The Accessibility for Ontarians with Disabilities Act (AODA) is a law that sets out a process for developing and enforcing accessibility standards. Recognizing the history of discrimination against persons with disabilities in Ontario, the purpose of this Act is to benefit all Ontarians by developing, implementing and enforcing accessibility standards to achieve accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises on or before January 1, 2025. To achieve accessibility, the AODA establishes five standards that recognize five areas of daily life:

1. Customer service standard
2. Information and communications standard
3. Transportation standard
4. Employment standard
5. Design of public spaces standard Together, these standards work towards making Ontario more accessible by ensuring people with disabilities can participate more actively in their communities Nour Private Wealth Inc. is committed to providing to our clients the highest standard of service possible.

Nour Private Wealth (NPW) commitment is;

• To provide our goods and services in a manner that respects the dignity and independence of persons with disabilities;
• To provide our goods or services to persons with disabilities and others in an integrated manner to enable a person with a disability to obtain, use or benefit from the goods or services;
• To allow our clients with disabilities, as much as is possible, an opportunity equal to that given to others to obtain, use and benefit from the goods or services;
• To ensure our policies deal with the use of assistive devices, service animals and support individuals* by persons with disabilities to obtain, use or benefit from NPW’s goods or services or the availability, if any, of other measures which enable them to do so.
• When communicating with a person with a disability, NPW shall do so in a manner that considers the person’s disability;

*In situations where confidential or personal information might be discussed, consent will be obtained from the client regarding the sharing of this information with the support individual.

The Canadian Securities Administrators have introduced securities laws that allow for alternative marketplaces to compete with the traditional stock exchanges, such as the Toronto Stock Exchange (TSX). Securities which trade on the TSX or the TSX Venture Exchange (TSX-V), currently the primary markets for Canada, may now also trade on an alternative marketplace. With the introduction of alternative marketplaces in Canada, NPW wishes to advise you of some of the conditions that could affect the execution of your orders.
The firm’s trading is not done directly on the exchanges; we are not a participating organization. NPW’s carrying broker, FCC, is a member of all the required exchanges and ATS’s. All trades are entered through the FCC trading infrastructure and the Dataphile order entry system. All orders entered through this system utilize a smart order router system and, therefore, cover all the required marketplaces.

NPW is committed to using all reasonable efforts to ensure that clients achieve “best execution” of their orders in respect to Canadian listed securities that are quoted or traded on Canadian marketplaces.

Marketplace Disclosure
An order executed on more than one marketplace will be disclosed on your trade confirmation as “Executed on Multiple Markets – Details on Request”. If you wish to know what quantities were executed on what marketplaces, please contact your Advisor, who can provide you with this information promptly and without charge.
If your trade was executed on a single exchange, that exchange will be noted on your trade confirmation with either an abbreviation (with details on the back of the confirmation) or noted in the trailer field.

Execution on Foreign Marketplaces
All Orders for Canadian and non-Canadian listed equities to be traded on marketplaces outside of Canada may be executed by third party broker dealers (“Third Parties”). Third Parties may execute such orders as either an agent or principal. The fees or commissions charged to us by Third Parties for such orders may be reported as a net price. NPW and/or FCC may earn a fee or premium on foreign exchange transactions resulting from or required by such orders. If you have any questions regarding this notification, please contact your account Advisor.

Foreign Currency Exchange
For transactions in currencies other than that of the currency of the account, a conversion of currency may be required and will be carried out by the firm. FCC and/or NPW maintain a foreign exchange market spread. In performing foreign currency transactions, we may act as an agent or principal. We attempt to make a profit on providing foreign exchange transactions. The rates depend on the size, currency and timing of the transaction. If you are initiating a transaction that will require an accompanying foreign exchange component, ask your advisor about the available rates. Unless otherwise specified or agreed to, the currency conversion will take place at our applicable bid and ask spread, based on the prevailing currency rates. NPW currently only permits U.S. dollar foreign currency holdings in registered plans (e.g. RRSP, RRIF). Thus, any transactions in such accounts involving any other foreign currency will be automatically converted by us into Canadian currency as described hereinabove.

Fair Allocation Procedures
When NPW is involved in small financings or has a small participation in a larger financing, it is impractical to solicit interest from all the firms’ advisors or from all our clients. NPW has a small retail account base and they show little interest in such products. Nevertheless, client priority must be respected. NPW will add a message to all statements annually outlining our clients’ obligation to express their interest in any such private placements to their advisor. This statement is now also part of the NPW new client application package and reads: “For any company attempting to raise funds via small private placement transaction, NPW has a policy that any client of the firm will be considered solely responsible for reflecting their interest to their advisor. All such interest reflected by any client will be dealt with on a best efforts basis only.” We are required to have policies and procedures that provide reasonable assurance that we will ensure fairness in the allocation of investment opportunities among our clients. Trade allocation must be determined on a basis that is fair, reasonable and equitable for all clients. All client orders which are received before the books are closed will participate in any new issue on a pro-rata allocation basis.

Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ life and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all the firm’s books and records, and allowing our customers to transact business. In accordance with IIROC Rule 17.16 in the event of an SBD, Nour Private Wealth (NPW) is required to provide all clients’ access to their assets within 48 hours following the event. Access to assets means the ability of our clients to buy, sell or redeem securities and have assets, including cash, delivered out based on the client’s instructions. If we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities. Our plan anticipates two kinds of SBDs, internal and external.

• External SBDs prevent the operation of the securities markets or several firms, such as a terrorist attack, or a wide-scale regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm.

• Internal SBDs affect only our firm’s ability to communicate and do business and may include anything from temporary interruptions due to power outages or connection failures, to more serious incidents where there is no access to our premises, such as a fire in our building and/or pandemic or any other such critical event.

The firm will provide customers with notice in the event of a planned or unexpected disruption to its services or facilities (e.g., a disruption to customer services phone lines, website, or physical access to the NPW location), advising clients of procedures to follow to trade or access funds in their accounts. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available. The notice will be placed on our website.

The firm will provide customers with notice in the event of a planned or unexpected disruption to its services or facilities (e.g., a disruption to customer services phone lines, website, or physical access to the NPW location), advising clients of procedures to follow to trade or access funds in their accounts. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available. The notice will be placed on our website www.npw.ca

Our customers Should contact the Fidelity Clearing Canada ULC our carrying broker in case of a significant business disruption at our firm and in the possibility that customers are unable to reach us. Trading desk 416-216-6358, Banking 416-216-2660, Settlements 416-216-2606 and Transfers 416-216-2620.

The NPW Complaint Process has been adopted with a commitment to engage in and promote honest and ethical conduct and to provide complete, fair, accurate, timely and understandable resolutions to client complaints. It is our belief that by demonstrating to our clients that their issues are dealt with seriously enhances everyone’s confidence in the industry. As a demonstration of this commitment, NPW has adopted this Complaint Process. There are two types of complaints, service complaints and complaints that may involve regulatory infractions. While the firm will investigate either type of complaint, what is carried out is the process that will be followed if a potential regulatory infraction is involved.

How do I make a Complaint?
There are several resources available to you if you wish to make a complaint. Your first option is to contact your Investment Advisor with the issue. If you feel that your issue requires attention at a more senior level, you may direct your concerns to either the business location’s Supervisor (Branch Manager) or the NPW Compliance Department directly. Complaints may be written or verbal.

How is the Complaint Investigated?
All complaints involving regulatory or legal issues are investigated by the Compliance Department in conjunction with the business location’s Supervisor and the staff member involved in the complaint. Upon receipt of a complaint, NPW will acknowledge the issue in writing with a letter to you within 5 days. The letter will summarize the complaint, introduce the individual responsible for the investigation with their contact information so that you may contact them throughout the investigation to determine the status of the file, a reference to the maximum amount of time the investigation may take, and will enclose a copy of the Investment Industry Regulatory Organization of Canada (“IIROC”) “An Investor’s Guide to Making a Complaint” brochure. Our investigation process includes a review of account documentation, including account opening forms and client statements. Our investigation process may also include a request to interview you to clarify or attain any additional information required to investigate a complaint.

Alleged misconduct includes, but is not limited to allegations of:
• A breach of confidentiality,
• Theft,
• Fraud,
• Misappropriation or misuse of funds or securities,
• Forgery,
• Unsuitable investments,
• Misrepresentation,
• Unauthorized trading,
• Or other inappropriate financial dealings with clients, and
• Engaging in securities related activity outside the dealer.

Upon completion of our investigation, you will receive a substantive response within 90 day that will contain the following:
A summary of your complaint;
The results of our investigation;
Our final decision on the complaint, including an explanation;

and A statement describing the options available to you if you are not satisfied with our response, including:
• arbitration;
• if a request is made within 180 days from the date of our final response, the ombudsperson service (i.e. the Ombudsman for Banking Services and Investments);
• submitting a regulatory complaint to IIROC for an assessment of whether disciplinary action is warranted; and
• Litigation/civil action.

Depending on the nature of the complaint and/or the outcome of an internal investigation, reporting to our regulators the Investment Industry Regulatory Organization of Canada (IIROC) through the National Registration Database and/or the Complaints and Settlement Reporting System (ComSet) may be required. NPW has designated the Chief Compliance Officer as the Designated Complaints Officer. The Designated Complaints Officer is charged with the oversight of the complaint handling process and may also act as a liaison between NPW and the Regulatory bodies. Any questions regarding the firm’s complaint handling process should be forwarded to the Designated Complaints Officer by contacting 905.845.9090. More information regarding the complaint handling procedures is provided on our website at www.npw.ca.

CONFLICTS OF INTEREST

Actual, potential, and perceived conflicts of interest may exist in any interaction you have with an individual or organization. Our relationship with you is no different.

NPW is what is referred to as a “retail” investment firm (or a retail investment dealer) since we provide mostly a range of retail client services and products. We recognize that, by definition, we are more susceptible to conflicts of interest than many other business activities since we may, for example, represent both sides to a transaction, namely, the buyer and the seller. There are generally three types of conflicts that can arise:
1) Conflicts of interest between you and us,
2) Conflicts of interest between you and our other clients, and
3) Conflicts of interest between us and our related and associated companies.

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, an Advisor may be trading for another NPW client where that client may be on the opposite side of your buy or sell transaction.

Management of Conflicts of Interest

In general, we deal with and manage relevant conflicts through:

•Avoidance: This includes avoiding conflicts that are prohibited by law, as well as conflicts that cannot effectively be addressed.
•Control: We manage acceptable conflicts through means such as physically separating different business functions and restricting the internal exchange of information.
•Disclosure: By providing you with information about conflicts, you are able to assess independently, their significance when evaluating our recommendations and any actions we take. Where existing/potential material conflicts cannot be avoided, they will be disclosed at account opening or as they arise. Conflicts are disclosed before or at the time they recommend the transaction or provide the service that gives rise to the conflict, or in a timely manner if they are identified later, to give you reasonable time to assess the conflict. An advisor cannot satisfy  his/her obligations to identify and address material conflicts of interest solely by providing disclosure to you. All material conflicts of interest must be promptly reported to NPW by the advisor, and it must be addressed in the client’s best interest. When providing disclosure, the conflict will be prominent, specific, clear, and meaningful, and it will be explained how the conflict could affect the service being offered.

The following information is intended to assist you in understanding and assessing material potential and actual conflicts of interest, including how we address them. However, this is an overview of a complex subject and is not meant to be an all-inclusive list of conflicts of interest.
If you ever have any questions or concerns, whether they involve conflicts of interest or anything else, you should never hesitate to say so, and you should ask your Advisor for an explanation as well as for more information.

Possible Conflicts and How They are Managed at our Firm

We earn compensation by selling products and services to you for which you pay us.

•We will inform you of fees, commissions, and other compensation in advance so that you know what you will be paying.
•Depending on the product or account type you choose, we may offer a variety of pricing options to choose from.

Different products and services have differing levels of compensation.

•Our compensation is disclosed to you and we offer pricing alternatives intended to reduce the conflicts associated with commission-based pricing.
•We are required by industry regulations and firm policy only to make “suitable” investment recommendations.
•We may choose not to offer a complex product that carries a high commission.

We may receive compensation from securities issuers and other third parties based on the products we sell to you. For example: “trailer fees” on mutual funds or “finder’s fees” on private placements.

•We disclose to you the situations and type of third-party compensation we may receive.
•Securities regulations require issuers to provide specific disclosure in the offering document (e.g. fund fact sheet)of such arrangements, and the compensation we will receive.

We are compensated in other ways as a result of the business you may do with us, including interest spreads on un-invested cash deposits with us and foreign exchange spread when you convert currencies.

•Various forms of other compensation we may receive are disclosed to you.

We may sell you securities that we own (called principal trades) and profit by doing so.

• We will tell you whether we acted as principal or agent for each transaction on the trade confirmation.

We may sell you securities of companies that are related or connected to us. Currently, there are no related or connected companies.

• We are required by regulation to disclose this when we make a recommendation to you.
• All of our related parties would be disclosed on our website.
• We would inform you whether a transaction involved a related or connected security on the trade confirmation.
• Our advisors receive the same commission compensation payout as a percentage of gross revenue or per share basis regardless of the product originator.

We may need to select which clients will be offered certain securities if availability is limited.

• We have a “fair allocation” policy for managed accounts.

If we were to provide investment research on securities of companies that may have other business relationships with us.

• We will provide full disclosure of any conflicts of interest in all research reports disseminated.
• Our research and recommendations would be subject to extensive and detailed regulatory requirements and internal standards.

We do not engage in the trading of securities for our own account (called proprietary trading).

• If we start, we will maintain information barriers between our corporate trading activities and retail advisory business.
• Firm and employee trades are identified as such and client trades are given priority to firm and employee trades in accordance with industry “client priority” regulations.

We may permit certain individuals who are registered with us (including your investment advisor) to be employed by, participate in, or accept compensation from other persons or firms, outside the scope of his/her relationship with us.

• We have adopted internal policies and procedures that supplement the regulatory requirements. Such arrangements are reviewed for potential conflicts of interest.

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. For more information on how Canadian securities regulations address conflicts of interest in order to safeguard the investing public, we suggest that you refer to the websites and publications of the provincial securities commissions (which are available through the Canadian Securities Administrators (CSA)) at www.securities-administrators.ca and the Investment Industry Regulatory Organization of Canada (IIROC) at iiroc.ca.

Other Services Offered by Advisors – Outside Business Activities

Your NPW Advisor could be involved in a business activity or offer products and services that are unrelated to NPW. These are referred to as “Outside Business Activities” and include any activities conducted outside of NPW by your NPW Advisor, for which direct or indirect payment, compensation, consideration or other benefit is received or expected.

Outside business activities also include any position of influence or an officer or director or other equivalent position held by a registrant. The most common outside business activities for advisors are the sale of life insurance products and segregated funds. Your advisor may only engage in outside business activities that have been pre- approved by NPW Compliance. NPW also provides annual reviews of all outside business activities to ensure compliance with securities regulations.

NPW wants to ensure that you are aware that, in addition to his/her IIROC registration, your NPW Advisor may also hold a licence with, and be regulated by, a regulator other than IIROC, or involved in an unregulated outside business activity. It is also important that you understand:

•Your NPW Advisor’s “Outside Business Activities” are not the business of NPW.
•NPW makes no representations or warranties and assumes no liability with your NPW Advisor’s outside business activities.
•The remuneration earned by your NPW Advisor may vary depending on the products and services purchased.
•Your personal information cannot be shared without your prior written consent or as required by regulation.

•NPW provides pre-approval of outside business activities, which is based on the following conditions:

•That the activity follows any condition set out by the applicable securities commission.
•That NPW has approved the outside business activity and reported it to our regulator.
•That the NPW Advisor follows the policies and procedures in place at NPW to ensure continuous service and that any potential conflict of interest has been identified and addressed.
•That the occupation is not one which would bring the securities industry into disrepute.

The recent amendments to IIROC’s Dealer Member Rules, which prohibit any personal financial dealing with clients stipulate that receiving any compensation directly from anyone other than the dealer member for activities conducted on behalf of a client is prohibited. It should be noted, however, that an exception is provided in the case of any compensation received from a client that is in exchange for services provided through an approved outside business activity.

Referral Arrangements

Securities legislation requires every NPW Advisor to inform clients of any referral arrangements where they pay or receive fees for client referrals. To provide products and services suitable to meet the financial planning needs of our clients, NPW may enter into referral arrangements for certain products and services. Referral fees paid to the firm under a referral arrangement will vary depending on the product or service purchased by the client. The referral fee may change at any time depending on the products and services being offered by NPW. Generally, a referral fee will be either a percentage of the account balances, a percentage of revenue generated or a fixed fee. NPW is registered as an investment dealer under securities legislation. Securities legislation requires that a written referral arrangement must be agreed to prior to paying or receiving a referral fee for client referrals. NPW Advisors may also be compensated for client referrals. A written disclosure, including information about the calculation of the referral fees and any identified conflict of interest, will be provided to you before you open an account or any service is provided to you by the person or company receiving the referral.

You acknowledge that by visiting, accessing and or using this web site that you agree to be bound by the terms and conditions of its use.

This web site shall be governed by the laws of the Province of Ontario and the Country of Canada and you voluntarily agree to submit to the jurisdiction over you by the courts of the Province of Ontario or any Federal court of Canada.

The information on this website does not constitute the official version of our disclosure documents and may not always be current. The website and access to it is provided strictly on an “as is” and “as available” basis without any warranties of any kind. The information contained in this web site is collected from sources believed to be reliable, but the accuracy and completeness of the information is not guaranteed.

In no event will Nour Private Wealth Inc. assume any responsibility or liability for the accuracy or losses caused by the use or misuse of this website or reliance on the information or content therein, including direct, indirect, special incidental, consequential, exemplary or punitive.

The information in this web site is intended for use by persons who residents in the jurisdictions where Nour Private Wealth Inc. is registered. Currently we are registered in the following Provinces in Canada, Alberta, British Columbia, Manitoba, New Brunswick, Nova Scotia, Ontario, Quebec, Prince Edward Island and Saskatchewan. We are members of the Canadian Investor Protection Fund (CIPF) and the Investment Industry Organization of Canada (IIROC).

Unless otherwise noted Nour Private Wealth Inc. is either the owner or licensed user of the copyrighted material on this website. The Nour Private Wealth Inc’s name, logo, brand names and all other trademarks, are the property of, or licensed to, Nour Private Wealth Inc. and unauthorized use is strictly prohibited.

The information offered on this web site is not intended to provide any specific wealth planning, tax, legal or accounting advice. The information offered on this web site is not to be considered an offer to buy, sell or a solicitation of any kind to buy or sell any security, derivate or any other investment product or service.

Without the use of secure encryption this web site is not a secure medium for electronic communications. Confidential use of this web site cannot be guaranteed. You there for acknowledge that any confidential information transmitted by a user utilizing this medium may be read and / or copied by unauthorized individuals. Nour Private Wealth Inc. assumes no responsibility or liability for any harm that may occur in connection with any breach or hack that may compromise personal information transmitted through this web site. Be advised that trading instructions should not be communicated via email and if any such instructions are received they will not be acted on. Insurance Services are provided in Ontario through Nour Insurance Services Inc. not Nour Private Wealth Inc. The sale of Insurance products by your advisor is based on that advisors Insurance registration through the Financial Services Commission of Ontario.

Nour Private Wealth Inc. reserves the right to use cookies on this website. Cookies are small harmless data file that web sites can write to your hard drive when you visit them. A cookie can include a user ID that the site uses to track the pages you visit. Cookies may also be used to enhance your experience on the web site, to determine user traffic patterns and for other purposes. Cookies can be removed from your browser at any time by accessing the Safety tab on your web browser screen and deleting your browser history.

It is the user’s responsibility to take all necessary precautions to scan for viruses and other malware. All internet email messages and their attachment received and sent through the facilities of this website and the computers used by all employee, agents and advisors are subject to review by supervisory personnel. Such communications are retained, and we may be required to produce them to our regulatory authorities. All products and services provided by Nour Private Wealth Inc. are subject to the terms and conditions of the applicable agreements governing their use.

Nour Private Wealth Inc. does not provide tax, legal or accounting advice. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors before engaging in any transaction. The content of this website is for informational purposes only and is not intended to provide financial, insurance, legal, accounting or tax advice, and shall not be relied upon by you in that regard.

The provinces of Quebec, Alberta and British Columbia have introduced regulations which set out specific responsibilities for the administration of “Unclaimed Property” if the last known address of the owner of the property was within one of these provinces. The legislation is designed to ensure that all reasonable efforts are made to return “Unclaimed Property to its owner. Unclaimed Property can include cash, stocks, bonds, mutual funds or other receivables held in client accounts at Nour Private Wealth Inc. (NPW), without recent activity (3 years), where the current location of the client is not known to us and the last known address is in one of Quebec, Alberta or British Columbia. NPW will maintain a database of accounts which may hold Unclaimed Property. The following provides specific information for each of these provinces and the rest of Canada.

Alberta
The province of Alberta has established a service for residents who have lost track of property as a result of business or personal circumstances. To access the service’s website, please click here: https://unclaimedproperty.alberta.ca/publicTracs/searchUnclaimedProperty.do?event=init

British Columbia
The province of British Columbia has regulations that require holders of unclaimed property, where the current or last known address of the owner is in British Columbia, to make reasonable efforts to contact the owners and advise them of their unclaimed assets. In addition, the province has established an unclaimed property program to assist residents with recovering unclaimed property. To access the program’s website, please click here: https://unclaimedpropertybc.ca/searchp/search/

Québec
The province of Québec has established a service that assists individuals with locating unclaimed property. Revenu Québec is the agency responsible for recovering and administering unclaimed property for citizens of Québec. To access the Register of unclaimed property, please click here: https://www5.services.mrq.gouv.qc.ca/mrqanonyme/BR/BR01/BR01A1_01A_ConsulterBNR_P C /P_Consultation.aspx?Clng=A&WT.co_f=2ddcf8dc657fe7e8b331384272584389&TV=E

If you have an enquiry or claim in respect of Unclaimed Property either on your own behalf or, for example, in your capacity as attorney under a power of attorney or as estate trustee, please provide full details including your full name and account number in writing to info@npw.ca.