Protecting your privacy and the confidentiality of your personal information has always been fundamental to the way we do business within Acker Finley Inc., and Acker Finley Asset Management Inc., collectively known as Acker Finley.

This Privacy Code informs you of our policy on privacy, and tells you about the ways we ensure that your privacy and the confidentiality of your information are protected.

PIPEDA

Personal Information Protection and Electronic Documents Act (PIPEDA) is the privacy legislation introduced by the federal government. It is based on 10 principles that form the ground rules for the collection, use and disclosure of personal information. Its purpose is to give individuals greater control over how their personal information is handled by the private sector. PIPEDA is implemented in three stages with the final stage slated to become effective on January 1, 2004. After this final stage is implemented PIPEDA, or an equivalent form of provincial legislation, will cover virtually all commercial activities within Canada.

What is Personal Information?

Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

• age, name, ID numbers, income, ethnic origin, or blood type;
• opinions, evaluations, comments, social status, or disciplinary actions; and
• employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs).

Personal information does not include the name, title, business address or telephone number of an employee of an organization.

Why do we collect your Personal Information?

We obtain most of our information about you directly from you. The information we ask for depends on which product or service you want. For every product or service, we need your name, address and some identification. Here is why we need some of the other information we ask you to provide.

Birth Date: This helps us identify you and ensure that no one is trying to impersonate you. We may also use it to determine your eligibility for products and services that may be of benefit to a particular age group.

Social Insurance Number (SIN): Your SIN is required for products which earn investment income, in order to comply with the Canada Customs and Revenue Agency's income reporting requirements.

Financial Information: This is used to ensure that the advice we give you or the investments you purchase are appropriate for you.We only collect the information we need and only use it for the purposes explained to you.

When you apply for a new product or service, we will indicate in the application or agreement how we intend to use your information. If we wish in the future to use it for another purpose, we will ask you for your consent at that time. We will only ask for the information we need for that particular product or service. We will indicate clearly which information would help us to serve you but is optional for you to provide.

Sharing Personal Information

With your consent, we may share your information with affiliates of Acker Finley. Sharing your information will help us serve you better and it helps us determine your financial needs because it allows us to review what services you have and how you use them.

This consent is optional and you can decide to withdraw it at any time. Please refer to the section "Your preference".

For regulatory purposes, self regulatory organizations including Market Regulation Services Inc., the Investment Dealers Association of Canada, the Mutual Fund Dealers Association of Canada, Bourse de Montreal Inc., and the Canadian Investor Protection Fund (collectively, "SROs") require access to personal information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by Regulated Persons. SROs collect, use or disclose such personal information obtained from Regulated Persons for regulatory purposes, including:

• Surveillance of trading-related activity,
• Sales, financial compliance, trade desk review and other regulatory audits,
• Investigation of potential regulatory and statutory violations,
• Regulatory databases,
• Enforcement or disciplinary proceedings,
• Reporting to securities regulators, and
• Information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.

In addition, we must give information in response to a valid demand, search warrant or other legally valid enquiry or order. We may disclose information to help us collect a debt owed to us by you. We may also disclose information to an investigative body in the case of a breach of agreement or contravention of law - this helps prevent fraud, money laundering or other criminal activity.

Protecting your Personal Information

We will protect your information with appropriate safeguards and security measures. We have thorough security standards to protect our systems and your information against unauthorized access and use.

When we provide information in response to a legal enquiry or order, we ensure that the order is valid and we disclose only the information that is legally required. All employees of Acker Finley are familiar with the procedures that must be taken to safeguard customer information. Client confidentiality is key to the operation of our business.

We retain your information only as long as it is required for the reasons it was collected. The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form.

Accessing Your Personal Information

Individuals have the right to verify the accuracy and completeness of their personal information, and may request that it be amended. A client who wishes to change or update his or her personal information may do so at any time. Please note that we may not make the change if the changed information is no longer needed to fulfill the stated purpose.

Under certain circumstances, Acker Finley may not be able to provide investors with access to specific portions of the information. For example: (i) information containing references to other persons, (ii) information containing proprietary information confidential to Acker Finley, (iii) information that relates to an investigation of a breach of agreement or contravention of laws, or cannot be disclosed for other legal reasons, (iv) information that has been destroyed, or (v) information that is too costly to retrieve.

Your Preference

We will explain your options of refusing or withdrawing consent to the collection, use or release of your information, and we will record and respect your choices. In most cases you are free to refuse or withdraw your consent at any time. If you don't want us to share information with affiliates of Acker Finley, you can change your options at any time. You may do so by contacting your investment advisor at 1 (888) 514-9136.

Questions and Concerns

Inquires and complaints received will be reviewed by Acker Finley's Privacy Dept. Contact Acker Finley's Privacy Officer, Marian Buklis at 1 (888) 514-9136.