Fairness in Client Dealings Policy

Polaris Financial Inc. provides fee-based investment advice and discretionary portfolio management services. This policy sets standards to ensure fairness in the allocation of investment opportunities among its clients.

1) Investment decisions: 

Investment decisions relating to client portfolios are made after considering the following factors: suitability, client investment objectives, risk tolerance, time horizon, income needs, liquidity needs, tax-related factors, constraints (security and industry), and the representatives’ asset mix targets.

2) Trading in client accounts:

 i) Trading by Security: In order to ensure fairness of order execution, orders for the purchase and sale of securities are entered alphabetically by households last name. This consistently applied process will mean that variations in market prices will affect clients randomly. The allocation of any initial public offerings will be done on a pro-rata basis without any favouritism.

ii)  Rebalancing by Household: In order to ensure fairness of order execution, each adviser rebalances account households alphabetically by name of Household. This consistently applied process will mean that variations in market prices will affect clients randomly. Priority may be given to clients with large cash positions (measured as a percent of account), recently transferred or matured securities, and off-target accounts.

iii) Personal Trading: Polaris Financial Inc. has a Personal Trading Policy. Advisors and staff must follow and acknowledge in writing that they understand and will abide by the firm’s Personal Trading Policy and the Code of Ethics and Conduct.

iv) One-off trading: One-off trading relates to trades that are exempt from the "Trading By Security" and "Rebalancing by Household" rules above. These trades result from: a direct request from a client; a contribution/withdrawal that affects the allocation of the portfolio; or any change in a client’s Investment Policy Statement.

3) Best price and Execution: 

In executing client transactions, every effort will be made to achieve the best price and execution for accounts. This includes negotiating commissions (whenever possible), ensuring timely order execution, and subsequent reviews of order fills to ensure reasonableness.

4) Partial fills and limited issues: 

All partial fills and limited issues will be allocated on a pro-rata basis.

5) Allocation of pricing and commissions on block trades: 

Average pricing is used when trades are blocked. This process will ensure clients receive the same pricing for each security traded as part of a block.

6) IPOs and “hot issues”: 

The allocation of IPOs and “hot issues” is based upon suitability. Once suitability has been established, allocation is done on a pro-rata basis.

7) Block trades at differing prices and/or lots: 

In the event of differing prices on block trades, average pricing is used. In the event of differing lots, trades are allocated on a pro-rata basis