BEYOND INVESTMENT
A. DESCRIPTION OF MEMBER FIRM
Highgate Group is what is referred to as an “integrated” investment firm since we provide a broad range wealth management client services and products. We recognize that by definition we are more susceptible to conflicts of interest than many other corporations since we may regularly represent both sides of a transaction, namely, the buyer and the seller. As an investment dealer, we are a financial intermediary. We facilitate transactions between you as our client and a third party on the other side of the transaction through an “agency” trade where we have no ownership interest in the security traded.
You can learn more about our firm at www.highgategroup.ca
Highgate Group defines a conflict of interest to include any circumstance where:
- The interests of different parties, such as the interests of a client and those of a registrant, are inconsistent or divergent.
- A registrant may be influenced to put their interests ahead of their client’s interests, or
- Monetary or non-monetary benefits available to a registrant, or potential detriments to which a registrant may be subject, may compromise the trust that a reasonable client has in their registrant.
- The general types of conflicts of interest which can arise are:
- Conflicts of interest between you (our client) and us,
- Conflicts of interest between you and our other clients, and
- Conflicts of interest between us and our related and associated companies.
B. MANAGEMENT OF CONFLICTS OF INTEREST
Highgate takes reasonable steps to identify existing material conflicts of interest, and material conflicts of interest that are reasonably foreseeable between Highgate and the client, and between each individual acting on Highgate’s behalf and the client. When identifying, addressing, and disclosing material conflicts of interests, Highgate Group takes into consideration the following:
- identify existing and reasonably foreseeable material conflicts of interest between a client and the firm or any individual acting on the firm’s behalf,
- address all material conflicts of interest in the best interest of the client,
- avoid material conflicts of interest that cannot be otherwise addressed in the best interest of the client, and
- provide affected clients with disclosure of material conflicts of interest at account opening or in a timely manner if they are identified later.
In general, we deal with and manage relevant conflicts as follows:
Avoidance: this includes avoiding conflicts that are prohibited by law as well as conflicts that cannot effectively be addressed.
Control: we manage acceptable conflicts through means such as physically separating different business functions and restricting the internal exchange of information.
Disclosure: existing and potential material conflicts of interest situations, where not avoided, will be disclosed to the client as they arise.
C. ADDRESSING MATERIAL CONFLICTS IN THE BEST INTEREST OF THE CLIENT
When addressing material conflicts of interest in the best interest of clients, Highgate and its registered individuals must put the interests of their clients first, ahead of their own interests and any other competing considerations. Registrants must address material conflicts of interest by either avoiding those conflicts or by using controls to mitigate those conflicts sufficiently so that the conflict has been addressed in the client’s best interest.
Registrants must avoid a material conflict of interest if there are no appropriate controls available in the circumstances that would be sufficient to otherwise address the conflict in the best interest of the client. Similarly, if a particular conflict is capable of being addressed by using controls, but the specific controls being used by Highgate are not sufficiently mitigating the effect of the conflict, Highgate must avoid that conflict until it has implemented controls sufficient to address the conflict in the best interest of the client.
Highgate must avoid a conflict if that is the only reasonable response in circumstances that is consistent with the obligation to address conflicts in the best interest of clients. Highgate must avoid such conflicts even if this means foregoing an otherwise attractive business opportunity or type of compensation for the firm or its registered individuals.
The following information is intended to assist you in understanding and assessing material potential and actual conflicts of interest, including how we address them. This is an overview of a complex subject. If you ever have any questions or concerns, whether they involve conflicts of interest or anything else, you should never hesitate to ask your advisor for an explanation and more information.
D. MORE INFORMATION
Canada has comprehensive and extensive securities regulatory rules and regulations, many of which are directed at protecting client and investor interests, including dealing with conflicts of interest. We suggest that you refer to the websites and publications of the provincial securities commissions through the Canadian Securities Administrators (CSA) and Canadian Investment Regulatory Organization (CIRO) for more information on how Canadian securities regulations address conflicts of interest in order to safeguard the investing public.
We document our core values and standards, including general standards for how we deal with conflicts of interest. You should also refer to the Statement of Policies. You can obtain a copy from your advisor on request or from our website at: www.highgategroup.ca.
E. POSSIBLE CONFLICTS AND HOW THEY ARE MANAGED
