Conflicts of Interest Risk

Conflicts of Interests

How the conflicts affect clients

How we address the conflicts

Relationship between LWM and other companies.

LWM offers a wide range of securities products that could be perceived as an actual or potential conflict of interest.

LWM is an independent wealth management firm and does not have an affiliation with any other entities or companies whose securities products we purchase on behalf of clients.

We do not have any proprietary product that could be perceived as an actual or potential conflict of interest.

Portfolio Manager (PM) compensation

LWM offer fee-based only accounts to clients. Our management fee is based on Assets under Management (“AUM”), which is payable quarterly in arrears and is based on AUM at the end of each period.

PMs are not compensated based on the type of products or the number of transactions that takes place in a client account.

Compensation is strictly based on the management fee of asset under administration for any given client.

PMs are paid a base salary and as well a percentage of the net management fees collected from clients. PMs are prohibited from receiving direct monetary or non-monetary benefits from any transaction.

Referral Agreements

Paid referral agreements where a PM provides or receives compensation for referring a client to another party, are an inherent conflict of interest.

The payment of compensation may lead an advisor to make a referral, even when the referral is not in the client’s best interests.

LWM does not receive any form of trailers, commissions, or referral fees from third parties.

LWM has referral arrangements in place with various financial professional i.e. accountants, financial planners, insurance advisors; and may pay employees for referring new clients to the firm. Any fees paid for such referral are paid by LWM and not charged to clients.

Before accepting a referral from any referral partners or third party, LWM will disclose important information about the referral arrangement include the compensation to be paid to the party making the referral.

This information is disclosed in our Relationship Disclosure Information form (RDI).

In addition to the RDI, the UDP must approve all referral agreements and the Chief Compliance Officer will conduct due diligence on potential third-party referrers and referrals.

We will obtain the individual(s) consent before proceeding with the arrangement and they are not obliged to agree to being referred.

Portfolio Managers are not permitted to directly engage in paid referral agreements under any circumstances.

Outside Business Activities

PMs must conduct all securities-related business through LWM. Any other activities or services conducted outside of LWM are considered as outside business activities.

Outside activities can create conflicts of interest if the activities impact the PM’s ability to provide unbiased advice in the best interest of the client; if the PM earns compensation from the activity; if activity requires too much of the PM’s time; if it is likely to cause client confusion; or by the nature of the position and the degree of influence the advisor holds.

LWM has policies in place to ensure that all outside activities are reported, considered, pre-approved and monitor by the Chief Compliance Officer.

LWM considers the issues relating to existing or potential conflicts of interests when determining whether to permit an outside activity.

All outside activities are evaluated on a case-by-case basis considering all existing and potential conflicts. LWM will disclose all outside activities in the Relationship Disclosure document describing the activity or activities.

Conflicts that cannot be resolved in the client’s best interests will not be permitted i.e., the PM will no longer engage in the outside activity.

The organizations that LWM employees volunteer at are not current or prospective clients of LWM.

For more information on outside business activities, please see Schedule C of our investment management agreement.

Fair Allocation

LWM will not be incented to provide certain trade opportunities to one client over another.

Whenever LWM propose to make an investment, the investment opportunity will be allocated on an equitable basis, generally pro rata bases on available capital between client’s account.

If, for any reason, an investment opportunity cannot be allocated pro rata among all participating Client accounts, every effort will be made to address any trading inequities at the next opportunity so that every account, large or small, will, over time, receive equitable treatment in the allocation of investment opportunities.

Best Execution

LWM may hire a brokerage firm to execute trades on client accounts based on a pre-existing relationship rather than objective qualitative or quantitative considerations. Therefore, it is considered the best execution conflicts of interest.

When executing trades for LWM client accounts, LWM employees will consider the price, quality and reliability of the brokerage service, research and investment information and certain other services provided by the executing brokerage.

While one brokerage may provide LWM a better overall price (price plus commissions) than another, LWM may also consider the relative value of the research, investment information and administrative services to determine the brokerage with which to place the trade.

LWM will consider its brokerage service providers annually in accordance with its general third-party review process.

Giving & Receiving of Gifts and Business Entertainment

When PMs receive gifts, other than gifts of minimal value from referral partners or any third parties, it creates a potential conflict of interest as the receipt of these benefits may affect, or give the perception that it affects, the PM’s ability to give impartial investment recommendations.

Gift giving between the PM and the client may also give rise to concerns of conflicts of interest, favouritism, or suggest a future obligation of the client or PM.

LWM has policies and procedures in place that prohibits the giving or receiving of gifts or business entertainment of more than a minimal value between PMs and their clients, and gifts and promotional items and activities to PMs from referral partners.

PMs must report any gifts received, business promotional items or activities paid for by a referral partner.

The Chief Compliance Officer will review gifts to ensure that it does not create a real or perceived expectation that the client providing the gift, receives better service than other LWM clients.

Clients Concerns or Complaints

LWM may have a potential conflict of interest when responding to a complaint.

LWM is committed to handling all concerns or complaints in a fair and reasonable manner and in accordance with our complaint handing procedures.

We investigate and response to all complaints and, if clients are not satisfied, they can escalate the matter to the Ombudsman for Banking Services & Investments (OBSI).

LWM will use the OBSI as the independent dispute resolution or mediation services for all unresolved client complaints. This information is disclosed in our RDI.

Personal & Financial Dealing with Clients

It is a conflict of interest for PMs to engage in any personal financial dealings with clients as this creates the risk that PMs are putting their own interest ahead of their clients.

LWM PMs are prohibited from lending money to clients, borrowing money or receiving a guarantee in relation to borrowing money, or other assets, from clients.

Except for the discretionary authority granted by the Portfolio Management Agreement (PMA), PM are prohibited from having full control or authority over the financial affairs of a client such as acting a power of attorney, executor, or trustee, unless the client is related to the PM and the arrangement is disclosed and approved by LWM.

Improper Trading Practice

It is a conflict of interest to participate in trading activities that is not in the best interest of the client.

LWM PMs are prohibited from engaging in manipulative and deceptive trading activities that give a false or misleading appearance of trading activities or that artificially increase or decrease the ask price or sale price, negatively affecting clients.

LWM manages client’s investment portfolios through discretionary authority granted by the PMA agreement between the client and PM. LWM policy and in keeping with applicable legislation, is to deal fairly, honestly and in good faith with its clients.

PMs are also prohibited from using their knowledge of clients’ trade for their benefit or frontrunning.

Frontrunning is managed through a combination of policies and procedures, personal trading monitoring and training.

Using leverage in client’s accounts

Leverage is when a client borrows money to purchase securities.

Trading on margin is permitted on clients account to accommodate withdrawals and to take advantage of attractive security purchases and sales opportunity.

There is a potential conflict of interest when clients borrow money to invest as this increases the size of the PM book of business. Along with the increased risks that come with using leverage, there are also increased cost associated with borrowing money, which may mean that using leverage is not in the clients’ best interest.

Before opening a Margin Account, PMs must review section 2.4 of the Portfolio Management Agreement (PMA) regarding trading on margin and must explain the risks of using borrowed money to invest.

Client accounts are approved, opened, and held at NBIN, our custodian and not at LWM.

Clients are responsible for repayment of all loans and interest due as required by the terms of each loan arrangements.