furthermore maintains standards ensuring fairness for its clients. As such, DIM ensures that: When taking investment action for its clients, and as required by law, it will consider its appropriateness and suitability prior to executing any transaction, or at any other time as required by law. In considering such matters and using reasonable judgment to determine the relevant factors, DIM will take into account: the needs and circumstances of its clients; the basic characteristics of the investment involved; the basic characteristics of the total portfolio. It is DIM s policy that no single account or type of account will receive preference in the allocation of investment opportunities. Accordingly, DIM and its staff shall act in a manner consistent with their obligation to deal fairly with all clients when: disseminating investment recommendations; disseminating material changes in prior investment advice; when taking investment action. 14

15 Member of the staff of DIM will conduct themselves in such a manner that transactions for the clients of DIM and their employer will have priority over transactions in securities or other investments of which they are beneficial owner, so that said transactions or investments do not conflict with the interest of the client. If a member of the staff of DIM decides to take investment action in a security or other investment, he or she shall give priority in executing such transactions to clients of DIM and his or her employer before acting on his or her own behalf. For completed block trades at one price, DIM allocates the same fill to all its clients and own accounts. If the block trade does not fill at one price, allocations to clients and DIM s own accounts will be made on a weighted average pricing basis. Partial fills on block trades will be distributed to client accounts on a pro-rata basis. Should DIM participate in the purchase of initial public offerings, it would do so only through its external sub-advisors and within the limits of the mandates given to them. In such case, treatment of such orders and distribution to DIM s client accounts would remain the same as with any other block trade or partial fills at DIM. DIM uses its buying power to negotiate the best possible commission arrangement. Trades allocated to client accounts, including block trades, are then charged on a pro-rata basis. When taking investment actions, members of the staff of DIM shall disclose to the clients any material conflict of interest related to them and any material beneficial ownership of the securities or other investments involved that could reasonably be expected to impair their ability to render objective and unbiased advice. Staff of DIM shall also disclose to their employer all matters that could reasonably be expected to interfere with their duty towards their employer or with their ability to render objective and unbiased advice. Staff of DIM shall also comply with all requirements related to the disclosure of conflicts of interest imposed by law, as well as rules and regulations of organizations governing their activities, and shall comply with any prohibitions on their activities should a conflict of interest exist. The foregoing policies will be revised from time to time in keeping with changes in regulatory requirements and industry practices. Risks of Using Borrowed Money to Finance the Purchase of a Security Using borrowed money to finance the purchase of securities involves greater risk than using cash resources only. If the client borrows money to purchase securities, the responsibility to repay the loan and pay interest as required by its terms remains the same even if the value of the securities purchased declines. 15

16 Montréal Tel.: Québec Tel.: Ottawa/Gatineau Tel.: gestionprivee@desjardins.com desjardinsprivatemanagement.com LOGO FSC À VENIR FKG43119 (1407)