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JONES, GABLE & COMPANY LIMITED

PRIVACY POLICY DISCLOSURE

On January 1, 2004, the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) took effect. This legislation is designed to help safeguard your personal information and applies to all organizations that collect, use, or disclose personal information in the course of commercial activities.

Jones, Gable & Company Limited (“JGCL”) is committed to protecting the personal information that you share with us, including the details of the advisory relationship that you have with your investment advisor.

As a result of this commitment, we have developed a privacy policy based on PIPEDA and wish to provide you with the following summary.

When you open an account with JGCL you provide us with certain personal information. This information includes your name, address, age, certain financial information, identification numbers (including your social insurance number which is used for income tax reporting purposes as required under the Federal and Quebec Income Tax Acts and for internal administrative purposes), your employment information, your investment objectives, investment knowledge and risk tolerance.

We use this information primarily to:

Your personal information can also be used to identify other services and products that are offered by JGCL, such as externally managed mutual funds, our data processing provider and our clearing broker, MRS Securities Inc. For Regulatory purposes, self-regulatory organizations including Market Regulation Services Inc., the Investment 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 or is used by Jones, Gable & Company Limited (“Regulated Persons”). SRO’s collect, use or disclose such personal information obtained by regulated persons for regulatory purposes, including: 

We take our responsibility for protecting the confidentiality of your personal information very seriously and value your choice in sharing this information with us. If you would like to confirm or update any of your information please notify your Registered Representative. If you have any questions or concerns regarding your information, please do not hesitate to contact our Chief Compliance Officer, Mr. Todd Doige at (416) 365-8060.

STATEMENT OF POLICIES CONCERNING CONFLICT OF INTEREST WITH RELATED ISSUERS AND CONNECTED ISSUERS AS AT JULY 2006

Securities laws of certain jurisdictions of Canada require securities dealers and advisors, when they trade in, or advise with respect to, their own securities or securities of certain other issuers to which they, or certain other parties related to them, are related or connected, to do so only in accordance with particular disclosure and other rules. In certain provinces and territories, these rules require dealers and advisors, prior to trading with or advising their customers or clients, to inform them of the relevant relationships and connections with the issuers of the securities. Client and customers should refer to the applicable provisions of those securities laws for the particulars of these rules and their rights or consult with a legal advisor.

General

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 party having an ownership or business relationship with us.

Since these transactions may create a conflict between our interests and yours, we are required by securities laws to disclose to you certain relevant matters relating to the transactions. This Statement contains a general description of the required disclosure.

Important Concepts

“Related Issuer” A party is related to us if, through the ownership of or direction or control over voting securities or otherwise, we exercise a controlling influence over that party.

“Connected Issuer” A party is connected to us if, due to indebtedness or certain other relationships, a prospective purchaser of securities of the connected party might question our independence from that party.

Required Disclosure

We must make certain disclosures where we act as your broker, advise you, or exercise discretion on your behalf with respect to securities issued by a related party or, in the course of an initial distribution, by a connected party. In these situations, we must disclose either our relationship with the issuer of the securities. We must also make a disclosure to you where we know or should know that, as a result of our acting as your broker or advisor, or of our exercising discretion on your behalf, securities will be purchased from or sold to us, an associated party or, in the course of an initial distribution by a connected party.

The following is a list of the time and manner in which these disclosures must be made:

Where we underwrite securities, the required disclosure will be contained in the prospectus or other document being used to qualify those securities.

Where we buy or sell securities for your account, the required disclosure will be contained in the confirmation of trade that we prepare and send to you.

Where we advise you with respect to the purchase or sale of securities, the disclosure must be made prior to our giving the advice

In addition, where we exercise discretion under your authority in the purchase or sale of securities for your managed account, we may not exercise that managed account discretion for the types of transactions described above unless we have obtained your prior specific and informed written consent.

We may, from time to time, be deemed to be related or connected to one or more issuers for the purpose of the disclosure and other rules of the securities laws referred to above. We are prepared to act as an advisor, dealer and underwriter in the ordinary course of our business to, and in respect of, any such related or connected issuer and in connection therewith to provide the full range of services customarily provided by us to and in respect of securities of other issuers. In any such case, such investment dealer and other services shall be carried on by us in the ordinary course of our business as an advisor, dealer or underwriter in accordance with our usual practices and procedures and in accordance with all applicable disclosure and other regulatory requirements.

Jones, Gable & Company Limited or its directors, officers, partners, salespeople or other employees may, from time to time, recommend that you trade in, or provide to you advice about, a security issued by these listed persons or companies. If you wish further information concerning the relationship between Jones, Gable & Company Limited and these listed persons or companies, or if you have any questions, please contact Mr. Todd Doige, Chief Compliance Officer at (416) 365-8060.

List of Related Parties:None

List of Connected Parties:
Impax Venture Income Fund Inc.                        Normiska Corporation
Macdonald Mines Exploration Ltd.                      Menora Resources Inc.
International Starteck Industries            Cimatec Environmental Engineering
Birim Goldfields Inc.                           FNX Mining Company Inc.   Ursa Major Minerals Inc.

SERVICE FEE SCHEDULE

EFFECTIVE DECEMBER 1, 2006

 

Amounts shown are inclusive of GST where applicable. 

All accounts
Transfer of entire account to another financial institution $ 100.00
- Transfer of individual securities to or from an account at another domestic financial institution $ 10.00 per security
- Registration of physical certificate $ 25.00 + CDS and transfer agent fees
- Deposit of physical certificate - domestic issuer $ 10.00 + CDS and transfer agent fees
- Deposit of physical certificate - foreign issuer $ 25.00 + CDS, transfer agent, and custodian fees
- Settlement of trade in security a of non-North American issuer $ 75.00
Registered Accounts
- Annual administration fee $ 100.00
- Full deregistration $ 50.00
- Partial deregistration $ 25.00
Banking
- Returned cheques $ 25.00
- Cheque certification $ 10.00
- Wire transfers - Within Canada
- Outside Canada
$ 20.00
$ 10.00 + cost
- Deposit cheque at bank (certification may be required) $ 10.00
- Early settlement ½ of 1%, minimum
$15.00
Records search
- Records search within last twelve months $ 10.00 + $1.00/page
- Records search prior to last twelve months $ 100.00 + $1.00/page
- Annual trading summaries $ 20.00