Privacy & Legal Registrations Jarislowsky, Fraser Limited is registered as a Portfolio Manager in all Canadian provinces and territories and as an Investment Fund Manager where required. It is also registered as an Investment Advisor with the Securities and Exchange Commission in the United States. Privacy Policy As our client, you are entitled to know how we protect your personal information and how we limit its disclosure. Accountability The collection, use and disclosure of data or information about individuals is subject to applicable laws on the privacy of information. To this effect, Jarislowsky, Fraser Limited (JFL) has designated a Privacy Officer to ensure adherence with this JFL Privacy Policy, which applies to all current and former clients of our firm, including all those who invest in our funds or have done so in the past. This privacy policy describes our policies and practices for collecting, disclosing, and safeguarding “personal information,” which may include financial or other information about you. Consent The knowledge and consent of the person is generally required for the collection, use and disclosure of personal information. You provided this consent at the time you opened your account(s) with us. We collect personal information about you from the following sources: Information we receive from you on our client profile form (know your client “KYC” form), the client profile update form, investment policy, agreement letters and other forms. We also collect personal information during both formal and informal meetings, as well as during our telephone conversations with you. This personal identifying information includes, but is not limited to, your name, address, date of birth, driver’s license or passport number, assets, income and any changes in your personal situation; as well as information about your transactions with us, your custodian and others, such as account balances and parties to transactions. JFL will be vigilant with respect to the initial and ongoing accuracy of the personal information we collect and asks that you keep us up to date by promptly notifying us of any changes such as your mailing or email address or phone number, employment status or income needs. Identifying Purposes Collecting personal information about you is essential to our being able to provide the personalized services that best meet your needs. While the personal information we collect may come directly from you, it may also be provided by your financial institution or custodian. Personal information may be used: To understand and assess your ongoing needs and to adjust your portfolio if warranted; For client communication, service and administration including invoicing and accounting purposes; For internal, external and regulatory audit purposes; To comply with legal and regulatory requirements; To facilitate investment transactions with other financial intermediaries; In compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act; To conduct and analyze client surveys to provide you with enhanced, personalized services. Please note that if you provide personal information about others (such as employees, dependents, etc.); we assume that you have obtained their consent. Limiting Use, Disclosure, and Retention JFL is a wholly-owned subsidiary of The Bank of Nova Scotia (“Scotiabank”). We only share your information with Scotiabank or other members of the Scotiabank group of companies so that Scotiabank can provide operational, administrative and support services, to meet legal and regulatory requirements and for fraud prevention purposes. Without your express permission, JFL does not share your information with the Scotiabank group of companies for marketing purposes. Otherwise, we do not disclose your personal information to anyone, except as permitted or required by law. This means, most importantly, that we do not sell client information – whether it is your personal information or the fact that you are our client – to anyone. Instead, we use your personal information primarily to complete transactions on your behalf. Here are the details: To complete certain transactions or account changes that you request, it may be necessary to provide identifying information to nonaffiliated third parties, such as trustees or custodians and broker-dealers. We will release your personal information if we are required by law to do so or in other limited circumstances permitted by law – for example, to protect your account from fraud, or if you otherwise give us the permission to do so. Should you wish us to share your personal information with a third party such as your accountant, auditor or consulting firm, we require written instructions describing the type of personal information you wish us to share as well as the name, address, phone, fax number and email address of the third party. Legislation and Regulations The applicable laws require organizations to obtain your consent to collect, use or disclose information about you. The Proceeds of Crime (Money Laundering) and Terrorist Financing Act, requires us to comply with certain client identification, recordkeeping, reporting and internal compliance measures. This includes reporting suspicious transactions to Canada’s financial intelligence unit, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). In addition, Article 41 of the United Nations Act and the related Regulations implemented under the Act impose certain duties on all Canadian financial institutions engaged in portfolio management or investment counseling, including the freezing of assets held directly or indirectly by persons in support of terrorism, reporting of property of these persons to both the Royal Canadian Mounted Police (“RCMP”) and the Canadian Security and Intelligence Service (“CSIS”), and reporting a review of our records on a monthly basis to the provincial securities commissions to confirm that our client base does not include the names of people or organizations in support of terrorism. What happens if you close your account? If you decide to close your account(s), we will adhere to the privacy policies and procedures described in this notice. JFL is subject to legislative requirements with respect to record retention periods, even after you close your accounts. Who has access to your personal information? Disclosure of your personal information is restricted to individuals who need access in order to provide services to you and as disclosed in these privacy policies and procedures. Safeguards We maintain physical, electronic and procedural safeguards that comply with Canadian and U.S. regulations to protect your personal information. Openness, Access, Recourse JFL will make available information about its policies and practices relating to the management of personal information upon request. You may obtain access to the personal information we hold about you at any time to review its content and accuracy. Please provide us with specific information in writing, to permit a comprehensive search through our files. JFL will respond to written requests within 30 days. If you require more information, or have concerns, please contact our Privacy Officer at compliance@jflglobal.com. JFL may update this policy from time to time. When we change the policy in a material way, an updated Policy will be sent or changes may be posted on our website. (Updated August 2019) Trade-Matching Statement National Instrument 24-101 – Trade Matching and Settlement To: All trade-matching parties providing trade orders to, acting on behalf of, or executing a trade with Jarislowsky, Fraser Limited This Trade-Matching Statement is being provided in accordance with National Instrument 24-101- “Institutional Trade Matching and Settlement” and Companion Policy 24-101CP [the “National Instrument”]. It applies to all trades that are subject to the National Instrument. We confirm that we have established, maintain, and enforce policies and procedures designed to achieve matching in accordance with the National Instrument. Use of Name and Logo No use of the Jarislowsky, Fraser Limited name, logo or any information contained on this website may be copied or redistributed without the prior written consent of Jarislowsky, Fraser Limited. About Institutional Private Wealth Global Research News & Insights Contact Client Portal Careers Privacy & Legal Accessibility CONTACT US © 2021 Jarislowsky, Fraser Limited. Canada - English Canada - Français United States - English International - English International - Español