At Coigne Capital Inc., we are committed to maintaining the highest ethical standards and regulatory compliance. Our dedication to prioritizing our client’s best interests aligns with the Client-Focused Reforms developed by Canadian industry regulators, including the Canadian Investment Regulatory Organization (CIRO) and the Autorité des marchés financiers (AMF) in Quebec. These reforms ensure we adhere to enhanced measures for managing conflicts of interest across all our financial services and advisory activities.

These guidelines govern the conduct of Coigne Capital Inc., its financial partners, stakeholders, broker-dealers, and advisors to ensure transparency, integrity, and client-first principles in all interactions.

About Coigne Capital Inc.

Coigne Capital Inc. is a financial distribution company registered for insurance and offers insurance solutions through Qualified Financial Services. Our investment solutions, advisory services, and related investment portfolios are offered through Global Maxfin Investments Inc. This structure ensures that we provide comprehensive financial services while adhering to all regulatory requirements CIRO and other relevant regulatory bodies set forth.

Understanding Conflicts of Interest

A conflict of interest arises when the interests of Coigne Capital Inc., its advisors, or its partners diverge from those of our clients. This can occur in various forms, including but not limited to:

Divergent Interests: When Coigne Capital Inc. or its advisors have personal or financial interests that may compromise their ability to act in the best interests of clients.
Potential Influences: Situations where financial incentives, rewards, or other benefits might lead advisors to prioritize their interests over those of clients.
Understanding and managing these conflicts is crucial to maintaining trust and ensuring our clients receive unbiased and suitable financial advice.

Identifying and Managing Conflicts of Interest
Coigne Capital Inc. recognizes that conflicts of interest may arise during business operations. Our policy focuses on promptly identifying, documenting, and disclosing any actual or potential conflicts to our clients. When a conflict is identified, we adhere to the following steps:

Documentation and Disclosure:

Thorough Documentation: The conflict is meticulously documented.
Client Disclosure: Clients are provided with a written disclosure detailing the conflict.
Communication:
Transparent Communication: The conflict’s nature, extent, and potential impact are communicated to the client.
Mitigation Measures:
Client Priority: Implement strategies that prioritize the client’s interests to resolve the conflict effectively.
Strategic Solutions: Strategies may include recusal from certain decisions, seeking independent advice, or restructuring business arrangements.
Avoidance and Control:
Conflict Avoidance: Coigne Capital Inc. strives to avoid conflicts of interest wherever possible.
Stringent Controls: If avoidance is impractical, rigorous controls and safeguards are applied to ensure that the conflict is managed in favor of the client.
Dual Occupation and Outside Activities
Advisors at Coigne Capital Inc. may engage in outside occupations or volunteer activities, provided these are:

Disclosed: Advisors must

Reveal these activities to Coigne Capital Inc. and obtain approval from the company and its financial partners, stakeholders, or broker-dealers.
If such outside activities present potential conflicts, advisors are required to:

Client Disclosure:
Inform Clients: Inform clients about the dual occupation.
Mitigation Explanation: Explain how the potential conflict will be mitigated.
Prior Notification:
Advance Notice: Ensure clients know about the dual occupation before any related transaction occurs.
This approach ensures that clients are fully informed and their interests remain protected.

Dual License Disclosure Statement

Coigne Capital Inc. advisors may hold licenses to offer financial investment products (e.g., mutual funds) and life insurance products. When clients purchase products from multiple companies, the following measures are taken to manage potential conflicts of interest:

Disclosure: Any potential conflicts arising from dual licensing are fully disclosed to clients.
Management: Appropriate strategies are implemented to manage and mitigate these conflicts, ensuring that recommendations are based solely on the suitability of the products for the client’s needs.
Outside Business Activities
Coigne Capital Inc. and its broker-dealers evaluate the impact of any outside business activities undertaken by advisors. These evaluations consider:

Regulatory and Product Knowledge:

Ongoing Education: Ensuring advisors remain current with regulatory requirements and product knowledge.
Client Service Capacity:
Service Quality: Assessing advisors’ approaches to serving clients without creating confusion or undue influence.
Conflict Avoidance:
Conflict Identification: Identifying and avoiding potential conflicts related to outside activities.
If any outside business activity poses a conflict of interest, the following steps are taken:

Disclosure: The conflict is disclosed to the client.
Mitigation: Appropriate measures are implemented to mitigate the risk.

Compensation and Referral Arrangements

As part of our business model, Coigne Capital Inc. and its advisors may receive compensation from third-party providers for distributing financial products such as mutual funds and insurance. To ensure full transparency:

Compensation Disclosure:
Full Disclosure: All forms of compensation received by Coigne Capital Inc. are fully disclosed to clients.
Recommendation Integrity:
Client Suitability: Product recommendations are based on client suitability, not compensation incentives.
Referral Fees:
Clear Outlining: Referral fees paid to Coigne Capital Inc. are clearly outlined in referral arrangements.
No Additional Costs: These fees do not result in increased costs for the client.
Maintaining transparency in compensation and referral arrangements ensures our clients receive unbiased and appropriate financial advice.

Addressing Other Potential Conflicts

Coigne Capital Inc. strictly prohibits personal financial dealings between clients and advisors to prevent conflicts of interest. This includes, but is not limited to:

Personal Roles:
Role Restrictions: Advisors acting as Power of Attorney (POA), Executor, or Trustee for a client unless the client is a related person under the Income Tax Act of Canada.
Private Financial Arrangements:
Prohibited Transactions: Advisors engaging in private financial arrangements or loans with clients.
These prohibitions are in place to maintain the integrity of the advisor-client relationship and to ensure that all advice remains objective and client-focused.

Client Complaints and Dispute Resolution
Coigne Capital Inc. takes client complaints seriously and addresses them promptly and effectively. The process includes:

Complaint Forwarding:
Immediate Action: Advisors must forward all complaints to Coigne Capital Inc.’s Compliance Department.
Independent Oversight:
Regulatory Compliance: The Compliance Department, an independent body, ensures adherence to regulatory guidelines and best practices.
Partner Involvement: Financial partners are involved in the resolution process.
Prohibited Actions:
Advisor Limitations: Advisors cannot resolve client complaints independently or offer compensation directly.
Regulatory Adherence:
Guideline Compliance: All complaint-handling procedures adhere to the guidelines set forth by CIRO and the AMF in Quebec.
This structured approach ensures client grievances are managed fairly and transparently, maintaining trust and accountability.

Continuous Monitoring and Review
At Coigne Capital Inc., we believe in the power of transparency and continuous improvement. Our approach includes:

Regular Policy Reviews:
Policy Updates: Conflict of interest policies are regularly reviewed and updated to comply with evolving industry regulations and best practices.
Client Notifications:
Timely Communication: Clients are notified of any material changes to the conflict of interest policy as required by regulatory guidelines, including those issued by CIRO and the AMF in Quebec.
Communication Channels:
Accessible Information: Notifications are disseminated through our official communication channels.
Client Engagement: Clients are encouraged to ask questions or seek further clarification to ensure they are always informed and involved.
This commitment to continuous monitoring ensures that our policies remain effective and aligned with regulatory expectations.

Compliance with Regulatory Guidelines
Coigne Capital Inc. strictly adheres to the guidelines established by CIRO and, in the province of Quebec, the Autorité des marchés financiers (AMF). This includes compliance with all regulatory frameworks governing the identification, disclosure, and management of conflicts of interest in the financial services sector. Key aspects include:

Regulatory Compliance:
Operational Adherence: Ensuring all operations comply with CIRO and AMF regulations related to conflicts of interest.
Dispute Management:
Prompt Action: Promptly disclosing and managing any disputes arising during operations, whether related to insurance or investment products, by CIRO and AMF guidelines.
Ongoing Education:
Advisor Training: Providing regular training to advisors on CIRO and AMF regulations and best practices for managing conflicts of interest.
By adhering to these guidelines, Coigne Capital Inc. ensures that our conflict of interest management practices meet the highest regulatory compliance and client protection standards.

Summary
At Coigne Capital Inc., our commitment to providing transparent, client-focused financial advice and services is unwavering. Our conflict of interest policy ensures that any potential or actual conflicts are:

Promptly Identified
Fully Disclosed
Effectively Managed
This approach permanently protects our client’s interests and is at the core of our operations. We encourage you to contact your Coigne Capital Inc. advisor for further information or to discuss any concerns regarding conflicts of interest.

Contact Information
For more information or to discuss any concerns regarding our conflict of interest policies, please get in touch with us through the following channels:

Address: 3773 Boul. Côte-Vertu, Bureau 460, Saint-Laurent, QC

Toll-Free: 1 (888) 333-0398

Email: [email protected]

Our team is here to assist you and ensure your financial needs are met with integrity and professionalism.