Policy

RP Investment Advisors (“RPIA”) is committed to fair information practices for individuals with whom it deals and for its employees.

This Privacy Policy outlines the principles by which RPIA operates to protect the Personal Information of individuals and employees that we collect, use or disclose in the conduct of our investment activities, governance, internal administration and contacts with the public.

This Privacy Policy incorporates the ten principles of the CSA Model Code which was published in March 1996 as a National Standard of Canada. It also incorporates the provisions of Part 1of the Personal Information Protection and Electronic Documents Act.

Principles

Accountability

RPIA is responsible for all Personal Information under its control, including Personal Information disclosed to third parties for processing.

Identifying purposes

RPIA will identify the purposes for which personal Information is collected at or before the time the personal information is collected. The purposes for which RPIA collects personal information shall be those that a reasonable person would consider appropriate in the circumstances.

RPIA collects personal information for the purpose of recruitment, administering the employment relationship between RPIA and its employees, undertaking diligence in respect of RPIA investment activities, managing investments, processing subscriptions, responding to requests for personal information or inquiries from the public and as required or permitted by law. Personal information may be collected from the individual or through the conduct of background or reference checks.

Consent

RPIA will inform the individual in a meaningful way of the purposes for the collection, use or disclosure of personal data. RPIA will obtain the individual’s consent before or at the time of collection, as well as when a new use is identified.

RPIA may collect, use or disclose personal information about an individual or employee without consent if it is clearly in the interests of an individual or employee and consent cannot be obtained in a timely way, such as when an individual or employee is seriously ill or incapacitated, in cases of emergencies threatening life, health or security, when seeking consent may defeat the purposes of collecting the personal information for an investigation of a breach of an agreement or contravention of a federal or provincial law, when Personal Information is disclosed to a lawyer representing RPIA, to comply with a subpoena, warrant or other court order, pursuant to lawful and authorized requirements or requests for