Client Relationship Disclosure

Reviewing this document will provide you with a good understanding of the following:
• Documents you will receive once you open your account;
• The fees and charges associated with your account;
• Reports you will receive related to your account;
• How we manage conflicts of interest; and
• How you can resolve any issues you may have with your account.

Financial Intermediary

FIN-XO is an investment dealer that acts as a Financial Intermediary with Investissement Québec to facilitate the mandatory investment under the Québec Immigrant Investor Program.

FIN-XO has entered into an agent agreement with CJ International Group Inc. (CJI), a Quebec registered entity specializing in investor immigration.  This agreement constitutes a referral arrangement between FIN-XO and CJI. Please refer to the FIN-XO Relationship Disclosure Document for the Québec Immigrant Investor Program for details.

Your Account Documentation

Securities regulations effective December 31, 2021 require FIN-XO to ask you for the name and contact information for a person that you trust, who is mature, has the ability to communicate and engage in potentially difficult conversations about your personal situation and preferably is not involved with making decisions with respect to your account (Trusted Contact Person or TCP) at account opening and on a periodic basis.

If applicable in your particular circumstances, we may, in our sole discretion, contact your TCP or your legal representative on file with us, if we notice signs of financial exploitation or if you exhibit signs of diminished mental capacity for decisions involving financial matters relating to your account. FIN-XO may also contact your TCP to confirm your contact information if we are unsuccessful in contacting you after repeated attempts, particularly if failure to contact you is unusual. We may ask the TCP to confirm the name and contact information of a legal representative (e.g. attorney under a power of attorney or a legal guardian). You can change your TCP by contacting us at operations@fin-xo.com.

You have agreed to (i) notify the TCP that you have identified them as your trusted contact, and advise us if they decline to serve as your TCP; and (ii) release us from all claims that relate to any decision we make regarding whether or not to contact the TCP, in your personal circumstances, and any information that we may share with the TCP.

If FIN-XO has a reasonable belief that you are being financially exploited or that you are experiencing diminished mental capacity which may affect your ability to make decisions involving financial matters relating to your account, we may place a temporary hold on your account or a particular transaction. We will provide you with a verbal or written notice explaining our actions, in addition to contacting your TCP, if any, as above.

Account Documentation

We will provide you with a copy of this Client Relationship Disclosure and the applicable Client Account Agreement for the type of account you open. We will also provide you with several documents containing the information you need to play an active role in monitoring your account and your investment.  These documents include:
• Your Relationship Disclosure Document for the Québec Immigrant Investor Program, which includes an acknowledgement that you received your account documentation
• Canadian Investors Protection Fund (CIPF) brochure
• Brochures issued by the Investment Industry Regulatory Organization of Canada (IIROC):

o    How IIROC Protects Investors
o    Making a Complaint - A Guide for Investors - Part 1 of 2
o    How Can I Get My Money Back? A Guide for Investors – Part 2 of 2

FIN-XO must assess the suitability of any investments for your account before making a recommendation to you and before conducting any trade. The factors guiding the FIN-XO mandatary in assessing the suitability of your investments include what he or she believes to be your current situation regarding:
• Your personal circumstances – your age, marital status, number of dependents, occupation, employer and whether you are an insider or a significant shareholder of any specific entity
• Your current financial situation – your assets (including your sources of income) relative to your debts: FIN-XO will evaluate the value of the transaction being considered in light of the net value of your assets (assets minus debts).
• Your investment knowledge and experience– this will be evaluated based on your past experience and on your own assessment of your knowledge of certain products and of the risks associated with investment products and complex investment strategies.
• Your investment needs and objectives– these are your specific financial objectives as provided to us, such as your wish to protect your investments (avoid loss of capital), increase your revenue or your capital via market growth.  
• Your risk profile Risk profile involves your risk tolerance, being  your comfort level if faced with the possibility of losing part of your money, even if you have many years in which to invest and save and your risk capacity, which is a more objective assessment on your financial ability to absorb any losses, given your personal and financial circumstances.
• Your time horizon – this is the period of time from when you provide the information to us until you will require all or part of  your capital, whether to buy a property, retire, or for any other purpose.
Your FIN-XO mandatary must put your interests first in making any recommendation or taking an investment action for your account.

As part of our relationship with you, we will send you a number of reports to help you monitor the progress of your investment.
Account statement – We will send you a monthly account statement whenever there is activity in your account, no later than the 15th day of the following month. Monthly statements are issued if your account has activity other than dividend, interest and systematic plans. If there is no such activity in your account, an account statement will be sent on a quarterly basis. The type of account you have is clearly identified as well as all of the securities and their market value, and an itemized list of all trades conducted in the account during the time period. It is your responsibility to closely examine each account statement and to inform us of any error or omission within 30 days of the date printed on the statement or the day we deem you to have received them, whichever is earlier. 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.
Book Values
Your monthly or quarterly statement will show the market value of the security based on either the last available market value/net asset value for the security or the book value of the security.
Annual fees and compensation report
This report summarizes the amounts we received to service your account over the past year. A portion of this sum is paid as remuneration to FIN-XO and CJI.
Conflicts of interest and statement of policies
FIN-XO is committed to putting the interests of our clients above all else. In addition, as a securities brokerage firm and member of IIROC, we must effectively address any situation which may give rise to a conflict of interest.  We must do this in your best interest.  We have described our conflicts of interest and how we manage them below.
Managing Conflicts of interest
FIN-XO Securities Inc. (FIN-XO, we or our) offers a wide range of products and services to individuals, companies and institutional investors. In the context of our varied activities, we are committed to ensuring that the interests of our clients always have precedence. Moreover, as an investment dealer and member of the Investment Industry Regulatory Organization of Canada (IIROC), we must ensure effective management of any situation which could give rise to a conflict of interest.  We seek to manage conflicts of interest in the best interests of our clients.
A conflict of interest arises when the interests of different persons, particularly your interests and those of FIN-XO or one of our Employees (which includes our administrators, managers, associates, staff, or agents) or Advisors are incompatible or divergent. Situations may arise that may influence or be perceived to influence FIN-XO or one of our Employees or Advisors to act in their own interests or those of a related entity and not in the client’s best interest.
Accordingly, conflicts of interest may occasionally arise between you and:

• FIN-XO or you and your Advisor;
• other clients whom we represent; or
• a person or company with whom we have a relationship.
• We have adopted policies and internal procedures to effectively address conflicts of interest in the client’s best interest. Canadian securities laws require us to take reasonable steps to identify and respond to material conflicts of interest in your best interest.  We also are required to tell you about them, including how the conflicts might impact you and how we address them in your best interest.
• We have policies and procedures in place to address how we will manage material conflicts of interest in your best interest, which are described below:
• We seek to avoid or minimize conflicts where reasonably possible. We seek to avoid actual or perceived favouritism or discrimination amongst clients and to ensure that no client receives preferential treatment over another in the operation and management of their account and execution of trades.  
• We avoid conflicts prohibited by law as well as material conflicts that we cannot effectively manage in your best interest. Some conflicts cannot be avoided. In situations in which we do not or cannot avoid conflicts and in which our interests may compete with yours, your interest is always put first.
• We control or manage acceptable conflicts by physically separating different business functions, restricting the internal exchange of information, whether in person or electronically, reducing the possibility of one part of our organization unsuitably influencing another, removing the financial incentive of an Employee or Advisor to favour a particular product or service over another that may be more suitable, and establishing and continuing testing of our operational review and approval processes.

We are a wholly owned indirect subsidiary of iA Financial Corporation Inc.  (iA Financial Corporation).  Our relationship to iA Financial Corporation and its other financial services subsidiaries (the iA Financial Group) creates conflicts of interest when we provide products and services to you that are sourced from or provided by other members of the iA Financial Group.  
iA Financial Corporation and its various financial services subsidiaries, including FIN-XO, are commercial businesses that seek to maximize profits while providing fair, honest and appropriate services to clients.  This means that we may encourage you to do more business with us and the other members of the iA Financial Group, and we may engage affiliates to provide us with products and services for your account, but will always do so in a way that we consider to be in your best interest.  We will only enter into these transactions or arrangements where we are permitted under applicable securities laws and where we believe they are in your best interest.
Although FIN-XO is under common ownership with the other members of the iA Financial Group and may from time to time have directors and officers in common with these other firms, FIN-XO is a separate and distinct corporate entity.
Any relationships that a FIN-XO director or officer might have with another iA Financial Group entity do not raise material conflicts as none of the individuals is in a position to personally influence clients of FIN-XO to invest in any of the investment products of the iA Financial Group, nor are they compensated by any of the iA Financial Group entities on a commission or other basis that could result in decisions being made, or influence being exerted, against the interest of any of our clients.
In addition to applicable regulatory provisions and contractual provisions respecting any business arrangements that may exist between FIN-XO and the other iA Financial Group entities, the directors, officers, Employees and Advisors of each of the firms are subject to iA Financial Group’s Code of Business Conduct governing their actions, in addition to our internal compliance policies and procedures.
FIN-XO generally carries on its activities independently from the other firms owned by iA Financial Corporation. However, from time to time there may be certain cooperative business arrangements between it and the other firms, such as arrangements relating to introduction of clients, distribution of products, advisory relationships or administrative support.
The following iA Financial Group entities provide services to you and/or FIN-XO:
<    iA Clarington Investments Inc. manages the iA Clarington family of investment funds, which FIN-XO Advisors may recommend as investment options for your accounts with FIN-XO.
<    Industrial Alliance Investment Management Inc. is the portfolio manager of the iA Clarington family of investment funds. FIN-XO Advisors may be licenced as insurance agents with PPI Management Inc. and may recommend that you acquire insurance and insurance products, such as segregated funds, provided by Industrial Alliance Insurance and Financial Services Inc.  

Investments in Related and Connected Issuers

Under certain circumstances, FIN-XO may cause your account to invest in securities in which the issuer of the securities or another party to the transaction is 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 have adopted policies and procedures to assist in identifying and minimizing any conflicts of interest that may arise.
iA Financial Corporation is a publicly traded company with securities listed on the Toronto Stock Exchange and as such it is a related issuer to FIN-XO. The iA Clarington investment funds are all related and connected issuers to FIN-XO.  For a full list of the related and connected issuers to the firms within the iA Financial Group, please visit: www.fin-xo.com/statement-of-policies.

Other Material Conflicts of Interest

Compensation of Advisors: We may compensate our Advisors by a combination of one or more of the following:

• base salary;
• compensation based on the value and/or types of assets under administration;
• bonus based on various performance criteria; and
• percentage of sales commissions, spreads, and trailer fees received by FIN-XO.

Gifts and Entertainment: Our executives and Advisors are not permitted to accept gifts or entertainment beyond what we consider consistent with reasonable business practice and applicable laws. We set maximum thresholds for permitted gifts and entertainment to avoid any perception that the gifts or entertainment will influence decision-making.

Personal Trading: Our policies and procedures and the iA Financial Group’s Code of Business Conduct require our Advisors to act in accordance with applicable laws that prohibit insider trading, front running and similar conduct. Individuals may be required to obtain prior approval before making trades in their personal securities accounts. Our Employees are prohibited from accessing non-public information for their direct or indirect personal benefit. We place securities on a “restricted list” to avoid trading when we have non-public information.  

Personal Dealings with Clients: Conflicts of interest can arise where our Advisors have personal financial dealings with you, such as acquiring assets outside of your investing relationship, borrowing money from or lending money to you, or exercising control over your financial affairs. To address these conflicts, FIN-XO has policies and procedures in place which prohibit personal financial dealings with clients who are not family members.

Referral Arrangements: As indicated above, there is a referral arrangement between FIN-XO and CJI. In addition, other referral arrangements may exist between FIN-XO and other iA Financial Group members and/or other regulated/non-regulated entities. A referral arrangement happens when a prospective client is referred to or from FIN-XO by a party and that party or FIN-XO may receive a referral fee. The purpose of referrals is to introduce our clients or potential clients to qualified persons who are best suited to help clients achieve their financial objectives.
If a referral arrangement is in place, a written disclosure will be provided to you wherein the specific details of the referral arrangement will include:

• the name of each party to the referral arrangement;
• the purpose and material terms of the referral arrangement, including the nature of the services to be provided by each party;
• any material conflicts of interest resulting from the relationship between the parties to the referral arrangement and from any other element of the referral arrangement, including a description of:
• The nature and extent of the conflict of interest;
• The potential impact on and risk that the conflict of interest could pose to the client; and
• How the conflict of interest has been, or will be, addressed;
• the method of calculating the referral fee and, to the extent possible, the amount of the fee; and
• the category of registration of each registrant that is a party to the agreement, with a description of the activities that the registrant is authorized to engage in under that category and, giving consideration to the nature of the referral, the activities that the registrant is not permitted to engage in.

FIN-XO is committed to handling client complaints in a fair and equitable manner. On opening an account, we will send you a document outlining our process for handling complaints, as well as a copy of a communication issued by IIROC entitled “Making a Complaint – A Guide for Investors”.
Our process for handling client complaints is available online at www.fin-xo.com. If your complaint relates to the servicing of your account, we ask that you raise your concerns with your FIN-XO mandatary identified on your Account Statement. If your complaint concerns alleged misconduct in the handling of your account or transactions in your account, we urge you to raise your concerns with the Branch Manager or our designated Complaints Officer at the address below. The following is a brief summary of our procedure for responding to complaints:

• Upon receipt of a complaint (apart from service complaints), we will send an acknowledgement letter to the complainant within five business days. We may request that you provide or clarify your complaint in writing.
• After analyzing the complaint, a detailed response letter and a copy of “Making a Complaint – A Guide for Investors” will be sent as soon as possible or 90 calendar days following the date of receipt of the complaint. This response will include the results of our investigation and our final decision on the complaint.
• If we are not able to send a final response within 90 days, you will be informed of the reason for the delay and of the new timeline for completion of the process.

FIN-XO Inc.
Attention: Complaints Officer
2200 McGill College Avenue, Suite 350
Montreal, QC, H3A 3P8
Sharing of office premises
Industrial Alliance Insurance and Financial Services Inc. (IAIFS) is the primary shareholder of FIN-XO Inc. (FIN-XO). Some FIN-XO mandataries may share office space with IAIFS or another financial entity related to or affiliated with IAIFS, or may share a receptionist and other administrative staff. Please see our Statement of Policies for all related or affiliated entities (www.fin-xo.com).
FIN-XO has adopted the Industrial Alliance Group privacy policy and is committed to comply with this policy.
The Industrial Alliance Group is composed of Industrial Alliance Insurance and Financial Services Inc. and its subsidiaries (“we/us”). Together, we are committed to protecting our clients’, employees’ and representatives’ (“you/your”) privacy, and to ensuring the confidentiality of the personal information provided to us in the course of our business.
Our Privacy Policy sets out our standards for collecting, using, disclosing and storing your personal information. Our Privacy Policy also explains how we safeguard your personal information and your right to access that information.
1. PERSONAL INFORMATION Personal Information is any information about an individual that identifies him or her, such as financial, lifestyle or health information, but not their name, title or business address, telephone or email. Personal information has to be protected regardless of its characteristics or its form, whether written, graphic, audio, visual, computerized or any other form.
2. PURPOSE OF INFORMATION COLLECTION Collecting information about you is necessary in order for us to provide you with high quality services. The nature and sensitivity of the information we collect about you varies according to the services we provide you and to legal requirements imposed on us (such as your social insurance number, where investment income is generated by a chosen product).
3. CONSENT When we collect personal information from you, we obtain your consent to use the information for the purposes collected. We will obtain your consent for any additional use or collection, or if the purpose of using the information is changed.
We generally seek your express written consent in order to collect, use or disclose personal information. Where appropriate, for less sensitive information, we may accept your verbal consent. Occasionally, we may imply consent where we can infer consent from your action or inaction.
Consent must be given by you or your authorized representative such as a legal guardian or a person having power of attorney.
You may withdraw your consent at any time, subject to legal or contractual restrictions (for example, your right to withdraw consent is necessarily limited where we need information to extend a loan against the value of a policy issued by us). We will inform you of the consequences of such withdrawal, including the possibility that we may not be able to provide a product or process a request. If you choose not to consent, we will record the decision in our file.
In limited circumstances, we have the right (or obligation) to collect, use or disclose personal information without your knowledge and consent. This occurs when legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the investigation of a potential breach of contract, the prevention or detection of fraud, or for law enforcement purposes, seeking consent might defeat the purpose of the information collection. Similarly, seeking consent may be impossible or inappropriate when you are a minor, seriously ill or otherwise incapacitated.
iA Financial Group, its affiliates and their agents may use and share your personal information with each other so that you can benefit from personalized offers and improved products and services. If you do not wish your information to be shared within the iA Financial Group, please contact us at:
FIN-XO Inc.
Privacy Officer
2200 McGill College Avenue – Suite 350 Montreal, QC H3A 3P8.
4.    LIMITS TO COLLECTION, USE AND DISCLOSURE We limit the collection of your personal information to what we need in relation to the purposes identified to you. We collect the information directly from you unless you allow us to collect information from a third party or in accordance with the law.
We limit the use of your personal information to the purposes we have identified to you. This means that we cannot use your personal information for other purposes without your consent, except as required by law.
Your personal information is only accessible to authorized persons, and only to the extent necessary to perform their duties.
You have the right to know, on request, to whom the information was disclosed. Only in rare instances are we prevented by law from making such disclosure. We maintain accurate records, recording to whom we disclose personal information and in what circumstances it was disclosed.
We will occasionally share your personal information with service providers or agents to ensure the proper administration of products, or to provide you with the services you require. These service providers or agents must agree to comply with privacy legislation before receiving any personal information.
In certain circumstances, we may use service providers outside Canada, including the United States. We are responsible for the service provider’s compliance with our Privacy Policy and will ensure that the level of protection of personal information is comparable to that provided by us. Any questions concerning the collection, transfer or use of personal information outside Canada can be forwarded to the Privacy Officer at the address provided below.
5. RETENTION We only retain your personal information as long as needed for the purpose it was collected. We must destroy this information in accordance with the law and our file retention guidelines. When we destroy your personal information, we make sure that confidentiality is secured and that no authorized person can access the information during the destruction process.
6. CLIENT LIST We do not sell client lists to third party.
7. ACCURACY We make every possible effort to ensure that your personal information is as accurate and complete as necessary for the purposes it is collected, used, or disclosed.
8. ACCOUNTABILITY We are responsible for your personal information in our possession or control, including information that may be transferred by us to third parties for processing. We require such third parties to keep personal information under strict standards of privacy and protection.
We adhere to legislated and self-imposed rules, aimed to safeguard your privacy. The rules are established by this Privacy Policy, the Code of Business Conduct (applicable to directors, officers and employees), the Market Conduct Standards (applicable to agents and brokers) as well as insurance industry guidelines and applicable law.
Our staff is trained on these processes and procedures and is provided with information about privacy laws.
9. SAFEGUARDS We have implemented and continue to implement rigorous safeguards so that your personal information remains strictly confidential and is protected against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
Protection methods include organizational measures such as requiring security clearances and limiting access to a “need-to-know” basis, physical measures (e.g. building access cards for employees, visitor registration and identification cards, off-site backups and archiving), and technological measures such as the use of password and encryption (e.g. the use of routinely changing passwords, firewalls and segmented operator access).
10. REQUEST FOR ACCESS TO INFORMATION AND AMENDMENTS You have the right to be informed whether we hold personal information about you and to see that information. You also have the right to enquire as to how we collected your information, how we used it and to whom it may have been disclosed. This information will be provided to you within a reasonable time from the date we receive your written request. We may charge a reasonable fee for processing your request.
In certain limited and specific circumstances, we may refuse to provide to you the requested information. Exceptions to your access right can include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, information that has been obtained in the course of an investigation of a potential breach of contract or fraud, and information that is subject to solicitor client privilege.
In cases where we hold medical information about you, we may refuse to provide you with direct access to this information and may instead request that a health care professional be designated to provide the information to you.
You may challenge the accuracy and completeness of your personal information. We will respond to an amendment request within a reasonable time.
Any request for access to information or request for amendment must be sent to the following address:
FIN-XO Inc.
Privacy Officer
2200 McGill College Avenue - Suite 350 Montreal, QC H3A 3P8
+1 (800) 361-7465
11. COMPLAINTS AND CONCERNS Our employees and representatives are trained to respond to your questions or concerns about personal information. Should you be unsatisfied with our employee’s or representative’s response, you may contact the Privacy Officer at the address mentioned above.
A complaint concerning the protection of personal information should be addressed to the Privacy Officer at the address provided above.