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APPENDIX D

Conflict Of Interest Policy For Sales Representatives Of Investors Group

(from the December 8, 1995 Sales Bulletin)

As professionals, there is a need for real and perceived integrity in all dealings with clients. The best interests of the client must always be the first consideration. There are a number of situations that can arise, resulting in a potential conflict of interest for a Representative. Representatives must avoid allowing their relationship with a client to produce an actual or perceived conflict between personal interests and those of the client.

Here are some examples of situations to avoid:

Power of Attorney: A client may wish to give you Power of Attorney over his/her affairs. There is potential for a conflict of interest if you deal with the client's investments. Accordingly, you are not to act as attorney for your clients. In cases where you are appointed without knowledge, you must decline to act in that capacity as soon as you become aware (See Section 6 of the Estate Planning Guide for more details).

Trustee: A trustee is responsible for the administration of the assets in a trust. That responsibility often requires the trustee to invest trust assets. It is possible that a client may request that you act in this capacity. Trustee activities can create a conflict of interest for you, and although it may seem very logical that the client appoint you as trustee, this must be avoided. If you are appointed without your prior knowledge, you should resign as soon as you become aware of the appointment, in order to avoid any potential conflict of interest (See Section 11 of the Estate Planning Guide for more details).

Executor of a client's estate: An estate is a form of a trust. The executor is normally also appointed as trustee of the estate and is responsible for investing the assets of the estate. Accordingly, the potential for a conflict of interest, as described in the immediately preceding section, could arise and must be avoided.

Beneficiary relationship: You should not permit a client to name you as a beneficiary of their estate or of a particular Investors Group account. By having a stake in their assets, a conflict of interest is created.

Borrowing from or lending to a client: Investors Group Representatives are not permitted under any circumstances to borrow from or lend to a client. Borrowing from or lending to a family member who is also a client must, in all instances, first be approved by the Regional Vice-President.

Gifts: Gifts cannot be used to induce the purchase of Investors Group products or services. You must limit the annual value of gifts to a client to $50 and such gifts must not be in the form of cash. Of course, you are not limited to the value of non-business related gifts to clients who are family members or close friends.

Outside Activities: You should avoid business relationships with clients other than those involving the products and services offered by Investors Group (e.g. buying or selling property or other items from or to a client). Again, these actions can affect your dealings with the client causing a potential conflict of interest.

Client Address: The address of any client on the records of Investors Group must be that of the client or such other address as the client may direct, but it cannot be that of the Region Office or your personal or business address.

Obviously some of these potential conflict of interest situations cannot be avoided in your dealings with close relatives (e.g. Your father names you as executor of his estate and a beneficiary). There may also be situations where a close friend asks you to act in a capacity that can lead to a potential conflict of interest and it may be difficult to refuse (e.g. A longtime friend names you as the trustee of a trust for their child). In such cases, you must immediately advice your Region Manager of the details of the situation that gives rise to the potential conflict of interest. Your Region Manager will review the information and if satisfied with it, will put that information in your file. In the event there are any concerns raised by that information, it will be referred to the Regional Vice-President for approval. You reduce the possibility of a conflict of interest complaint arising if someone who is responsible for reviewing your business activities is aware of the matter. Any transactions arising from such a potential conflict of interest situation must be carefully documented on the client's file, to show that the transaction was for the benefit of the client and not motivated by your potential personal gain. Again, please note that any loans between a client and yourself must be approved by your Regional Vice-President and not your Region Manager.

The situations presented above are some of the most common circumstances where a conflict of interest may arise. There may be others. The cost implications of a conflict of interest situation could be substantial. You might have to repay any commissions earned and possibly even compensate for any investment losses resulting from the investments that gave rise to the conflict of interest. There is a real need to protect yourself, and that is the objective of this policy. It is to your benefit to avoid conflict of interest situations. If the situation is unavoidable, fully documenting the circumstances will only take a few minutes and can prevent a very difficult, time consuming and expensive problem.

If you are currently involved in any of these situations, please let your Region Manager know immediately in writing. You should indicate the details of the situation; who is involved and what you action plan is to handle it. It is definitely in your best interest to deal with the situation before a problem arises.