Conflict of Interest Disclosure for Coigne Capital Inc.

At Coigne Capital Inc., our unwavering commitment to maintaining the highest ethical standards and regulatory compliance is a testament to our dedication to consistently prioritizing our client’s best interests. This commitment, in line with the Client-Focused Reforms developed by Canadian industry regulators, including the Autorité des marchés financiers (AMF) in Quebec, ensures that we adhere to enhanced measures for managing conflicts of interest across all 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.

What is a Conflict of Interest?

A conflict of interest occurs when:

• Coigne Capital Inc.’s or its advisors’ interests diverge from the clients’.
• A potential influence (such as financial incentives or rewards) that could lead an advisor to prioritize their interests over the clients’.

Identifying and Managing Conflicts of Interest

Coigne Capital Inc. recognizes that conflicts of interest may arise while conducting business. Our policy is promptly identifying, documenting, and disclosing any actual or potential conflicts to clients. When a conflict of interest arises, Coigne Capital Inc. ensures the following steps are taken:

• The conflict is documented and disclosed in writing to the client.
• The conflict’s nature, extent, and potential impact are communicated.
• Mitigation measures are implemented, prioritizing the client’s interests to resolve the conflict.

Wherever possible, Coigne Capital Inc. seeks to avoid conflicts of interest. If avoidance is impractical, stringent controls will be applied to ensure that conflicts are effectively 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 and approved by both Coigne Capital Inc. and its financial partners, stakeholders, or broker-dealers. If such outside activities present potential conflicts, advisors must:

• Disclose the activity to clients and explain how the conflict will be mitigated.
• Ensure clients are informed of the dual occupation before any transaction occurs.

Dual License Disclosure Statement

Coigne Capital Inc. advisors may be licensed to offer financial investment products (e.g., mutual funds) and life insurance products. When clients purchase products from multiple companies, Coigne Capital Inc. ensures that any potential conflicts of interest arising from dual licensing are disclosed and properly managed.

Outside Business Activities

Coigne Capital Inc. and its broker-dealers evaluate the impact of any outside business activities undertaken by advisors. Evaluations include:

• Advisors’ ability to stay current on regulatory and product knowledge.
• Advisors’ capacity to properly serve clients without creating confusion or undue influence.
• Avoidance of potential conflicts related to these activities.

Any outside business activity that poses a conflict of interest will be disclosed to the client, and appropriate measures will be taken to mitigate the risk.

Compensation and Referral Arrangements

As part of its 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:

• All forms of compensation received by Coigne Capital Inc. are disclosed to clients.
• Recommendations are not based on compensation but on the suitability of products for the client.
• Referral fees paid to Coigne Capital Inc. are clearly outlined in referral arrangements and do not increase client costs.

Addressing Other Potential Conflicts

Coigne Capital Inc. prohibits personal financial dealings between clients and advisors, including but not limited to:

• Advisors act 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.
• Advisors engaging in private financial arrangements or loans with clients.

Client Complaints and Dispute Resolution

Coigne Capital Inc. takes client complaints seriously and ensures they are promptly addressed. Advisors must forward all complaints to Coigne Capital Inc.’s compliance department, an independent body responsible for ensuring adherence to regulatory guidelines and best practices, and financial partners for resolution. Under no circumstances are advisors authorized to resolve client complaints independently or offer compensation directly. All complaint handling adheres to the guidelines set forth by the AMF in Quebec and other regulatory bodies.

Continuous Monitoring and Review

At Coigne Capital Inc., we believe in the power of transparency. We regularly review our conflict of interest policies to comply with evolving industry regulations and best practices. Clients will be notified of any material changes to the conflict of interest policy as required by regulatory guidelines, including those issued by the AMF in Quebec. This notification will be done through our official communication channels, and clients can ask questions or seek further clarification, ensuring that they are always informed and involved.

Compliance with AMF Guidelines

In the province of Quebec, Coigne Capital Inc. strictly adheres to the guidelines established by 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. Coigne Capital Inc. ensures that any disputes arising during its operations, whether related to insurance or investment products, are promptly disclosed to clients and managed according to AMF guidelines.

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, disclosed, and managed in a way that permanently protects the client’s best interests. This commitment to our clients is at the core of our operations. We encourage you to contact your Coigne Capital advisor for further information or to discuss any concerns regarding conflicts of interest.