Declaration Conflict of interest

Under the new securities regulations released on June 30, 2021, we are providing you below with additional information about existing and reasonably foreseeable important conflicts of interest that may affect your interests as a client, including how we address them in your best interests. These disclosures and the obligations arising from them are part of the regulatory requirements to which we are subject.

Generally, a conflict of interest may arise when:

• AURAY Capital Canada or a representative has separate business or personal interests that differ from the client’s interests;
• AURAY Capital Canada or a representative may be required to place their own interests ahead of those of the client;
• AURAY Capital Canada or a representative’s monetary or non-monetary advantages or disadvantages could compromise a client’s reasonable trust.

Generally, a conflict of interest is important if it could reasonably be expected to influence a client’s decisions or those of AURAY CAPITAL CANADA or its representatives in the circumstances.

If other important conflicts of interest are identified after the AURAY Capital Canada account is opened, we will notify you in a timely manner.

Generally, AURAY CAPITAL CANADA identifies and addresses important conflicts of interest through policies and procedures, including AURAY CAPITAL CANADA’s Code of Ethics, which clearly states that representatives must avoid any situation in which their personal interests conflict or appear to conflict with their responsibilities. AURAY CAPITAL CANADA’s policies and procedures also contain a general definition of “conflict of interest”, a defined escalation procedure for dealing with conflicts of interest, a clear definition of responsibilities between AURAY CAPITAL CANADA and its representatives, appropriate resources and authority for the Chief Compliance Officer and other internal control functions, regular internal reporting and periodic evaluations of the conflict management structure. In addition, AURAY CAPITAL CANADA has a system in place to confirm that clients have been informed of important conflicts of interest.

Information on how we manage important conflicts of interest

1. Services of related entities and external professional activities

People registered with AURAY CAPITAL CANADA may:

• be employed by another related company, and provide services to that company’s clients; and/or
• serve as a director of another entity or engage in outside business activities that would give these representatives access to privileged information.

AURAY CAPITAL CANADA manages these conflicts of interest by:

• complying with legal and regulatory requirements that impose restrictions on transactions between related companies or individuals employed with related companies;
• adopting internal policies and procedures that complement regulatory requirements, including privacy and confidentiality policies; and
• prohibiting individuals registered with AURAY CAPITAL CANADA from being employed by another person, participating in the activities of another person, or accepting compensation from another person outside of their relationship with AURAY CAPITAL CANADAC, unless they obtain prior approval from AURAY CAPITAL CANADA.

2. Gifts and entertainment

AURAY CAPITAL CANADA’s representatives may be offered or receive a gift or entertainment that could compromise or appear to compromise their independence. For example, a AURAY CAPITAL CANADA’ representative may offer or receive gifts to or from clients that may influence the services provided by the representatives.

AURAY CAPITAL CANADA manages these conflicts of interest by:

• adopting internal policies and procedures that complement regulatory requirements, including policies regarding gifts and entertainment to, among other things, track gifts and entertainment received by representatives; and
• prohibiting individuals registered with AURAY CAPITAL CANADA from accepting compensation from any other person, outside of their relationship with AURAY CAPITAL CANADA, unless they obtain prior approval from AURAY CAPITAL CANADA.

3. Referal arrangements

When a client and his immigration consultant appoint AURAY Capital Canada as a financial intermediary under the Quebec Immigrant Investor Program, this is considered a client referral arrangement under Article 13.10 of NI 31-103. The nature of a referral arrangement could compromise the independence of AURAY Capital Canada’s representatives. For example, a representative could favor the treatment of certain immigration consultants, which could have an influence on the fees and services of AURAY Capital Canada’s clients.

AURAY CAPITAL CANADA manages this conflict of interest by:

• by committing to achieve, in the best interest of the client, the immigration objectives under the Quebec Immigrant Investor Program;
• by complying with the provisions of Article 13.10 of NI 31-103. and by providing its clients with complete information on this referral arrangements; And
• by disclosing to clients the method of calculating the fee relating to the referral arrangement at its fair value and, to the extent possible, the amount of such fee;

This information is recorded in the Client disclosure and agreements and other contractual agreements between AURAY Capital Canada and its clients.