The Accessibility for Ontarians with Disabilities Act (AODA) is a law that sets out a process for developing and enforcing accessibility standards. Recognizing the history of discrimination against persons with disabilities in Ontario, the purpose of this Act is to benefit all Ontarians by developing, implementing and enforcing accessibility standards to achieve accessibility for Ontarians with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises on or before January 1, 2025. To achieve accessibility, the AODA establishes five standards that recognize five areas of daily life:
1. Customer service standard
2. Information and communications standard
3. Transportation standard
4. Employment standard
5. Design of public spaces standard Together, these standards work towards making Ontario more accessible by ensuring people with disabilities can participate more actively in their communities Nour Private Wealth Inc. is committed to providing to our clients the highest standard of service possible.
Nour Private Wealth (NPW) commitment is;
• To provide our goods and services in a manner that respects the dignity and independence of persons with disabilities;
• To provide our goods or services to persons with disabilities and others in an integrated manner to enable a person with a disability to obtain, use or benefit from the goods or services;
• To allow our clients with disabilities, as much as is possible, an opportunity equal to that given to others to obtain, use and benefit from the goods or services;
• To ensure our policies deal with the use of assistive devices, service animals and support individuals* by persons with disabilities to obtain, use or benefit from NPW’s goods or services or the availability, if any, of other measures which enable them to do so.
• When communicating with a person with a disability, NPW shall do so in a manner that considers the person’s disability;
*In situations where confidential or personal information might be discussed, consent will be obtained from the client regarding the sharing of this information with the support individual.
The Canadian Securities Administrators have introduced securities laws that allow for alternative marketplaces to compete with the traditional stock exchanges, such as the Toronto Stock Exchange (TSX). Securities which trade on the TSX or the TSX Venture Exchange (TSX-V), currently the primary markets for Canada, may now also trade on an alternative marketplace. With the introduction of alternative marketplaces in Canada, NPW wishes to advise you of some of the conditions that could affect the execution of your orders.
The firm’s trading is not done directly on the exchanges; we are not a participating organization. NPW’s carrying broker, FCC, is a member of all the required exchanges and ATS’s. All trades are entered through the FCC trading infrastructure and the Dataphile order entry system. All orders entered through this system utilize a smart order router system and, therefore, cover all the required marketplaces.
NPW is committed to using all reasonable efforts to ensure that clients achieve “best execution” of their orders in respect to Canadian listed securities that are quoted or traded on Canadian marketplaces.
An order executed on more than one marketplace will be disclosed on your trade confirmation as “Executed on Multiple Markets – Details on Request”. If you wish to know what quantities were executed on what marketplaces, please contact your Advisor, who can provide you with this information promptly and without charge.
If your trade was executed on a single exchange, that exchange will be noted on your trade confirmation with either an abbreviation (with details on the back of the confirmation) or noted in the trailer field.
Execution on Foreign Marketplaces
All Orders for Canadian and non-Canadian listed equities to be traded on marketplaces outside of Canada may be executed by third party broker dealers (“Third Parties”). Third Parties may execute such orders as either an agent or principal. The fees or commissions charged to us by Third Parties for such orders may be reported as a net price. NPW and/or FCC may earn a fee or premium on foreign exchange transactions resulting from or required by such orders. If you have any questions regarding this notification, please contact your account Advisor.
Foreign Currency Exchange
For transactions in currencies other than that of the currency of the account, a conversion of currency may be required and will be carried out by the firm. FCC and/or NPW maintain a foreign exchange market spread. In performing foreign currency transactions, we may act as an agent or principal. We attempt to make a profit on providing foreign exchange transactions. The rates depend on the size, currency and timing of the transaction. If you are initiating a transaction that will require an accompanying foreign exchange component, ask your advisor about the available rates. Unless otherwise specified or agreed to, the currency conversion will take place at our applicable bid and ask spread, based on the prevailing currency rates. NPW currently only permits U.S. dollar foreign currency holdings in registered plans (e.g. RRSP, RRIF). Thus, any transactions in such accounts involving any other foreign currency will be automatically converted by us into Canadian currency as described hereinabove.
Fair Allocation Procedures
When NPW is involved in small financings or has a small participation in a larger financing, it is impractical to solicit interest from all the firms’ advisors or from all our clients. NPW has a small retail account base and they show little interest in such products. Nevertheless, client priority must be respected. NPW will add a message to all statements annually outlining our clients’ obligation to express their interest in any such private placements to their advisor. This statement is now also part of the NPW new client application package and reads: “For any company attempting to raise funds via small private placement transaction, NPW has a policy that any client of the firm will be considered solely responsible for reflecting their interest to their advisor. All such interest reflected by any client will be dealt with on a best efforts basis only.” We are required to have policies and procedures that provide reasonable assurance that we will ensure fairness in the allocation of investment opportunities among our clients. Trade allocation must be determined on a basis that is fair, reasonable and equitable for all clients. All client orders which are received before the books are closed will participate in any new issue on a pro-rata allocation basis.
Our firm’s policy is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ life and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all the firm’s books and records, and allowing our customers to transact business. In accordance with IIROC Rule 17.16 in the event of an SBD, Nour Private Wealth (NPW) is required to provide all clients’ access to their assets within 48 hours following the event. Access to assets means the ability of our clients to buy, sell or redeem securities and have assets, including cash, delivered out based on the client’s instructions. If we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities. Our plan anticipates two kinds of SBDs, internal and external.
• External SBDs prevent the operation of the securities markets or several firms, such as a terrorist attack, or a wide-scale regional disruption. Our response to an external SBD relies more heavily on other organizations and systems, especially on the capabilities of our clearing firm.
• Internal SBDs affect only our firm’s ability to communicate and do business and may include anything from temporary interruptions due to power outages or connection failures, to more serious incidents where there is no access to our premises, such as a fire in our building and/or pandemic or any other such critical event.
The firm will provide customers with notice in the event of a planned or unexpected disruption to its services or facilities (e.g., a disruption to customer services phone lines, website, or physical access to the NPW location), advising clients of procedures to follow to trade or access funds in their accounts. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available. The notice will be placed on our website.
The firm will provide customers with notice in the event of a planned or unexpected disruption to its services or facilities (e.g., a disruption to customer services phone lines, website, or physical access to the NPW location), advising clients of procedures to follow to trade or access funds in their accounts. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available. The notice will be placed on our website www.npw.ca
Our customers Should contact the Fidelity Clearing Canada ULC our carrying broker in case of a significant business disruption at our firm and in the possibility that customers are unable to reach us. Trading desk 416-216-6358, Banking 416-216-2660, Settlements 416-216-2606 and Transfers 416-216-2620.
The NPW Complaint Process has been adopted with a commitment to engage in and promote honest and ethical conduct and to provide complete, fair, accurate, timely and understandable resolutions to client complaints. It is our belief that by demonstrating to our clients that their issues are dealt with seriously enhances everyone’s confidence in the industry. As a demonstration of this commitment, NPW has adopted this Complaint Process. There are two types of complaints, service complaints and complaints that may involve regulatory infractions. While the firm will investigate either type of complaint, what is carried out is the process that will be followed if a potential regulatory infraction is involved.
How do I make a Complaint?
There are several resources available to you if you wish to make a complaint. Your first option is to contact your Investment Advisor with the issue. If you feel that your issue requires attention at a more senior level, you may direct your concerns to either the business location’s Supervisor (Branch Manager) or the NPW Compliance Department directly. Complaints may be written or verbal.
How is the Complaint Investigated?
All complaints involving regulatory or legal issues are investigated by the Compliance Department in conjunction with the business location’s Supervisor and the staff member involved in the complaint. Upon receipt of a complaint, NPW will acknowledge the issue in writing with a letter to you within 5 days. The letter will summarize the complaint, introduce the individual responsible for the investigation with their contact information so that you may contact them throughout the investigation to determine the status of the file, a reference to the maximum amount of time the investigation may take, and will enclose a copy of the Investment Industry Regulatory Organization of Canada (“IIROC”) “An Investor’s Guide to Making a Complaint” brochure. Our investigation process includes a review of account documentation, including account opening forms and client statements. Our investigation process may also include a request to interview you to clarify or attain any additional information required to investigate a complaint.
Alleged misconduct includes, but is not limited to allegations of:
• A breach of confidentiality,
• Misappropriation or misuse of funds or securities,
• Unsuitable investments,
• Unauthorized trading,
• Or other inappropriate financial dealings with clients, and
• Engaging in securities related activity outside the dealer.
Upon completion of our investigation, you will receive a substantive response within 90 day that will contain the following:
A summary of your complaint;
The results of our investigation;
Our final decision on the complaint, including an explanation;
and A statement describing the options available to you if you are not satisfied with our response, including:
• if a request is made within 180 days from the date of our final response, the ombudsperson service (i.e. the Ombudsman for Banking Services and Investments);
• submitting a regulatory complaint to IIROC for an assessment of whether disciplinary action is warranted; and
• Litigation/civil action.
Depending on the nature of the complaint and/or the outcome of an internal investigation, reporting to our regulators the Investment Industry Regulatory Organization of Canada (IIROC) through the National Registration Database and/or the Complaints and Settlement Reporting System (ComSet) may be required. NPW has designated the Chief Compliance Officer as the Designated Complaints Officer. The Designated Complaints Officer is charged with the oversight of the complaint handling process and may also act as a liaison between NPW and the Regulatory bodies. Any questions regarding the firm’s complaint handling process should be forwarded to the Designated Complaints Officer by contacting 905.845.9090. More information regarding the complaint handling procedures is provided on our website at www.npw.ca.
A conflict of interest may arise in circumstances where the interests of different parties (such as you and your advisor) are inconsistent or divergent. Actual, potential and perceived conflicts of interest arise where an action or decision by someone has the effect of benefiting others at that person’s expense. Such conflicts exist in almost all human interactions and, as we are an intermediary, acting for both buyers and sellers, conflicts will arise from time to time:
• between you and our firm as well as between you and your advisor;
• between you and our other clients: we act for many clients and must allocate investment opportunities fairly among all of them, so as not to intentionally favour one client over another;
• between us and our related or associated companies.
We have policies and procedures in place to address the handling of conflicts of interest.
• We avoid conflicts prohibited by law as well as conflicts that we cannot effectively control.
In situations that we do not or cannot avoid, where our interests may compete with yours, your interest is always given priority by our acting in one of two ways:
• We control or manage acceptable conflicts by attempting to physically separate different business functions, restricting the internal exchange of information in person or through systems, reducing the possibility of one part of our organization unsuitably influencing another, removing the financial incentive of an employee to favour a particular product or service over another that may be more suitable, and setting up and testing our operational review and approval processes.
• We disclose information about any remaining conflicts to you so that, when you evaluate our recommendations and actions, you can assess independently if conflicts are significant for you.
To help you understand and assess material potential and actual conflicts of interest, we have prepared a more detailed explanation of typical conflicts with examples of what we do in the case of any material ones, which can be found at www.npw.ca. If you have any questions or concerns, regardless of whether they involve conflicts of interest or anything else, please ask your advisor for an explanation and more information.
You acknowledge that by visiting, accessing and or using this web site that you agree to be bound by the terms and conditions of its use.
This web site shall be governed by the laws of the Province of Ontario and the Country of Canada and you voluntarily agree to submit to the jurisdiction over you by the courts of the Province of Ontario or any Federal court of Canada.
The information on this website does not constitute the official version of our disclosure documents and may not always be current. The website and access to it is provided strictly on an “as is” and “as available” basis without any warranties of any kind. The information contained in this web site is collected from sources believed to be reliable, but the accuracy and completeness of the information is not guaranteed.
In no event will Nour Private Wealth Inc. assume any responsibility or liability for the accuracy or losses caused by the use or misuse of this website or reliance on the information or content therein, including direct, indirect, special incidental, consequential, exemplary or punitive.
The information in this web site is intended for use by persons who residents in the jurisdictions where Nour Private Wealth Inc. is registered. Currently we are registered in the following Provinces in Canada, Alberta, British Columbia, Manitoba, New Brunswick, Nova Scotia, Ontario, Quebec. We are members of the Canadian Investor Protection Fund (CIPF) and the Investment Industry Organization of Canada (IIROC).
Unless otherwise noted Nour Private Wealth Inc. is either the owner or licensed user of the copyrighted material on this website. The Nour Private Wealth Inc’s name, logo, brand names and all other trademarks, are the property of, or licensed to, Nour Private Wealth Inc. and unauthorized use is strictly prohibited.
The information offered on this web site is not intended to provide any specific wealth planning, tax, legal or accounting advice. The information offered on this web site is not to be considered an offer to buy, sell or a solicitation of any kind to buy or sell any security, derivate or any other investment product or service.
Without the use of secure encryption this web site is not a secure medium for electronic communications. Confidential use of this web site cannot be guaranteed. You there for acknowledge that any confidential information transmitted by a user utilizing this medium may be read and / or copied by unauthorized individuals. Nour Private Wealth Inc. assumes no responsibility or liability for any harm that may occur in connection with any breach or hack that may compromise personal information transmitted through this web site. Be advised that trading instructions should not be communicated via email and if any such instructions are received they will not be acted on. Insurance Services are provided in Ontario through Nour Insurance Services Inc. not Nour Private Wealth Inc. The sale of Insurance products by your advisor is based on that advisors Insurance registration through the Financial Services Commission of Ontario.
It is the user’s responsibility to take all necessary precautions to scan for viruses and other malware. All internet email messages and their attachment received and sent through the facilities of this website and the computers used by all employee, agents and advisors are subject to review by supervisory personnel. Such communications are retained, and we may be required to produce them to our regulatory authorities. All products and services provided by Nour Private Wealth Inc. are subject to the terms and conditions of the applicable agreements governing their use.
PERSONAL INFORMATION DISCLOSURE
We value you as a client and we are committed to protecting the privacy, confidentiality, accuracy and security of your personal information that we collect, use, retain and disclose in our efforts to providing you with superior products and services.
This Personal Information Policy spells out the responsibility of NPW (“we”, “our”, “us”), and your rights as our applicant, client, former client or claimant (“you” or “your”), regarding the collection, use and disclosure of your personal information.
Your Personal Information
NPW understands that trust is an important factor in our relationship, and at NPW we take this very seriously. Protection of your privacy and the confidentiality of your personal information is a fundamental part of our responsibility toward you. Clients of NPW are entitled to a high degree of care in the handling of their confidential information through our policies and procedures as well as state-of-the-art equipment and computer security measures. We ensure that your privacy and the confidentiality of your information are protected. The personal information you provide to NPW (or which the firm collects with you consent) with respect to your account application will be protected and maintained in a client investment file with NPW. The key components of the firm’s policy are as follows:
• The client’s knowledge and consent are required before an employee/agent may collect, use or disclose a client’s personal information;
• If any of the personal information collected is sensitive, such as health information, NPW must obtain additional written or oral consent from the client before using or disclosing the information;
• NPW shall use care when storing or destroying client’s personal information to prevent unauthorized access.
What is Personal Information?
The term “personal information” refers to any information that specifically identifies you, including information such as your home address, telephone numbers, social insurance number, date of birth, assets and/or income information, employment history and credit history.
How are we accountable?
NPW is responsible for your personal information in its possession or custody, including personal information that has been transferred to, or received from, a third party in the course of commercial activities for processing or other purposes for which you have consented to us collecting, using and disclosing your personal information.
Why do we do it?
We collect, use, and disclose personal information to provide you with the investment products and services of NPW. Specifically, we collect, use and disclose your personal information to: • Verify your identity and correct your personal information;
• Determine your eligibility for NPW products and services, and for products that may be of interest to you from business partners with whom we have formed an association, and offer you these products and services, as well as analyze the suitability of our products or services for you;
• Accuracy: NPW will keep personal information as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. NPW will minimize the possibility that inappropriate information is used to decide about the individual.
• Safeguards: NPW will protect personal information with security safeguards appropriate to the sensitivity of the information.
• Openness: NPW will be open about its policies and procedures with respect to the management of personal information. NPW will ensure that individuals are able to acquire information about the firm’s policies and procedures without unreasonable effort. NPW will make this information available in a form that is generally understandable.
• Individual Access: Upon a request in writing, NPW will inform the individual of the existence, use and disclosure of their personal information and the individual will be given access to that information, except where the law requires or permits NPW to deny access.
• Questions and Concerns: An individual will be able to direct a challenge concerning compliance with the above principles to NPW Chief Privacy Officer.
When produced, updated versions of this Personal Information Policy can be obtained from your account advisor, the compliance department or you can direct any queries about this policy to NPW, Privacy Officer at the telephone, e-mail address, or mailing address listed below. If you have a complaint related to the Personal Information Policy or any of our procedures, contact our Privacy Officer. If your complaint is justified, we will take the steps necessary to resolve the issue, including amending our policy and practices, if necessary. If we are not able to resolve your concern, or if you have any other concerns about NPW Personal Information Policy and procedures, you may contact the office of the Privacy commissioner. NPW Privacy Officer will provide you with this contact information upon request.
For more information, to file a privacy complaint, to make inquiries or to opt out of all or parts of this Policy, please contact us at: Nour Private Wealth Inc. 2845 Bristol Circle, Oakville, Ontario, L6H 6X5 Attention: Privacy Officer Tel.: 905.845.9090 Fax: 905.845.3115 Email: email@example.com
BENEFICIAL OWNERSHIP INFORMATION DISCLOSURE
National Instrument 54-101 Communication with Beneficial Owners of Securities of a Reporting Issuer
EXPLANATION TO CLIENTS
Based on your instructions, the securities in your account with us are not registered in your name but rather in our name or the name of our carrying broker holding your securities on our behalf. The issuers of the securities in your account may not know the identity of the beneficial owner of these securities.
We are required under securities law to obtain your instructions concerning various matters relating to your holding of securities in your account.
The provinces of Quebec, Alberta and British Columbia have introduced regulations which set out specific responsibilities for the administration of “Unclaimed Property” if the last known address of the owner of the property was within one of these provinces. The legislation is designed to ensure that all reasonable efforts are made to return “Unclaimed Property to its owner. Unclaimed Property can include cash, stocks, bonds, mutual funds or other receivables held in client accounts at Nour Private Wealth Inc. (NPW), without recent activity (3 years), where the current location of the client is not known to us and the last known address is in one of Quebec, Alberta or British Columbia. NPW will maintain a database of accounts which may hold Unclaimed Property. The following provides specific information for each of these provinces and the rest of Canada.
The province of Alberta has established a service for residents who have lost track of property as a result of business or personal circumstances. To access the service’s website, please click here: https://unclaimedproperty.alberta.ca/publicTracs/searchUnclaimedProperty.do?event=init
The province of British Columbia has regulations that require holders of unclaimed property, where the current or last known address of the owner is in British Columbia, to make reasonable efforts to contact the owners and advise them of their unclaimed assets. In addition, the province has established an unclaimed property program to assist residents with recovering unclaimed property. To access the program’s website, please click here: https://unclaimedpropertybc.ca/searchp/search/
The province of Québec has established a service that assists individuals with locating unclaimed property. Revenu Québec is the agency responsible for recovering and administering unclaimed property for citizens of Québec. To access the Register of unclaimed property, please click here: https://www5.services.mrq.gouv.qc.ca/mrqanonyme/BR/BR01/BR01A1_01A_ConsulterBNR_P C /P_Consultation.aspx?Clng=A&WT.co_f=2ddcf8dc657fe7e8b331384272584389&TV=E
If you have an enquiry or claim in respect of Unclaimed Property either on your own behalf or, for example, in your capacity as attorney under a power of attorney or as estate trustee, please provide full details including your full name and account number in writing to firstname.lastname@example.org.