Conflicts of Interest
A conflict of interest is any circumstance where the interests of a client and those of CI Direct Investing or individuals acting on our behalf are inconsistent or divergent. We take reasonable steps to identify and respond to material conﬂicts of interest and conflicts that are reasonably foreseeable. Conflicts of interest may include conflicts between:
CI Direct Investing is committed to ensuring that your interests always have precedence. We seek to ensure effective management of any situation that could give rise to a conflict of interest. We seek to manage conflicts of interest in your best interest.
We respond to conflicts of interest in a fair and transparent manner consistent with the best interests of our clients using three methods:
Avoiding Conflicts of Interest
We avoid conflicts that are prohibited by law as well as conflicts that cannot be responded to reasonably with controls or disclosures.
Controlling Conflicts of Interest
We have established policies and procedures to control material conflicts of interest, such as the design of our organizational structure and lines of reporting, physical separation of different business functions, and limiting the internal exchange of information.
Disclosing Conflicts of Interest
CI Direct Investing will provide you with information about any conflicts of interest that may reasonably affect the services we provide at the time of account opening and in certain situations before investing your account. Disclosure will be provided in a timely manner so that you have a reasonable amount of time to assess the conflict.
Conflicts of Interest Disclosure
In this section we share with you:
Conflicts of interest related to CI Direct Investing being part of CI Financial Corp.
CI Direct Investing employees may be shareholders of CI Financial Corp.
CI Direct Investing is a wholly owned subsidiary of CI Financial Corp. ("CIX"), a public company whose shares are traded on the Toronto Stock Exchange and The New York Stock Exchange. A principal business of CIX is the management, marketing, distribution and administration of mutual funds, segregated funds and other fee-earning investment products for Canadian investors through its wholly-owned subsidiary, CI Investments Inc, also known as CI Global Asset Management (“CIGAM”). Employees who work within CI Direct Investing and the other members of the CIX organization may hold CIX shares.
In the course of providing services to you, we may from time to time advise you with respect to the purchase or sale of securities from or to, or issued by, persons or companies which are related or connected to us. We will carry out such services in the ordinary course of its business in accordance with its usual practices and procedures and with all applicable regulatory requirements.
These transactions and arrangements may give rise to conflicts of interest; however, we have adopted policies and procedures to identify and respond to these conflicts. We will only enter into transactions or arrangements where they are permitted under securities laws, where they are consistent with your investment objectives, and where we consider they are in your best interest in the applicable circumstances.
If you invest in CIGAM products, CIX will, through its ownership of the CI affiliates, profit from ongoing asset management fees that are described in applicable Fund Facts and other offering documents. Accordingly, to the extent that CI Direct Investing employee owns securities of CIX, he or she will benefit from these fees, which contribute to the share price of CIX.
If this is the case, CI Direct Investing must manage the conflict of interest in your best interest, which generally means, in this context, considering a range of investment options for the portfolios and not solely those investment products managed by CIGAM. CI Direct Investing portfolios are constructed by a committee of advisors and follow an approval process to mitigate and avoid conflicts of interest associated with product selection. A recommendation to invest in CIGAM investment products will only be made if we consider such investment is in your best interest.
Given our affiliation with CIGAM, recommending a CIGAM investment product is a conflict of interest, and you may be concerned about whether this recommendation puts your interest first. To mitigate the associated conflicts of interest and address them in your best interests, we have adopted several controls, including a robust evaluation of all investment products that are approved for our investment portfolios.
In addition, CI Direct Investing employees to do not receive any direct incentives for recommending or selecting CIGAM investment products over non-proprietary investment products.
You will know whether an investment product is a CIGAM investment product generally because it will contain the term “CI” as part of its name. Your account statements will indicate which of the investment products held in your account are CIGAM investment products.
You should note that CIGAM investment products are “connected issuers” and/or “related issuers” to CI Direct Investing. A “related” issuer means a person or company that influences, or is influenced by, another person or company. A “connected” issuer is a company that has business relationship with CI Direct Investing that, in connection with a distribution of securities of the issuer, is material to a prospective purchaser of the securities.
Please refer to https://ci.com/en/legal/legal-notices for a current list of related and connected issuers. Alternatively, you may contact us at 1-888-373-7674.
CI Direct Investing is related to other subsidiaries of CIX
Securities legislation requires us inform clients if it has any principal shareholders, officers, partners or directors who are also principal shareholders, officers, partners or directors of another securities registrant. As well, we must provide client details of the policies and procedures adopted to minimize the potential for conflict of interest resulting from these relationships.
CIX is also a principal shareholder of the following Canadian securities registrants or service providers to securities registrants. Directors and officers of CI Direct Investing may be directors or officers of one these entities; however, they do not influence our investment decisions.
• Assante Capital Management Ltd.
• Assante Financial Management Inc.
• Assante Connect Inc.
• CI Private Counsel LP
• CI Investment Services Inc., including CI Direct Trading
• One Capital Management LLC
• Aligned Capital Partners Inc.
• Marret Asset Management Inc.
Each of CIX, CI Direct Investing and the related registrants is a separate legal entity which carries on its business independently. CI Direct Investing may enter into arrangements with its affiliates respecting such matters as the provision of support services, distribution of products and services, and client referrals.
Conflicts of interest resulting from the above relationships are minimized in a number of ways. CI Direct Investing has conflict of interest policies and complies with all applicable regulatory restrictions in dealing with its affiliates. Compliance with CI Direct Investing’s policies and procedures are monitored under the guidance of CI Direct Investing’s Compliance Department. For further information concerning these matters, please contact CI Direct Investing at 1-888-373-7674.
Conflicts of interest related to CI Direct Investing compensation
CI Direct Investing receives compensation for operating your account from a number of sources. These sources may include:
• management fees charged to you for account, these fees are set out in your fee-based account agreement;
Depending on how you are introduced to CI Direct Investing and the value of your assets invested, your management fee rate may differ than if you were to sign up directly from our website. Your fees are provided to you when you sign up in the Managed Investment Account Agreement. If you have an existing relationship with an introducing representative, you may be offered distinct portfolio options with a different management fee schedule. You are able to sign up directly on the CI Direct Investing site if you decided not to proceed with the introducing representative’s services.
Conflicts of interest related to compensation of CI Direct Investing employees
CI Direct Investing and its employees do not accept gifts, beneﬁts, compensation, or consideration that creates, or might reasonably be expected to create, a material conflict of interest.
Conflicts of interest related to outside business activities
Our directors, officers, and registered advisers may engage in business activities that are outside CI Direct Investing’s securities related business activities (“outside business activity”) only if they have received prior approval from us to do so. You should be aware that portfolio managers may provide other products and services that are outside of his/her affiliation with CI Direct Investing. These are not considered securities-related and are the responsibility of the portfolio manager alone. They may also be employees, officers and/or directors of affiliates, or may also be officers or directors of public companies.
We will, as best possible, monitor all outside business activity to ensure the activity doesn’t impair our ability to serve you and is consistent with our duty to deal fairly, honestly, and in good faith with you.
We will investigate and follow up on written client complaints relating to an outside business activity. CI Direct Investing makes no representations or warranties and assumes no liability in connection with any outside business activities of our directors, officers, and registered advisers.
If you have any questions, please contact CI Direct Investing’s Chief Compliance Officer at 1-888-373-7674.
Conflicts of interest related to referral arrangements
We may enter into referral arrangements with affiliated or non-affiliated registrants and non-registrants, some of which are related registrants to CI Direct Investing, so that we may provide portfolio management services to referred clients. We may pay a referral fee to the referrer. A referral fee is any benefit provided for the referral. We negotiate the referral fee with the referrer. Any investment management fee paid by referred clients remains the same regardless of any referral fee paid by CI Direct Investing to the referrer. We will inform all referred clients under a referral arrangement.
CI Direct Investing may also receive a referral fee for referring its clients to other service providers. The purpose of referrals is to introduce our clients or potential clients to qualified persons 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 you with the specific details of the arrangement, including:
• 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 conflicts of interest resulting from the relationship between the parties to the referral arrangement and from any other element of the referral arrangement;
• the method of calculating the referral fee and, to the extent possible, the amount of the fee;
• 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 under that category.
Clients of a PPI representative should view PPI Referral Arrangement Disclosure.
Conflicts of interest related to affiliate marketing
We employ affiliate marketing whereby third parties are compensated for client signups as a result of their online promotion of CI Direct Investing. If you sign up through these affiliate links, you may receive a discount on our services. You may decide to open an account with us without realizing that the online article is, in effect, a promotion paid by us. To mitigate this from happening, we disclose this payment to you on the affiliate’s signup link. We have controls in place to review the materials that these affiliates publish for accuracy, and we track the number of signups.
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