Sagard EMD Inc.

Sagard EMD Inc. is registered as an exempt market dealer in the provinces of British Columbia, Alberta, Manitoba, Ontario, Quebec, and Nova Scotia and will act as the dealer in respect of purchases of interests by Canadian investors in funds advised by Sagard Holdings Manager LP in the Canadian provinces in which Sagard EMD Inc. is registered as an exempt market dealer. The Ontario Securities Commission is the Principal Regulator of Sagard EMD Inc.

Privacy Policy

Confidentiality of client information

Sagard EMD Inc. (Sagard EMD) earns your trust by adhering to privacy principles in protecting your personal information. The term “personal information” refers to information that specifically identifies you as an individual and is provided to or collected by us. It includes, for example, your name and address, age and gender, personal information records, identification numbers such as your social insurance number, and your employment information.

Collection and use of personal information

Sagard EMD is required under securities legislation and anti-money laundering legislation to collect information to verify the identity and reputation of clients. Sagard EMD is also required under securities legislation to make a determination to ensure a proposed investment is suitable for you. To assess the suitability of proposed investments, Sagard EMD will obtain information relating to your investment objectives, risk tolerance, investment knowledge, financial situation and circumstances. In providing services to clients, Sagard EMD may be required to use and share personal information with employees, third party service providers and other financial institutions. When you submit a completed subscription agreement to us, you authorize us to collect this information during the course of our relationship. 

Sharing personal information

Sagard EMD may share personal information with affiliates (including those in Canada, the US and Europe) for business and relationship management, and marketing purposes.  You may opt out of marketing communications from Sagard EMD or affiliates.  Sagard EMD may transfer personal information to service providers, including providers located outside your region.  Sagard EMD will not use or disclose personal information for purposes other than those for which it was collected except with the consent of the client or as required by law. Personal information will be retained only as long as necessary for these purposes or required by law.

Safeguarding personal information

Client personal information is protected by security safeguards that are appropriate to the sensitivity level of the information. All employees of Sagard EMD and/or Sagard Holdings Manager LP and/or certain of their affiliates are responsible for protecting client privacy, confidentiality and security. This obligation remains in effect even after an employee leaves the Firm. Sagard EMD has appropriate controls in place over computer systems in compliance with its Privacy Policy.

Sagard EMD uses contractual and other measures to ensure that its affiliates and third party service providers requiring the use of personal information have appropriate security procedures and controls to protect the personal information of Sagard EMD’s clients. Note that law enforcement agencies in your region or other countries where personal information may be stored may have legal rights to access your personal information.

Updating and accessing your personal information

With some limited exceptions, you have rights to access and update personal information held by Sagard EMD about you. You may inquire about any personal information Sagard EMD may have about you, by sending an email to [email protected] You must include your full name, address and telephone number and a copy of an identity document (such as an ID card or passport). This allows Sagard EMD to verify your identity and whether the Firm has any personal information about you. Sagard EMD will contact you if the Firm needs additional information to make that determination. 

 

You may request that Sagard EMD correct, cancel, and stop processing personal information that Sagard EMD holds about you. If Sagard EMD agrees the personal information is incorrect, or the processing should be stopped, Sagard EMD will correct the personal information or stop the processing. If Sagard EMD does not agree the personal information is incorrect, Sagard EMD will inform you it does not agree. The Firm will record that you consider personal information to be incorrect in the relevant file.