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Teznia
as the Investment Counsel and Portfolio Manager adheres to the following policies and procedures:
(I) The company personnel is responsible for collection, documentation, and timely updates
of Know Your Client (KYC) and suitability information for clients. The KYC information is collected during the introductory
interview with the prospective customer and from written information provided by the customer in the new account sections
of personal data.
(II) The new account information provided by a client allows Teznia to comply with client's
specified investment restrictions or any other instructions.
(III) All of the investment decisions at Teznia must
be supported by sufficient research to support these decisions. All investment recommendations based on research must be in
writing. Any investment decision such as buying and selling securities, and portfolio weightings must be approved by the Investment
and Research Committee.
(IV) The activities of investment advisors (sales representatives), portfolio managers,
and analysts is supervised by the Ultimate Responsible Person and his/her appointed Alternate Responsible Persons. COMPLIANCE 1. The operating principle of Teznia is the compliance with all regulatory requirements,
including reviewing the opening of new accounts by the Chief Compliance Officer. The suitability of the recommended investment
portfolios of new clients and subsequent trades to invest funds is verified by the Ultimate Responsible Person or persons
empowered by Teznia.
2. Executive VP Operations is responsible for ensuring that registration pertaining to statutory
filing of forms and notices is submitted within required deadlines.
3. Executive VP Operations is responsible
for preparation and monitoring of monthly capital calculations, subject to approval by the Ultimate Responsible Person, to
fulfill minimum capital requirements defined in regulations.
4. Executive VP Operations is responsible for monitoring
trading activities of Teznia personnel and reporting any suspicious trades to the Chief Compliance Officer. The insider reporting
and early warning reporting to the OSC must be completed and sent within required deadlines using electronic systems.
5. Executive VP Operations is responsible for the United Nations Suppression of Terrorism monthly reporting.
6. Executive VP Operations in cooperation with the Ultimate Responsible Person is required to monitor and resolve conflicts
of interest and personal trading issues.
7. Executive VP Operations in cooperation with the Chief Compliance Officer
and the Ultimate Responsible Person is in charge of handling clients’ complaints.
8. The Chief Compliance
Officer in cooperation with the Board of Directors shall ensure compliance with all regulatory requirements in all jurisdictions
where Teznia business is conducted. PORTFOLIO
MANAGEMENT
1. Teznia policy is to sign the advisory agreement with each client, which is a part of each
new account agreement, prior to the commencement of managing of the account. Teznia staff must ensure that all clients read
and understand the agreement and the consent of the client is received by signing the agreement which must be witnessed by
authorized Teznia representative. The new account agreement between Teznia and the client gives Teznia discretionary power
over the account management.
2. Teznia advisory agreements are updated for all existing accounts whenever any
terms have changed. The full disclosure of the changes will be made to each affected client and their consent to these changes
must be obtained.
3. All Teznia advisory agreements detail the responsibilities of each of the parties involved.
These agreements are Teznia legal documents written in accordance with the Canadian law and enforceable in the Canadian courts.
4. Teznia is required to issue a written notice to terminate any advisory agreement in accordance with the cancellation
terms of the agreement. The clients are also required to give a written notice to Teznia to terminate any advisory agreement
in accordance with the terms of the previously signed agreement.
5. Teznia Investment and Research Committee is
required to review client holdings on a frequent basis to ensure that holdings are consistent with the investment objectives
and restrictions. All changes to Teznia investment objectives and investment management restrictions must be approved by the
Management Board of the company. Teznia conducts everyday, before the North American Markets opening sessions, “a brain
storm” meeting of the investment management team to identify daily investment opportunities and update existing information
on securities holdings. MARKETING
Teznia policy is to deal fairly, honestly and in good faith with clients and
ensure that all marketing materials include accurate information that is not misleading. The company takes all necessary steps
to ensure that:
• marketing material is regularly updated to ensure all information is complete, accurate
and not misleading to clients,
• established and enforced procedures are in place with respect to the preparation,
review and approval of marketing materials,
• established guidelines on the preparation of performance data
and the construction of composites are in place,
• VP Sales is requires to receive approval of all marketing
material from the Ultimate Responsible Person and submit this approval to the Executive VP who will maintain evidence of such
approval. PERSONAL
TRADING
Under a separate cover Teznia maintains written procedures and enforcement system for dealing
with clients conforming to prudent business practice. The Chief Compliance Officer is also responsible for enforcement of
a detailed policy on the personal trading. Teznia procedures ensure that conflicts of interest and abusive practices are avoided
by establishing the following policies and procedures:
• all Teznia staff is given instructions pertaining
to personal trading restrictions and reporting obligations to the Chief Compliance Officer,
• personal trading
procedures include blackout periods, requirement for pre-approval of all personal trades and a review of brokerage statements,
• Teznia requires all responsible persons to acknowledge in writing, on a semi-annual basis, that they understand
and will abide by the firm's personal trading policies,
• all Teznia employees must direct their brokers
to send statements of their accounts directly to Teznia for trading review,
• Executive VP Operations is
responsible for maintaining a record of personal trade pre-approvals and employees' brokerage statements as documentary evidence
that personal trading is being monitored,
• Teznia Chief Compliance Officer is responsible for reviewing
and maintaining personal trading records,
• Executive VP Operations is in charge of a monthly review of all
employee statements and reconcile all trades to the approvals granted,
• Teznia maintains under separate
cover procedures dealing with personal trading violations, including penalties for non-compliance. KNOW YOUR CLIENT AND SUITABILITY INFORMATION
Teznia and all personnel responsible for advising clients, research and managing portfolios are required to collect
and maintain current KYC information that allows the company to ascertain general investment needs of the clients, as well
as the suitability of a proposed transaction. Teznia collects the following information: a) customers’ investment objectives;
b) risk tolerance; c) investment restrictions; d) investment time frame; e) annual income; f)net worth; g) any information
deemed necessary to properly assess suitability of an investment for a client. All Teznia personnel dealing with clients must:
• complete KYC information for all clients,
• update periodically (at least semi-annually) KYC information for all clients,
• ensure that all
clients sign the KYC information form,
• ensure that a separate pending file is maintained for incomplete
KYC forms which must be completed on a timely basis before any trade execution. For more information, please send inquiries to info@teznia.com
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