1. 1. Any electronic mail you receive from an employee or representative of Cidel Bank and Trust Inc, (“Cidel”) or any subsidiaries, including any attachments thereto (“the email”), is subject to the Cidel e-mail disclaimer (“disclaimer”) as set out herein.
   2. The email may contain information which is confidential and private in nature. If you are not the stated addressee (or such person authorized representative) you must –

• • • notify the sender of this fact immediately by return e-mail, fax or telephone and delete the email from your system;
    • refrain from printing, copying, forwarding or otherwise disclosing any information contained in the email or any part thereof; and
    • refrain from reading, storing, using, selling or incorporating any information contained in the email into any database or mailing list for whatever reason, including for purposes of spamming or marketing.

Failure to do so may amount to the unlawful interception of a communication, the infringement of copyright and/or the infringement of the right to privacy.

1. 1. Neither Cidel, the sender of the email, or any other Cidel representative shall be liable for any loss, damage or expense of whatever nature (including without limitation that caused by the corruption or loss of data, damage to software programs and interruption of business operations) resulting directly or indirectly from the transmission of the email (including without limitation any malicious software code or viruses transmitted together with the email or any corruption to or loss of data contained in the email).
   2. The views and opinions expressed in the email do not necessarily reflect the views and opinions of Cidel. In particular, no Cidel representative or employee may send:

• • • unsolicited commercial messages (“spam”)
    • messages that infringe any third party’s copyright, trademarks or other rights and interests (“infringing content”) and
    • messages containing content that is offensive, derogatory, defamatory or otherwise unlawful (“offensive content”)

If the email constitutes spam, contains infringing content or offensive content, or was otherwise sent for purposes unrelated to the official business of Cidel, Cidel shall not be liable for any loss, damage or expense of whatever nature resulting therefrom.

1. Cidel reserves the right to read, monitor, access, block, delete, copy or otherwise intercept any email sent in reply to the email.
2. Where the time or date on which the email was transmitted is in issue, unless the content thereof expressly provides otherwise, Cidel will be deemed to have-
   • sent the email once reflected as “sent” on our mail servers; and
   • received an email once reflected as “received” on our mail servers
3. The disclaimer shall be governed by and interpreted in accordance with the laws and regulation of the country or territory that has the right to exercise jurisdiction over the matter. Jurisdiction of the applicable region shall supersede any terms contained in any email received by Cidel, insofar as these conflict with this disclaimer.

By accessing this Website, you acknowledge these terms of use and agree to be bound by them.  Cidel Bank & Trust Inc. (including its subsidiaries and affiliates, “Cidel”) reserves the right, in its sole discretion, to modify, alter or otherwise update these terms of use at any time and you agree to be bound by such modifications, alterations or upgrades.

Cidel is not responsible in any manner for direct, indirect, special or consequential damages, however caused, arising out of your use of this Website and/or any web browser, including any damages you may suffer if you transmit confidential or sensitive information to us or if we communicate such information to you at your request over the Internet. Links to other websites from this Website are for convenience only. No endorsement of any third party products, services or information is expressed or implied by any information, material or content referred to or included on, or linked from or to this Website.  This Website and the information is provided “as is”.  Cidel does not warrant the accuracy, adequacy, timeliness or completeness of this Website or Website information and disclaims liability for any errors or omissions.  No warranty or condition of any kind is given in the Website or Website information.  Cidel does not warrant that the Website will be available and meet your requirements, that access will be uninterrupted, that there will be no delays, difficulties in use, defects, incompatibility, failures, errors, omissions or loss of transmitted information.

Certain names, words, titles, phrases, logos, icons, graphics or designs, or other content on the Website are trademarks or trade names owned by Cidel or its subsidiaries.   Nothing on this Website shall be construed as conferring any license of any intellectual property rights, whether by estoppel, implication or otherwise.  Except when otherwise stipulated, the information otherwise may not be copied, displayed, distributed, downloaded, licensed, modified, published, reposted, reproduced, reused, sold, transmitted, used to create a derivative work or otherwise used for public or commercial purposes with the express written consent of Cidel or its subsidiaries.  Any unauthorized downloading, re-transmission, or other copying or modification of trademarks and/or the content of the Website may be a violation of federal or other law that may apply to trademarks and/or copyrights, and such actions could subject the copier to legal action.

In compliance with the Bank Act and the Trust and Loans Companies Act, the following offices have been designated by Cidel Bank & Trust Inc., Cidel Bank Canada, Cidel Asset Management Inc., Cidel Trust Company, and Cidel Pty Ltd. for the service of enforcement, including for Canada Revenue Agency and Family Maintenance and Support Orders.

Cidel (Pty) Ltd.
32 Impala Rd
Chislehurston
Sandton, 2196
South Africa

Cidel Bank & Trust Inc.
Cidel Place
Lower Collymore Rock
St. Michael
Barbados

Attention: Legal Department

Cidel Trust Company
Vintage Towers 1
Suite 403, 322-11th Avenue SW
Calgary, Alberta
T2R 0C5
Canada

Attention: Legal Department

Cidel Bank Canada
60 Bloor St. West 9th Floor
Toronto, ON M4W 3B8
Canada
Attention: Legal Department

Barbados signed the Multilateral Competent Authority Agreement (MCAA) on October 29, 2015 and joined over 100 jurisdictions participating in the Convention, who have agreed to embrace the Automatic Exchange of Information standard which sets out the due diligence and reporting rules to be applied to nancial institutions of participating jurisdictions. This OECD initiative encourages governments around the world to implement greater cross border tax compliance, transparency and cooperation, with the ultimate goal to reduce tax evasion through enhanced information reporting.

Click here to download Controlling Person Tax Residency

Click here to download Entity Self-Certication for FATCA and CRS

Click here to download Individual Self-Certication for FATCA and CRS

Cidel is licensed and regulated by the Central Bank of Barbados and is subject to the International Financial Services Act, 2002-5. The Board of Directors, Audit Committee, senior management and employees of Cidel are guided by internal policies as well as the Money Laundering and Financing of Terrorism (Prevention and Control) Act, 2011-23, the Anti-Terrorism Act, 2002-6 and the Anti-Money Laundering (AML) / Combating Financing of Terrorism (CFT) Guidance Note issued by the Central Bank of Barbados in conjunction with the Anti-Money Laundering Authority (revised 2011).

By nature of Cidel’s banking licence, it is restricted from conducting business with local residents. The business is sourced from Cidel’s related entities located in Canada (Cidel Financial Group, Cidel Trust Company and Toron Capital Markets), South Africa (Cidel Pty Ltd) and Bermuda (AFL Investments Ltd).

The Canadian subsidiaries are subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its related Regulations and Guidelines. The Act is administered by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and Cidel undertakes reasonable measures to ensure compliance with the Canadian AML requirements. Whereas Cidel Pty Ltd is regulated by the South African Financial Services Board as an approved Investment Manager. AFL Investments Limited is licensed and regulated by the Bermuda Monetary Authority under the Investment Business Act and subject to the Guidance Notes for Anti-Money Laundering(AML)/Anti-Terrorist Financing (ATF) Regulated Financial Institutions on Anti-Money Laundering and Anti-Terrorist Financing (October 2010) and the Proceeds of Crime Act, 1997.

Cidel is required to take reasonable and appropriate measures to establish the identities of their clients and to open accounts and conduct transactions only after identity is verified to our satisfaction. These measures are also applicable to Cidel’s relations with custodians, correspondent banks, professional intermediaries, investment advisors and agents.

Money laundering and Terrorist Financing are criminal offences in Barbados and in many other jurisdictions in which we operate. Cidel is committed to preventing the use of its business for such purposes, by establishing policies and procedures to ensure that

• Business acceptance policies are in place for identification and approval of new business.
• A senior employee has been designated the Chief Compliance Officer and the Money Laundering Reporting Officer.
• There are reporting obligations to the board of directors, the Audit Committee and senior management on Cidel’s AML/CFT framework.
• Adequate monitoring tools through the use of automated management information reports are used.
• Prohibition of accounts and relationships with shell banks.
• Client accounts are reviewed at a minimum every three years.
• Employees are trained to recognize and react appropriately to unusual or suspicious activity and understand their legal obligation to report activity and transactions.
• There is an internal and external reporting of suspicious transactions.
• Appropriate records of client information and transactions are retained for at least five (5) years after the relationship is concluded.
• Pre-employment background screening checks are also performed.

An annual independent AML review is conducted by an external party and the results are reported to the Board of Directors. From time to time, Cidel is also subject to an inspection by the Central Bank of Barbados which involves assessing the risk management framework of the Bank.

Cidel has developed and implemented various solutions to assist in generating management information reports which supports the compliance monitoring programme. In addition, Cidel’s client database is scanned monthly against the OFAC and EU/UN sanction lists to ensure that Cidel is not knowingly engaging in business with a listed individual or entity. World-Check, risk intelligence technology is also used to screen all parties connected to the client at inception and during the course of the relationship.

For further information, please contact, Shonda Forde, Chief Compliance Officer (sforde@cidel.com or 246 430-5350 ext 271).

Cidel Bank & Trust Inc. (hereinafter referred to as “the Bank”)

The Bank will accept funds and securities from time to time from Clients, who may be trusts, corporations or individuals, for the purpose of making investments on behalf of such Client in accordance with instructions received from the Client. All funds and securities received will be accepted by the Bank in trust for the Client in accordance with the terms and conditions set out herein which shall govern the relationship between the Bank and its Clients and seek to facilitate the expeditious handling of Clients’ instructions. In addition, special regulations and conditions may apply to particular kinds of business and service provided by the Bank and, if a copy of the same is not provided at the commencement of such business or service,those special regulations and conditions shall nevertheless apply.

Any funds transferred into the Bank’s trust account shall be deemed to be funds entrusted for safekeeping by the Bank. Such funds will be held in a bank account at a correspondent bank or custodian in the Bank’s name designated as a client account. At all times this account will be segregated from the Bank’s own funds.The funds may be held with other client money in a pooled arrangement at the correspondent bank or custodian. Where funds held on a Client’s behalf are placed on deposit at another financial institution, all interest earned on such funds will be credited to the Client’s account.
The Bank does not ensure the tax consequences of any transaction.

The list of signatures of persons authorized to sign for the Client, which the Client had filed with the Bank, shall be binding upon the Client until written notice of changes shall have been received by the Bank. The Bank will require each authorized signatory to provide its standard due diligence information as set out in its application form. Each new signatory to an account will also be required to provide the Bank’s standard due diligence information for consideration before being accepted as a signatory to an account.The Bank reserves the right to reject any signatory to an account where such signatory fails to satisfy or maintain the Bank’s established standards. Each authorized signatory will be required to provide updated due diligence information from time to time. Failure to provide updated information upon request may lead to the suspension of the relationship.

All funds, property or other assets held by the bank for the credit of two or more Clients jointly or in joint names shall be the property of the joint account holders as joint tenants, and the Bank may rely upon and act in accordance with the instructions of and deal with instructions purporting to be made, drawn, accepted, endorsed or given by either or all of them or otherwise as indicated on the Account Opening Form.The liability of joint account holders to the Bank shall be joint and several. Unless expressly indicated to the contrary,the Bank may act upon the instructions of a survivor and deal with instruments signed by the survivor alone. Such survivors shall notify the Bank immediately upon the death of one of their number and the Bank shall be entitled to call for and rely upon evidence (if any) of death. If a joint account is opened, remittances received by one account holder only shall automatically be credited to the joint account unless a separate account exists in the exclusive favour of the named Client or unless the Bank is in possession of instructions to the contrary.

A corporate Client shall notify the Bank in writing of any amendments to its Memorandum, Articles of Association or corresponding documents or any change in its name, directors, officers, authorized signatories or mandate as contained in the Account Opening Form or the then-current mandate. The Bank may rely upon, or decline any notice of amendment, or revocation of any mandate, or instructions given to it, until such time as evidence to its satisfaction has been received confirming the authority and validity of such notice. Until such time, the Bank may rely and act upon instructions given to it by an authorized signatory designated as such in the then-current mandate without liability on its part.

The Bank at the close of each accounting period, for the particular client account shall forward to the Client unless otherwise directed, a statement pertaining to that particular account for the preceding accounting period. Objections to such statement or to other communications from the Bank must be made immediately. In the case of delay in making such objection, any loss resulting therefrom shall be borne by the Client. Further notice must be given immediately to the Bank when an expected notice is not received by the Client in due time. If notice is not given within thirty (30) days, the statement of account shall be deemed to be approved. All communication by the Bank shall be deemed to have been transmitted when sent to or held at the disposal of the Client in accordance with his instructions, or for his protection in a manner which deviates therefrom. The date of the copies or mailing lists in the possession of the Bank shall be deemed to be at the time of dispatch.

The funds held on behalf of Clients corresponding to Clients’ credit balances in foreign currencies are held in the same currency in or outside of the country whose currency is involved.The Client bears proportionately to his account balance all economic and legal consequences resulting from measures taken by the country of the currency or by the country where the Client’s funds are invested and affecting all the Bank’s trust assets held in either country.Obligations of the Bank arising from foreign currency client accounts shall be discharged exclusively at the place of business of the Bank. Remittances received in a currency for which there is no corresponding account of the Client shall be credited at the Bank’s discretion to an already-existing account of the Client and shall be maintained in the currency of the said existing account of the Client.

If drafts, cheques and other instruments received by the Bank for collection or discount are not paid, or if the proceeds thereof cannot be freely disposed of, the Bank shall be entitled to cancel any credit given and charge the Client’s account for the same, and shall retain its rights in connection with such instruments until the payment of all indebtedness including all costs and expenses of the collection. The Bank will give value for cheques and drafts only after the lapse of the number of business days indicated in its Schedule of Minimum Amounts, Fees and Conditions, calculated from the business day following the day of receipt.

Damage resulting from delays, losses or mistakes in transmission of any advice, instructions in whatever format shall be borne by the Client. Likewise, the Client shall bear all losses resulting from failure by the Bank to discover forgeries or other defects, particularly with respect to identification or capacity to act. Neither the Bank or any related person shall be liable for any costs, expenses, losses or damages whatsoever excluding only the consequences of actual fraud on the part of the Bank or any employee of the Bank. Moreover, the Bank shall be entitled without liability on its part to refuse to act if in its opinion,there is any doubt as to the validity or authenticity of any instructions given.

The Bank will execute payment instructions provided they do not include conditional clauses, timing requirements or approval of documents. Where payments are executed through a correspondent bank, that Bank’s charges, if any, will be borne by the beneficiary, unless otherwise stipulated by the Client. In case of delay in carrying out payment instructions, the Bank shall in no event be liable for more than the payment of interest for the period involved, except where its attention has been specifically directed to the risk of additional damage.

• Duties of the Bank -Securities and other valuables shall be kept in custody accounts with the same care as the Bank’s own property..The Bank may keep the property in custody abroad in its name for the account and risk of the Client. Unless the Client specifies separate custody and agrees to assume expenses thereof, the Bank is expressly authorized to effect the safekeeping of securities in nominee format pooled with other Client securities. Any additional amounts that may be paid to the Bank as a result of pooled investments will be for the Bank’s account and not that of the Client. The safe custody charges set out in the Bank’s Schedule of Services and Fees will apply.
• Duties of the Client -Unless otherwise agreed, the Client must take all other steps necessary to protect his rights in connection with the property deposited, in particular, the giving of instructions for the exercise or sale of subscription rights or conversion rights for the payment of calls on partly paid shares, and for effecting exchanges of securities. If no instructions are received from the Client, the Bank shall be entitled to act in its discretion.

Where a Client is acting as Trustee or in any other fiduciary capacity or where the rights of the Client against the Bank are subject to any encumbrance, equity or third-party interest, then, notwithstanding any notice of the same, the Bank shall be entitled to disregard the same and to treat the Client as absolute beneficial and unencumbered owner subject to any written directions from the Client to the Bank properly made in accordance with these conditions and the then-current mandate.This provision and all other provisions contained in these conditions and the current mandate shall be binding on all third parties claiming an interest in the account.

Except where otherwise agreed by the Bank in writing, the Bank shall be entitled to adjust interest credits, exchange rates and commissions, effective immediately, to the prevailing conditions, and at any time to terminate business relationships. The Bank shall be entitled at any time to set-off against each other the balances of all accounts of the Client (irrespective of the currency of the account), or to enforce the same individually. The Bank shall have a lien on all assets which are held for the Client for all claims, whether or not such claims shall be due, and whether or not in the case of extensions of credit such claims shall be unsecured by specific collateral. In the event of default by the Client, the Bank shall be entitled to realize such assets, which assets are hereby transferred to the Bank for such purpose.

The Bank shall not be liable for decisions left to its discretion or otherwise in the absence of its fraud and dishonesty. The Client shall indemnify the Bank against all loss, damage, liability and expense as it may suffer or incur as a result of the relationship otherwise than as a result of its fraud or dishonesty, and the Bank shall be entitled to debit any account of the Client for the purpose of satisfying such indemnity.

Place of Performance -The place of business of the Bank shall be the place of performance of the obligations of the Bank and the Client, as well as the place for the instituting of proceedings for the collection of debts owed by Clients domiciled abroad.
Governing Law -The legal relationship between the Bank and the Client shall be governed by the laws of Barbados.The Client shall submit to this jurisdiction in the case of any legal proceedings brought by the Bank against him, but the Bank shall be entitled to bring proceedings against the Client at his country of domicile or in any other competent jurisdiction, in which event, the laws of Barbados will nevertheless apply. The service of process out of any court in any proceedings instituted against the Client may be effected by air-mailing of copies with postage prepaid to such address as shall have been notified to the Bank or known to the Bank and in any other manner permitted by law.
Conflicting Claims -In the event of conflicting claims in respect of any Client account or any part of the monies or other assets held by the Bank, the Bank may in its absolute discretion take such steps as it may deem necessary to safeguard its interest and shall not in any event be liable for complying with any order of any court in Barbados or elsewhere.The Bank shall be entitled without liability to the Client, pending determination of any such claim, to refuse to pay or deliver to the Client any monies or other assets in its possession or control which are the subject of such conflicting claims
Probate Laws -In the event of death of a single signatory to an account, the probate laws of Barbados in force shall apply.

The Bank’s Schedule of Minimum Amounts, Fees and Conditions from time to time in force is an integral part of these General Conditions, and special regulations and conditions applying to particular kinds of business and service shall become a part of these General Conditions in the event the particular kinds of business and service are provided by the Bank.

The preservation of secrecy for banking establishments carrying on business within Barbados provided for under Section 46 of the International Financial Services Act, Chapter 325 of the Laws of Barbados, or any amendments thereto, is subject to qualifications. The Bank, its officers and directors, employees and mandatories are obliged to furnish certain information when lawfully required to do so by any Court of competent jurisdiction within Barbados under the provisions of any law of Barbados.Further,they may disclose information relating to the identity, assets, liabilities, transactions and accounts of the Client with the express or implied consent of the Client. The establishment of client accounts and securities deposits maintained under numbers or passwords is an internal measure by the Bank, affecting in no way its obligation vis-à-vis authorities to give evidence or information. The Bank shall at all times be subject to the direction of the Client. Unless otherwise advised by the Client, the Bank may act on oral instructions from any person authorized to give written directions pending delivery to the Bank of such written directions.The Bank shall not be obliged or required to determine whether any instructions issued to it by the Client are in compliance with any law or regulation.
Nothing herein shall restrict, limit or negate any rights of the Bank by law expressed or implied.

Click here to download the South Africa Mandate

This policy has been established by Cidel Bank Canada, Cidel Asset Management Inc. and Cidel Trust Company (collectively referred to as ‘Cidel’) in light of the obligations arising under the Accessibility for Ontarians with Disabilities Act, 2005 (the ‘Act’), and in consideration of the Integrated Accessibility Standards O.Reg 191/11 (the ‘Regulation’).

Cidel strives to meet the needs of persons with disabilities and has implemented standards to break down barriers and increase accessibility in areas of information and communication, employment, and customer service.

Cidel is committed to ensuring equal access and participation for people with disabilities, and to treating all people in a way that allows them to maintain their dignity and independence.

Cidel believes in integration and equal opportunity. We are committed to meeting the needs of people with disabilities by preventing and removing barriers to accessibility in a timely manner, and by satisfying the accessibility requirements under the Act and the Regulation.

Cidel’s Accessibility Plan sets out how we achieve accessibility by satisfying the requirements of the Regulation, and further provides strategic guidance on how we aim to improve accessibility and opportunities to Ontarians with disabilities. This plan is reviewed and updated at least once every 5 years, and a copy of the Accessibility Plan will be provided in an accessible format upon request. Please see the table below for the most recent Accessibility Plan.

Cidel ensures that training is provided to its directors, officers, employees and agents on the requirements under Ontario’s accessibility laws, and on the Ontario Human Rights Code, as it pertains to persons with disabilities. Training will be provided in a format that is suitable and appropriate to the duties of the recipients.

In accordance with the Regulation, Cidel will continue taking steps to ensure directors, officers, employees and agents are provided with appropriate training by:

• Adhering to the ongoing training requirements under the Act, Regulation, and the Ontario Human Rights Code, as it pertains to persons with disabilities;
• Ensuring training content is appropriate and relevant to address changes in the workplace;
• Providing training to new employees, and all employees whenever changes are made to the Accessibility Policy, as soon as practicable; and
• Maintaining a record of the training provided, including training dates, and the number of individuals in attendance.

Cidel’s training program is completed by all directors, officers, employees and agents on an annual basis and covers the following topics:

• The purpose and requirements of the Act and accompanying Regulations.
• How to interact and communicate with people with various types of disabilities.
• The purpose of assistive devices, and how to interact with people that use them.
• The purpose of service animals and how to interact with people that use them.
• The purpose of support persons, and how to interact with people who are accompanied by a support person.
• What to do if a person with a disability is having difficulty accessing Cidel’s services.

Cidel is committed to meeting the communication needs of people with disabilities, and shall consult with persons with disabilities to determine their information and communication needs.

In the event that information or a communication distributed by Cidel cannot be converted to an accessible format, it shall provide the person requesting the information or communication with an explanation as to why the information or communication cannot be converted, and a summary of relevant information or communication.

Feedback

Cidel will continue to ensure that its process for receiving and responding to feedback is accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communication supports upon request. As a part of this process, we will identify existing feedback processes and review them for accessibility purposes. Wherever necessary, Cidel will take steps to remove barriers to accessibility, in a timely manner, once they are identified.

Accessible Format and Communication Supports

Upon request, Cidel will provide, or will arrange for the provision of accessible formats and communication supports which account of the person’s accessibility needs due to disability. Cidel will consult with the person making the request in determining the suitability of an accessible format or communication support.

Accessible Website and Web Content

Cidel ensures that its website, including all of its web content, conforms to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level AA, except where this is impracticable.

Cidel is committed to fair and accessible employment practices. The Ontario Employment Standards Act, 2000 builds upon the existing requirements under the Ontario Human Rights Code, 1990 in relation to accessibility at all stages of the employment cycle.

Recruitment

Cidel will continue taking steps to notify applicants, the public and its employees that accommodations will be made available upon request to persons with disabilities during the recruitment and assessment process, in relation to the materials or processes to be used, and when people are hired.

Where a request for accommodation is received, Cidel will consult with the person to provide, or arrange to provide, suitable accommodations in a manner that takes account of the person’s accessibility needs due to disability.

When an offer of employment is made, Cidel will notify the successful applicant of its policies for accommodating employees with disabilities.

Informing Employees of Supports

Cidel will continue to inform its employees of the policies, and any updates thereto, that are used to support employees with disabilities. This includes policies on the provision of job accommodations which account for an employee’s accessibility needs due to disability. This information will be provided to new employees as soon as practicable after commencing employment.

Accessible Formats and Communication Supports for Employees

Upon request by an employee with a disability, Cidel will provide, or arrange for the provision of, accessible formats and communication supports for information that is required to perform the employee’s job, and information that is generally available to other employees in the workplace. In determining the suitability of an accessible format or communication support, Cidel will consult with the employee making the request.

Workplace Emergency Response

Cidel will provide individualized workplace emergency response information to employees where it is required due to the employee’s disability. If an employee with an individualized workplace emergency response plan requires assistance, with the employee’s consent, Cidel will ensure that a designated person is available to assist the employee. Cidel will provide this information as soon as practicable after becoming aware of the need for accommodation.

Cidel will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodations needs or plans are reviewed, and when Cidel reviews its general emergency response policies.

The Company will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodations needs or plans are reviewed, and when The Company reviews its general emergency response policies.

Individual Accommodation Plans

Cidel will develop individual accommodation plans for employees with disabilities in accordance with its established process.  Where requested or required, an employee’s individual accommodation plan will include any information regarding the provision of accessible formats and communications supports, as well as any individualised workplace emergency response information.

Return to Work Process

Cidel will develop a process for an employee returning to work after being absent due to disability, and requires disability-related accommodations in order to return to work. This process involves documenting the steps Cidel will take to facilitate the employee’s return to work, and will include an individual accommodation plan for the employee.

Performance Management, Career Development and Advancement & Redeployment

Cidel will account for the accessibility needs and individual accommodation plans of employees with disabilities when conducting performance management processes, providing career development and advancement opportunities to employees, or when redeploying employees.

Cidel is committed to service excellence, and is mindful of the principles of independence, dignity, integration and equal opportunity when engaging with persons with disabilities. Cidel recognises that persons with disabilities may require the use of assistive devices, such as communication aids or personal mobility aids, and wherever possible Cidel will make accommodations to ensure that persons with disabilities can access our services and facilities.

Cidel welcomes clients with disabilities that are accompanied by support persons, or assisted by service animals in our offices.

Cidel will ensure that our employees are trained and familiar with various assistive devices or supports that may be used by clients with disabilities, in accordance with our internal policies and procedures. A copy of these documents will be made available upon request.

Notice of Temporary Disruptions

In the unlikely event that Cidel experiences a disruption in the provision of its services, we shall provide clients with a disability who use the service notice of the disruption, details of the cause, its anticipated duration and a description of alternative facilities or services that will be made available in the interim.

Feedback Process

Cidel is committed to delivering the highest level of service to all of our clients. As a result, feedback from clients regarding the delivery of service to persons with disabilities may be given in confidence by telephone, in person, in writing or alternative methods through the following:

Email:    hr@cidel.com

Mail:      Cidel Asset Management

60 Bloor Street West

Toronto

ON M4W 3B8

Telephone:  (416) 925 5504 (Please ask for Human Resources)

Part I – General

Part 2 – Information and Communications Standards

Part 3 – Employment Standards

Part 4 – Customer Service Standards

Each Cidel entity (“Cidel”) is committed to ensuring that its internal policies, practices, and systems are free of barriers, emphasize the value of diversity, and promote full participation to ensure dignity, respect, and equal access for all employees.

Through our processes and practices, we are working to eliminate barriers to employment for people who are usually underrepresented in Canada’s workforce – Aboriginal people, people with disabilities, racialized persons, and women.

Consistent with human rights legislation, employment equity recognizes the value and dignity of each individual and ensures everyone has genuine, open and unhindered access to employment opportunities, free from any barriers, systemic or otherwise.

Cidel’s established employment equity statement reflects this:

Cidel is committed to equity in its policies, practices, and programs, supports diversity in employment, learning and work environments, and ensures that applications from members of underrepresented groups are seriously considered under its employment equity policy. All qualified individuals who would contribute to the further diversification of Cidel are encouraged to apply.

Click here to download the External Privacy Policy

Click here to download Relationship Disclosure Information.

Click here to download the Trade Matching and Settlement Statement

Click here to download the CBC/CTC Complaint and Dispute Resolution.

For the CAM Complaint and Dispute Resolution please reference our Relationship Disclosure Information above.

Number of Complaints dealt with by the Dispute Resolution Office– 0

Number of Complaints resolved by the Dispute Resolution Office – 0

Average length of time (in days) taken by the Dispute Resolution Office to deal with a complaint – 0

June 30, 2020

FORM CRS RELATIONSHIP SUMMARY FOR CIDEL ASSET MANAGEMENT INC.

Item I:  INTRODUCTION

The name of our firm is Cidel Asset Management Inc. and we are registered as an investment adviser with the SEC. It is important for you to understand that investment advisory fees and brokerage fees are different from one another. You may wish to avail yourself of free and simple tools that are available to you for the purposes of researching our firm as well as other firms and financial professionals at Investor.gov/CRS, which also provides information about broker-dealers, investment advisers, and investing in general.

Is an Investment Advisory Account Right for You?

There are different ways you can get help with your investments.  You should carefully consider which types of accounts and services are right for you. We are an investment adviser and provide investment advisory services rather than brokerage accounts and services.  This document gives you a summary of the types of services we provide and how you pay.  This document also provides specific questions you may want to ask us to understand our services in greater detail.

Item II: RELATIONSHIP AND SERVICES

What investment services and advice can you provide me?

We provide investment advice to our clients on either a discretionary and non-discretionary basis to managed accounts through the use of a range of third party portfolio managers that invest in both traditional and alternative assets If you select to open an account with us on a discretionary basis, we will be responsible for making all of the investment decisions for your account, in accordance with your stated investment objectives, without providing contemporaneous notification or consent to or from you. If you elect to open an account on a non-discretionary basis, we must receive your consent prior to making any transactions in your account. The nature and terms of your account will be agreed upon and memorialized in your investment advisory agreement (“IMA”) with us. Our advice may involve us providing you with asset allocation and the selection of investments. The advice we provide is guided by your stated investment objectives (i.e., maximum capital appreciation, growth, etc.). The process we use with respect to opening and maintaining your account starts with establishing and monitoring your appropriate asset allocation. Your risk tolerance and financial objectives will be considered in tailoring an asset allocation that is suitable to you. This allocation will primarily include equities, fixed income and cash equivalents, but may from time to time include other asset classes or products. Primary emphasis will be on large capitalization, publicly traded, domestic and international common stocks. We will review your account on at least a monthly basis to ensure it is being maintained in accordance with your stated investment objectives. There is currently no minimum amount required in order to open an account with us. Please see our ADV Part 2A (“Brochure”) that contains greater details about the firm’s services, personnel, risks and policies at:

https://www.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=569668.

We believe it is important for you to understand your account, its terms and limitations and our mutual relationship thoroughly. It is in this connection that we should have a conversation where we, at minimum, help you to understand the answers to the following questions:

*Given my financial situation, should I choose an investment advisory service? Why or why not?

*How will you choose investments to recommend to me?

*What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean?

Item III: FEES, COSTS, CONFLICTS AND STANDARD OF CONDUCT

What fees will I pay?

Your account will be charged a negotiable, asset-based management fee typically ranging from an annualized 0.10% to 1.75%. The management fee is agreed upon and memorialized in your IMA with us and is generally paid on a monthly or quarterly basis. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. The main conflict that exists between our interests and yours is that the greater the assets in your account, the greater the management fee we will collect; we, therefore, have an incentive to encourage or facilitate the increase of assets in your account.

*Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?

*What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have?

Standard of Conduct When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means. For a more detailed list of risks and conflicts related to your account or your relationship with the firm, please see the firm’s Brochure that can be accessed using the link provided in Item II above.

            *How might your conflicts of interest affect me, and how will you address them?

*How do your financial professionals make money?

We make money solely based on our collection of the management fee described in Item III above. The management fee we assess to your account is based on the amount of assets we advise on your behalf; the greater amount of assets, the greater the management fee we collect. While we will typically collect the management fee whether your account generates a positive or negative return, it is in our best interest for your account balance to increase.

Item IV: DISCIPLINARY HISTORY

Do you or your financial professionals have legal or disciplinary history?

No. However, we welcome you to visit Investor.gov/CRS for a free and simple search tool to research our firm and our financial professionals.

As a financial professional, do you have any disciplinary history? For what type of conduct?

Item V: ADDITIONAL INFORMATION

Should you wish to obtain additional materials about us and/or the services we provide, please see our Brochure that can be accessed using the link provided in Item II above. If you wish to receive a copy of this Relationship Summary or other available, up-to-date information regarding our firm, please call us at + 416-925-4047 or email us at BTAMBLYN@CIDEL.COM.

Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?

Your primary contact person at the firm is the firm’s Chief Compliance Officer, Bryan Tamblyn. He can be reached at either the phone number or email address listed above in Item V