Compliance

At J. Zechner Associates Inc. (“JZAI”) our staff, including the partners, are held to the highest level of professional integrity. A restriction on personal investing is monitored vigilantly by our compliance committee. As well, JZAI is audited on an annual basis by an independent accounting firm. We ensure that all portfolios comply with their respective mandates. Our compliance process operates on several different levels to maximize consistency and accountability to our clients.

On a basic level, our portfolio administrators make sure all client accounts – including specific customer constraints – are operating on our computerized system. Our portfolio accounting system tracks client-induced constraints by sector or security.

In addition, a manual template is constructed for each account. On a daily basis, the portfolio managers go through each client portfolio and compare them to the consolidated matrix report to ensure consistency.
Finally, our partners conduct a review on a daily basis to match each client portfolio with the policy mandate.

Handling of Complaints

In the event that a client wishes to make a complaint about the firm, JZAI will make every endeavour to remedy the matter, following the complaint handling practice recommended by the Ontario Securities Commission and available upon request. If a dispute should arise that JZAI and the client are unable to resolve together, the clients is directed to the Dispute Resolution Ombudsman of the Ontario Securities Commission available for that purpose.

Integrity & Conflicts of Interest

JZAI is registered as both a portfolio manager and exempt market dealer across all ten Canadian provinces, and additionally registered as an investment fund manager in Ontario and Quebec. We offer clients investment advice; we also manage our line of pooled funds (the “Pooled Funds”), and may invest in Pooled Funds to manage some client accounts under fully discretionary managed account agreements; they may also directly subscribe for units of a Pooled Fund by signing a subscription agreement. Moreover, we provide advisory services for clients through separately managed accounts that invest directly in a portfolio of securities and other investments.

Under our registration as an investment fund manager, we provide discretionary portfolio management services to our clients, as well as manage the day-to-day business affairs of the Pooled Funds. We are registered as an exempt market dealer to enable clients to invest in the Pooled Funds, whether selected by JZAI under its discretion or directly by the client.

Disclosure of Conflicts

Securities legislation in Canada requires us to make certain disclosures regarding the nature and extent of conflicts of interest that might be expected to arise between JZAI and its clients.

We must take reasonable steps to identify existing material conflicts of interest and material conflicts that we reasonably expect to arise between the firm and a client. As part of identifying these conflicts, we collect information from the individuals acting on our behalf regarding the conflicts they expect to arise with our clients. Further, if a reasonable investor would expect to be informed of the nature and extent of an identified conflict of interest, JZAI must do so. We avoid situations that would result in a serious conflict of interest that would be too high a risk for our clients or market integrity. In other circumstances involving a conflict of interest, we take the appropriate steps to control the conflict of interest.