Enhanced Conflicts of Interest Disclosure

Dear Clients,

As you may be aware, the Canadian Securities Administrators are implementing “client- focused” reform amendments to certain of the obligations that firms and their registered representatives owe to clients. As of June 30, 2021 this will include an enhanced conflict of interest standard. Under this standard, we will be required to address and manage existing, as well as reasonably foreseeable, material conflicts in the best interest of our clients.

A conflict of interest can include any circumstance where: (a) the interests of different parties, such as the interests of the firm and those of a client, are inconsistent or divergent, (b) the firm or one of its registered representatives may be influenced to put their interests ahead of a client’s interests, or (c) monetary or non-monetary benefits available to the firm or a registered representative, or potential detriments to which they may be subject, may compromise the trust that a reasonable client has in the firm or the individual. Whether a conflict is “material” or not depends on the circumstances. In determining whether a conflict is material, the firm will typically consider whether the conflict may be reasonably expected to affect the decisions of the client in the circumstances, and/or the recommendations or decisions of the firm or its registered representatives in the circumstances.

In addition to other measures that will be taken to address existing and reasonably foreseeable material conflicts of interest, the firm will typically provide clients with disclosure in respect to the potential conflict. It is important that clients read this disclosure to help inform their decision when evaluating our business practices, conflicts management and overall performance on an ongoing basis. The Canadian Securities Administrators note that conflict disclosure is critical to a client’s ability to make an informed decision about how to manage and evaluate its relationship with a firm. If you have any questions in regard to our conflicts of interest disclosure or, more generally, in respect to conflicts, please contact us by telephone at 1.888.436.9955 or email: invest@gold-im.com and a portfolio manager will gladly assist.

The firm’s enhanced conflicts of interest disclosure is contained in our current Relationship Disclosure Information document and is now available for viewing. We will send you an e-mail letting you know the disclosure has been posted to the website. Additionally, a reminder will also be contained in the materials you receive from the firm following the June 30th end of quarter, including how you can instruct us to make this information available to you by paper copy at your request.


Gold Investment Management Ltd.