Conflicts of Interest Disclosure

Camber Capital Co. (“Camber”) is a registered Portfolio Manager and Exempt Market Dealer regulated, primarily, by the Alberta Securities Commission (ASC), a member of the Canadian Securities Administrators (“CSA”). Canadian securities laws require Camber to take reasonable steps to identify and respond to existing, or reasonably foreseeable, material conflicts of interest. This Statement describes the potential material conflicts of interest that arise or may arise in our capacity as your portfolio manager.

At Camber, we believe in financial planning, evidenced-based decision-making, leveraging technology, and, always, acting in the client’s best interest. We are committed to building your wealth in an open, honest and transparent manner. In line with this commitment, we continuously work to identify, disclose, and manage any material conflicts.

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 limiting the internal exchange of information.

Disclosure: By providing you with information about conflicts, you are able to assess independently their significance when evaluating our recommendations and any actions we may take.

The table below summarizes specific material conflicts of interest and how Camber has addressed them.

Fee-based investment accounts:

Control: Camber only offers fee-based investment accounts. That is: a percentage fee based on the assets under management of a client

Disclosure: Camber discloses all fees and charges at the time of account opening. Fees and charges paid for each calendar year are reported via annual reports.

Fee-for-service financial planning:

Control: Camber offers fee-for-service financial planning, separate from investment management services.

Disclosure: Camber discloses fees and terms & conditions at the time of purchase.

Cash vs Dividend Reinvestment Plan (DRIP):

Control: disclosure of management fee collection process is included in client onboarding communications.

Disclosure: Disclosed to clients at the time of account opening, with the need for cash to pay advisor management fees. Camber does not use DRIP and instead sets distributions to cash. This avoids short-term market risk, and reduces the change of transactional and/or human error.

Exempt Market Dealer compensation:

Control: For clients that participate in private security/exempt product offerings, Camber has policies in place which require the client to receive disclosure, and provide acknowledgement and consent of fees paid to Camber (EMD).

Disclosure: Disclosures are presented to, and signed by, clients prior to participating in any offerings. Disclosures include clear language detailing any compensation paid to Camber.

Gifts and events:

Avoidance: Camber has policies prohibiting the receipt of any compensation that may be perceived as an attempt to influence Camber’s decision-making.

Control: Camber’s policies ensure that gifts or services accepted are considered reasonable and do not influence business decisions in any way that would be detrimental to the client’s best interests.

Outside activities:

Avoidance: Camber has policies prohibiting outside business activities if they are likely to conflict with the activities of Camber or may be detrimental to the client’s best interests.

Control: Camber staff must attest to any outside business activities.

Personal trading:

Avoidance: Camber has policies prohibiting the use of material, non-public information for personal gain.

Control: Personal trading controls are addressed in Camber’s Policies and Procedures Manual. Staff accounts are managed by Camber Private Wealth, are full discretionary, restricting any personal trading. Any outside trading accounts are monitored by Camber’s CCO and require pre-approval on any trades.

Trading best execution:

Control: Camber’s trading policy, outlined in Camber’s Policies and Procedures Manual, ensures trades are executed in compliance with the principles of best execution.

Other conflicts of interest:

Camber management meets regularly to review identified and discuss potential conflicts of interest, and takes appropriate action to control, avoid, and disclose in the best interest of the client.

If you have any questions regarding these potential conflicts of interest or how we avoid or manage them, please contact us at CamberHQ@camberco.ca.