STATEMENT OF POLICIES AND RELATED ISSUERS
Respect for the Law: RN Croft Financial Group Inc., its officers and employees meticulously abide by, in letter and spirit, all laws governing our business and securities activities.
RN Croft Financial Group Inc. and its officers and employees must deal fairly, honestly and in good faith with clients.
Confidentiality of Client Information: Confidentiality of client information is an essential standard of our firm. R.N. Croft Financial Group Inc. will make every effort to ensure that only authorized parties have access to a clients’ personal information. R.N. Croft Financial Group Inc. may release client information only where such information is reasonably required in the normal course of servicing and managing a client’s portfolio. R.N. Croft Financial Group Inc. will use such information only for the purpose for which it was intended or for a use consistent with that purpose. R.N. Croft Financial Group Inc. may also disclose information where it is required to do so by law.
Misuse of Confidential and Insider Information: The misuse of confidential information or misuse of any insider information not generally disclosed, for personal gain or for the benefit of anyone else, is prohibited and grounds for immediate dismissal of the offending party/parties employed by R.N. Croft Financial Group Inc. and/or its subsidiaries.
Conflicts of Interest: To uphold public confidence and esteem, we continue to adopt and amend our policies and procedures to assist us in identifying and minimizing conflicts of interest that we may face.
Related/Connected issuer to RN Croft Financial Group Inc.: A related/connected issuer means a person or company that influences, or is influenced by, another person or company.
The following are related/connected issuers to RN Croft Financial Group Inc:
Nature of the Relationship: RN Croft Financial Group Inc. acts as Investment Manager and Trustee for the related issuers. RN Croft Financial Group Inc has an agreement in place with Croft Capital Management Inc, (a related company), to provide administrative support and marketing services for the related issuer.
Disclosure: RN Croft Financial Group Inc. acts as portfolio manager, and as such it will, before acquiring discretionary authority in respect of the securities of a related/connected issuer of RN Croft Financial Group Inc. or of the connected issuers listed above, or in the course of a distribution, in respect of securities of a connected issuer of RN Croft Financial Group Inc, and once within each twelve-month period thereafter, provide the client with its current Statement of Policies and obtain the specific and informed consent of the client to the exercise of the discretionary authority.
The securities laws of certain jurisdictions in Canada require securities dealers and advisers, when they trade in or advise with respect to their own securities or securities of certain other issuers to which they, or certain other parties related to them, are related or connected, to do so only in accordance with particular disclosure and other rules. These rules require dealers and advisers, prior to trading with or advising their customers or clients, to inform them of the relevant relationships and connections with the issuers of the securities. Clients and customers should refer to the applicable provisions of these securities laws for the particulars of these rules and their rights or consult with a legal adviser.
Revision or Amendment: Revisions or amendments to this statement of policies will be provided to each client in accordance with the applicable law.
For questions or clarification of items, please contact
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