Gravitas Securities Inc. (‘GSI’) believes that a solid client relationship begins with a disclosure of who and what GSI is and what we can provide our clients to ensure that they meet or exceed their financial objectives. This ‘Client Relationship Disclosures’ (‘CRD’) ensures that GSI’s clients understand the products and services that they can receive from GSI, the kinds of accounts they have with GSI, the manner in which the client accounts are operated, a description of GSI’s regulatory requirements issued under Canadian Securities Legislation and regulators for ‘Know-Your-Client’ (‘KYC’) requirements, GSI’s responsibilities to our clients and our clients responsibilities to GSI.
Who are we?
GSI is a brokerage ﬁrm and a member of the Investment Industry Regulatory Organization of Canada (IIROC) and of the Canadian Investor Protection Fund (CIPF). The company provides a comprehensive range of specialized services to private individuals, businesses and institutional investors. GSI will only act as a brokerage firm in the jurisdictions that GSI is licensed.
GSI provides the following services:
GSI is an Introducing Broker. Under this arrangement, GSI has partnered with the National Bank Independent Network (‘NBIN’), a wholly owned subsidiary of the National Bank of Canada, Canada's leading supplier of brokerage services which serves many independent firms to provide administration, settlement, and safekeeping services for GSI’s clients' assets.
GSI does have several affiliated companies: Please refer to our Statement of Policies section noted below for a complete and up to date list as of the date of this CRD.
GSI will provide a copy of our CRD at the time a client opens an account with GSI. GSI will update our CRD whenever there is a material change to the CRD and update our clients in a timely manner. The most current version of our CRD will be posted on GSI’s website (www.Gravitasssecurities.com).
As an investment dealer, GSI offers a complete range of ﬁnancial services and products designed to meet our client’s needs. Below is a summary of the services and products offered by GSI.
Services offered by GSI
GSI offers advisory (Commission and Fee based accounts) and managed accounts with different compensation structures.
Commission-based advisory account
If you open a commission-based advisory account, you will need to speak to your Investment Advisor (‘IA’) prior to making any transaction on your account (whether buying or selling). You are responsible for making the investment decisions concerning your account, but may base your choices on the advice given by your IA. Your IA is responsible for the advice given and to make suitable investment recommendations and provide unbiased investment advice. You will need to stay informed and to participate actively in making investment decisions since you will ultimately be responsible for all decisions made. This type of account allows you to work closely with your IA to select individual investments. Commission fees will normally be charged for each transaction.
Fee-based advisory accounts
If you open a fee-based advisory account, you will need to speak to your IA prior to making any transaction on your account (whether buying or selling). You are responsible for making the investment decisions concerning your account, but may base your choices on the advice given by your IA. Your IA is responsible for the advice given and to make suitable investment recommendations and provide unbiased investment advice. You will need to stay informed and participate actively in making investment decisions since you will ultimately be responsible for all decisions made. This type of account allows you to work closely with your IA to select individual investments. Buying or selling commissions normally paid to your IA are replaced by fees based on the value of your assets at the end of each month. However, depending on the type of agreement, operation fees may be charged as described in the fee-based advisory account agreement that you will be asked to sign.
If you open a managed account, investment decisions will be made on an ongoing basis by your Portfolio Manager (‘PM’). Your PM will therefore make no recommendations and you will have no decisions to make since your account will be managed according to a pre-established investment policy statement (‘IPS’) based on Know your Client (‘KYC’) form. Account fees will be based on a pre-established agreement with your PM.
Account types may include the following:
Other services offered by GSI
RRSP loan – this service allows clients to borrow the funds they need to contribute to an RRSP or use their unused contribution room;
Automatic revenue transfer – this allows clients to transfer investment dividends and interest from the revenue account to a bank account at any ﬁnancial institution.
Our Investment Products
With the help of your IA, you need to make sure that you fully understand how the investment product works and identify all costs associated with it. Your Investment Advisor or Portfolio Manager will make sure that the product matches your investment objectives, risk tolerance and time horizon. As the potential performance of an investment increases, generally the risk of the investment increases. Investments with high returns and low risk simply do not exist. To obtain the best performance, you must find you level of your acceptable risk.
Low-risk cash products
Generally, these offer the option to cash an investment product quickly and at a low cost.
Fixed income securities
When you subscribe to bonds or other types of ﬁxed income securities, you are lending money to the Government or issuing organization for a certain amount of time. In return, the issuer promises to pay interest at a ﬁxed rate, at set times and to repay the face value of the security when it matures. Fixed income securities may be purchased or sold at a price higher or lower than their face value, which varies with the interest rates. Value is also a function of the issuer’s credit rating. The risk associated with these types of product ranges from low to high. Below is in a non-exhaustive sampling of securities considered to be of the ﬁxed income type:
‘Know-Your-Client’ Information and Documentation
KYC rules include personal information about our clients as required by the regulators which must be updated by our clients when material changes occur. This information contains other critical information needed to ensure that the appropriate investments are recommended:
KYC information is collected by your IA or PM and noted on your ‘New’ Client Account Application (‘NCAF’). A copy of the completed NCAF and other KYC forms will be provided to you when your account is opened. Depending on the nature of the kind of account you have with GSI, you may receive additional documents that are relevant to your particular account type(s).
It is very important that our clients keep our IA’s and PM’s up to date at all times on their KYC information to ensure that their IA’s or PM’s can make the appropriate recommendations or investment decisions.
Suitability of Client Investments – The importance of KYC information
Before GSI makes any kind of investment recommendation or decision, GSI reviews our KYC information provided by our clients. This is a key reason for our clients to ensure that their KYC information is kept up to date at all times. For example, a client may have had a change in financial circumstances wherein a specific kind of an investment may or may not be suitable for the client. E.g. change in job, change in income, marital status, insider status etc.
A client’s Investment knowledge and experience are critical factors in determining suitability of an investment for a client. Investment knowledge and experience do change over time.
A client’s Net Worth is calculated with the client’s and the client’s spouse’s (if applicable) financial assets and liabilities combined. Annual Income is normally separated between the client’s and the client’s spouse, and both are noted separately on the KYC form.
A client’s Risk Tolerance is linked to the client’s willingness and ability to accept risk and absorb investment losses within the client’s account. Risk tolerance is noted as within or parts of the following categories:
A Client’s Investment Objectives are based on the risk that the client is willing to tolerate. Investment Objectives are allocated based on the following categories:
A client’s Time Horizon is the length of time the client has to invest their monies until such time as the client needs to sell their investment. This is an important concept when trying to decide what kinds of investments the client should have in their portfolio. A client who does not need their money for decades can own a riskier portfolio compared to someone who needs their money next week. Time horizons can range from seconds, in the case of a day trader, all the way up to decades for a buy-and-hold investor. There is no ‘right’ time frame; this is dependent on the client’s individual objectives. GSI’s categories are as follows:
Investment Suitability Assessment Process
Here is a brief summary of the process used by GSI to assess the suitability of your investments with regard to the information you have provided.
It is your responsibility to notify GSI without delay about any errors in the information contained in these documents.
Should you ask your IA to conduct a transaction which we deem to be unsuitable for you with regard to your information and investor proﬁle, we will advise you not to carry out this transaction.
Your IA will explain the reasons why this transaction is unsuitable for you. If, in spite of this explanation, you still want to carry out this transaction, your IA will ask you for a letter stating that you have been advised against it and have been made aware of the associated risks. The IA and GSI reserve the right to refuse to carry out the transaction.
Frequency of Investment Suitability Assessment
In order to make sure that your investments remain suitable as time passes, your IA will assess the investments in your account at least once every year. In addition, GSI will assess the suitability of the investments in your account with regard to the criteria described above whenever:
Please note that an investment suitability reassessment will not necessarily be conducted in the event of signiﬁcant market ﬂuctuations. Feel free to contact your IA if necessary.
Should your IA ﬁnd a discrepancy while assessing the suitability of your investments, he or she will contact you to discuss it. Such conversations may be documented as required by applicable regulations or in compliance with best business practices
Leverage/Margin Risk Disclosure
The use of leverage may not be suitable for all investors. Using borrowed money (whether through a margin account or some kind of leveraged investment product) to finance the purchase of securities involves increased risk over using cash to purchase a security. If a client borrows money to purchase the security, the client is responsible for the repayment of the loan and any interest that may be owed by the terms granted on the loan, regardless of whether the security declines in value. In the case of a margin account, the client may also be responsible for covering margin calls as required under the margin agreement, regardless of the price of the security. This use of leverage can result in investment losses which could exceed the amount of the money invested in the security.
Referral arrangements may exist from time to time with GSI and other affiliates and other regulated and non-regulated entities. A referral arrangement is where a prospective client is referred to or from GSI by a party and that party or GSI may receive a referral fee. The purpose of referrals is to introduce our clients or potential clients to experts who are best suited to help them achieve their financial objectives.
If a referral arrangement is in place, a written disclosure will be provided to the client to acknowledge wherein the specific referring party will be disclosed along with the specific fee being received.
GSI will send to our clients a number of reports to help you monitor the progress and performance of your investments:
It is the client’s responsibility to closely examine each conﬁrmation and to inform us of any error or omission and of any transaction unauthorized by you within 7 days following receipt of the conﬁrmation. It is our understanding that if you do not contact us within this time, you conﬁrm and approve each transaction listed in the conﬁrmation as well as the completeness and accuracy of other details connected to each transaction.
In addition, your account statement will indicate the purchase price, when available, or the market value of the security at the moment of transfer into your account.
It is your responsibility to closely examine each account statement and to inform us of any error or omission and of any transaction unauthorized by you within 30 days following receipt of the account statement. It is our understanding that if you do not contact us within this time, you conﬁrm and approve each transaction listed in the account statement as well as the completeness and accuracy of all other information in the account statement.
A client can review how your investments are doing by comparing the rate of return on the securities you hold to a performance benchmark. Your rate of return is affected by, among other things, changes in the value of your securities, dividends and the interest you earn, as well as when you make deposits and withdrawals.
There are many different benchmarks. When choosing a benchmark, pick one that reﬂects your investments. For example, the S&P/TSX Composite Index follows the share prices of the largest companies listed on the Toronto Stock Exchange. This index would be a good benchmark for assessing performance of a Canadian equity fund that invests only in large Canadian companies. It would be a poor benchmark if your investments are diversiﬁed in other products, sectors or geographic areas.
Please speak to your IA or your Portfolio Manager if you have questions about the performance of your portfolio or what benchmark(s) might be appropriate for you.
GSI provides you with the return on your investments an on annual basis. Your annual Investment Performance Report provides you with the annual performance of your accounts since inception with GSI using Time Weighted Rate of Return (TWRR) and Money Weighted Rate of Return (MWRR). The definitions of these performance calculations are:
Please note that you may earn more or less than others may have made on the same investments or that you may read in market commentary due to differences in when you buy and sell securities
Fee and Commission Report: As noted under the topic fees above, on an annual basis we will issue a report to you detailing all fees and commissions paid by you to your Advisor and GSI. These fees and commission include but are not limited to: managed account fees, fees paid on fee-based accounts, commission paid on buys and sells of equities, commissions embedded in fixed income products, front end and back end commissions on mutual funds, trailer fees paid on mutual funds and exempt product, etc.
After opening your account, GSI will supply several documents containing the information you need to play an active role in managing your accounts. These documents are as follows:
When you receive any account reporting from GSI, regardless of the type, please review in a timely manner to ensure that the information is correct. If you have noted any questions or concerns, please contact your IA or PM to review.
Conflicts of Interest
GSI provides retail investment advisory, portfolio management and investment banking services. As a member of IIROC, GSI must ensure effective policies and internal procedures are in place to effectively manage situations which could give cause to a conflict of interest.
A conﬂict of interest arises when the interests of different persons, particularly client interests and those of GSI or one of its employees (representatives, administrators, managers, associates, staff, agents) are incompatible or divergent. A conﬂict of interest may be existing, potential or apparent. More speciﬁcally, an employee, or GSI, is in a conﬂict of interest when he, she or it is in a situation of any nature which causes (existing conﬂict of interest), may cause (potential conﬂict of interest) or could be perceived to cause (apparent conﬂict of interest) this individual or it to act in his, her or its own interests or that of a related person against the client’s interests.
The general types of conflicts of interest which can occasionally arise are:
Role of an Investment Dealer
As an investment dealer, we are a financial intermediary. As is the common practice in the brokerage industry, sometimes we may be the party on the other side of the transaction (referred to as a “principal” trade) where we own the security we sell to you. On other occasions, we simply facilitate a transaction between you as our client and a third party on the other side of the transaction through an “agency” trade where we have no ownership interest in the security traded. In still other cases, we advise an issuer of securities on how to best raise funds by selling securities, while contemporaneously recommending that our clients buy those same securities.
GSI has policies and internal procedures in place to effectively address conﬂicts of interest. The organizational structure of GSI is designed to effectively control conﬂicts of interest.
Management of Conflicts of Interest
With the introduction of Client Focused Reforms effective June 30, 2021, when managing conflicts of interest, all conflicts must be addressed in the best interest of the client. In general, we take reasonable steps to identify existing and reasonably foreseeable material conflicts of interest between a client and the firm, or any individual acting on the firm’s behalf; we address all material conflicts of interest in the best interest of the client. We deal with and manage relevant conflicts as follows:
Conflicts can arise when IAs are involved in outside activities such as board members or pursuing outside business interests. GSI requires that all IAs and employees to promptly report and obtain approval prior to engaging in any outside activities. GSI will review the request for any potential conflicts of interest. In the event of a potential conflict of interest the approval may be subject to certain conditions or the outside activity may not be permitted if it cannot be appropriately managed and/or controlled.
Gifts and Entertainment
GSI has adopted an internal policy that is designed to ensure that IAs neither give or receive gifts or entertainment that are not within reasonable business practices. Nominal gifts cannot be given or accepted if, to a reasonable person, it could appear that the gift would influence a business decision.
Personal Dealings with Clients
Conflicts of interest can arise when an IA has personal financial dealings with clients, including, but not limited to, lending or borrowing from a client, accepting remunerations for services outside of GSI, and acting in the capacity of an Executor or Trustee. GSI has internal policies prohibiting IAs from engaging in, directly or indirectly, personal financial dealings with clients.
Related and Connected Issuers
GSI is required to disclose to client when a purchase of, sale of, or advice with respect to a related or connected issuer. This disclosure is provided when the recommendation is made and on the trade confirmation. In the case of a managed account, written consent from the client will be obtained for investments in connected or related issuers. GSI Investment Advisors receive the same compensation regardless of the issuer of the security. A detailed list of GSI’s related and connected issuers can be found in the Statement of Policies – Related Issuers and Connected Issuers included in the Relationship Disclosure Document.
Investment Advisor Compensation
GSI Investment Advisors are compensated based on one or a combination of the following:
GSI’s compensation plans do not provide incentives to IAs to purchase or sell specific products or services including any particular type of account. For commission based accounts, our IAs are required to disclose to you prior to executing the trade any commissions or fees associated with the trade. Any shift to fee-based and managed accounts are reviewed to make sure they are in the best interest of the clients and on an ongoing basis. Any fees to be charged in these accounts on a per trade basis are included at the time of account opening. In these accounts, any products for which the IA would be compensated in addition to the fee-based or managed fee charged are not included in the monthly or quarterly fee charged. All purchases of new issues for clients whether in a commission, fee-based or managed account, are based on the best interest of the client and suitability assessment of the client. GSI Investment Advisors are not compensated for sales targets nor are they permitted to accept any compensation, payment or sales incentive directly or indirectly, from a person or company that is not GSI.
GSI may enter into referral arrangements with other entities wherein GSI refers a client to such entity and receive a benefit or such entity refers a client to GSI and receives a benefit from GSI. The purpose of these referrals is to introduce clients or potential clients to persons/entities that are best suited to help the client with their financial needs. The detail of the referral arrangement including the benefits received and the other entity involved are disclosed to the client in writing at the time of the referral.
Commission based accounts are charged fees on a transaction basis while fee-based accounts are charged a fixed fee as a percentage of the assets in the client’s accounts. The conflict of interest in offering these two types of accounts are address by the monitoring for suitability and the client’s investment needs and objectives.
This is an overview of a complex subject. Despite that, we believe the simplest control is the most effective – our client’s continued satisfaction and patronage. If a client ever has any questions or concerns, whether they involve conflicts of interest or anything else, the clients should never hesitate to say so and ask their Investment Advisor for an explanation and more information.
Canada has comprehensive and extensive securities regulatory rules and regulations, many of which are directed at protecting client and investor interests, including dealing with conflicts of interest. We suggest that you refer to the websites and publications of the provincial securities commissions through the Canadian Securities Administrators (CSA) and Investment Industry Regulatory Organization of Canada (IIROC) for more information on how Canadian securities regulations address conflicts of interest in order to safeguard the investing public.
Account, Product and other Administrative Fees and Charges
Existing regulations require GSI to disclose any fees and charges related to the acquisition, disposal and holding of your investments which you may or will incur, according to the type of account or service. These fees and charges may vary depending on the products and services offered. They may change with time, in which case you will be advised of the change in writing at least 60 days before the change is effective:
Your IA will provide you with a pre-trade cost disclosure. If information about actual commissions is not available, a reasonable dollar estimate will be provided.
Commission-based advisory accounts
In the case of commission-based advisory accounts, GSI will charge you a commission for every transaction in your account (sale or purchase) based on the following:
NOTE: A minimum commission may be charged. The commission charged will appear on the trade conﬁrmation which will be sent to you.
In the case of mutual funds, fund managers normally charge administration and transaction fees that are deducted from the returns of the fund. Here is a description of the types of administration and transaction fees that may be associated with investment transactions in mutual funds:
The management expense ratio (MER) represents a percentage of the assets in the funds that is deducted yearly of your assets to pay Portfolio Managers and meet operating costs such as research, analysis and marketing. The MER is indicated in the fund’s prospectus and is usually between 1% and 3%. Part of these charges, usually between 0.25% and 1.25% of your assets, is distributed yearly by the funds company to GSI and your IA as long as you are a shareholder of these funds; this is sometimes referred to as ‘trailer fees’. This commission compensates the ongoing service and advice offered by your advisor. Trailer fees are included in the management costs and the rate varies with the costs option (described above) that you have chosen.
Some costs may not apply in your case. We recommend that you read the prospectus for further information on charges and costs applicable to the investments you are considering and discuss the matter with your advisor.
No commission is charged when you purchase a New Issue. It is the issuer that pays a commission to your IA. Please refer to the prospectus or offering document in which fees and commissions are fully disclosed.
Fee-based advisory accounts
In the case of fee-based advisory accounts, fees are charged (monthly, quarterly) to your account. These are calculated using the Daily Average balance of the value of the account. Rates may vary up to a maximum of 2.0% yearly with a minimum of $120 monthly.
For managed accounts, the fee schedule varies according to assets under management. Final fees can be negotiated with the client and noted in the managed account agreement. All managed accounts may be subject to a $15 transaction fee and administrative fees.
The following grid is a guideline for clients.
to 1 million: up to 2.25%
to 2.5 million: up to 1.75%
million and above: up to 1.50%
Service charges and fees can have a significant effect on investment returns and decisions. That’s why it’s our policy to minimize service charges and fees. In most cases, they represent only the costs we incur from other financial institutions. In all instances, they are competitive with industry standards.
The Trustee for your Registered Plan is Natcan Trust Company.
|Partial Plan Transfer*||$ 100|
|Full Plan Transfer||$ 175|
|Partial Plan Deregistration*||$ 75|
|Full Plan Deregistration (including estates)||$ 175|
|Swap Fee||$ 25|
|Unscheduled RRIF Withdrawal||$ 25|
|Shares held in Canadian Controlled
Private Corporation (CCPC) (one time)
Registered Plan Annual Administration Fee>
|Registered Savings Plan (RIF /LIF)||$ 120|
|Registered Savings Plan (RSP, LIRA, RESP, RDSP)||$ 100|
OTHER SERVICE CHARGES
|Partial Investment Account Transfer-out||$ 50|
|Full Account Investment Transfer-out||$ 150|
|Certificate Registration (per cert.)||$ 95|
|Rush Certificate Registration (per cert.)**||$ 250|
|Deposit/Withdrawal at Custodian (DWAC)||$ 75|
|Wire Transfer||$ 25|
|Certified Cheque||$ 20|
|Cheque - Not Sufficient Funds**||$ 35|
|Cheque - Not Negotiable & Returned (Other)||$ 35|
|Cheque Stop Payment||$ 30|
|Ineligible Mutual Fund (per month)||$ 10|
|Drip Enrollment (initial fee)||$ 10|
|Inactive Account Fee (per year)||$ 25|
*Gravitas Securities Inc. reserves the right to charge up to $750 on partial transfers or partial de-registrations where the only positions left behind are illiquid securities/mutual funds.
**Not including third party charges.
Any miscellaneous fees for services provided by other financial institutions will be charged through at cost.
ALL FEES ARE SUBJECT TO SALES TAX WHERE APPLICABLE. RATES AND FEES ARE EFFECTIVE JUNE 1, 2016. CHARGES FOR OTHER GRAVITAS SECURITIES INC. MISCELLANEOUS SERVICES ARE AVAILABLE UPON REQUEST
Gravitas Securities Inc. (GSI) takes all client complaints seriously. GSI has adopted the following procedures to enhance our open and honest review process for client complaints.
How does a client make a complaint?
A client has several options when making a complaint. Firstly, a client should contact their IA to resolve any concerns that they may have. Alternatively, the client may wish to contact the Branch Manager of their local GSI office: they may also contact the Compliance department in our Toronto Head Office. Complaints may be verbal or in writing.
What will GSI do once they have received a client complaint?
GSI will respond to all client complaints in writing. The letter to the client will include the contact information for the compliance department staff member who will be conducting the investigation and the client will also be advised as to the maximum time that the investigation may take. This will allow the client to follow the investigation and provide any information that they feel is relevant. Our compliance staff may also request additional information from the client to be able to conduct the investigation.
The client will receive a copy of Making a Complaint: A Guide for Investors (Part 1 of 2) and How Can I Get My Money Back? A Guide for Investors (part 2 of 2).These brochures will provide information on how to make a complaint to an IIROC Member firm and the other options that are available to the client.
How will GSI investigate a client complaint?
All client complaints are investigated by the compliance department. Information is collected with assistance from our Branch Managers, the staff member involved, the client, as well as from other sources deemed necessary.
How will the client be informed of the results of the investigation?
At the conclusion of the investigation, compliance will forward the client a letter outlining the following:
GSI Designated Complaints Officer
GSI has designated our Chief Compliance Officer as our Designated Complaints Officer, who is responsible for the oversight of the customer complaint handling process. If you have any questions or comments about our complaint handling process, please contact our Designated Complaints Officer at:
Gravitas Securities Inc.
RBC Centre, 155 Wellington St. W, Suite 2920, Toronto ON, M5V 3H1
Attention: Complaints Officer
Statement of Policies - Related Issuers and Connected Issuers
The securities laws of the Canadian Provinces require securities advisers, when they trade in, or advise with respect to, their own securities or securities of certain other issuers to which they, or certain other parties related to them, are related or connected, to do so only in accordance with particular disclosure and other rules. These rules require securities advisers, prior to trading with or advising their customers or clients, to inform them of the relevant relationships and connections with the issuer of the securities. Clients and customers should refer to the applicable provisions of the securities laws of the province in which they reside for the particulars of these rules and their rights or consult a lawyer.
Under certain circumstances we may deal with or for you in securities transactions where the issuer of the securities or the other party to the transaction is this firm or a party having an ownership or business relationship with us.
Since these transactions may create a conflict or the appearance of a conflict between our interests and yours, we are required by securities laws to disclose to you certain relevant matters relating to the transactions. This statement contains a general description of the required disclosure. ‘We’ or ‘us’ or ‘the firm’ shall mean GSI Inc. for the purpose of this disclosure.
Key Concepts to Remember when Reading this Statement
‘Related Issuer’ is a person or company related to us if:
‘Connected Issuer’ means an issuer or selling securityholder distributing securities:
‘Influential Securityholder’ – An influential securityholder generally means a person, company or professional group that directly or indirectly:
We must make certain disclosures where we advise you, or exercise discretion on your behalf with respect to securities issued by us, by a related party or, in the course of an initial distribution, by a connected party. In these situations, we must disclose either our relationship with the issuer of the securities, or that we are the issuer. We must also make disclosure to you where we know or should know that, as a result of our acting as your dealer or adviser, or of our exercising discretion on your behalf, securities will be purchased from or sold to us (as principal), an associated party or in the course of an initial distribution, from a related or connected party.
The following is a list of the time and manner in which these disclosures must be made:
In addition, where we exercise discretion under your authority in the purchase or sale of securities for your account, we may not exercise that discretion for the types of transactions described above unless we have obtained your prior specific and informed written consent.
We may, from time to time, be deemed to be related or connected to one or more issuers for the purpose of the disclosure and other rules of the securities laws referred to above. We may have acted, and are prepared to continue to act, as an adviser with respect to securities of such related or connected issuers and to provide the full range of services customarily provided by us in respect of securities of other issuers. We shall carry out such services in the ordinary course of our business in accordance with our usual practices and procedures and in accordance with all applicable disclosure and other regulatory requirements.
GSI has a relationship with the companies listed in this statement. GSI, its directors, officers, partners, sales staff or other employees may from time to time provide to you advice about a security issued or managed by those listed companies. If you wish further information concerning the relationship between the firm and those listed companies, please contact us. This ‘Statement of Policies’ is updated annually and or when a material change occurs.
GSI does not allow registrants that are directors, officers or partners of outside companies to give any financial advice on the outside companies of which the registrant is a director, officer or partner. GSI will notify all clients of the registrant in writing of the registrant’s conflict of interest.
Related and/or Connected Issuers
The following list of related and/or connected issuers to GSI is as of the date of this disclosure document. The following entities are related and/or connected issuers to GSI or who, by reason of its relationship with GSI, or one of its subsidiaries may be deemed to be related and/or connected to GSI. Each related and connected issuer are reviewed for conflicts of interest in the best interest of the client. Where the conflict of interest cannot be adequately managed, it is avoided.
Officer and Director Disclosure
Additionally, the directors or officers of GSI may act as directors or officers of other companies or organizations. GSI has policies and procedures that minimize the potential for conflicts of interest resulting from any such positions, including specific, up-front disclosure of such relationships when needed. GSI closely supervises the trading activity of any individual who is also a director of a public company for continuous compliance with the conflict-of-interest provisions to be in the best interest of the client. If the conflict cannot be managed adequately, it is avoided.
Required director and officer’s disclosure:
A Director of GSI is also a director of FGF Hold Co. (a private issuer)