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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

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.

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.

Personal operations

AURAY CAPITAL CANADA’s representatives may have access to confidential client trading information. They could then use this information for their own personal trading, which could be detrimental to clients as they could place their trades ahead of their clients (i.e., trade ahead of the market).

AURAY CAPITAL CANADA manages this conflict of interest by:

  • complying with legal and regulatory requirements that impose restrictions on personal trading;
  • adopting internal policies or procedures that complement regulatory requirements for handling personal trading; including:
  • at the time of recruitment and on an annual basis, obtaining a statement of trading accounts (i.e. PRO accounts) from an appropriate AURAY CAPITAL CANADA representative; and
  • regularly monitoring and reviewing transactions in the PRO accounts.

Order routing and payment receipt for order processing

Our firm has established a carrying broker arrangement for order routing with certain exchanges, brokers/dealers or other market centers (collectively, “Market Centres”) or acts as a Market Centre on behalf of AURAY CAPITAL CANADA. This arrangement was notably made to ensure the perceived quality of execution offered by these Market Centres, as assessed using guidelines provided by Canadian securities regulators.

All client orders that are subject to these order routing arrangements are sent to market centers that are subject to best execution principles.

AURAY CAPITAL CANADA manages these conflicts of interest through best execution policies and procedures.