Optimum Asset Management Inc. takes reasonable measures to detect all significant existing conflicts of interest or those that it reasonably expects to see occur between its employees and clients.
This policy on conflicts of interest explains the measures put in place to enable it to honour this undertaking.
WHAT IS A CONFLICT OF INTEREST ?
We presume the existence of a conflict of interest when the interests of different people, in particular the interests of one of our clients and those of a registered employee, are incompatible or divergent.
A conflict of interest may involve a relationship with a related issuer, an employee of Optimum Asset Management Inc. who is a member of an external board of directors or who carries out external activities for compensation, a compensation practice that is incompatible with obligations to clients or a securities transaction over which a person of authority or person related to that the person of authority may have a right or exercise influence or control.
DETECTING AND PREVENTING CONFLICTS OF INTEREST
All employees of Optimum Asset Management Inc., regardless of their activities and the framework of the duties they perform, are obliged to annually declare and confirm the possession of all securities' accounts in their name or in the name of related persons. This declaration enables Optimum Asset Management Inc. to ascertain and to monitor all held securities' position. Moreover, an internal procedure requires that each employee obtain authorization from a specified person of authority before trading for his or her personal account or for the account of a related person.
Should a position held by an employee or related person place the employee in a conflict of interest, the employee undertakes to disclose this conflict of interest and to sell the security if Optimum Asset Management Inc. makes the request.
Moreover, it is a requirement at Optimum Asset Management Inc. that employees make an annual declaration of the external activities they carry out for compensation or benefit as well as any involvement in an external board of directors.
MONITORING, AVOIDANCE AND DECLARATION
With its internal policies and procedures, Optimum Asset Management Inc. ensures it is able to identify existing conflicts of interest and prevent those that may occur.
Measures have been taken to avoid and to monitor conflicts that could cause prejudice to its clients or to the financial markets.
Optimum Asset Management Inc. undertakes to declare the existence of known conflicts where a reasonable investor would expect to be informed or conflicts that could compromise the integrity of the firm with respect of its clients or the financial markets. Optimum Asset Management will obtain the specific authorizations, as necessary, before making recommendations or carrying out transactions.
Optimum Asset Management Inc. has selected, primarily, the following provisions regarding securities of an issuer with a relationship to Optimum Asset Management Inc. or to one of its partners, officers or directors:
1. It publishes on its website an up-to-date list of all securities of related issuers;
2. It provides a list of securities of related issuers to all new clients, when an account is opened; and
3. It obtains authorization from clients before purchasing or selling securities of a related issuer.
Moreover, Optimum Asset Management Inc. does not hold any exclusivity agreement with dealers in respect of transactions. The executing dealers selected are those that offer the best services with regards to the following criteria: best possible execution price, quality of execution and effectiveness of research provided. The satisfaction of client needs is a priority for the selection of our dealers.
Optimum Asset Management Inc. has also adopted a whistleblowing policy that encourages employees to inform to the Compliance Manager of any wrongdoing or real or apparent conflict of interest on their part or, on the part of another employee.