Conflicts of Interest

In the course of our normal business activities we have the responsibility to deal fairly, honestly and in good faith with our clients, and to act in their interests. Many financial services companies act as a financial intermediary where they may at times act for both the buyer and the seller of a security. We recognize that there is the potential for conflicts of interest to arise between the interest of the clients, its advisors and the firm.

Accordingly, we have implemented policies and procedures designed to manage those potential conflicts, using three basic mechanisms to do so; depending on the circumstances we will either control the conflict, disclose the potential conflict to you in order for you to factor it into your decision making or, when there is serious potential impact to the firm or its clients, avoid it, usually by forgoing the business opportunity giving rise to the potential conflict.

Disclosure Statement – Conflicts of interest

Under certain circumstances we may deal with or for you in securities transactions where the issuer of the securities or the other party to the transaction is a firm or party having an ownership or business relationship with us. Since these transactions may create a conflict between our interests and yours, we are informing you of the relevant relationships and connections relating to the transactions. Any future unresolved material conflict of interest situations will be disclosed to you as they arise.

Important Concepts

A person or company is a “related issuer” of us if the person or company is an influential security holder of us if we are an influential security holder of the person or company or each of us and the person or company is a related issuer of the same third person or company.

A "connected issuer" is a party that is distributing securities and has a relationship with us that may lead a reasonable prospective purchaser of the securities to question if we and the issuer are independent of each other as respects the distribution of such securities.

Disclosure

Harbourfront Wealth Management Inc. (“Harbourfront”) currently does not have any related issuers. The shares of Harbourfront are not publicly traded.

Harbourfront and a related company, Harbourfront Estate Planning Services Inc., operate out of the same office premises in certain locations. Harbourfront is the entity that is registered and licensed as an investment dealer; all of your securities transactions and holdings will be reflected in accounts through Harbourfront. Harbourfront Estate Planning Services Inc. is licensed and registered to provide insurance products, including life, disability and critical illness. All insurance related products will be provided and reported by Harbourfront Estate Planning Services inc. independent of Harbourfront.

Harbourfront has appointed NBCN Inc./National Bank Financial Inc. (the “Carrying Broker”) as its agent for trading, clearing and settling transactions with you. The Carrying Broker is affiliated with National Bank of Canada (“NBC”).

Harbourfront is a connected issuer with NBC by virtue of certain agreements entered into by Harbourfront and one of its major shareholders with NBC and two of its affiliates, National Bank Financial & Co. Inc. and National Bank Financial Ltd., the latter being a securities registrant, whereby NBC has agreed that certain payments will be made to Harbourfront and/or its major shareholder, so long as the Carrying Broker is the carrying broker for Harbourfront, for maintaining client investment loans with NBC, where a proportion of the loan proceeds are invested in NBC investment products and for generating revenues resulting from the purchase by Harbourfront clients of specified products and services of NBC or its affiliates.