Fairness Policy

The objective of Optimize Wealth Management (Optimize) Fairness Policy is to promote fair and reasonable treatment of all clients with respect to investment management; to provide for situations where two or more client accounts participate simultaneously in a buy or sell order involving the same security and to provide for occasions where there may be insufficient quantities of a security at the same price to satisfy the requirements of all our clients.   No client will receive preferential treatment as to pricing or security allocation and all clients in the respective investment mandates will hold the same security positions on a pro rata basis subject to client specific restrictions, constraints or tax loss selling. All clients may take advantage of tax loss selling opportunities but their ability to do so will be determined by client specific tax status and taxation. Clients employing tax loss selling will be advised and must acknowledge that such transactions may alter their investment portfolio and its performance results.   Specific securities bought or sold in segregated accounts will be bought or sold in all other segregated accounts whose investment mandate is the same, on a modified pro rata basis according to assets under management at the average price so that no account would achieve unfair advantage with respect to the other. When the total amount of an order is not executed, partially executed orders will be allocated on the modified pro rata basis among the participating accounts in an equitable manner. This policy recognizes that no rigid formula will always lead to a fair and a reasonable result, and that some flexibility is required to adjust to specific circumstances, as appropriate. Therefore trades may be subject to a modification of a mathematically exact pro-rata allocation if an order is unreasonable as measured against the particular account’s asset size and target weighting for the security in question. Accordingly, allocation on a basis other than strictly pro rata based on order size is permitted in certain circumstances where it can be established that such allocation is fair and reasonable.   The policy of Optimize is to not participate in initial public offerings on behalf of clients, however if that policy were to change clients would be treated in the same manner as set out in this Policy.