Disclosure - Freedom International Brokerage Company

Securities legislation in Canada requires Freedom International Brokerage Company (“Freedom”) to make certain disclosures regarding conflicts of interest. This statement is to inform you of the nature and extent of conflicts of interest that might be expected to arise between Freedom and its clients.

It is important for you to be informed about how we identify and respond to conflicts of interest in order to minimize their impact.

A “conflict of interest” occurs whenever the personal interests of Freedom, or an individual acting on its behalf, may potentially conflict with those of a client, or in a situation where Freedom, or an individual acting on its behalf, has an obligation to more than one party whose interests are different.  A conflict of interest can also exist where monetary or non-monetary benefits are made available to Freedom, or an individual acting on its behalf, as incentives.

Conflicts of interest may be large enough to be material (in which case they are addressed as described in this disclosure statement) or small enough to be immaterial (in which case no further action is taken to address them). In determining the materiality of a conflict of interest, Freedom will consider whether the conflict may be reasonably expected to affect the decisions of its client in a particular situation or the recommendations and/or decisions Freedom makes on behalf of its client.

Freedom addresses material conflicts of interest in the best interest of its clients. This is done by placing the interests of clients first, ahead of the personal interest of Freedom and any other competing considerations. As such, Freedom takes reasonable steps to identify, address and avoid, any existing material conflicts of interest or foreseeable material conflicts of interest that we would reasonably expect to arise (i.e., between us and a client and between each individual acting on our behalf and a client). Freedom determines the level of risk for each material conflict. Freedom avoids situations that would result in a serious conflict of interest that would be too high a risk for clients or market integrity and will ensure that it will act in the client’s best interest. In other circumstances involving a conflict of interest, Freedom takes the appropriate steps to control the conflict of interest Similarly, if a particular conflict is capable of being addressed by using controls, but the specific controls being used by us are not sufficiently mitigating the effect of the conflict, we will avoid that conflict until we have implemented controls sufficient to address the conflict in the best interest of the client.

Individuals acting on behalf of Freedom also are required to identify potential conflicts of interest and bring them to the attention of Freedom, and will also disclose any relevant information that may arise in a potential conflict of interest to Freedom. If the individual is uncertain as to whether a potential conflict of interest exists or could arise, the matter will be directed to our Chief Compliance Officer for discussion.  Any individual who identifies a potential conflict of interest will await approval from our Chief Compliance Officer prior to acting on behalf of the client, in order to ensure that any actions taken on the client’s behalf are in their best interest.

Freedom, whose office is located in Toronto, Ontario is an exempt market dealer in Ontario and Québec, and is an inter-dealer bond broker with the Investment Industry Regulatory Organization of Canada, and is in the business of providing inter dealer brokerage services to its clients.

Freedom takes proactive measures to anticipate reasonably foreseeable conflicts of interest, assesses the materiality of such conflicts to distinguish between those conflicts that are material and those that are not and has developed adequate procedures identify existing conflicts.  The situations in which Freedom could be in a conflict of interest, and the way in which Freedom intends to respond to such conflicts, are described below.

Our personnel may find themselves in situations where their personal interests are in conflict with those of a client.

Our Code of Ethics and related policies and procedures establish basic principles for employee conduct which, among other things, prohibit an employee from:

• Using confidential information acquired in connection with his or her duties;

• Accepting gifts, entertainment and compensation that would influence decisions to be taken in the course of performing his or her duties; and

• Engaging in activities that could interfere or conflict with his or her duties.

Freedom does not allow any of its personnel to engage in activities outside the scope of their duties, including serving as a director of a company or other entity, without first ensuring that such activities do not compromise the interests of our clients.

An unfair allocation of trades by us is a potential conflict of interest. To avoid any potential conflicts of interest, we have adopted trading policies designed to ensure fair allocation of securities among our clients. A copy of our fair allocation policy is provided to new clients before opening an account with us and thereafter when a significant change to this policy is made.

From time to time, other conflicts of interest may arise. Freedom will continue to take appropriate measures to identify and respond to such situations fairly and reasonably and in the best interests of its clients.

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This document is kept current and is posted on our website at [www.freedom.ca or you may contact us for the most recent version at [jniskanen@freedom.ca].

June 30, 2021