Client Relationship Disclosure Information

General

Open Access Limited (OAL) was part of the mutual fund division of Hodgson Roberton Laing Limited, an investment management company established in 1928, serving pension funds, insurance companies and private investors. Open Access is registered as a trademark and is the property of Open Access Limited. The registered trademark is protected under the copyright laws of Canada.

OAL has prepared this relationship disclosure information document (RDI) in order to provide you with a description of our products and services, the nature of your account(s) and the manner in which it will operate, and our responsibilities to you. In this document, when we use the terms “we”, “us” or OAL are used, we mean Open Access Limited. When we refer to “you” or “your”, we are referring to you as the holder or joint holder of an account (an “Account”) with us and when applicable, anyone authorized to give instructions in respect of your Account. You will be provided with the RDI at account opening or before we begin providing services to you. If there is a significant change to the information provided in the RDI, we will provide you with an updated RDI in a timely manner.

Registration

Open Access Limited (OAL or the Firm) is a privately owned independent firm. It is registered in all 13 jurisdictions as a Portfolio Manager. It is also registered as a Mutual Fund Dealer in Ontario and Nunavut and as an Exempt Market Dealer in Ontario. As a Portfolio Manager, OAL may be instructed by its clients to exercise discretionary investment management authority over their accounts.

To provide Group Retirement services OAL is registered as a Mutual Fund Dealer. OAL’s mutual fund dealer activities are incidental to the provision of Group Retirement services and OAL was granted an exemption from membership in the Canadian Investment Regulatory Organization (CIRO). This exemption allows OAL to continue to provide efficient, cost-effective service of the highest quality to you. A requirement of the exemption is the following disclosure to plan participants:

• OAL is currently not a member and does not intend to become a member of CIRO. CIRO members (investment dealers and mutual fund dealers) belong to the Canadian Investor Protection Fund (CIPF). CIPF provides compensation, within prescribed limits, if a CIRO member becomes insolvent and client property (cash and securities) held by that firm is missing or unavailable. Consequently, our clients’ accounts are not covered by CIPF. This means that, in the unlikely event of our firm’s insolvency, CIPF would not provide compensation in respect of assets held with us. As with CIRO member firms, however, neither CIPF nor any other protection fund insures against investment losses due to market movements, issuer defaults or unsuitable investment choices.
• It is OAL’s policy to ensure all dealings are in compliance with the provisions of applicable securities pension, tax, and corporate legislation, regulations and policies and to the terms of its registrations with Canadian securities regulatory authorities.

Business activities

OAL is a retirement plan administrator and provides plan sponsors with a complete outsourcing solution for small and medium size companies on Group Retirement Savings Plans, Deferred Profit Sharing Plans, and Defined Contribution Pension Plans. Only the employees for the companies we serve can become OAL clients. Client accounts are usually funded through payroll deductions and there is no minimum investment for clients. We offer registered (RSP and TFSA) and non-registered plans.

Our Process: Knowing You, Our Client

Our process is to understand your circumstances as an investor through our Investor Profile (IP) and Member Application Form. We need to:

1. Establish your identity and reputation,
2. Establish whether you are an insider of a public company,
3. Collect information around your personal and financial circumstances,
4. Establish your investment needs and objectives,
5. Establish your investment knowledge,
6. Establish your risk profile,
7. Establish your investment time horizon,
8. Collect the information of a trusted contact person if you wish to name one,
9. Establish whether someone else is authorized to provide instructions on Your account, and
10. Establish whether someone else has a financial interest in Your account.

In order to establish your identity and reputation we collect your name, date of birth, address and contact information and verify your identification (government issued ID). The information we collect to establish your personal circumstances include your civil status or family situation, number of dependents, employment and occupation. Your financial circumstances are established by collecting your annual income, liquidity needs, financial assets, net worth and whether you are borrowing money to invest. When applicable, net worth will include your assets and your spouse’s.

All this information is collected through the IP and Member Application Form by one of our registered representatives. You are asked to provide us with your complete, accurate and current information as part of your account opening process. You have agreed to notify us immediately of any change to such information.

A document with the information you have provided to us will be given to you, including at the time of account opening and when a material change in your “know your client” information has come to our attention; you should review this document carefully and advise us promptly if any of your information is not accurate. Every year, we ask you to update this know your client information to assist us in determining whether your existing portfolio is still suitable for your individual circumstances.

When we open your account, we also collect your preference to receive correspondence including statements and obtain your authorization for electronic delivery of information. In addition, we will also disclose fees associated with the administration of your account or portfolio management and explain how these fees impact your investment returns over time. Your contact with an OAL representative can be through the phone, online or in person. OAL does not provide credit or margin on accounts.

Key Definitions

Investment Time Horizon – the period of time from the investment date, until the time that you may need to access some or all of your investments.

Risk Tolerance – your willingness to withstand a decline in the value of the investment.

Risk Capacity – your ability to endure potential financial losses.

Risk Profile – the lower of your Risk Tolerance and your Risk Capacity.

Investment Needs and Objectives – the result or outcome desired by you from the investment chosen, such as capital preservation, income generated by invested capital, capital growth or speculation.

Capital Preservation, is a conservative investment strategy focused on protecting principal and avoiding losses, while it offers security, returns are modest and can be eroded by inflation over time. It usually involves investments like money market funds and Treasury bills.

Income, is an investing strategy that seeks investments that pay above average distributions, focusing on generating short term income rather than long-term growth. It usually involves investment like bonds and stocks with high yield dividends.

Equity or Growth, is a more aggressive strategy that seeks investments with the potential for capital appreciation, traditionally it is referred as the equity or stock market.

Balanced, is a combination of the strategies above.

Speculation, is the most aggressive strategy involving high risk transactions with the highest potential gains, the strategy spans various markets but it is most used in the stock market and involves buying and selling stocks to profit from short-term price fluctuations rather than focusing on the long-term fundamental value of a company.

You may express your objectives in non-technical terms, such as saving for retirement to maintain a certain lifestyle, increasing wealth by a certain percentage in a specific number of years, investing for purchase of a home, or investing for the post-secondary education of your children.

Investment Knowledge – your understanding of financial markets, the relative risk and limitations of various types of investments, and how the level of risk taken affects potential returns. Our representative may also ask you about your previous experiences with finances and investments.

Annual Income – represents annual income from all relevant sources.

Net Worth – calculated as estimated financial assets plus fixed assets less estimated liabilities. When applicable, net worth will include assets of the account holder and his or her spouse.

Trusted Contact Person – If you provide us with the name and contact information for a trusted contact person, we may contact and share information about you and your accounts with your trusted contact person to protect your financial interests. We will contact your trusted contact person only when we are concerned about your mental capacity to make decisions involving financial matters or suspect you are being financially exploited, or to confirm your contact information if we are unable to reach you and we think that is unusual, or to locate your legal representatives.

If we suspect that you are being financially exploited or have concerns about your mental capacity to make decisions involving financial matters, we may place a temporary hold on the purchase or sale of a security or on the withdrawal or transfer of cash or securities from your account. We will notify you of such a temporary hold and will notify you again within 30 days of placing the temporary hold and within every subsequent 30 days until the temporary hold is revoked.

Determining a Suitable Investment for You

After completing the IP questionnaire, we review your responses and assign a score that would determine the portfolio suitable for you. When recommending a CAP Portfolio, we must put your interests first, and we will not recommend a portfolio that we believe is unsuitable for your circumstances, even if you request it. Our OAL representative will recommend one of the nine (9) Capital Accumulation Plan (CAP) portfolios managed by OAL. Each portfolio is composed by institutionally priced third-party mutual funds and is carefully monitored and rebalanced from time to time. The suitability determination conducted by OAL and its representatives will be limited to the CAP Portfolios, and will not consider the larger market and listed products or whether those products would be better, worse or equal in meeting your needs and objectives.

Your Role in Our Relationship

It is important that you actively participate in our relationship. In particular, we encourage you to:

• promptly advise us of any material change to information that may result in a change to the types of investments appropriate for you, such as, a change to your income, investment objectives, risk tolerance, time horizon or net worth;
• review account reporting, documentation and other information we provide to you regarding your investments; and
• raise any questions you have about your investments, anyone acting on our behalf or your relationship, with us.

Custodian

Since 2013, OAL has used Canadian Western Trust (“CWT”) as the custodian for your account assets, and those of our other clients. That is, while OAL has discretionary authority to trade the investments in your account, and therefore has access to such assets, CWT holds these assets as the trustee and custodian. CWT is a Canadian federally regulated trust company and is a member of the Canada Deposit Insurance Corporation (“CDIC”). Cash deposits held with CWT are eligible for insurance coverage by CDIC.

Assets are held in trust by CWT on an omnibus basis under the terms of each applicable trust for the different types of plans we offer. In accordance with certain agreements which OAL has with CWT, OAL is the record keeper for these trust accounts. As the record keeper, OAL maintains all records of the underlying ownership of cash and securities by each individual plan member and the related transactions which produce those balances.

OAL provides CWT with a monthly reconciliation of cash and securities shown on OAL’s record keeping system to the cash and securities in each trust account at CWT. CWT will periodically audit these reconciliations, on either a scheduled or an unscheduled basis.

It should be noted that the OAL business model involves the purchase of institutional class units of the mutual funds acquired for your accounts and those of our other clients.

Conflicts of Interest

OAL must take reasonable steps to identify any foreseeable conflicts of interest that OAL in its reasonable opinion would expect to arise, between itself including, everyone acting on its behalf, and a client. OAL must respond to existing or potential conflicts of interest identified, and if a reasonable investor would expect to be informed of a material conflict of interest, OAL will disclose, in a timely manner, the nature and extent of the conflict of interest to you and explain how the conflict is addressed in the best interest of the client (you).

OAL seeks to provide advice that puts clients’ interest first in respect of the products and services available to you. Employees at OAL will not receive incentives nor will they receive commissions based on revenues generated through individual transactions. Some fund companies may occasionally provide compensation to OAL such as subsidizing portions of advertising, continuing education, and promotional programs; this does not influence which CAP portfolio is recommended.

OAL has policies requiring the disclosure, review and approval of all outside activities of its registered representatives to ensure that there is no potential for conflicts of interests with the firm or our clients. Our representatives are prohibited from entering into personal financial dealings with clients including exercising control or authority over client accounts or lending or borrowing to/from clients. Exceptions for employees to exercise control or authority over client accounts are only available for members of their immediate family and must be approved by Compliance. Immediate family defined as a spouse or common law partner, parents, sisters/brothers, children, grandparents, parents-in-law, sisters/brothers-in-law, stepparents, stepchildren, step-grandparents, stepsisters/brothers, grandchildren and legal dependents of the employee.

OAL does not invest client portfolios in any company with whom it or its directors or officers have a direct or indirect relationship. OAL has no related or connected issuers that would create a potential for any conflict of interest. This reduces many of the related‑party conflicts typically associated with fund‑of‑funds structures, such as favouring affiliated products over third‑party managers. However, certain structural conflicts remain, including the layering of fees between the underlying funds and the Portfolio itself, and OAL’s discretion in selecting and allocating capital among eligible third‑party managers. To mitigate these conflicts, OAL only invests in underlying institutionally priced funds, we apply a documented due diligence and manager‑selection process and provide clear disclosure of all Portfolio‑level and underlying fund‑level fees and expenses to investors.

OAL receives an ongoing investment management fee for providing portfolio management and related services to the CAP Portfolios. This fee is calculated as a percentage of the net asset value and is accrued and paid from the assets of the portfolios, which reduces the returns otherwise available to investors. Because our compensation increases as the portfolios’ assets increase, a conflict of interest arises in that we have an incentive to encourage net asset growth (including through additional subscriptions and reduced redemptions). We seek to manage this conflict by applying its investment mandate and risk management processes consistently, regardless of fee considerations, and by clearly disclosing all management fees and other expenses to investors.

New OAL clients are all employees of the companies for which OAL provides services, OAL does not enter into any referral arrangements for new client accounts.

Benchmarks

We believe that you should be able to assess our performance in the context of the broader market. A benchmark is a point of reference that allows you, the investor, to understand OAL’s ability to add value to your portfolio relative to the performance and risks of the broader market. When we construct and prescribe a benchmark for our clients we do so with the following objectives:

Appropriateness: The benchmark assigned to you must be appropriate to your circumstances and how your portfolio is being managed. The relative risks and returns of the benchmark should be similar to those of your portfolio.

Replicable/Investable: We believe that for a benchmark to have meaning you should be able to invest in it and replicate it easily either through a single product or through a portfolio of the same underlying constituent holdings.

Measurable: For a benchmark to provide valuable information to you, it must be capable of providing ongoing, updated information with regards to its value. We always try to use benchmarks that have an ability to be measured frequently.

Mutual funds have fees that reduce their performance; indices do not. You cannot invest directly in a benchmark index. OAL CAP portfolios may underperform the benchmark after factoring in underlying fund and OAL fees, fund expenses, and/or the size and timing of your purchases and redemptions.

The six components that make up each CAP portfolio’s benchmark are as follows:

• S&P/TSX Composite Index, representing the risk and return profile of Canadian equities
• S&P 500 Index ($C), representing the risk and return profile of U.S. equities in Canadian dollars
• MSCI EAFE Net ($C) measuring the risk and return profile of international developed equity markets outside North America in Canadian dollars
• FTSE TMX Canada Universe Bond Index, representing a broad universe of diversified Canadian investment-grade bonds
• FTSE TMX Canada Short Term Bond Index, representing a broad universe of diversified Canadian investment-grade bonds with maturities ranging from 1 to 5 years
• FTSE TMX Canada 91 Day T-Bill Index, representing cash/a T-bill with 91-day maturity in the portfolio

Investment Risks

There are general risks associated with investing in a discretionary managed portfolio. It is important for you to have a general understanding of what these types of risks are so that you can better engage with us to help us better identify your risk tolerances and objectives. Having a proper discourse related to your investment objectives and discussing how the various risks may create uncertainty in the outcome of your objectives is fundamental to the concept of suitability and prescribing a portfolio that meets your needs.

Your portfolio will be comprised of several different asset classes and securities, having exposure to various regions around the world. As such, having a basic understanding of these risks will aid you to better understand what to expect for your portfolio. Your portfolio will be exposed to various risks. These risks will cause your portfolio to fluctuate in value. The degree of fluctuation will be dependent on your level of risk tolerance. Your portfolio is not a guaranteed investment. There are instances when losses can and will occur and investments may not be profitable. It is important that you take some time to understand your own risk tolerance and what you are comfortable with. The following points lay out some of the risks related to the type of portfolio that may be created for you.

Interest Rate Risk

Interest rate risk describes the sensitivity of the value of an interest-bearing security to the general interest rate environment. Typically, when interest rates decline, the price of an interest-bearing security (like a bond) rises. When interest rates rise, interest bearing securities tend to drop in price. Depending on the maturity, amount of interest earned (coupon) and the change in prevailing interest rates, prices and values can have large changes.

Equity Risk

Equity Risk refers to of investing in securities known as shares or stocks. Typically, stocks trade on public markets where investors can buy and sell with a high level of frequency. The ongoing buying and selling of stocks/shares can cause major changes in the price of these securities and can result in both great gain and in certain instances complete loss. The prices of shares are dependent on company specific issues and general market, economic and financial circumstances. Equity (shares, stocks) price movements are difficult to predict.

Liquidity Risk

Liquidity risk refers to the risk that an investment you hold cannot be traded quickly enough in the market without greatly impacting the price of the holding. In the case of purchasing a security, that is of an illiquid nature, the price may increase dramatically from where it was priced prior to your bid. In the case of selling a security, the price of that same security may drop dramatically before the trade is complete.

Foreign Exchange Risk

Foreign exchange exists when a security is owned that is denominated in a currency other than Canadian dollar. In addition, foreign currency risk may also be present in owning a domestic stock that has most of its revenues denominated in foreign currency. As such, foreign currency risk relates to the fluctuations of the investment that are specific to currency effect on the value of those securities you own in your portfolio. This risk can add or subtract to the positive (or, negative) returns of the investment you already hold. For example, if you owned a stock that trades in the United States, is denominated in US dollars, and the US dollar drops in value you may experience a negative return on your total investment despite having a positive return on the price of the stock – once you convert the value of your investment into Canadian dollars, Foreign Exchange risk may also be referred to as FX Risk or Currency Risk.

Credit Risk

Credit Risk relates to the risk of default on a security, typically an interest-bearing security like a bond. In such an instance, the issuer of the security can no longer make payments for the promised interest or coupon. Credit risk is affected by company specific events and operations and can also be affected by general economic circumstances. Credit risk can change over time and in certain instances can be tracked by Credit Rating Agencies. The value of your investments will change with the change of credit rating in an underlying security issuer or with their default.

Geopolitical, Geographical Risk

When investing in securities that have exposure to different regions around the world we are exposed to the political and economic uncertainties of the region we are investing in. Governments can change aspects related to foreign investment, taxation, currency policy which may have adverse effects on the value of your portfolio. In addition, owning securities that have exposure to different regions of the globe expose your investments to regional economic and financial circumstances that can be vastly different than your domestic markets.

Commodity Risk

Commodity risk refers to the general fluctuations of prices and values related to commodities. Commodity price risk can be related to the supply and demand of a commodity, political decisions and general world economic circumstances.

Derivative Risk

Derivatives are securities that derive their value from an underlying security or commodity. Derivatives can be used to grant the holder either the right to sell or buy a specific security or commodity. Derivatives are available on stocks, bonds, indices, commodities and currencies. Derivatives can be used for several purposes. Portfolio managers may use derivatives to hedge or insure the downside of a portfolio or security, gain exposure to a potential upside move in the underlying, reduce the volatility of a security or increase an income stream from a portfolio. As the underlying prices of securities fluctuate so do derivatives. Hedging using derivatives can also be imperfect, there is no assurance that a portfolio manager can use a derivate to protect or insure portfolios. There is also Counterparty Risk associated with the use of derivatives. Counterparty risk is the risk associated with other party to a derivative not being able to honour the terms of the specified derivative contract. Derivatives can face all the similar risk disclosed above, depending on the type of underlying the derivative represents.

Fairness Policy

OAL allocates investment opportunities in a manner that ensures all portfolios and the underlying investors are treated fairly. No portfolio is given preferential treatment in the execution of trades made for more than one portfolio. Trades for portfolios will always be filled before those of employees of OAL.

OAL allocates trading costs and commissions are on a pro-rata basis for trades that are bunched or blocked. The basis for the allocation will be the percentage of the total trade that is executed on behalf of each portfolio. Each portfolio will pay a percentage of the total transaction cost equal to the percentage of the securities allocated to the applicable portfolio. OAL charges the average price of the securities for trades that are blocked or bunched on behalf of multiple portfolios.

OAL allocates partially filled orders to buy or sell securities on behalf of multiple portfolios on a pro-rata basis. Each portfolio will receive the quantity of securities equal to the percentage of the total order that is filled for OAL portfolios.

Similarly, if OAL receives less than a full allocation of securities that are part of an initial public offering, the securities will be allocated among portfolios on a pro-rata basis. Each portfolio that was part of the original order will receive the quantity of securities equal to the percentage of the total order that is filled for OAL portfolios.

Automatic Rollover of Assets for Investment Changes

If a client changes his/her profile and move to another CAP Portfolio, all current holdings will automatically be converted to the new investment asset mix. There is no additional fee or commission charged.

Cash

You can only hold one of the CAP Portfolios in your Account, Cash holdings cannot be accommodated by OAL.

Investor Protection Fund

OAL has obtained an exemption from the requirement in Ontario securities law to participate in an approved compensation fund or contingency trust fund. These funds provide for certain compensation to eligible clients of a participating dealer who suffer a financial loss as a result of the dealer becoming insolvent and not being able to return assets which it was holding on behalf of clients.

As a condition of this exemption, OAL may not hold any client assets.

Compensation and Fees

OAL receives an investment management fee for each portfolio it manages. This is applied on a monthly basis and is based on the daily net asset value of the investments held by the plan during the period, this fee reduces the returns otherwise available to investors.

Operating Charges: OAL charges an administration fee to each client account at the beginning of the calendar year based on the market value of the account as at December 31.

Transaction Charges: An administrative fee would apply when a client account is withdrawn in full or in part, transferred or deregistered.

Any applicable redemption fees and fund manager fees are paid from the assets of the CAP Portfolios and the underlying funds, which reduces returns to investors. OAL will provide clients with a minimum of sixty (60) days’ notice of any change in fees. The details of the fees are clearly outlined in OAL’s Fee Schedule.

Content and Frequency of Account Reporting

Account statements

OAL provides a client with an account statement every three months. The statement contains position cost information, details of securities transactions during the period covered by the statement and the client’s account holdings at the end of the statement’s period.

We will send you an annual report on the performance of your account, including information about the annualized percentage return your account may have generated, and information about deposits and withdrawals you have made throughout the year. This report also summarizes all fees related to your account that we earned during the year. It clearly identifies fees we received from you and any fees we may have received from others related to investment products and services provided to you over the year.

OAL will only deliver monthly statements if you have requested to receive monthly statements.

Trade Confirmations

For plans that involve ongoing, pre‑authorized payroll deduction contributions invested according to your standing instructions, individual purchases under the plan will generally not generate separate trade confirmations; instead, information about these transactions will be provided through periodic account statements, in accordance with applicable securities legislation. Trade confirmations will normally be issued only for ad hoc or unscheduled transactions that are not executed under such pre‑authorized payroll instructions or where a separate confirmation is otherwise required by regulation. OAL will deliver the trade confirmations with the transaction details including date, quantity, price, name of the dealing representative, charges or commissions and all other required information related to the trade.

Borrowed money

If you are considering using borrowed money to purchase a security you must understand that you are responsible for that borrowed money even if the value of the security goes down or you are unable to sell the security. This is an additional risk to borrowing money to purchase securities.

OAL does not recommend that you borrow money to make your investments with us. If the funds you propose to invest with us are partially or fully obtained from borrowed funds, this will increase your investment risk. Using borrowed money to finance the purchase of securities involves greater risk than using available cash resources only. If you borrow money to purchase securities, your responsibility to repay the loan and interest as required by its terms remains the same even if the value of the securities purchased declines. Purchasing securities using borrowed money magnifies your gain or loss. If you choose to borrow money to finance the purchase of a security, you should also be aware of the terms of any loan secured by securities. For example, the lender may require that the amount outstanding on the loan not fall below an agreed percentage of the market value of the securities.

Complaint Process

If you have a complaint about the services provided by OAL, or an OAL product, please contact us at:

1-866-625-4777

inquiry@openaccessltd.com

Open Access Limited

Attn: Chief Compliance Officer

302 Bay Street, Suite 503-01

Toronto, ON, M5H 0B6

Tell us:

• what went wrong;
• when it happened; and
• what you expect, for example, money back, an apology, account correction.

We will acknowledge your complaint and do so in writing, as soon as possible, typically within five (5) business days of receiving your complaint.

We may ask you to provide clarification or more information to help resolve your complaint. Please help us resolve your complaint sooner by:

• Making your complaint as soon as possible;
• Replying promptly if we ask you for more information; and
• Keep copies of all relevant documents, such as letters, emails and notes of conversations with our representatives.

OAL will provide its decision in writing, usually within 90 days of receiving a complaint. It will include:

• a summary of the complaint;
• the results of our investigation; and
• OAL’s decision to make an offer to resolve the complaint or deny it, and an explanation of our decision.

If OAL’s decision is delayed and or we cannot provide you with a decision within 90 days, we will:

• inform you of the delay;
• explain why OAL’s decision is delayed, and
• give you a new date for OAL’s decision.

You may be eligible for the independent dispute resolution service offered by the Ombudsman for Banking Services and Investments (“OBSI”). If you are not satisfied with our decision You may be eligible for OBSI’s dispute resolution service. If you are a Québec resident, you may consider the free mediation service offered by the Autorité des marchés financiers.

A word about legal advice

You always have the right to go to a lawyer or seek other ways of resolving Your dispute at any time. A lawyer can advise you of your options. There are time limits for taking legal action. Delays could limit your options and legal rights later on.

Dispute resolution

OAL offers independent dispute resolution or mediation service through OBSI, at its own expense, to clients to resolve client complaints. This service is available to clients with an eligible complaint, at no cost to the client. The Firm may be required to make the independent service available when a complaint:

• relates to a trading activity of OAL or its Representatives, and
• is raised within six years of the date when the client knew or ought to have known of the activity (or omission) that caused or contributed to the complaint.

The client may escalate an eligible complaint to the independent service made available by OAL in two circumstances:

• The Firm failed to give the client notice of its decision within 90 days of receiving the complaint. The client is entitled to escalate the complaint to the independent service immediately or at any later date until the Firm has notified the client of its decision. Informing the client that OAL plans to take more than 90 days to make its decision does not change this deadline.
• The Firm has given the client notice of its decision about the complaint, and the client is not satisfied with the decision. The client then has 180 days in which escalate the complaint to the independent service.

In either instance, the client may escalate the complaint by directly contacting the independent dispute resolution or mediation service.

Filing a complaint with OBSI

Email: ombudsman@obsi.ca

Telephone: 1-888-451-4519 or 416-287-2877 in Toronto

OBSI will investigate

OBSI works confidentially and in an informal manner. It is not like going to court, and you do not need a lawyer. During its investigation, OBSI may interview you and representatives of OAL. OAL is required to cooperate in OBSI’s investigations.

Information OBSI needs to help You

OBSI can help you best if you promptly provide all relevant information, including:

• Your name and contact information;
• OAL’s name and contact information;
• the names and contact information of any of OAL’s representatives who have been involved in your complaint;
• details of your complaint and
• all relevant documents, including any correspondence and notes of discussions with OAL.

OBSI will provide its recommendations

Once OBSI has completed its investigation, it will provide its recommendations to you and OAL. OBSI’s recommendations are not binding on you or OAL.

OBSI can recommend compensation of up to $350,000. If your claim is higher, you will have to agree to that limit on any compensation you seek through OBSI. If You want to recover more than $350,000, You may want to consider another option, such as legal action, to resolve your complaint. You always retain the right to pursue other options, such as making a complaint to a securities regulator or taking legal action. For more information about OBSI, visit www.obsi.ca

Privacy Policy

OAL collects, uses and discloses your personal information only as permitted by applicable privacy laws and in accordance with our Privacy Policy. Our Privacy Policy explains in more detail what personal information we collect, how we use and safeguard it, the circumstances in which we may share it with affiliates or third parties, and your rights to access and correct your information. You can obtain a copy of our current Privacy Policy at https://openaccessltd.com/privacy-policy/ or by contacting us at 1-866-625-4777 or inquiry@openaccessltd.com.

If you have any questions concerning the content of this document, please contact one of the OAL Customer Service Representatives at 1-866-Open Access-GRSP (625-4777) or (416) 364-6667.