Actual, potential and perceived conflicts of interest arise where an action or decision by someone has the effect of benefiting an individual (including such an individual) or a group of people at the expense of others. Such conflicts can arise from time to time:
- between you and our firm, as well as between you and your Advisor.
- between you and our other clients: we act for many clients and must allocate investment opportunities among all of them fairly, so as not to favour intentionally one client over another.
- between us and our related or associated companies.
Altium has policies and procedures in place to address the handling of conflicts of interest.
- We avoid conflicts prohibited by law as well as conflicts that we cannot effectively.
In situations that we do not or cannot avoid, where our interests may compete with yours, your interest is always given priority by our acting in one of two ways:
- We control or manage acceptable conflicts by physically separating different business functions, restricting the internal exchange of information in person or through systems, reducing the possibility of one part of our organization unsuitably influencing another, removing the financial incentive of an employee to favour a particular product or service over another that may be more suitable, and setting up and testing our operational review and approval processes.
- We disclose information about any remaining conflicts to you so that, when you evaluate our recommendations and actions, you can assess independently if conflicts are significant for you.
To help you understand and assess material potential and actual conflicts of interest, we have prepared a more detailed explanation of typical conflicts, with examples of what we do in the case of any material ones. It can be found at www.altium.ca. If you ever have any questions or concerns, whether they involve conflicts of interest or anything else, please ask your Advisor for an explanation and more information.
DESCRIPTION OF OUR FIRM
Altium Wealth Architecture Inc. (“Altium”) is registered as a portfolio manager with the Autorité des Marchés financiers (AMF), the Ontario Securities Commission (OSC), the Consumer Services Commission of New Brunswick (FCNB) and the British Colombia Securities Commission (“BCSC”). You can learn more about our firm at www.altium.ca.
DESCRIPTION OF OUR ROLE AS A PORTFOLIO MANAGER
Altium manages your portfolio typically under a discretionary mandate and with a long-term vision, according to various factors that are specific to you, such as your objectives, your investment profile and your risk tolerance, as well as external factors, such as market performance, investment opportunities and the geopolitical context.
DESCRIPTION OF OUR ROLE AS A FINANCIAL PLANNER
Altium is also registered as a financial planning firm. Thus, if you so desire, a financial planning representative will be able to help you complete your financial planning, by creating an action plan based on your needs, your constraints and your personal goals. These services are offered to you at no additional costs, since they are included in the annual fees detailed in Schedule A of your Wealth Management Agreement.
MANAGEMENT OF CONFLICTS OF INTEREST
In general, we deal with and manage relevant conflicts as follows:
This includes avoiding conflicts that are prohibited by law as well as conflicts that cannot effectively be addressed.
We manage acceptable conflicts through means such as physically separating different departments and restricting the internal exchange of information.
For example, at Altium’s, the functions susceptible to create a conflict of interest are strictly separated:
- The people authorized to trade on the market are formally identified with the securities custodians;
- The portfolio managers must promote the client’s interests at all times. In that respect, they must exercise their activities ensuring respect for the integrity and transparency and must refrain from any initiative that would directly or indirectly place their own interests, or any third party’s interests, ahead of the clients’ interests.
- Thus, the portfolios’ structuring is done by an Investment Committee comprised mainly from portfolio managers that do not generally serve the clients directly as advising representatives.
- The Investment Committee undertakes a rigorous and transparent process for the selection of investment solutions:
- Screening and analysis of investment strategies universe, in order to narrow down a list of candidates. This initial universe is comprised of a very large number of strategies, with a lot of various investment approaches.
- In-depth analysis of each managers from the list of candidates, in order to draw up a list of finalists:
- 90 minutes videoconference with each manager;
- Drafting of a complete, qualitative and quantitative summary of each strategy, based on the meetings;
- Rating of each strategy according to the team, the investment process, the risk management, the performance and the operations;
- Complete due diligence process (investment and operations process) and selection of a final candidate;
- Integration of this manager on Altium’s investment platform, according to the needs, profile and personal situation of each client.
- All investment decisions in the clients’ portfolios are exclusively driven by the clients’ best interests.
By providing you with information about conflicts, you are able to assess independently their significance when evaluating our recommendations and any actions we take.
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 other matters, you should never hesitate to say so and ask your Advisor for an explanation and/or further information.
Canada has comprehensive and extensive securities 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) (www.securities-administrators.ca).
POSSIBLE CONFLICTS OF INTERESTS AND HOW THEY ARE MANAGED
Conflict of interests: We earn compensation for the services we are providing to you.
Managed by: Disclosure and control
- We disclose the fees that we are receiving so that you know exactly what you are paying. We do not receive any other form of compensation from our clients or our external managers
- You can consult our schedule of fees in Schedule A of your Wealth Management Agreement.
- Our employees and advisors are compensated through a combination of salary and bonus driven by many components, such as professional practice standards, the firm’s performance as a whole, both in qualitative and quantitative terms, and client satisfaction.
- None of the employees and/or advisors are receiving any direct commission.
Potential conflict of interests: We would like you to refer our services to your network (always on a purely voluntary basis)
Managed by: Avoidance and Control
- We do not engage in “tied selling”, where purchase of one service is conditional on buying another as well, a practice that is prohibited by regulation.
- Our business model prohibits recommendations solely for the purpose of generating revenue for us without any benefit to you, since you are paying fixed fees based on the total assets covered by your Wealth Management Agreement.
- The firm has implemented a compliance system to monitor advisors and help identify and address concerns.
Potential conflict of interests: Relationship between Altium et Raymond Chabot Grant Thornton SENCRL (RCGT)
Managed by: Disclosure, Avoidance and Control
- On September 24th, 2015, the relationship between Altium and Raymond Chabot Grant Thornton L.L.P. (“RCGT”) was ended.
- Altium and RCGT are no longer related companies, which puts an end to the potential for conflict of interest that this relationship could entail.
- All potential for a material conflict of interest between the Client and Altium is controlled, since the Client’s assets are mostly managed through independent third-party Investment Professionals, which are carefully selected by Altium
Conflict of interests: Some portfolio managers at Altium own an account with Altium with the same securities custodian, accessible through the same tool and administratively managed by the same managers than all of Altium’s clients.
Managed by: Avoidance and Control.
- Altium has implemented a formal procedure for the control of personal transactions, including any transactions done by managers for their own personal accounts. These transactions are registered by Altium’s Director of Operations and documented in a Client Relationship Management (CRM) software, which allows for the control of the pre-assignment of orders, as well as the observance of transactions with respect to the monitoring lists and prohibitions.
- It is worth mentioning that thanks to Altium’s business model, the average number of transactions executed on a daily basis allows for a relatively easy control by the Director of operations and the Investment Committee, of all the transactions executed within the firm.
Potential conflict of interests: Some employees and advisors have family relationships with clients
Managed by: Avoidance and Control
- Clients under discretionary management delegates their portfolio management to Altium, not to a particular manager of the firm.
- The Investment Committee takes all the decisions based on the investments’ suitability for the clients, the analysis of their own risk profile and the assets allocation in the portfolios.
- No manager is exclusively dedicated to the management of a particular account.
Potential conflict of interests: The individual or collective compensation is influenced by the global performance of the portfolios under our management.
Managed by: Disclosure and control
- The portfolios’ structuring is completed by an Investment Committee comprised mainly from portfolio managers that do not generally serve the clients directly as advising representatives.
- All investment decisions in the clients’ portfolios are exclusively driven by the clients’ best interests, according to their own investment profile and personal situation.
- Our portfolio managers do not receive any commission for the sale of any particular product or service.
Potential conflict of interests: Formal and informal referral agreements
Managed by: Disclosure and Control
- Formal referral agreement against commission
- To this date, Altium has only concluded one client referral agreement, in June 2018, with Groupe DCB inc. («DCB»).
- This agreement states that Altium will pay to DCB a referral commission of 25% of the net fees received by Altium as defined in the wealth management agreement signed with yourself, retroactive to the account opening date with Altium, and for a three-year period from that date, if you remain a client of Altium during that period. This commission will be paid bi-annually on a consolidated basis.
- lt is important to specify that this commission will neither increase nor affect in any other way the total cost of your management fees, since it is a portion of the fees you are paying in accordance with your wealth management agreement with Altium.
- DCB and Altium are bath registered with the Autorité des marchés financiers. DCB provides group insurance, insurance for individuals and financial planning services. Altium as you know is a Multi Family Office, which provides portfolio management and financial planning services.
- Informal referral agreement without commission
- Altium’s network is comprised of a certain number of people and companies (the “network”), with whom and which referrals may occur from time to time.
- An updated register of this network is maintained by the firm.
- At all time, for each client referral done by Altium to any person or entity in its network, Altium ensures that this referral is in the client’s best interest, according to the client’s expressed needs. In all cases, Altium does not gain any advantage or benefit other than better serve its clients.
- The same goes for the informal references received by Altium from its network. This network is comprised of professionals from various industries that do not offer portfolio management services, all client references to Altium are done in the clients’ best interests, according to the client’s expressed needs and to better serve them.
- Altium is never obligated to accept a referral from any source whatsoever and respects at all times the inherent criteria of its usual due diligence process about all prospective clients, before offering them its services.
Potential conflict of interests: We may need to select which clients will be offered certain securities if availability is limited.
Managed by: Control
- We have a “fair allocation” policy to ensure equitable treatment of clients.
- The markets nature inevitably creates performance spreads. Our managers are obligated to limit these spreads as much as possible. Altium’s fiduciary obligations include the best execution of transactions of client’s assets. Altium deploys its best efforts to obtain the best execution possible and to get the best settlement possible. Its approach does not always allow to obtain the lower price for a purchase, nor the highest price for a sale, because it also takes into account of several other factors.
- When the allocation of a solution must be integrated to several portfolio simultaneously and in the event of a partial execution of an investment order, the quantity obtained will be allocated between the clients in proportion to the qualities registered on the allocation, provided that the operation is economically profitable for the relevant portfolios.
- As well, the best execution of the orders for clients is based on the respect of the norms and the use of the same processes for all traded markets and financial instruments. However, the vast diversity of the markets and instruments forces Altium to take into account several factors in its approach for the best execution. If a client gives a particular execution order, this order is executed as requested; Altium may then be precluded to comply to its best execution approach and obtain the best possible result.
Potential conflict of interests: We distribute investment research that is produced by third parties. This may include research on securities of companies that may have other business relationships with us.
Managed by: Control
- The Investment Committee undertakes an in-depth due diligence process of all potential investment solutions for our clients’ portfolios.
- While Altium believes the research, analysis or information documents from external sources to be trustworthy, it clearly states to its clients that it cannot guarantee their accuracy, completeness, currency or reliability.
Potential conflict of interests: Individuals may serve on a board of directors or take on other activities, compensated or not.
Managed by: Avoidance and Control
- It is prohibited to serve as a director of another registered firm that is not an affiliate of our firm.
- When an Advisor or representative sits on a board of directors of a charity or undertakes other community activities in any substantive way, they are subject to regulatory guidance on the disclosure and approval of outside business activities. This disclosure can be found in the Client Relationship Disclosure in Schedule 2 of your Wealth Management Agreement.
- Altium ensures that this type of activity must not be susceptible to take your the time or the attention of your advisor or your client-service team away from the management of your account.
Potential conflict of interests: Potential relevant conflicts may arise from gifts and entertainment from third parties to Altium’s employees with which Altium has active or potential business relationships.
Managed by : Avoidance and Control
- Representatives are required to obtain pre-approval, before accepting any gifts where the value exceeds $100.
- No representative may give or accept cash gifts or cash equivalents to or from a client, prospective client, or any entity that does business with or on behalf of the company.
- No representative may provide or accept extravagant or excessive entertainment to or from a client, prospective client, or any person or entity that does or seeks to do business with or on behalf of the company.
- Representatives may provide or accept a business entertainment event, such as dinner or a sporting event, of reasonable value. Receipt of entertainment is acceptable if the expenses would have been paid as a firm business expense.
Mode of communication
Our policy for the management and prevention of conflict of interests is available in the “Legal” section of our website at www.altium.ca.
To indicate your choice of receiving all communications electronically and to request a copy of this policy, you may contact Altium directly by email at email@example.com or by regular mail at
Altium Wealth Architecture Inc.
C/O : Operations Department
1130, Sherbrooke street West, Suite 400
Montreal (QC) H3A 2M8
All Wealth Management Agreements systematically include a summary and a reference to Altium’s policy for the management and prevention of conflict of interests.
Our complaint process
Filing a complaint with us
If you have a complaint about our services or a product, contact our compliance department by mail at 1130 Sherbrooke Street West, Suite 400, Montréal, Québec H3A 2M8 or by email at firstname.lastname@example.org.
- what went wrong
- when it happened
- what you expect, for example, money back, an apology, account correction
We will acknowledge your complaint
We will acknowledge your complaint in writing, as soon as possible, typically within 5 business days of receiving your complaint.
We may ask you to provide clarification or more information to help us resolve your complaint.
Help us resolve your complaint sooner
- Make your complaint as soon as possible.
- Reply promptly if we ask you for more information.
- Keep copies of all relevant documents, such as letters, emails and notes of conversations with us.
We will provide our decision
We will endeavor to provide our decision in writing within 90 days of receiving a complaint. It will include:
- a summary of the complaint
- the results of our investigation
- our decision to make an offer to resolve the complaint or deny it, and an explanation of our decision
If our decision is delayed
If we cannot provide you with our decision within 90 days, we will:
- inform you of the delay
- explain why our decision is delayed, and
- give you a new date for our decision
You may be eligible for the independent dispute resolution service offered by the Ombudsman for Banking Services and Investments (OBSI).
If you are not satisfied with our decision
You may be eligible for OBSI’s dispute resolution service.
If you are a Québec resident
You may consider the free mediation service offered by the Autorité des marchés financiers.
A word about legal advice
You always have the right to go to a lawyer or seek other ways of resolving your dispute at any time. A lawyer can advise you of your options. There are time limits for taking legal action.
Delays could limit your options and legal rights later on.
Taking your complaint to OBSI
You may be eligible for OBSI’s free and independent dispute resolution service if:
- we do not provide our decision within 90 days after you made your complaint, or
- you are not satisfied with our decision
OBSI can recommend compensation of up to $350,000.
OBSI’s service is available to clients of our firm. This does not restrict your ability to take a complaint to a dispute resolution service of your choosing at your own expense, or to bring an action in court. Keep in mind there are time limits for taking legal action.
Who can use OBSI
You have the right to use OBSI’s service if:
- your complaint relates to a trading or advising activity of our firm or by one of our representatives
- you brought your complaint to us within 6 years from the time that you first knew, or ought to have known, about the event that caused the complaint, and
- you file your complaint with OBSI according to its time limits below
Time limits apply
- If we do not provide you with our decision within 90 days, you can take your complaint to OBSI any time after the 90-day period has ended.
- If you are not satisfied with our decision, you have up to 180 days after we provide you with our decision to take your complaint to OBSI.
Filing a complaint with OBSI
Telephone: 1-888-451-4519 or 416-287-2877 in Toronto
OBSI will investigate
OBSI works confidentially and in an informal manner. It is not like going to court, and you do not need a lawyer.
During its investigation, OBSI may interview you and representatives of our firm. We are required to cooperate in OBSI’s investigations.
Information OBSI needs to help you OBSI can help you best if you promptly provide all relevant information, including:
- your name and contact information
- our firm’s name and contact information
- the names and contact information of any of our representatives who have been involved in your complaint details of your complaint
- all relevant documents, including any correspondence and notes of discussions with us
OBSI will provide its recommendations
Once OBSI has completed its investigation, it will provide its recommendations to you and us. OBSI’s recommendations are not binding on you or us.
OBSI can recommend compensation of up to $350,000. If your claim is higher, you will have to agree to that limit on any compensation you seek through OBSI. If you want to recover more than $350,000, you may want to consider another option, such as legal action, to resolve your complaint.
For more information about OBSI, visit www.obsi.ca