Aventine Asset Management Inc.

Aventine Management Group is committed to maintaining the highest level of confidentiality regarding the personal information that clients and other related parties share with us. We have always recognized that this is your information, not ours, and we only share it when we have your express permission. Aventine is guided and governed by the Personal Information Protection and Electronic Documents Act (PIPEDA), which regulates our collection, use and disclosure of personal information.

Accountability

Aventine is responsible for the personal information you have provided to us. We have procedures in place to ensure that this information is appropriately safeguarded and review these processes regularly. All employees and partners of Aventine must abide by the principles outlined below.

Collecting Personal Information

Personal information includes your name, address and telephone number, birth date, social insurance, government issued photo ID, and your financial asset or investment information. Personal information is collected through account applications and other forms, or through conversations or other correspondence with you. We collect this information about you in order to identify you, to contact you or a designated representative, to understand your investment needs, to make suitable investment decisions for your portfolio, to manage the administration of your account, and to satisfy legal, regulatory, custodial and tax reporting requirements.

Obtaining Your Consent

Aventine’s Managed Account Agreements contain a number of sections in which you are requested to supply personal information about yourself. We only request information that is necessary for the opening and operating of your investment account. By completing and signing this agreement or by providing us with personal information by any other means, you are consenting to the collection of your personal information and any subsequent personal information that is collected by us for the purposes which we have set out. You may withdraw your consent at any time, subject to legal and contractual conditions; however, this may have an impact on the services that we are able to provide to you.

Limiting the Use, Disclosure, and Retention of Your Information

All employees of Aventine are accountable for safeguarding and maintaining the privacy of personal information under their control. Employees have been appropriately instructed and trained to ensure that account information is only supplied to people who are expressly authorized by you to receive it. To maintain awareness of our policies and practices in this regard, annually we have all of our employees sign a Confidentiality Agreement affirming their undertaking to faithfully abide by these policies. To satisfy regulatory requirements, personal information is to be retained for at least seven years.

We will not disclose your personal information to third parties, except to the extent required to fulfill the purposes we have set out. We use service providers in various aspects of the services we provide to you, including, but not limited to, custodians, transfer agents, fund accounting, administrators, storage facilities, information technology providers, auditors, lawyers and other third parties. These third parties are only provided with the information necessary to perform the required services, and we require, under written agreements that these third parties protect the privacy of your information. We may be required to disclose your personal information to domestic and international governments, and other regulators. We will only do so when required by law. We will never sell your personal information.

Responding to Inquiries and Complaints

Inquiries or complaints will be dealt with promptly. Please direct your communication in writing, to the address indicated below. The Compliance Team will acknowledge your query, investigate and provide you with a response within 30 days.

Aventine Management Group Inc
Suite 3400, 2 Bloor Street West
Toronto ON M4W 3E2
Attention: Compliance & Privacy Department