Conflict of Interest

Omega Securities Inc’s (OSI) mission is to maintain the highest level of integrity, and thus best serve our Subscribers, the Canadian Financial market and the Nation as a whole. In order to achieve this we have endeavoured to instill in our Directors, Officers and Employees a culture of compliance where both the letter and spirit of the regulation that governs our industry and the best interest of our clients and the trading community is PARAMOUNT.
In order to achieve this Omega Securities Inc has managed conflict of interest on three fronts:

EDUCATION:

• Each director, officer and employee is made aware of and complies with their responsibilities as set out in all Company Policies and Procedures Manuals and The Internal Controls – Procedures Manual, written acknowledgement from each individual is received on an annual basis.
• OSI communicates all compliance-related bulletins from regulatory and self-regulatory bodies to its employees in a timely manner. All directors, officers and employees confirm in writing their understanding of and compliance with these Policies and Procedures on an annual basis.
• All registered employees comply with course, training and continuing education requirements.
• OSI educates its employees about trading rules and ethical standards. Specifically, employees are made aware of (i) what the legal restrictions are on the use of trading information, (ii) what the legal consequences are for OSI and its employees if applicable rules are breached (i.e. civil and quasi-criminal liability and securities commission and self-regulatory organization disciplinary proceedings), and (iii) what their ethical responsibilities are.
• OSI supervises and documents the implementation and execution of all employee training programs and courses, to ensure that they are compliant with national policies established by applicable regulatory and self-regulatory bodies
• All employees of OSI receive periodic training with respect to anti-money laundering laws and regulations.

INFORMATION BARRIERS

• OSI has established, maintained and enforces reasonable safeguards and procedures to protect trading information with a view to ensuring that there is no improper use of proprietary information by employees, officers and directors.
• Access to trading information on OSI’s information systems is limited to the appropriate employees and such employees are instructed in methods aimed at preventing other employees of OSI or its affiliates from gaining access to such information.
• Employees in possession of Inside Information must maintain the confidentiality of such information and abstain from trading for OSI or for a Personal Account or a Related Account until it has been generally disclosed.

SUPERVISION

• All proposed trades by employees and consultants with direct access to live client orders and confidential post-trade information (“Direct Access Personnel”) must first be pre-approved by the Chief Compliance Officer (CCO. Employees may not deal with another member of IIROC without the prior written consent of the CCO. All such pre-approvals will, among other things, be conditional on a copy of all confirmations and statements subsequently being provided to OSI, and consent is not intended to be given where price-sensitive order information is known or otherwise available to the employee and has not been publicly disclosed. Employees’ spouses and accounts under employees’ control will be subject to similar constraints wherever practical and reasonable.
• Ensure that OSI’s employees register Outside Business Activities (OBA’s) to insure that the OBA is not contrary to the provisions of applicable securities legislation and pre-approved by the CCO for OSI.

Through the continuous updating of these three policy pillars, with the assistance of the regulatory and self-regulatory bodies OSI intends to continuously update and improve our internal controls to maintain a marketplace that best serves society as a whole.

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