The Securities Commission

OSC Bulletin

August 8, 2019

Volume 42, Issue 32

(2019), 42 OSCB

The Ontario Securities Commission administers the Securities Act of Ontario (R.S.O. 1990, c. S.5) and the Commodity Futures Act of Ontario (R.S.O. 1990, c. C.20)

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Table of Contents

Chapter 1 Notices ...... 6615 Chapter 12 Registrations ...... 6707 1.1 Notices ...... 6615 12.1.1 Registrants ...... 6707 1.1.1 OSC Staff Notice 33-750 Compliance and Registrant Regulation – Summary Report for Chapter 13 SROs, Marketplaces, Dealers, Advisers and Investment Fund Clearing Agencies and Managers ...... 6615 Trade Repositories ...... 6709 1.1.2 CSA Staff Notice 51-358 – Reporting of 13.1 SROs ...... 6709 Climate Change-related Risks ...... 6617 13.1.1 Investment Industry Regulatory Organization 1.2 Notices of Hearing ...... 6619 of Canada (IIROC) – Amendments Respecting 1.2.1. Sean Daley et al. – ss. 127(8), 127(1) ...... 6619 Provision of Price Improvement by a Dark 1.3 Notices of Hearing with Related Order – Notice of Commission Approval ...... 6709 Statements of Allegations ...... (nil) 13.2 Marketplaces ...... 6710 1.4 Notices from the Office 13.2.1 CSE – Amendments to Trading System of the Secretary ...... 6620 Functionality & Features – Notice and 1.4.1. Sean Daley et al...... 6620 Request for Comment ...... 6710 1.5 Notices from the Office 13.2.2 CSE – Notice of Withdrawal of Proposed of the Secretary with Related Amendments to Trading Rules ...... 6713 Statements of Allegations ...... (nil) 13.3 Clearing Agencies ...... 6714 13.3.1 Banque Centrale De Compensation Carrying Chapter 2 Decisions, Orders and Rulings ...... 6621 on Business as LCH SA – Application for 2.1 Decisions ...... 6621 Exemption from Recognition as a Clearing 2.1.1 Foresters Asset Management Inc. et al...... 6621 Agency – OSC Notice and Request for 2.1.2 Freedom International Brokerage Company Comment ...... 6714 et al...... 6625 13.4 Trade Repositories ...... (nil) 2.2 Orders...... 6628 2.2.1 Delivra Corp...... 6628 Chapter 25 Other Information ...... 6723 2.2.2 Sean Daley et al. – ss. 127(1), 127(5) ...... 6630 25.1 Consents ...... 6723 2.3 Orders with Related Settlement 25.1.1 Newstrike Brands Ltd. – s. 4(b) of Ont. Agreements ...... (nil) Reg. 289/00 under the OBCA ...... 6723 2.4 Rulings ...... (nil) 25.2 Application to Extend Temporary Order 25.2.1 Sean Daley et al. – ss. 127(8), 127(1) ...... 6725 Chapter 3 Reasons: Decisions, Orders and Rulings ...... (nil) Index ...... 6727 3.1 OSC Decisions ...... (nil) 3.2 Director’s Decisions ...... (nil)

Chapter 4 Cease Trading Orders ...... 6631 4.1.1 Temporary, Permanent & Rescinding Issuer Cease Trading Orders ...... 6631 4.2.1 Temporary, Permanent & Rescinding Management Cease Trading Orders ...... 6631 4.2.2 Outstanding Management & Insider Cease Trading Orders ...... 6631

Chapter 5 Rules and Policies...... (nil)

Chapter 6 Request for Comments ...... (nil)

Chapter 7 Insider Reporting...... 6633

Chapter 9 Legislation ...... (nil)

Chapter 11 IPOs, New Issues and Secondary Financings ...... 6697

August 8, 2019 (2019), 42 OSCB

Chapter 1

Notices

1.1 Notices

1.1.1 OSC Staff Notice 33-750 Compliance and Registrant Regulation – Summary Report for Dealers, Advisers and Investment Fund Managers

OSC Staff Notice 33-750 Compliance and Registrant Regulation – Summary Report for Dealers, Advisers and Investment Fund Managers is reproduced on the following separately numbered pages. Bulletin pagination resumes at the end of the Staff Notice.

August 8, 2019 (2019), 42 OSCB 6615

Notices

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August 8, 2019 (2019), 42 OSCB 6616

Summary Report for Dealers, Advisers and Investment Fund Managers

Compliance OSC Staff Notice 33-750 and Registrant Regulation August 8, 2019 CONTENTS

- 3 - Director’s message

- 4 - Introduction

- 8 - Outreach

- 14 - Information for dealers, advisers and investment fund managers

- 43 - Initiatives impacting registrants

- 46 - Acting on registrant misconduct

- 53 - Staff directory

OSC Staff Notice 33-750 Director’s message

We are happy to publish this year’s Summary contact list with the names and phone numbers Report for Dealers, Advisers and Investment Fund of all CRR team members. This year we’ve also Managers (Summary Report) that provides an provided information to clarify our CRR team overview of our work during the 2018-2019 fiscal structure which is focused on each of our primary year. direct registrant categories. If you have a question, comment or want to discuss regulatory policy, In addition to the work set out in this year’s compliance practices, registration processes or any Summary Report, the Compliance and Registrant matter impacting your business model, you’ll have Regulation Branch (CRR) is actively engaged in the tools to know who to contact! the Ontario Securities Commission’s new Burden Reduction Task Force. We understand the We continue to update our Registrant Outreach frustration of duplicative, unclear or inconsistent program which includes educational seminars, requirements and are moving as an organization to the Topical Guide for Registrants and a listing of tackle these issues. Through the Burden Reduction Director’s Decisions by topic and year. initiative, we are evaluating stakeholder comments to identify areas that CRR can focus on to reduce This year, our compliance reviews will focus on the burden. It’s important that compliance with our following areas: requirements is not unduly burdensome and does • suitability assessments, including not stand in the way of economic growth and concentration and prospectus exemptions, innovation. • firms that have recently acquired another firm to assess the compliance structure of As an operational branch, we monitor and the newly integrated firm, consistently meet our service standards for • high-risk registrants that were identified registration and exemptive relief applications. The through “Registration as the First service standards apply to routine applications Compliance Review” program, and and the clock starts ticking once we receive a • high-impact and high-risk firms. complete application. However, applications that are incomplete or raise novel matters may take We continue to receive positive feedback from longer than the expressed service standards. We registrants on our Summary Report and are open will continue to respond as promptly as feasible to suggestions that would further enhance its and assist our registered firms and individuals usefulness for you. As always, we look forward to (collectively, registrants) wherever possible. engaging with our registrants in the upcoming year.

While we strive for strong and open lines of Debra Foubert communication with registrants, we heard that you Director, Compliance and want a contact person to call who is familiar with Registrant Regulation your type of business. We continue to provide a

OSC Staff Notice 33-750 3 Introduction

Who we are The CRR Branch of the Ontario Securities Commission (OSC, the Commission) is responsible for the registration and ongoing regulation of firms and individuals who are in the business of trading in, or advising on, securities or commodity futures and firms that manage investment funds in Ontario. The OSC’s mandate is to: • provide protection to investors from unfair, improper or fraudulent practices, • foster fair and efficient capital markets, and • contribute to the stability of the financial system and the reduction of systemic risk.

CRR’s activities are integral to the OSC’s vision of being an effective and responsive securities regulator, fostering a culture of integrity and compliance and instilling investor confidence in the capital markets.

The purpose of this report This Summary Report prepared by staff of the CRR Branch is designed to assist registrants with information on the following:

• Education and outreach Part 1 of this report provides links and information to the registration and ongoing educational resources and outreach opportunities available to current and prospective registrants.

• Regulatory oversight activities and guidance Part 2 of this report can be used by registrants as a self-assessment tool to strengthen compliance with Ontario securities law and, as appropriate, to make changes to enhance their systems of compliance, internal controls and supervision.

• Impact of upcoming initiatives Part 3 of this report provides insights into some of the new and proposed rules and other regulatory initiatives that may impact a registrant’s operations.

• Registrant conduct activities Part 4 of this report is intended to enhance a registrant’s understanding of our expectations and our interpretation of regulatory requirements. This section also provides insight into the types of regulatory actions the CRR Branch may take to address non-compliance.

Structure The following page sets out the organizational structure of the CRR Branch. We encourage registrants to reach out to staff with any inquiries they may have. Contact information for directors, managers and staff within the branch can be found in the Staff directory presented at the end of this report.

OSC Staff Notice 33-750 4 OSC Staff Notice 33-750 5 Advisory committees Established in January 2013, the Registrant Advisory Committee (RAC) is currently comprised of 11 external members. The RAC’s objectives include: • advising on issues and challenges faced by registrants in interpreting and complying with Ontario securities law, including matters related to registration and compliance, and • providing feedback on the development and implementation of policy and rule-making initiatives that promote investor protection and fair and efficient capital markets.

The RAC meets quarterly, with members serving a minimum two-year term and is chaired by Debra Foubert. Topics of discussion over the past fiscal year included: • the OSC’s whistleblower initiative, • CSA Staff Notice 61-303 and Request for Comment Soliciting Dealer Arrangements, • CSA Staff Notice 23-320 Consideration of the Markets in Financial Instruments Directive (MiFID II) Unbundling Requirements on the Regulatory Requirements in Canada, • MFDA Bulletin #0748-P Discussion Paper on Expanding Cost Reporting, • sales practices and the OSC’s recent enforcement proceedings, and • regulatory burden reduction and the cost of compliance.

The Fintech Advisory Committee (FAC) was established in 2017 to advise OSC staff on developments in the fintech space as well as the unique challenges faced by innovation businesses.The current FAC includes key players from a broad spectrum of the fintech community, ranging from start-ups, auditors, lawyers, and representatives from regulated entities and industry organizations.

The FAC meets quarterly, with members serving a minimum one-year term and is chaired by Pat Chaukos. Topics of discussion over the past fiscal year included: • investment limits, • crypto-asset trading platforms and custody of client assets, • resale of coins/tokens, • open data, and • artificial intelligence in financial services.

Who this report is relevant to This Summary Report provides information for registrants that are directly regulated by the OSC. These registrants primarily include exempt market dealers (EMDs), investment fund managers (IFMs), portfolio managers (PMs) and scholarship plan dealers (SPDs). At present, registrants overseen by the OSC include:

1,053 68,366 Firms1 Individuals

224 5163 3084 5 5 EMDs2 IFMs PMs SPDs

1 This number excludes firms registered as mutual fund dealers or firms registered solely in the category of investment dealer or other registration categories (commodity trading manager, futures commission merchant, restricted PM, and restricted dealer). 2 This number includes firms registered as sole EMDs. 3 This number includes firms registered as sole IFMs and IFMs also registered in other registration categories. 4 This number includes firms registered as sole PMs and PMs also registered as EMDs, and in other registration categories. 5 This number includes firms registered as sole SPDs and SPDs also registered as IFMs.

OSC Staff Notice 33-750 6 In general, firms must register with the OSC if they conduct any of the following activities in Ontario: • are in the business of trading in, or advising on, securities (this is referred to as the “business trigger” for registration), • act as an underwriter or as an IFM, or • conduct trading and advising activities involving commodity futures contracts or commodity futures options.

Individuals must register if they trade, advise or underwrite on behalf of a registered dealer or adviser, or act as the Ultimate Designated Person (UDP) or Chief Compliance Officer (CCO) of a registered firm.

There are seven dealer and adviser categories for firms trading in or advising on securities, or acting as an underwriter, as applicable: • EMD, • SPD, • restricted dealer, • PM, • restricted portfolio manager, • investment dealer (ID), who must be members of the Investment Industry Regulatory Organization of Canada (IIROC), and • mutual fund dealer (MFD), who must, except in Quebec, be members of the Mutual Fund Dealers Association of Canada (MFDA).

There are four dealer and adviser categories for firms trading in or advising on commodity futures: • commodity trading adviser, • commodity trading counsel, • commodity trading manager, and • futures commission merchant.

There is a separate category for firms that direct the business, operations, or affairs of investment funds: • IFM.

The OSC also registers firms and individuals in the category of MFD and dealing representatives, and firms in the category of ID; however, these firms and their registered individuals are directly overseen by the self-regulatory organizations (SROs): the MFDA and IIROC, respectively. Although this report focuses primarily on registered firms and individuals directly overseen by the OSC, firms directly overseen by the SROs should review Part 2 of the Summary Report as certain information is applicable to them as well.

Applications for registration are reviewed by CRR staff, nonetheless, we remind firms seeking registration in the category of ID, MFD or futures commission merchant to also apply separately for membership with the relevant SRO.

Service standards The CRR Branch is committed to accountability and transparency and to ensuring services are delivered in the most efficient and effective ways possible. For information about CRR’s service standards and timelines, refer to the OSC Service Commitment webpage.

OSC Staff Notice 33-750 7 Part 1 OUTREACH

1.1 Outreach program and resources

1.2 Registration

1.3 OSC LaunchPad

OSC Staff Notice 33-750 8 1.1 Outreach program and resources

We continue to interact with our stakeholders through our Registrant Outreach program, which was launched in 2013. The objectives of our Registrant Outreach Registrant Outreach program are to strengthen communication with Ontario since inception registrants that we directly regulate and with other industry participants (such as lawyers and compliance consultants), to promote stronger compliance practices and to enhance investor protection.

Interested in attending an upcoming Registrant Outreach seminar? 62 Click here for our calendar of upcoming events. In-person and webinar seminars held Looking for information about regulation matters? Take a look at our Registrant Outreach webpage or our Topical Guide for Registrants for help with key compliance issues and policy initiatives.

Want to be informed about newly released guidance? 5,117 Register to receive our e-mail blasts here. Web replays viewed Looking for a listing of recent e-mail blasts and links to each? Refer to the OSC Compliance Reports, Staff Notices & E-mail blasts webpage.

12,529 Interested in reading previously published Director’s Decisions? Individuals that have Refer to the Director’s Decisions webpage. attended outreach sessions If you have questions related to the Registrant Outreach program or have suggestions for seminar topics, please send an e-mail to [email protected]. >10,000 Topical Guide for Registrants - page views annually

OSC Staff Notice 33-750 9 1.2 Registration

National Registration Database access best practices for Authorized Firm Representatives

In January 2019, the Canadian Securities Administrators (CSA) sent the Authorized Firm Representative (AFR) Account Management Best Practices Checklist (the AFR Guide) to each firm’s Chief Authorized Firm Representative (CAFR).

The AFR Guide is designed to help firms better manage and protect the data of firms and individuals maintained in the National Registration Database (NRD).

The security of the data contained in NRD is paramount. The CSA conducts regular reviews of NRD to ensure that necessary protections and controls are in place to safeguard the data. The CSA also uses industry-recognized security services to monitor and protect NRD and the data contained in the system from malicious activity.

Despite the safeguards in place at the system level, the failure of a firm to adequately manage its users’ access to NRD can lead to the unauthorized modification, destruction, or disclosure of firm or individual specific information contained in NRD.

The AFR Guide was prepared by the CSA based on ISO 27002 best practices for information technology. Although firms are expected to have their own security policies and procedures already in place, the CSA recommends that firms review their existing internal processes and controls against these best practices.

For more information, please refer to the AFR Guide.

Data analytics and Natural Language Processing The CRR Branch uses a variety of data analytics, text mining and reporting tools to assist with the review of various filings and other documents. For example, we use Natural Language Processing (NLP) to sift through filings and comment letters to discover common themes. We also use NLP to determine overall sentiment and assess the tonality of comments. These tools and techniques allow us to map and gain insights about the registrant population, including trends and risks.

As we gain more experience with these tools, we expect that our data strategy will further enhance our evidence-based decision making and allow us to work more efficiently. By combining data and connecting the dots, we will be able to use data analytics to achieve appropriate regulatory outcomes and also aid in reducing regulatory burden. In terms of regulatory burden, we know that filers want to “tell the regulator once”, and that filers would appreciate receiving forms that have some data pre-populated.To be responsive, we are trying to identify situations where this might be possible, as part of our regulatory burden reduction plan.

OSC Staff Notice 33-750 10 1.3 OSC LaunchPad

Modernizing regulation to support fintech innovation

OSC LaunchPad seeks to support the development of innovative financial business models by deepening engagement with novel fintech businesses and creating flexible, timely and proportionate regulatory approaches.

OSC LaunchPad is comprised of a core team that is exclusively focused on fintech and an extended team representing the various branches at the OSC. Drawing on the expertise across the OSC, we have developed specialized working groups to consider novel issues and respond quickly to emerging developments. The work of the OSC LaunchPad team focuses on three main areas:

Providing direct support to Taking learnings and applying Engaging with the fintech eligible fintech businesses them to similar businesses community in navigating regulatory going forward requirements

OSC LaunchPad’s Direct Support Process

Our direct support process provides an opportunity for firms to discuss their business and proposed approaches as well as raise questions. We are interested in hearing from businesses that meet the following criteria:

You are a fintech business that has not yet started operations or is in the process of applying to the OSC for registration or exemptive relief.

You have a new innovation or significantly different product, service or application from those currently available.

Your innovation will likely provide identifiable benefits to investors.

You understand the necessity of investor protections and will invest time and energy in understanding and addressing them.

You acknowledge the application of securities laws and have considered how it applies to your business.

For more information on how to apply for direct support, please visit OSC LaunchPad’s webpage.

OSC Staff Notice 33-750 11 Key accomplishments of OSC LaunchPad to date

369 Meetings held with fintech businesses and stakeholders

230 Requests for support received and direct support provided to fintech businesses

136 Events that OSC LaunchPad has participated in or hosted

Collaborative reviews with the CSA Regulatory Sandbox of novel businesses that want 32 to operate across Canada

Emerging trends

Over the past year, despite the decline in value of crypto assets, the industry focus has continued to be on crypto-asset related businesses, including crypto-asset investment funds, initial coin/token offerings and crypto-asset trading platforms.

Auditors and crypto-asset custodians have critical roles to play in the crypto-asset ecosystem with respect to the safeguarding of crypto assets. We have heard from businesses that are developing crypto-asset custody solutions that they are experiencing challenges with obtaining audit reports, which provide assurance on the operating effectiveness of custody solutions. Other crypto-asset related businesses have also indicated that they are experiencing challenges in obtaining audited financial statements and audited options with respect to crypto assets. We have engaged in discussions with audit firms and custodians to better understand these challenges.

Other emerging industry trends include RegTech services (technology-facilitated regulatory compliance services), SupTech services (technology-facilitated regulatory supervision services), artificial intelligence and machine learning, and open data. We expect additional developments in these areas in the coming year.

For a complete list of novel product offerings and services in respect of which relief has been granted, please visit OSC LaunchPad’s webpage.

OSC Staff Notice 33-750 12 Publications and resources

In March 2019 we published Joint CSA/IIROC Consultation Paper 21-402 Proposed Framework for Crypto- Asset Trading Platforms, which sets out a proposed regulatory framework and seeks input from the fintech community, market participants, investors and other stakeholders on a number of areas that will assist in determining appropriate requirements for crypto-asset trading platforms. These include how to address custody and verification of assets, price determination, market surveillance, system and business continuity planning, conflicts of interest, crypto-asset insurance and clearing and settlement.

The comment period ended May 15, 2019. The CSA and IIROC will be reviewing the comments received and determining next steps in the consultation. We intend to take a flexible approach to regulation and use the feedback to establish tailored requirements for crypto-asset trading platforms that considers the benefits of this technology, while addressing risks to investors and creating greater market integrity.

In June 2018 we published CSA Staff Notice 46-308 Securities Law Implications for Offerings of Tokens to help token issuers determine when an offering of tokens is considered a distribution of securities, including tokens that are commonly referred to as “utility tokens”.

While innovation can offer great investment opportunities, it also comes with risks. OSC LaunchPad continues to support our Investor Office in the publication of fintech-related guidance and research that can assist Canadians in making informed decisions. For a complete list of publications and resources, please visit OSC LaunchPad’s webpage.

Co-operation with International Regulators

In January 2019, the OSC, along with 28 other financial regulators and organizations, joined forces to establish the Global Financial Innovation Network (GFIN). GFIN aims to drive more collaboration with regulators and easier cross-border trials for innovative firms and also provides a forum for different financial services regulators to share knowledge, experiences and approaches to emerging issues.

GFIN has also launched the pilot phase of cross-border testing intended to create an environment to allow firms to trial and scale new technologies in multiple jurisdictions, gaining real-time insight into how a product or service might operate in the market. Several Canadian firms and international firms seeking to operate in Canada have submitted applications for participation in the cross-border testing pilot. GFIN is currently reviewing applications and expects the pilot testing phase to begin in Q3 2019.

More information about OSC LaunchPad’s international regulatory partnerships can be found on the OSC LaunchPad webpage.

OSC Staff Notice 33-750 13 Part 2 INFORMATION FOR DEALERS, ADVISERS AND INVESTMENT FUND MANAGERS

2.1 Annual highlights

2.2 Registration and compliance deficiencies

OSC Staff Notice 33-750 14 How to navigate Part 2 of the Summary Report

Part 2 of the Summary Report provides an overview of the key findings and outcomes from compliance reviews conducted during the 2018/2019 fiscal year.

The highlights in section 2.1 provide readers with a direct link between the key compliance reviews conducted, the guidance issued as a result of our findings and a list of the registration categories that the guidance applies to. Section 2.2 discusses key or novel issues, suggests best practices and specifies applicable legislation and relevant guidance to assist firms in addressing each of the topic areas. For ease of reference, registration categories are listed beside each deficiency heading to indicate the information that is relevant to firms registered in this capacity.

We encourage registrants to review all the information set out in Part 2 of this report as the guidance presented may be helpful to registration categories other than those listed.

OSC Staff Notice 33-750 15 2.1 Annual highlights

a) 2018 Risk Assessment Questionnaire b) High-risk registrants c) Referral arrangements d) Short-term trading and excessive trading e) High-impact registrants f) Compensation and incentive practices g) Expanded exempt market h) Illiquid holdings i) Online dealer platforms j) Sales practices k) Capital-raising activity

OSC Staff Notice 33-750 16 WHAT WE DID REFERENCE REGISTRANTS

a) 2018 RISK ASSESSMENT QUESTIONNAIRE

Consistent with prior years, in April 2018 we issued • section 2.2.2 IFM a comprehensive risk assessment questionnaire (the (page 30) RAQ) to 1,058 firms that were registered with the OSC in the categories of PM, restricted PM, IFM, EMD and PM restricted dealer. The RAQ is issued on a two-year cycle, so registered firms can expect to receive the next version in 2020. The RAQ is our primary tool to gather EMD information about our registrants’ business operations, which supports our risk-based approach to select firms for on-site compliance reviews or targeted reviews.

The information collected from the 2018 RAQ was analyzed using a risk assessment model. Every registrant’s response was risk-ranked and a risk score was generated. Firms may be risk-ranked as high based on a variety of factors, including the broad nature of a firm’s business activities, a large amount of client assets under management (AUM), the size of the firm, and the number of clients and/or the type of clients serviced by the firm. Firms that are risk-ranked as high may be selected for a compliance review. In addition, if we conduct a targeted review of a particular area of interest, we may select firms for this review based on their RAQ responses.

b) HIGH-RISK REGISTRANTS

In 2018 we commenced compliance reviews of • section 2.2.1 IFM high-risk registrants identified through the RAQ process (page 24-29) as discussed above. A sample of registered firms that were risk-ranked as high based on their responses to • section 2.2.2 PM the 2018 RAQ were selected for review. We are in the (page 30) process of completing these reviews and will report the findings from these reviews to each firm. As is our EMD normal process, depending on the deficiencies identified • section 2.2.3 during a compliance review, we may consider further (page 33) regulatory action to remediate the deficiencies. SPD • section 2.2.4 (page 34)

OSC Staff Notice 33-750 17 WHAT WE DID REFERENCE REGISTRANTS

c) REFERRAL ARRANGEMENTS

In 2018, we conducted a sweep (the referral sweep) • section 2.2.5 PM of six registered firms that have a business model (page 40) based on attracting new clients by way of client referrals from third parties (referral arrangements). EMD The referral sweep focused on determining how PM and EMD firms address the following inherent risks present in referral arrangements: SPD • client confusion as to the roles and responsibilities of the registrant and referral agent, and • the risk that an unregistered referral agent may conduct registerable activity.

d) SHORT-TERM TRADING AND EXCESSIVE TRADING

In 2018, we conducted a review to assess how IFMs • section 2.2.5 IFM monitor short-term trading and excessive trading (the (page 39) STT review) by unitholders of their investment funds. We selected 25 IFMs to participate in the STT review. MFD The STT review focused on assessing whether the IFMs had developed and implemented adequate policies ID and procedures to monitor and deter short-term trading and excessive trading activities in the investment funds they manage. We also reviewed details regarding the circumstances under which a short-term trading fee was being waived to determine whether such action could have an adverse impact to the remaining unitholders of the affected investment fund. Lastly, we investigated whether short-term trading fees were being waived consistently for certain unitholders or unitholders of dealing representatives who had a large level of client assets invested in the IFM’s investment funds (i.e., the “top producers”).

OSC Staff Notice 33-750 18 WHAT WE DID REFERENCE REGISTRANTS

e) HIGH-IMPACT REGISTRANTS

As part of our risk-based approach to selecting firms for • section 2.2.2 IFM review, we include firms that could have a significant impact (page 30) on the capital markets if there were a breakdown in their compliance structure or key operations (high-impact • section 2.2.5 PM firms). (page 37-38) In 2018, we completed compliance reviews of six firms which were classified as high-impact. These firms have a combined AUM of $325 billion. The types of deficiencies we identified during these reviews were similar to the deficiencies we identified at other firms in our registrant population.

High-impact firms more frequently use an automated compliance system (ACS) to monitor and manage compliance for their trading and portfolio management practices. We continue to note that improvements are required around high-impact firms’ controls over their use of an ACS. The use of an ACS by high-impact firms was discussed in detail in section 3.1(c)(iv) of OSC Staff Notice 33-748 Annual Summary Report for Dealers, Advisers and Investment Fund Managers.

f) COMPENSATION AND INCENTIVE PRACTICES

We conducted a review of 14 PMs and EMDs focusing on • section 2.2.5 PM their compensation and incentive practices. (page 42)

The purpose of this review was to: EMD • obtain a better understanding of the compensation practices at PMs and EMDs including compensation practices for staff in a compliance or supervisory role, SPD • assess compliance with the conflicts of interest requirements in Part 13 of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103), and • determine whether firms have adequate controls in place to mitigate against conflicts of interest arising from compensation arrangements.

OSC Staff Notice 33-750 19 WHAT WE DID REFERENCE REGISTRANTS

g) EXPANDED EXEMPT MARKET

We completed a second review to assess the use of • section 2.2.1 EMD prospectus exemptions recently introduced in Ontario (page 26) (the expanded exempt market review). The expanded exempt market review was coordinated in conjunction with the New Brunswick, Quebec and Saskatchewan securities commissions and included 18 EMDs, 10 of which were reviewed by the OSC. The EMDs reviewed facilitated the distribution of securities in reliance on the offering memorandum (OM) and/or the family friends, and business associates (FFBA) prospectus exemptions. The objective of the review was to assess the use of the OM and FFBA prospectus exemptions, and for the OSC to assess whether there had been improved compliance since the first expanded exempt market review conducted in 2017.

h) ILLIQUID HOLDINGS

We conducted a review of 11 IFMs who managed • section 2.2.2 IFM investment funds with large holdings in illiquid securities (page 31) (the illiquid holdings review). The illiquid holdings review focused on assessing the adequacy of the IFMs’ PM valuation procedures. In addition, our review assessed whether the IFM was appropriately overseeing the investment fund’s compliance with applicable regulatory restrictions or investment restrictions as stated in the investment fund’s offering document.

i) ONLINE DEALER PLATFORMS

In 2017 and 2018, we conducted compliance reviews • OSC Staff Notice EMD of 8 EMD and restricted dealer firms that operate online 33-749 (page 34) dealer platforms for the distribution of exempt market products. The purpose of these reviews was to determine if the firms had designed and established appropriate compliance systems and supervisory controls to effectively address the unique risks associated with their online business models. Through these reviews we also engaged with firms to understand the challenges they faced in operating an online platform and interacting with investors using this medium. Refer to OSC Staff Notice 33-749 Annual Summary Report for Dealers, Advisers and Investment Fund Managers (OSC Staff Notice 33- 749).

OSC Staff Notice 33-750 20 WHAT WE DID REFERENCE REGISTRANTS

j) SALES PRACTICES

We conducted a focused desk review of sales practices • section 2.2.5 IFM (the sales practices desk review) involving the (page 35) provision of non-monetary benefits through items, activities and charitable donations provided under Part MFD 5 and Part 7 of NI 81-105. We selected 25 IFMs to participate in the sales practices desk review. Our work focused on sales practices that could be perceived as ID inducing dealers and their representatives to sell mutual fund securities on the basis of incentives they were receiving, rather than what was suitable for their clients.

k) CAPITAL-RAISING ACTIVITY

We completed a review of 16 issuers that conducted • section 2.2.1 EMD capital-raising activity without involving a registered (page 26) dealer and were not registered as a dealer or in any other category of registration. The purpose of the review was to identify issuers who were in the business of trading and required registration as a dealer or relied on an appropriate prospectus exemption.

OSC Staff Notice 33-750 21 2.1.1 Summary of deficiencies identified

The following chart summarizes our findings from reviews set out in the annual highlights section. Deficiencies we identify during the fiscal year are impacted by various factors including the following: • CRR’s planned reviews of specific aspects of a firm’s operational activities, • the nature and complexity of the firms reviewed, and • firms’ compliance with securities law.

OSC Staff Notice 33-750 22 2.2 Registration and compliance deficiencies

2.2.1 Registration & Commission filings • Form 33-109F4 filing submissions that were returned • Certification in Form 33-109F4 not being followed • Registerable activity by non-registered parties • Novel exemptive relief for dealer business models 2.2.2 Compliance systems • Inconsistent and inaccurate responses provided in RAQ • Supervision of dealing representatives using multiple languages • Valuation of illiquid assets

2.2.3 Financial condition & custody • Custody requirements for registered firms

2.2.4 Know your client (KYC), know your product (KYP) & suitability • Concentration and suitability

2.2.5 Conflicts of interest & referral arrangements • Sales practices • Prohibited investment in a related entity • Prohibited inter-fund trades • Short-term trading and excessive trading • Referral arrangements • Compensation and incentive practices

OSC Staff Notice 33-750 23 2.2.1 Registration & Commission filings

a) Form 33-109F4 filing submissions that were returned (All)

This year, we returned 3,413 submissions on NRD to AFRs for correction or updating. In addition to delays, and the need for additional staff effort, a returned submission renders the submission ineligible for service standard guarantees.

The most common sections of Form 33-109F4 Registration of Individuals and Review of Permitted Individuals (33-109F4) requiring correction are: • Item 6 - Individual categories - 34% of all returns • Item 10 - Current employment - 26% of all returns • Item 8.1 - Proficiency experience - 10% of all returns • Item 1 - Name - 2% of all returns

Examples of common deficiencies in these items include: • requesting an inappropriate category for the applicant’s activities, • not including the title for officers who are Permitted Individuals, • not appropriately describing conflicts of interest in the section provided in the current employment entry, • not providing sufficient or clear proficiency experience details to support claims of relevant experience required for the registration category being sought by the applicant, and • not providing full legal names, former names, aliases, or trade or business names that the applicant operates under.

Registered firms should: • understand the activities permitted by each registration category, • have a discussion with applicants concerning their names and titles, • finalize the activities contemplated by the firm before adding a registration category, • speak with applicants to confirm their understanding of the questions set out in the 33-109F4 and review their responses for completeness before submitting their application to the OSC, • periodically remind applicants of their ongoing reporting obligations and review updates for completeness prior to submission, • provide sufficient descriptions of outside business activities or other disclosures, and • have adequate supervision systems to determine if existing procedures are functioning.

Legislative reference and guidance • National Instrument 33-109 Registration Information (NI 33-109) • Companion Policy 33-109CP Registration Information (NI 33-109CP)

OSC Staff Notice 33-750 24 b) Certification in Form 33-109F4 not being followed (All)

Some individual applicants complete the 33-109F4 without fully understanding its content and potentially without an adequate level of support and due diligence from their sponsoring firm.The 33-109F4 currently requires a certification of truth and completeness. It also requires the applicant to certify that they have discussed the form with a supervisory officer of their firm and that, to the best of the applicant’s knowledge, the officer was satisfied that the applicant understood the questions.

We generally receive a positive certification with 33-109F4 filings. However, in some cases, upon further review, the applicant has not always discussed the form with their firm’s supervisory officer, nor do they understand the nature and extent of the information being requested. For example, staff have encountered situations in which applicants, after failing to disclose necessary information, admit that they did not review the application with any other person before certifying that they had discussed the form with a supervisory officer.

Section 5.1 of NI 33-109 requires sponsoring firms to make reasonable efforts to ensure the truth and completeness of information that is submitted. We remind registered firms of their responsibility in overseeing applicants they sponsor. This includes confirming that the applicant fully understands the questions being asked of them in the 33-109F4.

Registered firms should: • provide individual applicants with an opportunity to have a meaningful discussion with their firm about the 33-109F4 and its content, • inquire whether individual applicants have any questions or are confused regarding the questions set out in the 33-109F4, • develop measures that identify areas prone to common errors and proactively discuss these areas with applicants prior to filing the 33-109F4, • discuss the 33-109F4, its content, and the applicant’s completion process prior to submitting the 33-109F4, and • have policies and procedures that validate the certification contained in the 33-109F4 is being followed.

Legislative reference and guidance • NI 33-109 • NI 33-109CP

OSC Staff Notice 33-750 25 c) Registerable activity by non-registered parties (All)

Registerable activity by non-registered issuers

We are aware of issuers that are directly interacting with investors to raise money under certain exemptions from the prospectus regime including the OM and FFBA prospectus exemptions. In some cases, issuers are directly soliciting and selling investment opportunities to the public via websites and social media. We have conducted reviews of these issuers in response to a concern that certain issuers may be in the business of trading and are not registered as a dealer. Our focus in these reviews were issuers relying on the new prospectus exemptions in Ontario where there may be a misunderstanding on how to utilize these exemptions.

We focused on issuers who: • filed multiple Form 45-106F1 Report of Exempt Distribution (45-106F1) filings identifying that no compensation was paid to a registered dealer or registered individual in connection with the distribution(s), • submitted multiple 45-106F1 filings within a period of time - this raised concerns that the trading activity was being done with repetition, regularity or continuity, • appeared to be directly soliciting investments through advertising over the internet and social media, and/or • distributed securities and had large capital raises from Ontario investors.

In some cases we identified regulatory concerns as there appeared to be significant capital-raising activity conducted by these issuers and transactions processed directly by these issuers without the involvement of a registered dealer or reliance on an appropriate registration exemption. Furthermore, many of these transactions relied on the OM prospectus exemption, but in some cases, the transactions were above the investment limits and the amounts invested would have required the involvement of a registered dealer to assess the suitability of the transaction and determine that the transaction was suitable (i.e., positive suitability assessment), in order to be permissible under the exemption. In other cases, the issuer: • purported to rely on the involvement of an entity or individuals to sell its securities; however, they were not in fact registered, or • represented that a registered dealer was involved in the transaction but there was no documentation to evidence the involvement of a registered dealer and there was no compensation disclosed on the issuer’s filings to the Commission.

In addition, the FFBA prospectus exemption was used for a significant number of all of the transactions processed by certain issuers, which continues to raise concerns for staff that investors may not actually meet the definition of family, friends or business associates.

We remind issuers that offer their own, or an affiliate’s securities, to continually reassess whether they are in the business of trading or advising and thus require registration. Some factors to consider when assessing if the issuer has met the business trigger are set out in OSC Staff Notice 33-749 on page 27. This activity does not have to be the entity’s sole or even primary endeavour for it to be considered in the business of trading in, or advising on, securities. We remind registrants that when interacting with issuers, to be aware of the requirements under the various prospectus exemptions relied on, and whether it is the issuer or the registered dealer’s obligation to conduct certain activities and to maintain evidentiary documentation that the requirements of the exemption have been fulfilled.

Legislative reference and guidance • Section 8.5 of NI 31-103 • Section 1.3 of Companion Policy 31-103CP Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103CP) • Sections 1.5 and 1.9 of National Instrument 45-106 Prospectus Exemptions (NI 45-106) • Section 3.2 of Companion Policy 45-106CP Prospectus Exemptions (NI 45-106CP) • OSC Staff Notice 33-749, page 27

OSC Staff Notice 33-750 26 c) Registerable activity by non-registered parties (cont’d)

Employees trading without appropriate registration

During the course of our reviews, we also identified registered firms that employed individuals who conducted trading/dealer activities on behalf of the firm without these individuals being registered to do so. Registered firms are responsible for the conduct of individuals acting on behalf of the firm.

In limited instances, we noted that employees who are not registered as dealing representatives (but may be registered in other categories) are soliciting clients. If the employee is soliciting clients for the registered firm, they are required to be registered as a dealing representative. This includes individuals who are registered as UDP, CCO and/or who are registered as an advising representative.

In other instances, employees are recommending securities to clients without registration as a dealing representative. Registered firms and individuals have specific obligations owed to clients under NI 31-103 including know-your-client (KYC) and suitability. These obligations must be fulfilled by registered dealing representatives that are appropriately trained and supervised by the firm.

Registering individuals in the wrong category

Similar to the issue of unregistered individuals conducting registerable activity is the problem of registering individuals in the incorrect category. During compliance reviews, staff have seen situations where individuals have registered in a category that does not match the type of activity being conducted. For example, some individuals have obtained registration as dealing representatives when they are conducting registerable activity for managed account clients (for example, collecting KYC information or having discussions about portfolio performance). In these circumstances, the individuals require registration as advising representatives or the activity should be conducted by an appropriately registered advising representative.

Activities of “finders” in the context of private placements and prospectus offerings

We have seen a number of situations where issuers have purported to distribute securities to investors on the basis of a “non-brokered” private placement or prospectus offering while at the same time paying finder’s fees/ warrants, broker fees/warrants, referral fees or similar types of compensation to finders, referral agents, investor relations consultants or similar third-parties (collectively referred to here as finders). In some cases, the finders have been registered firms or individuals while in other cases the finders are not registered and included former registrants or registrants under suspension.

Staff generally consider a person acting as a finder to be engaging in registerable activity (i.e., an activity that requires registration or an exemption from registration) based on the principles set forth in section 1.3 of NI 31-103CP.

Accordingly, where a prospectus or other offering document or a report of exempt distribution indicates that a person has acted as a finder in an offering – and particularly where it appears that no other dealer or underwriter has been involved in the offering – staff may raise comments requesting further information relating to: • the identity of the finders, • the role played by each finder and the manner of compensation for each finder in the fering,of • an explanation of how the finder’s role, functions and compensation are different from the role, functions and compensation of a dealer or underwriter in an offering, • the registration status, if any, of each of the finders, and • if the finders are registered, confirmation that the finders have complied with their registrant obligations in connection with the transaction, including their KYC, KYP and suitability obligations, their obligation to identify and respond to conflicts of interest, and their client disclosure obligations in relation to referral arrangements.

OSC Staff Notice 33-750 27 c) Registerable activity by non-registered parties (cont’d)

The policy reasons for raising these comments include, among others, the concern that: • a person who is engaging in registerable activity as a dealer and/or underwriter may not be appropriately registered as a dealer or underwriter under subsections 25(1) and (2) of the Securities Act (Ontario) (the Act), • a person who is performing a similar function to, and being compensated in a similar manner to, an underwriter in a prospectus offering may be seeking to avoid underwriter liability to investors under the prospectus simply by labelling their role as a “finder” rather than “dealer” or “underwriter”, • an EMD who is performing a similar function to, and is being compensated in a similar manner to, an underwriter in a prospectus offering may be seeking to avoid the restrictions on EMDs participating in prospectus offerings in Part 7 of NI 31-103 simply by labelling their role as a “finder” rather than “dealer” or “underwriter”, and • an ID or PM that is managing a client’s managed account and that purchases securities from the issuer for the client’s managed account while at the same time taking a finder’s fee from the issuer may be in a significant conflict of interest with their clients and may be in breach of other obligations to their clients.

Where staff become aware of a person engaging in dealer activities without appropriate registration or an exemption from registration, or a registrant engaging in registerable activities without compliance with registrant obligations, staff may recommend compliance or enforcement action against the person and/or registrant as appropriate. We also remind market participants that, where a distribution of securities is made in breach of the registration requirements of Ontario securities law, this may provide investors with a civil right of action for rescission or damages against the issuer, its principals and any intermediaries involved in the transaction.

Registered firms should: • have adequate internal controls to prevent non-registered individuals from conducting trading/advising activity, including promoting, soliciting, or recommending a security, • review the role and nature of interaction between a registered firm’s clients or potential clients and non-registered employees, and • provide adequate training to employees on the limitations on what activities they can perform based on their registration category.

Legislative reference and guidance • Section 8.5 of NI 31-103 • Section 1.3 of NI 31-103CP • Paragraph 25(1)(b) of the Act • Paragraphs 25(3)(b) and (c) of the Act • Part 6 - Activities of “finders” in the context of prospectus offerings of OSC Staff Notice 51-706 Corporate Finance Review Program Report

OSC Staff Notice 33-750 28 d) Novel exemptive relief for dealer business models (EMD)

Staff regularly assess exemptive relief applications from both the dealer registration requirements as well as specific securities law obligations for registered dealers that operate unique business models where the existing obligations may not be applicable or appropriate for their business. The review standard for granting relief varies, but it generally requires a decision maker to determine that granting the requested relief would not be prejudicial to the public interest.

Staff support the development of novel business models and are continuously working to facilitate timely exemptive relief for firms that require this relief in order to operate in compliance with securities regulation.

Examples of firms that have recently received novel exemptive relief include the following: • a registered dealer that only introduces non-individual permitted clients to issuers and is not involved in the negotiation, documentation, financing or transaction closing of any investment received relief from the trade confirmation and account statement requirements in NI 31-103, • a not-for-profit angel investor network for accredited investors that relies on and is restricted by government grants to fulfil its mandate and is also not involved in the negotiation, documentation, financing or transaction closing of any investment received relief from the excess working capital, trade confirmation and account statement requirements in NI 31-103, and • a PM that received relief from the dealer registration requirement, the KYC and suitability requirements, and the requirements to deliver account statements and investment performance reports in respect of investors in a model portfolio service offered by an affiliated MFD.

We encourage firms engaging in similar or other novel business models and their counsel to contact us to discuss their business plans and potential options, including applying for exemptive relief.

Before making a formal application for exemptive relief, firms may wish to first submit a pre-filing.The purpose of a pre-filing is to enable a firm to consult with staff on a specific issue to understand how securities legislation will be interpreted by the OSC. Staff will work with the firm and their counsel to assess whether exemptive relief is required in order to help the firm determine its next steps.

Legislative reference and guidance • National Policy 11-203 Process for Exemptive Relief Applications in Multiple Jurisdictions • OSC Staff Notice 33-747 2016 Annual Report for Dealers, Advisers and Investment Fund Managers, page 37 • OSC Staff Notice 33-746 2015 Annual Report for Dealers, Advisers and Investment Fund Managers, pages 45-47

OSC Staff Notice 33-750 29 2.2.2 Compliance systems

a) Inconsistent and inaccurate responses provided in RAQ (IFM / PM / EMD)

We assess the accuracy of registered firms’ responses to the RAQ during our compliance reviews. In many instances, we have noted that information provided in the RAQ was not consistent with information obtained during the compliance review. It is imperative that the responses provided to us by registrants are both accurate and complete. In addition, complete and accurate responses to the RAQ will assist CRR staff in planning for upcoming compliance reviews and ensuring reviews are conducted as efficiently and effectively as possible. Finally, providing accurate responses avoids the potential for registered firms to be selected as part of a sweep that focuses on a particular topic of interest based on incorrect information provided in the RAQ.

While we acknowledge that the RAQ requires registrants to provide us with a lot of information, registered firms are given six weeks to submit their responses to the RAQ and ten weeks to submit the Prospectus- Exempt Fund Form spreadsheet (for IFMs only). For help completing the RAQ, please attend our outreach session “Completing the Risk Assessment Questionnaire”. This session is typically held shortly after the RAQ is issued and discusses frequently asked questions and provides a walk-through of areas of the RAQ which have been challenging for registrants in the past. Any additional questions can be sent to staff at [email protected].

Individuals involved in the completion of the RAQ for their registered firm are also encouraged to make use of the following resources to assist in the completion of the RAQ: • FAQ and User Guide, including the section titled “Basics for Completing the Questionnaire”, • Help Page provided in each section of the RAQ, and • Interactive features in the navigation bar on each page of the RAQ.

b) Supervision of dealing representatives who speak multiple languages (EMD / SPD)

During our reviews of EMDs and SPDs, we noted several instances where firms did not establish and maintain systems of controls and oversight for effectively supervising and monitoring the firm’s dealing representatives who communicate with clients using multiple languages. In particular, scenarios were identified where clients were provided disclosure documents and offering materials printed in English and French, while a different language was used by dealing representatives to discuss the key features, risks and fees of the product. This increases the risk of misinformation as clients may be solely relying on the communication provided by the dealing representative to understand the investment opportunity. Dealing representatives may communicate with their clients in whichever language best serves the client; however, registered firms must be able to effectively supervise those communications as part of the overall obligation to supervise each dealing representative’s activities.

Registrants are required to establish a system of controls and supervision by establishing, maintaining and applying policies and procedures. Firms should ensure that they are aware of what language is being used to communicate with clients and have a system of controls to supervise the activity conducted in these languages.

OSC Staff Notice 33-750 30 b) Supervision of dealing representatives who speak multiple languages (cont’d)

Dealers should: • identify dealing representatives who use multiple languages, • have a process in place to supervise the dealing representatives who use multiple languages, and • document any special supervisory needs relating to monitoring dealing representatives who use multiple languages.

Legislative reference and guidance • Section 11.1 – Compliance system of NI 31-103 and related NI 31-103CP • Subsection 32(2) of the Act

c) Valuation of illiquid assets (IFM / PM)

Some firms do not have an adequate process to identify and value illiquid assets. During our reviews, we noted that some firms considered an equity investment held by their investment fund to be liquid as long as the investment was listed on an exchange, without further consideration of market activity and conditions. As a result, firms did not always adequately value securities held by their investment funds that were i) thinly traded, ii) subject to trading restrictions or iii) private (collectively, illiquid holdings). Some firms used closing market prices with no adjustments to reflect fair value for the following: • securities subject to trading restrictions, and • securities for which there was insufficient trading volume to support an active market.

An IFM has a legal obligation to determine fair value of the securities held by its investment fund for net asset value (NAV) calculation purposes. An IFM’s valuation procedures should assess whether the investment fund would be able to dispose of the securities held at the publicly quoted price by taking market activity and conditions into consideration. A stock listing does not necessarily mean that an equity investment could be disposed of at closing market price. If the IFM believes that it would not be able to dispose of the securities at the publicly quoted trading price, the IFM must determine a value that is fair and reasonable in the circumstances by considering whether any adjustments to the publicly quoted price are required.

Other deficiencies we noted relating to the valuation of illiquid holdings included: • inadequate documentation of the firm’s valuation methodology, • infrequent updating of market inputs when valuing securities using a valuation model, • reliance on the PM’s pricing of the illiquid security without the IFM performing an independent verification of the stated price.

OSC Staff Notice 33-750 31 c) Valuation of illiquid assets (cont’d) Non-compliance with illiquid asset concentration restrictions Additionally, we also noted that some mutual funds that are reporting issuers (public funds) did not always comply with the concentration restrictions in illiquid assets outlined in section 2.4 of NI 81-102. A public fund must not purchase an illiquid asset if, immediately after the purchase, more than 10% of the public fund’s NAV will be made up of illiquid assets. In addition, a public fund must not invest 15% of its NAV in illiquid assets for a period of 90 days or more. An IFM should have an adequate process to monitor compliance with the concentration restrictions for illiquid assets including taking the appropriate corrective action in a timely manner for any breaches identified.

IFMs and PMs should: • review the publicly-traded securities held by the investment fund to determine whether the publicly quoted trading price of the securities reflects fair value, • determine an adequate valuation methodology, including establishing the appropriate frequency for valuation relating to all securities that are not traded/quoted on a public exchange, • periodically review the valuation methodology to confirm that it is still appropriate, • verify that the market inputs of the valuation model used have been appropriately updated at each valuation date, • maintain adequate documentation to support the valuation of thinly traded, restricted and private securities, and • establish a process to monitor the investment fund’s compliance with the liquidity requirements stated in its offering documents including any restrictions imposed by NI 81-102 (if applicable).

Legislative reference and guidance • Part 11 – Division 1 Compliance of NI 31-103 and related NI 31-103CP • Section 2.4 of NI 81-102 Investment Funds (NI 81-102) • OSC Staff Notice 81-727 Report on Staff’s Continuous Disclosure Review of Mutual Fund Practices Relating to Portfolio Liquidity

OSC Staff Notice 33-750 32 2.2.3 Financial condition & custody

Custody requirements for registered firms (IFM / PM)

On June 4, 2018, the amendments to NI 31-103 that enhanced the custody requirements of registered firms (the Custody Rules) came into force.

During our normal course reviews, we noted that IFMs had not updated their prime brokerage agreements to meet the requirements of the Custody Rules. Section 14.5.2 of NI 31-103 requires IFMs to exercise due skill, care and diligence in the selection and appointment of the custodian for the investment funds they manage. This includes confirming that the investment fund’s custodial agreements or prime brokerage agreements address key matters such as the location of portfolio assets, any appointment of a sub-custodian, the method of holding portfolio assets, the standard of care of the custodian and the responsibility for loss.

Additionally, we noted that disclosure documents provided by IFMs to clients (where the IFM was distributing its own products or also acting as the PM for an investment fund) did not always include adequate disclosure. We noted that the following risks were not disclosed: • the differing standard of care between a prime broker and a custodian, and • the potential risk of using a prime broker instead of a traditional custodian.

We also noted that IFMs do not always hold cash-in-transit in accordance with the new requirements under the Custody Rules. Under section 14.5.3 of NI 31-103, cash-in-transit for an investment fund or client should be held as follows: • in an account in the name of the fund or client with a qualified custodian, or • in a designated trust account in the name of the IFM in trust for the fund or the client, and separate and apart from the IFM’s own property.

IFMs and PMs should: • review their relationship disclosure documents to confirm that this disclosure has been updated to include: • the location where, and a general description of the manner in which, the client’s (including an investment fund’s) assets are held, and • a description of the risks and benefits arising from the assets being held at that location and in that manner.

IFMs should: • review their custodial and prime brokerage agreements to verify that these agreements include key matters such as the location of portfolio assets, any appointment of a sub-custodian, the method of holding portfolio assets, the standard of care of the custodian and the responsibility of loss. If these key matters are not included, we expect IFMs to work with the prime broker or custodian to update the agreement, create an addendum to the agreement, or enter a stand-alone agreement to incorporate these details, and • hold cash, specifically cash-in-transit, in accordance with the Custody Rules.

Legislative reference and guidance • Sections 14.5.2 and 14.5.3 of NI 31-103 and related NI 31-103CP

OSC Staff Notice 33-750 33 2.2.4 Know your client (KYC), know your product (KYP) & suitability

Concentration and suitability (EMD / SPD)

We noted instances where dealers did not adequately assess clients’ concentration risk as part of their suitability assessment. In certain cases, dealers did not collect enough KYC information to reasonably assess concentration risk and, as a result, concentration risk was not considered as part of the suitability assessment.

We also observed that certain EMDs used client-directed-trade instructions as a tool to circumvent their suitability obligations. During compliance reviews, we noted some firms used client-directed trade instructions in a large portion (in some cases over 40%) of client files reviewed by staff. In these cases, EMDs would assess a transaction to be unsuitable (for excessive concentration risk or other reasons) and include a client- directed trade instruction in the client’s file and proceed with the transaction. This raises concerns that firms are not appropriately discharging their obligation to assess the suitability of the transaction, and are routinely documenting trades as being unsuitable and using client-directed trade instructions as an alternative to engaging in a meaningful suitability conversation with the client.

Dealers should: • establish policies and procedures for assessing concentration risk, including what information should be collected from clients to assess concentration risk, how concentration risk is calculated and what thresholds would cause a client to be over-concentrated, • if a dealer has concerns that a client has a high concentration in a single issuer, group of related issuers, or a single industry, they should: • engage in a meaningful dialogue with the client to explain the importance of diversification and the risk of over-concentration, • consider a lower investment amount that would reduce the client’s concentration risk, and • document why the transaction was deemed suitable despite the client’s concentration risk. • if a transaction is deemed to be unsuitable due to over-concentration concerns, but the client nevertheless wishes to proceed with the transaction, the dealer should: • document the discussion with the client regarding the client’s concentration risk and the unsuitability of the transaction, and • obtain a signed client-directed trade instruction, which includes a specific explanation of the unsuitability of the transaction.

Legislative reference and guidance • CSA Staff Notice 31-336 Guidance for Portfolio Managers, Exempt Market Dealers and Other Registrants on the Know-Your-Client, Know-Your-Product and Suitability Obligations • OSC Staff Notice 33-740 Report on the results of the 2012 targeted review of portfolio managers and exempt market dealers to assess compliance with the know-your-client, know-your-product and suitability obligations

OSC Staff Notice 33-750 34 2.2.5 Conflicts of interest & referral arrangements

a) Sales practices (IFM / MFD / ID)

We executed a focused desk review relating to the provision of non-monetary benefits by IFMs to participating dealers and dealing representatives under Part 5 and Part 7 of NI 81-105. The sales practices desk review included a sample of 25 IFMs and focused on the provision of non-monetary benefits through items and activities (both promotional and non-promotional) over a period of approximately 18 months covering the IFM’s fiscal 2017 and fiscal 2018 (up to August 31, 2018). The following chart summarizes the total number of promotional items and activities reviewed through this desk review across the 25 IFMs.

Review period (Fiscal 2017 – August 31, 2018) Total promotional items 15,750 items given

Total promotional activities 57,800 events attended by 105,200 dealing representatives

The purpose of the sales practices desk review was to: • determine if there had been improvement in sales practice compliance resulting from the recent sales practices settlement agreements in 2017 and 2018, and the previously issued guidance in OSC Staff Notice 33-743, and • review and assess an IFM’s internal controls and policies, procedures, and practices relating to the provision of non-monetary benefits.

The majority of IFMs included in the sales practices desk review used the most recently published sales practices settlement agreements and OSC Staff Notice 33-749 to improve their policies and procedures with respect to the provision of non-monetary benefits through items and activities provided as promotional. Some IFMs also decreased the limits set per item, per activity and the total overall non-monetary benefits provided on an annual basis.

Part 5 of NI 81-105 Part 5 of NI 81-105 regulates the sales practices of industry participants in connection with the distribution of publicly offered securities of mutual funds to safeguard the interests of investors. As a result, NI 81-105 establishes a minimum standard of conduct to ensure that any compensation or non-monetary benefits provided to participating dealers and their respective representatives are not so extensive or so frequent so as to provide a perception of influence over the selection of mutual funds for distribution by a representative to their clients.

Non-compliant sales practices Although we noted improvements in the sales practices provided by IFMs, we continued to raise deficiencies in the following areas: • provision of promotional items of non-minimal value, • provision of excessive business promotion activities, • provision of non-promotional items and activities, • provision of non-monetary benefits on a frequent basis, • provision of monetary support to non-educational participating dealer and/or dealing representative events, • inadequate internal controls to monitor the provision of non-monetary benefits, and • inadequate written policies and procedures governing the provision of non-monetary benefits and the solicitation of non-compliant monetary and non-monetary benefits.

OSC Staff Notice 33-750 35 a) Sales practices (cont’d)

We have reported the findings from this current initiative to each IFM included in the sales practices desk review.

We would like to remind IFMs of their obligations to comply with Part 5 of NI 81-105 when engaging in sales practices with participating dealers and dealing representatives. We strongly encourage registrants to use the guidance included in the most recent OSC Staff Notice 33-749, particularly the example qualitative framework provided, to improve their understanding of, and compliance with, applicable regulatory requirements. All previously issued guidance related to sales practices is meant to assist IFMs in meeting their duty to act honestly, in good faith, and in the best interests of their investment funds as required by section 116 of the Act. Many of the concepts related to sales practices require judgment. Through previously issued guidance, we have tried to establish parameters around these concepts which best correlate with an IFM’s standard of care. We would like to remind IFMs that in establishing internal sales practice parameters the overarching objective and spirit of the rule must always be at the forefront and adhered to.

Prohibited categories of spending

We noted instances where IFMs were providing monetary support solicited by participating dealers and dealing representatives for dealer events that did not comply with the available exemptions under Part 5 of NI 81-105. IFMs can provide monetary support solicited by participating dealers and dealing representatives under sections 5.1 and 5.5 of NI 81-105 if there is an educational component to the event. We noted IFMs provided monetary support for dealer events such as: • holiday parties, • activity days, • dinner for prospective and existing clients, and • appreciation dinners for dealing representatives.

IFMs, MFDs and IDs should: • establish clear written policies and procedures, including illustrative examples, of when monetary support can be provided to a participating dealer and/or dealing representative for events, • establish clear written policies and procedures to address when IFM support can be provided in response to solicitation by participating dealers and/or dealing representatives, and • provide monetary support only for events solicited by participating dealers and/or dealing representatives that comply with the available exemptions in Part 5 of NI 81-105 and an IFM’s written policies and procedures.

Legislative reference and guidance • Section 2.1 of National Instrument 81-105 Mutual Fund Sales Practices (NI 81-105) • Section 2.2 of NI 81-105 • Part 5 of NI 81-105 • Section 11.1 – Compliance system of NI 31-103 and related NI 31-103CP • Section 2.2.5(c) of OSC Staff Notice 33-749 • OSC Staff Notice 33-743 Guidance on sales practices, expense allocation and other relevant areas developed from the results of the targeted review of large investment fund managers

OSC Staff Notice 33-750 36 b) Prohibited investment in a related entity (IFM / PM) During the course of our reviews, we identified instances where a registered adviser’s managed account clients, including clients that are investment funds, were invested in securities of a related issuer (i.e., where an officer, director or adviser of the firm was also an officer, director or partner of the issuer). Registered advisers did not always take appropriate steps, prior to purchasing securities of a related issuer for their managed account clients, to comply with securities law. Specifically, for managed account clients, including where the client was a private investment fund, the registered adviser did not disclose and obtain consent for the purchase of securities in the related issuer from the managed account clients prior to the purchase.

Under section 13.5(2)(a) of NI 31-103, a registered adviser is allowed to purchase securities of an issuer related to the registered adviser for a portfolio it manages, including a private investment fund it manages, if this conflict is: (i) disclosed to the client, and (ii) written consent is obtained from the client prior to the purchase of the security.

If the client is a private investment fund, the disclosure should be provided to, and the consent obtained from, each security holder of the investment fund in order to be meaningful. Disclosure to the client should be prominent, specific and clear.

This approach may not be practical for public funds, as such, firms should consider the specific exemption codified under section 6.2 of NI 81-107 which allows public funds to make or hold an investment in the security of an issuer related to it, its manager or an entity related to the manager if, at the time the investment is made, the Independent Review Committee (IRC) approves the trade and the purchase is made on an exchange on which the securities of the issuer are listed and traded.

IFMs and PMs must: • maintain adequate policies and procedures to identify all conflicts of interest, including a purchase of securities of a related issuer for an investment portfolio managed by it, including an investment fund it manages, • when purchasing securities of a related issuer for managed account clients, including private investment funds: • provide adequate disclosure, and • obtain written consent from clients prior to the purchase. • when purchasing securities of a related issuer for public funds, at the time that the investment is made, ensure that: • the IRC has approved the investment, and • the securities are purchased through an exchange where the securities of the issuer are listed and

Legislative reference and guidance • Paragraph 13.5(2)(a) of NI 31-103 and related NI 31-103CP • Paragraph 111(2)(c) of the Act • Section 6.2 of National Instrument 81-107 Independent Review Committee for Investment Funds (NI 81-107)

OSC Staff Notice 33-750 37 c) Prohibited inter-fund trades (IFM / PM)

We continue to see registered firms allowing prohibited inter-fund trades to occur between investment funds (that are not reporting issuers) that are both managed and advised by the registered firm.

During the course of our reviews we noted instances where the registered firm traded securities between two private investment funds both managed and advised by the registrant. The inter-fund trading was the result of a rebalancing of the portfolio securities held by both private investment funds. The securities were in line with the investment objectives and investment restrictions of the funds and were held by the fund prior to the occurrence of the inter-fund trades. The inter-fund trade occurred at the closing price through a registered dealer. The investment funds and ultimately the underlying unitholders were not negatively affected. However, due to the potential for conflicts of interest in these types of transactions, the inter-fund trades were offside securities law.

Section 13.5(2)(b) of NI 31-103 strictly prohibits inter-fund trading between two investment funds that have the same adviser. This transaction gives rise to an actual or perceived conflict of interest as the registered adviser is responsible for determining the terms of the trade for both funds. Registered advisers wishing to engage in inter-fund trading between two private investment funds managed and advised by them can apply for exemptive relief. The exemptive relief contains safeguards that we feel are necessary to allow for this inter-fund trading to occur in a manner that adequately addresses any actual or perceived conflict of interest. These safeguards include: • ensuring the inter-fund trade is consistent with the investment objectives of the participating private investment funds, • requiring that the matter is approved by an IRC, and • requiring that the inter-fund trade is transacted at the current market price, and in respect of exchange-traded securities, the inter-fund trade is executed at the last sale price.

There is an exemption from this prohibition that exists for inter-fund trades between two public funds in section 6.1 of NI 81-107.

IFMs and PMs must: • maintain policies and procedures that prohibit inter-fund trades between two private investment funds, or between a public fund and a private investment fund, and • put in place adequate pre-trade controls to identify and prevent prohibited inter-fund trades from occurring.

Legislative reference and guidance • Paragraph 13.5(2)(b) of NI 31-103 and related NI 31-103CP • Section 6.1 of NI 81-107

OSC Staff Notice 33-750 38 d) Short-term trading and excessive trading (IFM)

We conducted a desk review to assess how IFMs monitor short-term trading and excessive trading by unitholders of their investment funds.

Short-term trading activity can be harmful to unitholders and funds by increasing costs to the fund, by disrupting a PM’s strategies and by requiring PMs to maintain higher levels of cash. There is also the conflict of interest if an IFM were to consistently waive short-term trading fees for certain unitholders or unitholders of certain dealing representatives with a large level of client assets invested in the IFM’s funds.

Overall, we found that all firms reviewed were monitoring for short-term trading activity with most firms having adequately documented policies and procedures. We did identify some instances where IFMs waived the short-term trading fee for the benefit of the redeeming unitholder or the redeeming unitholder’s dealing representative, without considering the impact to the remaining unitholders in the affected investment fund. Our review found that, although short-term trading fees were waived in some instances, the impacts to the affected investment funds were negligible and that short-term trading fees were not being consistently waived for certain unitholders or unitholders of certain dealing representatives.

IFMs should:

• have a system of controls in place to monitor for short-term trading and excessive trading by unitholders of their investment funds, • maintain clearly documented policies and procedures which contain (but are not limited to): • the criteria used by the firm to identify a short-term trade, • the criteria used by the firm to identify excessive trading, • the process used by the firm to monitor for short-term trading and excessive trading activity, • whether the firm utilizes a first-in first-out or last-in first-out methodology for monitoring short-term trading and excessive trading activity, • the consequences for a redeeming unitholder who is identified to be in breach of the firm’s short-term trading and excessive trading policy, • the circumstances under which a short-term trading fee could be waived, • the person(s) at the firm who have the authority to waive a short-term trading fee and the process by which a fee can be waived, • periodically evaluate whether the established policies and procedures are adequate and effective in monitoring and deterring short-term trading and excessive trading activity in their investment funds, and • maintain adequate documentation, including the firm’s rationale for waiving a short-term trading fee.

Legislative reference and guidance • Part 11 – Division 1 Compliance of NI 31-103 and related NI 31-103CP • Section 116 of the Act

OSC Staff Notice 33-750 39 e) Referral arrangements (PM / EMD / SPD)

During the year we continued to assess the nature and extent of the use of referral arrangements by registrants and the structure of referral fee payments. The following graphs are derived from data gathered from our 2016 and 2018 RAQ processes and illustrate trends in the space. Specifically: • there has been a 69% increase in the number of referral arrangements entered into with non-registered referral agents in 2017 when compared to 2015, • 74% of the referral arrangements in 2017 were entered into with non-registered parties in comparison to 58% in 2015, • the amount of referral fees made to non-registered referral agents has increased 108% to $79m in 2017 from $38m in 2015, and • the percentage of referral fees made to non-registered referral agents over the total of referrals paid increased to 26% in 2017 from 11% in 2015.

In addition, based on responses to the 2018 RAQ, 216 of the 280 firms (or 77%) who entered into a referral arrangement reported that referral agents were compensated on an ongoing basis and, in some cases (approximately 14%), referral agents received over 50% of the fees earned by the registrants as illustrated in the following chart:

OSC Staff Notice 33-750 40 e) Referral arrangements (cont’d )

i) Oversight of referral agents

During the referral sweep, we found some referral agents continue to be involved in servicing clients that have been referred to a registered firm. We continue to be concerned that referral agents are conducting activities that require registration under securities law or are representing themselves as being able to perform registerable activities. To mitigate against these inherent risks, registrants should develop and execute policies and procedures to proactively monitor and assess if referral agents are conducting themselves as agreed upon in the referral arrangement agreement.

PMs, EMDs and SPDs should:

• develop policies and procedures specific to the oversight of referral agents that: • define the responsibilities of the referral agent, • define the activities a referral agent is prohibited from conducting, • provide training on a periodic basis to referral agents on their roles and responsibilities within the arrangement, • monitor the referral agent’s relationship with referred clients to determine whether the referral agent is performing an activity that requires registration, • evaluate how referral agents are marketing their services (for example, through a website or social media) to assess the adequacy of disclosure explaining the services offered under the referral arrangement, and • address cases in which it is determined that a referral party is performing an activity that requires registration.

(ii) Reducing client confusion about the roles and responsibilities of referral parties

A common theme we noted as a result of speaking to clients was that many continued to interact primarily with the referral agent and were unsure about the role of the registrant. In these situations, communications between the registered individual and the referred client were typically infrequent. Further, we found that the majority of referred clients had a long-term relationship with their referral agent before they were introduced to the registrant. As a result of the continuing relationship between the referral agent and the client, we found that: • communications between registered individuals and clients were typically not in person, but rather through telephone calls or email. These communications were infrequent throughout the year, which created a challenge for registered individuals to truly establish a relationship with the referred client., • clients primarily communicated with referral agents even on topics that should have been discussed with the registered individual (e.g., questions about portfolio holdings, questions about the client’s account and changes in a client’s KYC information), and • in some cases, the nature of the relationship resulted in undue reliance by the registered individual on the referral agent to transfer client information on matters that required a registered individual’s involvement.

In combination, these practices can lead to client confusion and make it difficult for referred clients to “know” their advising representative or dealing representative, and more importantly, understand the roles and responsibilities of both the registered individual servicing their investment accounts and the referral agent.

OSC Staff Notice 33-750 41 e) Referral arrangements (cont’d )

PMs, EMDs and SPDs should:

• monitor the effectiveness of the firm’s policies and procedures regarding oversight of referral agents, • take steps to develop a relationship with referred clients so these clients understand the registrant’s role, • develop specific policies and procedures to mitigate against and address client confusion, including procedures to: • identify and monitor confusion amongst the firms’ clients on an ongoing basis, • resolve instances where clients continue to remain confused about the role of the registrant and/ or referral agent, • address situations in which a referral party’s actions have led to the client confusion, and • address situations in which a registered individual’s actions have led to the client confusion.

Legislative reference and guidance • Section 11.1 – Compliance system of NI 31-103 and related NI 31-103CP • Sections 13.2 Know your client and 13.3 Suitability of NI 31-103 and related NI 31-103CP • Part 13 - Division 3 Referral arrangements of NI 31-103 and related NI 31-103CP • Section 4.2(a)(iii) - Referral arrangements and finders of OSC Staff Notice 33-745 Annual Summary Report for Dealers, Advisers and Investment Fund Managers • Section 4.3.1 - Delegating KYC and suitability obligations to referral agents of OSC Staff Notice 33-742 2013 Annual Summary Report for Dealers, Advisers and Investment Fund Managers

f) Compensation and incentive practices

During our compensation and incentive practices review, we did not identify any serious non-compliance issues as registrants appeared to have adequate controls to address compensation-related conflicts such as: • use of both quantitative (e.g., AUM level, client billings) and qualitative factors (e.g., leadership skills, client feedback) to determine bonuses for employees, • use of a rolling period (e.g., one year) to determine the AUM for calculating bonuses, • use of a product-neutral grid (e.g., commission rates remain the same regardless of product(s) distributed), • use of claw-back provisions to address issues such as non-compliance or client complaints, • reviewing accounts having similar mandates to identify performance outliers that may indicate the potential risk of advising representatives chasing investment performance to increase their compensation, • reviewing and monitoring accounts on an ongoing basis to ensure investment portfolios remain aligned with clients’ investment objectives and risk parameters, and • requiring that the Board of Directors or risk committee review the compensation practices at least annually to ensure that controls remain effective to address compensation-related conflicts.

We would like to remind firms of their obligation to review their compensation arrangements and incentive practices to ensure compliance with the requirements set out in Part 13 of NI 31-103. These include: • identifying conflicts of interest that should be avoided, • determining the level of risk that a conflict of interest raises, and • responding appropriately to conflicts of interest.

Legislative reference and guidance • Part 13 - Division 2 Conflicts of interest of NI 31-103 and related NI 31-103CP • CSA Staff Notice 33-318 Review of Practices Firms Use to Compensate and Provide Incentives to their Representatives

OSC Staff Notice 33-750 42 Part 3 INITIATIVES IMPACTING REGISTRANTS

3.1 Derivatives regulation

3.2 Modernization of investment fund product regulation

3.3 Syndicated mortgages

3.4 Consequential custody amendments

OSC Staff Notice 33-750 43 3.1 Derivatives regulation

CRR staff have been working with the Derivatives Branch to develop a number of rules relating to the regulation of derivatives, including proposed rules that will set out the principal business conduct and registration requirements and exemptions for derivatives dealers and derivatives advisers (collectively, derivatives firms). We are developing these rules to help protect investors, reduce risk, improve transparency and accountability, and to implement a comprehensive regime for the regulation of persons or companies that are in the business of trading derivatives and in the business of advising on derivatives.

On April 19, 2018, the CSA published for comment Proposed National Instrument 93-102 Derivatives: Registration and a related companion policy. Similarly, on June 14, 2018 the CSA published for a second comment period Proposed National Instrument 93-101 Derivatives: Business Conduct and a related companion policy for a second comment period. We are continuing to review the comments received on these proposed rules in consultation with our CSA colleagues.

In addition, CRR staff continue to work with the Derivatives Branch on the implementation of other rules relating to derivatives, including conducting compliance reviews of derivatives firms in connection with their compliance with OSC Rule 91-507 Trade Repositories and Derivatives Data Reporting and National Instrument 94-102 Derivatives: Customer Clearing and Protection of Customer Collateral and Positions.

3.2 Modernization of investment fund product regulation

On October 4, 2018, the CSA published a notice of amendments to NI 81-102 and other instruments relating to the establishment of a regulatory framework for alternative mutual funds (collectively, the Alternative Fund Amendments). The Alternative Fund Amendments came into force on January 3, 2019.

The Alternative Fund Amendments reflect the CSA’s efforts to modernize the investment fund regulatory regime in Canada and more specifically to help facilitate the introduction of more alternative and innovative strategies typically associated with “liquid alternative” funds, in the retail investment space, while maintaining appropriate restrictions on the use of those strategies. The key aspect of the Alternative Fund Amendments is the establishment of a new category of mutual fund called “alternative mutual funds”. This replaces the old category of commodity pool resulting in existing commodity pools becoming alternative mutual funds. Alternative mutual funds differ from more conventional mutual funds primarily in the ability to make greater use of leverage, including through direct borrowing and margin, increased short selling and the use of derivatives.

The Alternative Fund Amendments include alternative mutual fund-specific prospectus and financial reporting disclosure requirements. The Alternative Fund Amendments also include changes for conventional mutual funds to permit limited exposure to alternative mutual fund strategies through fund of fund investing and to codify certain exemptive relief routinely granted to those funds.

For more information, see the CSA Notice of Amendments Modernization of Investment Fund Product Regulation - Alternative Mutual Funds, published on October 4, 2018.

In addition, an overview of the Alternative Fund Amendments may be found in the Registrant Outreach Session, available at the following link: www.osc.gov.on.ca/documents/en/Dealers/ro_20190514_ alternative-funds.pdf

OSC Staff Notice 33-750 44 3.3 Syndicated mortgages

On March 8, 2018, the CSA published for comment proposed amendments to both NI 31-103, NI 45-106 and ‌NI 45-106CP relating to the transfer of regulatory oversight of syndicated mortgage investments from the Financial Services Commission of Ontario to the OSC (the 2018 Proposal).

We received a number of comment letters in response to the 2018 Proposal. Considering the comments received, on March 15, 2019, the CSA published for comment revised proposed amendments to NI 31-103, NI 31-103CP, NI 45-106 and NI 45-106CP (the 2019 Proposal). The proposed changes include the following: • removing the registration and prospectus exemptions for “non-qualified” syndicated mortgages in Ontario and certain other jurisdictions, • providing additional guidance in NI 31-103CP with respect to the “relevant securities industry experience” requirement for firms and individuals that previously relied on a registration exemption, • introducing additional requirements to the OM prospectus exemption under section 2.9 of NI 45-106 that apply when the exemption is used to distribute syndicated mortgages, and • amending the private issuer prospectus exemption under section 2.4 of NI 45-106 so that it is not available for the distribution of syndicated mortgages.

The proposed amendments are expected to come into effect on December 31, 2019. The comment period for the 2019 Proposal ended May 14, 2019. The CSA is reviewing the comments received and plans to publish a final notice of amendments after the review is complete.

3.4 Consequential custody amendments

On March 14, 2019, the CSA published (in final form) custody-related amendments to NI 31-103 which came into force on June 12, 2019 (the 2019 Custody Amendments). The 2019 Custody Amendments were published for comment by the CSA on October 25, 2018; the comment period ended on December 24, 2018 and no comments were received.

The purpose of the 2019 Custody Amendments is to continue to align the permissible custodial practices in section 14.6.1 of NI 31-103 with the similar permitted custodial practices for investment funds in subsection 6.8(2) of NI 81-102. Subsection 6.8(2) of NI 81-102 was amended on January 3, 2019 and it addresses which entities may hold portfolio assets as margin for certain derivatives transactions outside Canada.

The custody provisions in NI 31-103 have generally permitted the same types of custodians to hold assets for prospectus-exempt funds as are permitted for prospectus-qualified funds (Retail Funds), except where there is a policy justification to allow additional custodians for prospectus-exempt funds.

In part, the amendments to subsection 6.8(2) of NI 81-102 broadened the pool of entities that may hold portfolio assets of Retail Funds as margin by allowing Retail Funds to deposit portfolio assets with members of regulated clearing agencies in respect of certain prescribed margin transactions. These additional entities, and the dealers that are currently permitted to act as custodians in NI 81-102, will also be able to hold assets deposited with them in respect of an additional type of margin transaction, namely, transactions involving cleared specified derivatives. The 2019 Custody Amendments will provide continued alignment with the custody provisions in NI 81-102.

OSC Staff Notice 33-750 45 Part ACTING ON REGISTRANT 4 MISCONDUCT

4.1 Annual highlights and trends

4.2 Opportunity to be Heard (OTBH) process

4.3 Cases of interest

OSC Staff Notice 33-750 46 4.1 Annual highlights and trends

The Registrant Conduct Team within the CRR Branch is responsible for investigating conduct issues involving individual and firm registrants, recommending regulatory action where appropriate, and conducting Opportunity to be Heard (OTBH) proceedings before the Director. Potential registrant misconduct is identified through compliance reviews, applications for registration, disclosures on NRD, and by other means such as complaints, inquiries or tips.

Acting on registrant misconduct matters is central to effective compliance oversight. It also promotes confidence in Ontario’s capital markets, both among the investing public and among the registered firms and individuals who make best efforts to comply with Ontario securities law. Registrants must remain alert and monitor for potential misconduct by enacting and implementing appropriate policies and procedures, and ensuring that controls are in place to detect and address instances of misconduct.

The following chart summarizes the regulatory actions taken by CRR staff against firms or individuals engaged in registrant misconduct or serious non-compliance with Ontario securities law.

CRR Regulatory Actions FYE 2015 - 2019

CRR is continually improving our information tools, which are used to identify high-risk registrants and applicants for registration. This has resulted in a trend to increased regulatory actions over the past five years. Sources of information include our risk-based compliance reviews, background and solvency checks on individual registrants or individual applicants, responses to the RAQ, external contacts received by OSC staff, and referrals from SROs and other organizations.

OSC Staff Notice 33-750 47 The chart illustrates that CRR makes use of regulatory actions along the compliance-enforcement continuum, the action being commensurate with the magnitude of misconduct or non-compliance in a given situation. Terms and conditions, denials of registration, and suspensions of registration are all tools available to CRR staff to address serious non-compliance. Referrals are made to the Enforcement Branch in cases where the appropriate tool is a power that can only be exercised by the Commission.

The statistical reduction in denials of registration from 63 in fiscal 2017/2018 to 45 in fiscal 2018/2019 reflects a recordkeeping change. This category of regulatory action no longer includes situations where a firm withdraws an individual’s application for registration before the matter has been assigned to staff of the Registrant Conduct Team.

In more serious cases, registered firms may decide not to continue sponsoring registration for individuals who are subject to a conduct review by staff. Typically, this involves conduct that might result in staff recommending suspension. In these situations, we characterize the outcome as an “avoided suspension”. During the past fiscal year, there were six avoided suspension matters in which the firms terminated their sponsorship of the particular registered individuals, in addition to the five registration suspensions noted in the chart.

Referrals to the Enforcement Branch increased to ten in fiscal 2018/2019 from four in fiscal 2017/2018 as a result of our registration and compliance review activity.

One example of a referral made by CRR to the Enforcement Branch was in the matter of Clifton Blake Asset Management Ltd., et al. in which the Commission issued an order on March 28, 2019 approving a settlement agreement between Enforcement Staff and the individual and corporate respondents. The respondents were in the business of trading in the securities of a mortgage investment entity (MIE), Clifton Blake Mortgage Fund Trust, and sold approximately $25 million worth of these securities to approximately 144 investors. Those activities required registration pursuant to the registration requirements in the Act and in NI 31-103. The respondents were not registered with the OSC and, among other violations of Ontario securities law, failed to ensure that the investments were suitable for their investors. The settlement agreement required the respondents to pay an administrative penalty of $100,000 and to honour requests from certain investors to redeem their securities.

In the past, Enforcement staff have entered into settlement agreements with other MIEs, mortgage brokers, administrators and their principals involved in trading in securities without registration. Those settlements involved substantial penalties and costs being levied against businesses and individuals, as well as the requirement to reimburse investors. For example, in February 2016, the Commission approved a settlement in the matter of Liahona Mortgage Investment Corp., et al. pursuant to which the respondents were required to pay an administrative penalty of $50,000 and costs of $45,000. The various settlement agreements demonstrate that the OSC continues to enforce compliance with the registration requirements as they apply to the MIEs, and that the associated monetary penalties have increased over time.

As the Commission recently stated in another decision:

Registration is another cornerstone of Ontario securities law. It protects investors and promotes confidence in the capital markets by seeking to ensure that those who sell or promote securities are proficient and solvent and that they act with integrity. When an unregistered individual or firm engages in activity that requires registration, the individual or firm defeats some of the necessary legal protections, shields the activity somewhat from regulatory monitoring, puts investors at risk, and undermines the integrity of the capital markets.1

1 Meharchand (Re), 2019 ONSEC 7, para. 47.

OSC Staff Notice 33-750 48 4.2 Opportunity to be Heard (OTBH) process

Before a Director of the OSC imposes terms and conditions on registration, refuses an application for registration, or suspends a registration, an applicant or registrant has the right under section 31 of the Act to request an OTBH before the Director. A registrant or applicant may also request a hearing and review by the Commission of a Director’s decision under section 8 of the Act.

DIRECTOR’S DECISIONS

Director’s decisions on OTBH proceedings are published in the OSC Bulletin and on the OSC website at Director’s Decisions, where they are presented by topic and by year. Director’s decisions can be used as an important resource for registrants, as they highlight matters of concern to the OSC, as well as the regulatory action that may be taken as a result of misconduct and non-compliance. The publication of Director’s decisions also ensures that CRR’s response to serious misconduct is visible to market participants and investors.

Eight Director’s decisions were published in the fiscal year 2018/2019 on registrant conduct issues. Two decisions followed contested OTBHs, and one decision approved staff’s recommendation in respect of a registrant who did not request an OTBH. The remainder of the Director’s decisions were made on a basis of joint recommendations made to the Director by staff and registrants pursuant to settlement agreements. A settlement agreement typically contains an agreed statement of facts in addition to a joint recommendation to the Director. Therefore, proceeding by way of a joint recommendation with staff allows the registrant to participate in setting out the factual narrative that becomes the basis for the Director’s decision.

In three of the decisions, registrants were suspended as a result of their failure to comply with the terms and conditions of their registration. Specifically, these registrants were required to complete a course by a specified deadline. Staff reminds registrants that failure to comply with terms and conditions of registration can lead to a suspension. Further, if a registrant is required to complete a course or satisfy terms and conditions by a certain deadline, the sponsoring firm should have appropriate controls and supervision in place to ensure that the required activity occurs within the specified time period.

The Registrant Conduct Team continues to investigate instances where registrants failed to make the required criminal disclosure, the consequences of which may include regulatory action such as suspension of registration. See, for example, the summary of the Director’s decisions regarding Todd Milligan and Glenn Coulson in the Cases of Interest section below. In the latter decision, the registrant did not make a required disclosure to staff regarding a criminal charge, relying on the advice of his criminal lawyer who had no experience in securities law and with whom the registrant did not discuss the specific disclosure obligation. As part of the settlement agreement with staff, the registrant admitted that his reliance on the advice of his criminal lawyer was not reasonable. While the Director accepted the joint recommendation on the basis of the agreed facts and admissions, rather than make findings on this issue, the decision nevertheless highlights that reliance on legal advice in not making a required disclosure, and whether such reliance is reasonable, should be considered in light of the expertise of the lawyer and the nature of the advice requested and given.

OSC Staff Notice 33-750 49 4.3 Cases of interest

DIRECTOR’S DECISIONS AND SETTLEMENTS BY TOPIC

Todd Milligan (May 30, 2018)

Topic: Misleading Staff or sponsor firm

Mr. Milligan was a registered mutual fund dealing representative. On February 26, 2016, Mr. Milligan was informed by the police that he was going to be charged with disobeying a court order. After an administrative delay, Mr. Milligan was charged on May 4, 2016. On July 20, 2016, Mr. Milligan pled guilty to the charge and received a conditional sentence. Mr. Milligan did not report either the charge or the disposition on NRD as required by Ontario securities law. Staff subsequently became aware of the charges and recommended to the Director that Mr. Milligan’s registration be suspended for failing to comply with his disclosure obligation. Following an OTBH, the Director suspended Mr. Milligan for a period of three months.

Anna Joanna Knight (July 13, 2018)

Topics: Reliance on prospectus exemptions; Trading or advising without appropriate registration; Conflicts of interest; and KYC, KYP, and suitability

Ms. Knight, a dealing representative in the category of MFD and EMD, applied to reactivate her registration on September 21, 2017 with a new sponsoring firm. At that time, she was under investigation by the MFDA for using two pre-signed forms and selling a small amount of an off-book product at her former firm. Her former firm and its principals were also under investigation by the MFDA for serious breaches of Ontario securities law including the off-book sale of the same exempt product sold by Ms. Knight. Ms. Knight knew that the principals of her firm controlled the issuer but did not disclose the conflict of interest to her clients. Ms. Knight also sold the product to two clients who were not qualified to purchase a prospectus-exempt product and to clients for whom it was not suitable.

In February 2016, Ms. Knight was issued a warning letter by the MFDA for using copied and altered forms in 2014 and signed an undertaking to her firm promising not to use pre-signed forms, photocopied forms or altered forms. Despite this, two pre-signed forms were found during the MFDA field review of Ms. Knight’s former firm in November 2016. The field review also revealed that Ms. Knight had advised clients to sell exchange-traded securities when she was not registered as an adviser, and where no exemptions from the adviser registration requirement were available to her.

Following settlement discussions, Ms. Knight agreed to withdraw her application and only submit a further application for registration as a mutual fund dealing representative following a full audit report of Ms. Knight’s Certified Financial Planner business and licensed insurance business covering a specified period. Ms. Knight was also required to complete two courses prior to reapplying for registration and agreed that she would be under strict supervision for at least one year and ineligible to apply for registration as an exempt market dealing representative while under strict supervision.

Ms. Knight has since reapplied for registration as a mutual fund dealing representative, having complied with the terms of the settlement agreement, and her application was approved subject to the terms and conditions set out above.

OSC Staff Notice 33-750 50 Antonetta Adebayo (July 16, 2018)

Topics: Compliance with terms and conditions of registration; Courses for proficiency requirement

Ms. Adebayo was registered as a mutual fund dealing representative. On August 2, 2017, terms and conditions were imposed on Ms. Adebayo’s registration, to which she consented, due to Staff’s concerns with her solvency and a failure to disclose a personal business, a direction to pay the Canada Revenue Agency, and a consumer proposal. The terms and conditions required Ms. Adebayo to complete the Conduct and Practices Handbook Course (the CPH) no later than April 30, 2018 as well as close supervision on her registration for a minimum of one year.

As of June 11, 2018, Ms. Adebayo had not complied with the terms and conditions, having not received a passing grade on the CPH. As a result, and given Ms. Adebayo’s failure to disclose the required financial information, it was staff’s view that Ms. Adebayo lacked the proficiency required of a registered individual. Staff was also of the view that by failing to satisfy the terms and conditions, Ms. Adebayo failed to comply with Ontario securities law and rendered her registration objectionable. Ms. Adebayo did not request an OTBH, and the Director suspended Ms. Adebayo’s registration, as recommended by staff.

Karine Brizard (July 18, 2018)

Topics: Compliance with terms and conditions of registration; Courses for proficiency requirement

Ms. Brizard was registered as a mutual fund dealing representative. In September 2017, terms and conditions were imposed on Ms. Brizard’s registration, to which she consented, due to staff’s concerns related to Ms. Brizard’s insolvency and ongoing consumer proposal as well as her failure to disclose an earlier bankruptcy. The terms and conditions required Ms. Brizard to complete the CPH within six months as well as close supervision on Ms. Brizard’s registration. Ms. Brizard failed to complete the CPH before the deadline, and after requesting and being granted two extensions by staff to write the CPH exam, she failed two additional attempts after the deadline. As a result, staff recommended that Ms. Brizard’s registration be suspended.

Following an OTBH, the Director determined that Ms. Brizard’s registration should be suspended on the basis that she did not comply with the terms and conditions of her registration by failing to successfully complete the CPH within the required timeframe. The Director also took into account Ms. Brizard’s failure to meet her ongoing registration obligations by not disclosing her bankruptcy which was material to her solvency and suitability for registration. The decision also provided that Ms. Brizard could reapply to be registered if she completed the CPH.

Chris Triantos (August 31, 2018)

Topic: Compliance with terms and conditions of registration

Mr. Triantos was a registered mutual fund dealing representative. In October 2017, the Director imposed terms and conditions on Mr. Triantos’s registration that, among other things, required him to successfully complete the CPH by April 26, 2018. Mr. Triantos wrote the CPH exam on April 26, 2018, but did not achieve a passing mark. Prior to informing staff of his unsuccessful attempt at the exam, Mr. Triantos registered to re-write it on May 25, 2018, and at staff’s request, his sponsor firm prohibited him from trading in securities pending the outcome of his second attempt at the exam. Mr. Triantos did not pass the exam on his second attempt, or on a third attempt on July 28, 2018. The Director approved a settlement agreement pursuant to which Mr. Triantos’s registration was suspended. The settlement agreement provided that Mr. Triantos could apply to reactivate his registration if he successfully completed the CPH or the Ethics and Professional Conduct Course.

OSC Staff Notice 33-750 51 Glenn Coulson (October 16, 2018)

Topic: Misleading Staff or sponsor firm

Mr. Coulson was a registered mutual fund dealing representative. Shortly after becoming registered in August 2015, Mr. Coulson was charged criminally in relation to conduct that had occurred several years before he became a registrant. The charges were laid in September 2015. Ontario securities law required that Mr. Coulson disclose the charges on NRD within 10 days of their occurrence, however he did not comply with this requirement. Mr. Coulson received an absolute discharge in August 2017, and informed his sponsor firm about the charges in December 2017 (the firm subsequently disclosed the charges on NRD on Mr. Coulson’s behalf). Between the date he was charged and the date of his absolute discharge, Mr. Coulson completed two annual certifications for his sponsor firm in which he indicated that his regulatory disclosure was up-to-date. Mr. Coulson did not make the required disclosure to staff, or to his sponsor firm, because his criminal lawyer had instructed him not to discuss the matter with anyone. However, the lawyer had no experience in securities law, and Mr. Coulson did not discuss the specific disclosure obligation with him. The Director approved of a settlement agreement pursuant to which Mr. Coulson’s registration was suspended for a period of two months as a result of his failure to comply with his disclosure obligation.

Donald Mason (October 29, 2018)

Topic: Duty to supervise

Mr. Mason, a registered mutual fund dealing representative, was the subject of a November 30, 2017 Director’s Decision imposing terms and conditions by which Mason was restricted from acting as a dealing representative with members of the church (or their families) where he acted as lay minister. The Commission dismissed Mr. Mason’s request for a stay of the Director’s Decision pending a hearing and review which he had requested.

The parties agreed to settle the matter prior to the hearing and review commencing. Mr. Mason agreed to narrower terms and conditions restricting him from dealing with individuals (and their families) whom he visited in a caregiving role pursuant to his Christian Worker’s licence. Mr. Mason was not restricted from dealing with church members generally, given his non-leadership role at the church and that he would only deliver messages to the church infrequently and at the direction of the pastor. The Director approved this joint recommendation and the revised terms and conditions took effect.

Maria Psihopedas (November 21, 2018)

Topic: Duty to supervise

This case was the settlement of an application for a hearing and review of a decision of the Director to refuse Ms. Psihopedas’s registration as a mutual fund dealing representative. In March 2018, following an OTBH, the Director refused Ms. Psihopedas’s application for registration on the basis that she had misrepresented the sentence imposed on her by a court following a criminal case against her. Ms. Psihopedas applied for a hearing and review of the Director’s decision, and before that hearing was held, Ms. Psihopedas obtained new evidence that provided a reasonable explanation for why she had misrepresented her sentence. The matter was therefore remitted back to the Director for her consideration, together with a joint recommendation from Staff and Ms. Psihopedas that she be granted registration, subject to terms and conditions that she complete the Ethics and Professional Conduct Course. The Director accepted the joint recommendation.

OSC Staff Notice 33-750 52 STAFF DIRECTORY

OSC Staff Notice 33-750 53 Director’s Office

Debra Foubert, Director 416-593-8101 | [email protected]

Elizabeth King, Deputy Director, Registrant Conduct 416-204-8951 | [email protected]

Felicia Tedesco, Deputy Director, Operations 416-593-8273 | [email protected]

Pat Chaukos, Deputy Director, LaunchPad & Policy 416-593-2373 | [email protected]

Ranjini Srikantan, Branch Administrator 416-593-2320 | [email protected]

OSC LaunchPad

Jonathan Yeung, Senior Business Adviser 416-595-8924 | [email protected]

Amanda Ramkissoon, Fintech Regulatory Adviser 416-593-8221 | [email protected]

Asad Akhtar, Legal Counsel 416-263-3787 | [email protected]

Amanda Barone, Fintech Coordinator 416-597-7238 | [email protected]

Team 1 - Portfolio Manager

Elizabeth Topp, Manager 416-593-2377 | [email protected]

Sabrina Philips, Administrative Assistant 416-593-2302 | [email protected]

Chris Jepson, Senior Legal Counsel 416-593-2379 | [email protected]

Kat Szybiak, Senior Legal Counsel 416-593-3686 | [email protected]

Rachel Keane, Legal Counsel 416-263-7681 | [email protected]

Shruti Joshi, Legal Counsel 416-597-7237 | [email protected]

Carlin Fung, Senior Accountant 416-593-8226 | [email protected]

Scott Laskey, Senior Accountant 416-263-3790 | [email protected]

Daniel Panici, Accountant 416-593-8113 | [email protected]

Eugenie Chung, Accountant 416-597-7223 | [email protected]

George Rodin, Accountant 416-263-3798 | [email protected]

Tai Mu Xiong, Accountant 416-263-3797 | [email protected]

Vanesa Pavlovski, Accountant 416-597-7207 | [email protected]

OSC Staff Notice 33-750 54 Team 2 - Investment Fund Manager

Debra Foubert, Director 416-593-8101 | [email protected] Vera Nunes, Manager 416-593-2311 | [email protected]

Elizabeth King, Deputy Director, Registrant Conduct 416-204-8951 | [email protected] Margot Sobers, Administrative Assistant 416-593-8229 | [email protected]

Felicia Tedesco, Deputy Director, Operations 416-593-8273 | [email protected] Erin Seed, Senior Legal Counsel 416-596-4264 | [email protected]

Pat Chaukos, Deputy Director, LaunchPad & Policy 416-593-2373 | [email protected] Maye Mouftah, Senior Legal Counsel 416-593-2358 | [email protected]

Ranjini Srikantan, Branch Administrator 416-593-2320 | [email protected] Robert Kohl, Senior Legal Counsel 416-593-8233 | [email protected]

Faustina Otchere, Legal Counsel 416-596-4255 | [email protected]

Jennifer Lee-Michaels, Legal Counsel 416-593-8155 | [email protected]

Lindsey Mahoney, Legal Counsel 416-593-8190 | [email protected]

Nick Hawkins, Legal Counsel 416-596-4267 | [email protected]

Alizeh Khorasanee, Senior Accountant 416-593-8129 | [email protected]

Estella Tong, Senior Accountant 416-593-8219 | [email protected]

Merzana Martinakis, Senior Accountant 416-593-2398 | [email protected]

Teresa D’Amata, Acting Senior Accountant 416-595-8925 | [email protected]

Elizabeth Topp, Manager 416-593-2377 | [email protected] Catherine Muhindi, Accountant 416-597-7808 | [email protected] Sabrina Philips, Administrative Assistant 416-593-2302 | [email protected] Daniel Brown, Accountant 416-593-2353 | [email protected]

Chris Jepson, Senior Legal Counsel 416-593-2379 | [email protected] Daniela Schipani, Accountant 416-263-7671 | [email protected]

Kat Szybiak, Senior Legal Counsel 416-593-3686 | [email protected] Lisa Piebalgs, Accountant 416-593-8147 | [email protected]

Rachel Keane, Legal Counsel 416-263-7681 | [email protected] Paul Bertucci, Accountant 416-593-8159 | [email protected]

Shruti Joshi, Legal Counsel 416-597-7237 | [email protected] Saleha Haji, Accountant 416-593-2397 | [email protected] Carlin Fung, Senior Accountant 416-593-8226 | [email protected]

Scott Laskey, Senior Accountant 416-263-3790 | [email protected] Team 3 - Dealer

Daniel Panici, Accountant 416-593-8113 | [email protected] Dena Staikos, Manager 416-593-8058 | [email protected]

Eugenie Chung, Accountant 416-597-7223 | [email protected] Linda Pinto, Administrative Assistant 416-595-8946 | [email protected]

George Rodin, Accountant 416-263-3798 | [email protected] Gloria Tsang, Senior Legal Counsel 416-593-8263 | [email protected]

Tai Mu Xiong, Accountant 416-263-3797 | [email protected] Paul Hayward, Senior Legal Counsel 416-593-8288 | [email protected]

Vanesa Pavlovski, Accountant 416-597-7207 | [email protected] Adam Braun, Legal Counsel 416-593-2348 | [email protected]

OSC Staff Notice 33-750 55 Yuliya Khraplyva, Legal Counsel 416-597-7244 | [email protected]

Jeff Sockett, Senior Accountant 416-593-8162 | [email protected]

Susan Pawelek, Senior Accountant 416-593-3680 | [email protected]

Stratis Kourous, Senior Accountant 416-593-2340 | [email protected]

Kevieon Barker, Accountant 416-593-8311 | [email protected]

Louise Harris, Accountant 416-593-2359 | [email protected]

Mark Delloro, Accountant 416-597-7225 | [email protected]

Matthew Andreacchi, Accountant 416-204-8977 | [email protected]

Michael Man, Accountant 416-593-8145 | [email protected]

Vincent Chow, Accountant 416-593-8127 | [email protected]

Team 4 - Registrant Conduct

Michael Denyszyn, Manager 416-595-8775 | [email protected]

Judy Ross, Administrative Assistant 416-593-8284 | [email protected]

Mark Skuce, Senior Legal Counsel 416-593-3734 | [email protected]

Anastasija Sumakova, Legal Counsel 416-593-8184 | [email protected]

Joyce Taylor, Legal Counsel 416-596-4273 | [email protected] Marlene Costa, Legal Counsel 416-593-2192 | [email protected]

Moira Hare, Legal Counsel 416-593-8306 | [email protected]

Trevor Walz, Senior Accountant 416-593-3670 | [email protected]

Allison McBain, Compliance Examiner 416-593-8164 | [email protected]

Rita Lo, Registration Research Officer 416-593-2366 | [email protected]

Team 5 - Data Strategy and Risk

Louise Brinkmann, Manager 416-596-4263 | [email protected]

Judy Ross, Administrative Assistant 416-593-8284 | [email protected]

Wayne Choi, Senior Business & Data Analyst 416-593-8189 | [email protected]

Joanna Leung, Business Analyst 416-597-7812 | [email protected]

Clara Ming, Registration Data Analyst 416-593-8349 | [email protected]

OSC Staff Notice 33-750 56 Team 6 - Registration

Jeff Scanlon, Manager 416-597-7239 | [email protected]

Linda Pinto, Administrative Assistant 416-595-8946 | [email protected]

Feryal Khorasanee, Registration Supervisor 416-595-8781 | [email protected]

Kamaria Hoo, Registration Supervisor 416-593-8214 | [email protected]

Colin Yao, Legal Counsel 416-593-8059 | [email protected]

Anita Chung, Registration Accountant 416-593-8131 | [email protected]

David Tong, Accountant 416-593-8120 | [email protected]

Isabelita Chichioco, Financial Analyst 416-593-8105 | [email protected]

Adrienne Chao, Corporate Registration Officer 416-597-7201 | [email protected]

Amy Fraser, Corporate Registration Officer 416-593-3674 | [email protected]

Anne Leung, Corporate Registration Officer 416-593-8235 | [email protected]

Anthony Ng, Corporate Registration Officer 416-263-7655 | [email protected]

Edgar Serrano, Corporate Registration Officer 416-593-8331 | [email protected]

Igor Perebeinos, Corporate Registration Officer 416-596-4293 | [email protected]

Jane Chieu, Corporate Registration Officer 416-593-3671 | [email protected]

Jenny Tse Lin Tsang, Corporate Registration Officer 416-593-8224 | [email protected]

Kipson Noronha, Corporate Registration Officer 416-593-8258 | [email protected]

Linda Tam, Acting Corporate Registration Officer 416-204-8957 | [email protected]

Pamela Woodall, Corporate Registration Officer 416-593-8225 | [email protected]

Dianna Cober, Individual Registration Officer 416-593-8107 | [email protected]

Lucy Gutierrez, Acting Individual Registration Officer 416-593-8277 | [email protected]

Michael John Egerdie, Individual Registration Officer 416-597-7806 | [email protected]

Toni Sargent, Individual Registration Officer 416-593-8097 | [email protected]

Azmeer Hirani, Registration Officer 416-596-4254 | [email protected]

Cheryl Pereira, Registration Officer 416-593-8149 | [email protected]

Andrea Gochuico, Registration Support Officer 416-593-2386 | [email protected]

OSC Staff Notice 33-750 57 CONTACT US Ontario Securities Commission Inquiries and Contact Centre 8:30 a.m. to 5:00 p.m. Eastern Time - Monday to Friday 1-877-785-1555 (Toll-free) 416-593-8314 (Local) [email protected] www.osc.gov.on.ca/en/contactus_index.htm

www.osc.gov.on.ca

If you have questions or comments about this report, please contact:

Daniel Panici Accountant Compliance and Registrant Regulation [email protected] 416-593-8113 Notices

1.1.2 CSA Staff Notice 51-358 – Reporting of Climate Change-related Risks

CSA Staff Notice 51-358 – Reporting of Climate Change-related Risks is reproduced on the following separately numbered pages. Bulletin pagination resumes at the end of the Staff Notice.

August 8, 2019 (2019), 42 OSCB 6617

Notices

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August 8, 2019 (2019), 42 OSCB 6618

CSA Staff Notice 51-358 Reporting of Climate Change-related Risks

August 1, 2019

Executive summary

The focus on climate change-related issues in Canada and internationally has grown rapidly in recent years. In order to make informed investment and voting decisions, investors, particularly institutional investors, are seeking improved disclosure on the material risks, opportunities, financial impacts and governance processes related to climate change.

Securities legislation in Canada requires reporting issuers1 (issuers) to disclose the material risks affecting their business and, where practicable, the financial impacts of such risks.2 Although climate change-related risks are expected to be more pervasive than some other types of risk, they can be difficult to assess and quantify as they may be subject to greater uncertainty.

We recognize that, while disclosure of material climate change-related risks is important for investors to make informed investment decisions, this disclosure presents challenges and other potential burdens for all issuers, especially smaller issuers with more limited resources. The key objective of this notice is to provide issuers, particularly smaller issuers, with guidance as to how they might approach preparing disclosures of material climate change-related risks. In particular, the guidance contained in this notice is primarily focused on issuers’ disclosure obligations as they relate to the MD&A and AIF. For purposes of those forms, information is likely material if a reasonable investor’s decision whether to buy, sell or hold securities in an issuer would likely be influenced or changed if the information in question was omitted or misstated. Securities legislation imposes a different test for materiality in certain other contexts, and issuers should consider the applicable test when preparing disclosure in respect of climate change-related information or other information.

In addition to addressing regulatory requirements, these disclosures provide issuers with an opportunity to inform investors about the sustainability of their business model and to provide insights into how they are mitigating and adapting to these risks.

This notice does not create any new legal requirements or modify existing ones. It reinforces and expands upon the guidance provided in CSA Staff Notice 51-333 Environmental Reporting Guidance (SN 51-333) and should be read in conjunction with SN 51-333, which continues to

1 In this notice, references to reporting issuers refer to reporting issuers other than investment funds. 2 See section 5.2 of Form 51-102F2 Annual Information Form (the AIF or Form 51-102F2) and section 1.4(g) of Form 51-102F1 Management’s Discussion and Analysis (the MD&A or Form 51-102F1). -2- provide guidance to issuers on existing continuous disclosure requirements relating to a broad range of environmental matters, including climate change.

Staff of the Canadian Securities Administrators (Staff or we) encourage boards of directors (boards) and senior management (management) of issuers to review this notice as it:

• provides an overview of the responsibilities of boards and management relating to risk identification and disclosure;

• outlines relevant factors to consider in assessing the materiality of climate change-related risks;

• provides examples of some of the types of climate change-related risks to which issuers may be exposed;

• includes questions for boards and management to consider in the climate change context; and

• provides an overview of the disclosure requirements if an issuer chooses to disclose forward-looking climate change-related information.

Why this guidance?

Climate change-related risks are a mainstream business issue. Issuers should consider these risks as part of their ongoing risk management and disclosure processes and they must disclose any such risks that are material to their business. Like other business risks, the materiality of climate change- related risks varies among industry sectors and issuers within those sectors.

This notice has been motivated by three key factors: • Increased investor interest – Over the past several years, many investors, particularly institutional investors, have become increasingly focused on climate change-related risks and have expressed concerns that they are receiving insufficient disclosure of these risks from issuers. Securities regulators have a role to play in assisting issuers in their efforts to provide investors with the material information they reasonably need to make informed investment and voting decisions.

• Room for improvement in disclosure – Based on our reviews of the disclosure of a sample of TSX-listed issuers, we noted variations in disclosure practices.3 Of the 78 issuers we reviewed, 22% provided boilerplate disclosure on climate change-related risks and another

3 The detailed results of our review are summarized in CSA Staff Notice 51-354 Report on Climate change-related Disclosure Project (SN 51-354). -3-

22% provided no disclosure at all. The disclosures lacked comparability among issuers and in some instances omitted information necessary to provide sufficient context for the disclosure.

• Domestic and global developments – We have observed growing interest by stakeholders, including Canadian issuers and institutional investors, in voluntary disclosure frameworks, such as the Climate Risk Technical Bulletin published by the Sustainability Accounting Standard Board (SASB) published in October 2016 (the SASB Framework), and the final recommendations of the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) published in June 2017 (the TCFD Recommendations). The TCFD Recommendations contemplate voluntary disclosure in four areas: governance, strategy, risk management and metrics and targets. We have also noted a number of global and domestic initiatives since the publication of SN 51-354 which acknowledge the importance of climate change-related risks.4

This guidance is intended to assist issuers, including their boards and management, to identify material climate change-related risks and to improve their disclosure of such risks. Disclosure of climate change-related risks provides an opportunity for issuers to explain to existing and potential investors how they are adapting their business model to any material risks that they are facing and to address questions regarding the sustainability of the business model.

Climte Forward- Why this Board and Voluntary Materiality Change- looking Guidance? Management Disclosure related Risks Information

What are the roles and responsibilities of the board and management?

The board (including, for some responsibilities, its audit committee) has a role in strategic planning, risk oversight and the review and approval of an issuer’s annual and interim regulatory filings.

• Strategic planning – The board should adopt a strategic planning process and approve a strategic plan which takes into account, among other things, the opportunities and risks of the business.5

• Risk oversight – The board should adopt a written mandate explicitly acknowledging its responsibility for, among other things, identification of the principal risks of the issuer’s

4 In Canada, the Bank of Canada has recently issued a report which identifies climate change as one of the vulnerabilities in the Canadian financial system and the Government of Canada’s Expert Panel on Sustainable Finance has published its final report which includes recommendations on issues related to sustainable finance, including climate change-related disclosure. Internationally, the International Organization of Securities Commissions recently published a statement on disclosure of environmental, social and governance matters by issuers and there are many ongoing policy initiatives focused on climate change and capital markets, such as the ongoing work of the TCFD and the Central Banks’ and Supervisors’ Network for Greening the Financial System. 5 See paragraph 3.4(b) of National Policy 58-201 Corporate Governance Guidelines (NP 58-201). -4-

business and ensuring the implementation of appropriate systems to manage these business risks.6

• Review and approval of disclosure –

o The audit committee is required to review an issuer’s financial statements and MD&A before the issuer publicly discloses this information. The audit committee must be satisfied that adequate procedures are in place for the review of the issuer’s public disclosure of financial information extracted or derived from the issuer’s financial statements (other than the issuer’s financial statements, MD&A and annual and interim earnings press releases) and must periodically assess the adequacy of those procedures.7

o The board must approve the annual and interim financial statements and MD&A. The board may delegate approval of interim financial statements and MD&A to its audit committee.8

Management also has a key role to play in risk management and the preparation of the issuer’s annual and interim regulatory filings.

• Risk management – It is management’s responsibility to implement systems to manage business risks.

• Preparation and certification of disclosure –

o Management is responsible for preparing the issuer’s annual and interim regulatory filings.

o Certifying officers9 must certify, among other things, that the issuer’s financial statements and the other financial information included in the issuer’s MD&A and AIF, if applicable, fairly present, in all material respects, the issuer’s financial condition, financial performance and cash flows.10

Why is this relevant in the context of climate change-related risks?

Climate change-related risks and their potential financial impacts are mainstream business issues. However, they may differ from many other business risks because their impacts may be uncertain and are expected to develop over time. Despite the potential uncertainties and longer time horizon associated with climate change-related risks, boards and management should take appropriate steps to understand and assess the materiality of these risks to their business. This assessment should

6 See paragraph 3.4(c) of NP 58-201. 7 See subsections 2.3(5) and 2.3(6) of National Instrument 52-110 Audit Committees. 8 See sections 4.5 and 5.5 of National Instrument 51-102 Continuous Disclosure Obligations (NI 51-102). 9 The term “certifying officers” has the meaning given to it in National Instrument 52-109 Certification of Disclosure in Issuers’ Annual and Interim Filings (NI 52-109) and generally means the CEO and CFO. 10 See Part 2 of NI 52-109. -5- extend to a broad spectrum of potential climate change-related risks over the short-, medium- and long-term.

What does this mean for boards and management?

We encourage the board and management to assess their expertise with respect to sector specific climate change-related risks. This will enable them to ask the right questions about climate change- related risks and opportunities, and make informed decisions about both risk management and disclosure.

In preparing and approving risk disclosure, we encourage the board and management to avoid vague or boilerplate disclosure. Relevant, clear and understandable entity-specific disclosure will help investors understand how the issuer’s business is specifically affected by all material risks resulting from climate change. This risk disclosure should provide context for investors about how the board and management assess climate change-related risks.

Below are select questions for boards and management to help inform their consideration of material climate change-related risks.11 Discussion and analysis of the following questions may be helpful in evaluating and preparing appropriate climate change-related risk disclosures.

Select questions for boards

• Is the board provided with appropriate orientation and information to help members understand sector specific climate change-related issues?

• Has the board been provided sufficient information, including management’s materiality assessments in respect of the issuer’s climate change-related risks, to appropriately oversee and consider management’s assessment of these risks?

• Is the board comfortable with the methodology used by management to capture the nature of climate change-related risks and assess the materiality of such risks?

• Is the board aware of how their investors are factoring climate change-related risks into their investment and voting decisions?

• Is oversight and management of climate change-related risks and opportunities integrated into the issuer’s strategic plan, and if so, to what extent?

• Has the board considered the effectiveness of the disclosure controls and procedures in place in relation to climate change-related risks?

11 These questions have been derived from the Engagement Guide for Asset Owners & Asset Managers published by SASB and CPA Canada’s Climate Change Briefing: Questions for Directors to Ask. -6-

Select questions for management

• Does management have, or have access to, the appropriate expertise to understand and manage material climate change-related risks that may affect the issuer?

• Has management appropriately considered how each of the different categories of climate change-related risks may affect the issuer (e.g., physical and transition risks)?

• Has management considered which business divisions or units have responsibility for identifying, disclosing and managing material climate change-related risks and what their reporting lines are to senior management? To what extent are these responsibilities integrated with mainstream business processes and decision-making?

• Is management aware of current climate change-related litigation which may pose a litigation threat to the issuer now or in the future?

• Has management implemented effective systems, procedures and controls to gather reliable and timely climate change-related information for purposes of management analysis, decision-making and disclosure to investors, regulators and other stakeholders?

• Has management appropriately assessed the current and future financial impacts of material climate change-related risks on the issuer’s assets, liabilities, revenues, expenses and cash flows over the short, medium and long-term?

• Do the issuer’s regulatory filings contain the required disclosures in respect of material climate change-related risks? Is this disclosure boilerplate or entity-specific?

Climte Forward- Why this Board and Voluntary Materiality Change- looking Guidance? Management Disclosure related Risks Information

Why is materiality important?

Materiality is the determining factor in any assessment of whether information is required to be disclosed in an issuer’s continuous disclosure. Only material information needs to be included in an issuer’s AIF and MD&A. For purposes of those forms, information is likely material if a reasonable investor’s decision whether to buy, sell or hold securities in an issuer would likely be influenced or changed if the information in question was omitted or misstated. Securities legislation imposes a different test for materiality in certain other contexts, and issuers should consider the applicable test when preparing disclosure in respect of climate change-related information or other information. Issuers can also find guidance on assessing materiality in National Policy 51-201 Disclosure Standards and section 2.1 of SN 51-333. -7-

The disclosure regime set out in NI 51-102 requires issuers to report matters that are material to the issuer. Omitting or misstating material information in an issuer’s required continuous disclosure documents can lead to the board, management, and the issuer itself facing potential risks including litigation, enforcement, or other regulatory actions (e.g., refiling of continuous disclosure documents).

Under NI 52-109, certifying officers of a TSX-listed or other issuer which is not a venture issuer12 are required to certify, among other things, that they are responsible for establishing and maintaining disclosure controls and procedures. Management of such issuers should have controls and procedures in place to ensure climate change-related information is accumulated and communicated to management to allow timely decisions regarding required disclosure, including materiality assessments. Securities legislation also contains general prohibitions against making statements that a person or company knows (or reasonably ought to know) are materially misleading or untrue. Misrepresentations in a continuous disclosure document also include an omission to state a material fact that is required to be stated or is necessary to be stated in order for that statement not to be misleading.

What are the guiding principles for determining materiality?

Many issuers, including those in non-carbon intensive industries, are or will be exposed to climate change-related risks, though these risks will affect issuers in different industries, and different issuers within the same industry, in different ways. The key question for an issuer is whether a particular climate change-related risk under consideration is material and requires disclosure. We generally consider information to be material if a reasonable investor’s decision whether or not to buy, sell, or hold securities of the issuer would likely be influenced or changed if the information was omitted or misstated.13

The following guiding principles, derived from SN 51-333, are intended to serve as a general guide and not an exhaustive list of the factors to be considered when making materiality determinations. No new materiality obligations or principles are created by this notice. These guiding principles are not meant as legal or other advice as to whether a particular risk, including climate change-related risk, is material for a particular issuer.

• No bright-line test – There is no uniform quantitative threshold at which a particular type of information becomes material. The materiality of certain information may vary between industries and even between issuers within an industry according to their particular circumstances. An event that is “significant” or “major” for a smaller issuer may not be material to a larger issuer. In our view, issuers should consider both quantitative and qualitative factors in determining materiality.

• Context – Materiality depends on the nature and amount of the item judged in the particular circumstances of its omission or misstatement. Some facts are material on their own. When one or more facts do not appear to be material on their own, materiality must be considered

12 The term “venture issuer” has the meaning given to it in NI 52-109. 13 See Part 1(f) of Form 51-102F1 and Part 1(e) of Form 51-102F2. -8-

in light of all the facts available. An issuer should not “lose sight of the forest for the trees” by assessing the materiality of individual facts piecemeal.

• Timing – Determining whether information is material is a dynamic process that depends on the prevailing relevant conditions at the time of reporting. In assessing materiality, an issuer should consider whether the impact of an environmental matter might reasonably be expected to grow over time, in which case early disclosure of the matter might be important to reasonable investors. This would be particularly relevant where the issuer is in an industry with a longer operation or investment cycle or where new technologies are going to be required.

• Trends, demands, commitments, events and uncertainties – Generally, the time horizon of a known trend, demand, commitment, event or uncertainty may be relevant to an issuer's assessment of materiality. As with other types of disclosure, materiality in cases of a known environmental trend, demand, commitment, event or uncertainty turns on an analysis of:

o the probability that the trend, demand, commitment, event or uncertainty will occur, and o the anticipated magnitude of its effect.

What are the specific considerations for determining materiality in the context of climate change-related risk?

We acknowledge that materiality assessments in relation to climate change-related risks may be more difficult than those in relation to other risks due to the evolving understanding of these risks, the potential difficulty in quantifying these risks, and, in some cases, the longer time horizon for certain of these risks to materially impact an issuer’s business. Despite these challenges and uncertainties, the disclosure issuers provide should reflect a thoughtful assessment of the information available as to the materiality of certain risks affecting their business and the impact of such risks. We encourage issuers to carefully consider if they have any material exposure to climate change-related risks – most industries and issuers have some exposure to these types of risks, even if they are not directly involved in a carbon-intensive industry. We encourage issuers to undertake an analysis before concluding they have no material exposure to climate change-related risks.

An assessment of materiality in relation to climate change-related risks may require issuers to adapt their existing approaches to risk assessments in order to better understand the potential impacts of climate change-related risks and their materiality. In some cases, this may involve adjusting their approaches to consider the longer time horizon associated with and how to effectively quantify these types of risks.

Issuers are reminded that there are resources to assist them in making their materiality assessments in this area. For example, the SASB Framework found that 72 out of 79 “sustainable industry classification” industries are significantly affected in some way by climate change-related risk.14 If

14 More information regarding SASB’s ongoing work in this area, including the SASB Framework and SASB’s Materiality Map, can be found at https://www.sasb.org/standards-overview/materiality-map/. -9- appropriate, issuers may consider benchmarking their climate change-related disclosure against their peers when determining their materiality assessments.

Timing

An issuer should not limit its materiality assessment to near-term risks. If an issuer concludes that a climate change-related matter would likely influence or change a reasonable investor’s decision whether or not to buy, sell, or hold securities of the issuer, we expect it to be disclosed, even if the matter may only crystallize over the medium- or long-term or if there is uncertainty whether it will actually occur. The timing of realization of the risk and the uncertainty of it occurring may impact the analysis of whether the matter is material but not whether it needs to be considered and analyzed as to materiality. Even if the likelihood of the risk occurring diminishes the materiality of the matter, issuers should still consider whether it is appropriate to disclose the matter as a risk factor.

Measurement

As part of a materiality assessment, issuers should not only consider the existence of material climate change-related risks, but also, where practicable, quantify and disclose the potential financial and other impact(s) of such risks, including their magnitude and timing.

In certain instances, securities legislation may require the quantification of these types of risks. For example, Item 5.1(1)(k) of Form 51-102F2 requires an issuer to disclose the financial and operational effects of environmental protection requirements in the current financial year and the expected effect in future years.

In other cases, issuers should consider how to effectively measure and quantify climate change- related risks as part of their broader risk assessment process. While acknowledging that the precise impacts of climate change-related risks may be difficult to quantify or measure, we are of the view that issuers should consider both quantitative and qualitative factors in making their materiality assessments and may consider using assumptions and estimates which have a reasonable basis and are within a reasonable range. External resources and benchmarking against industry peers may also be appropriate in this regard.

Where to disclose material information about climate change-related risks?

In general, issuers should disclose material information relating to climate change-related risks in an AIF (risk factors relating to the issuer and its business that would be most likely to influence an investor’s decision to purchase the issuer’s securities) and MD&A (analysis of the issuer’s operations for the most recently completed financial year, including commitments, events, risks, or uncertainties that the issuer reasonably believes will materially affect its future performance). -10-

Climte Forward- Why this Board and Voluntary Materiality Change- looking Guidance? Management Disclosure related Risks Information

What are potential climate change-related risks and why is their disclosure important?

Disclosure of climate change-related risks and opportunities provides investors with insights into the sustainability of the issuer’s business model.

Climate change-related risks can generally be grouped into the categories shown in the diagram below. The risks and their impact may occur over the short-, medium- or long-term.

Climate Change-related Risks

Physical Transition Time Horizon Reputational Short-term Acute Market Regulatory Policy Chronic Legal Long-term Technology

Physical Risks15

Physical risks resulting from climate change can be event-driven (acute) or longer-term shifts (chronic) in climate patterns. Physical risks may have financial implications for organizations, such as direct damage to assets and indirect impacts from supply chain disruption. Issuers’ financial performance may also be affected by changes in water availability, sourcing, and quality; food security; and extreme temperature changes affecting their premises, operations, supply chain, transport needs, and employee safety.

Acute physical risks refer to those that are event-driven, including increased severity of extreme weather events, such as cyclones, hurricanes, or floods. Chronic physical risks refer to longer-term shifts in climate patterns (e.g., sustained higher temperatures) that may cause sea level rise or chronic heat waves.

15 Derived from the TCFD Recommendations. -11-

Transition Risks16

Transition risks include reputational, market, regulatory, policy, legal and technology-related risks. These risks may have a shorter to longer term impact.

• Reputational risks arise from changing internal and external stakeholder perceptions related to the way that an issuer is viewed as contributing to (or hindering) a transition to a low- carbon economy.

• Market risks arise from shifts in supply and demand for certain commodities, products and services as climate change-related impacts are increasingly considered in decision making.

• Regulatory risks arise from increased regulation of climate change-related matters, for example increased costs of greenhouse gas (GHG) emissions, enhanced disclosure requirements or regulatory action as a result of non-compliance with existing climate change-related disclosure requirements.

• Policy risks arise from policy actions that attempt to constrain actions that contribute to climate change or policy actions that seek to promote adaptation to climate change, such as carbon-pricing mechanisms, incentives for the adoption of lower emission sources of energy and energy-efficient solutions and the promotion of more sustainable land-use practices.

• Legal risks arise from exposure to legal action resulting from a variety of factors including, for example, failure to appropriately address climate change-related risks and insufficient disclosure of material risks.

• Technology risks arise from the introduction of new technology which displaces old systems and disrupts some part of the economic system and include the costs associated with investing in lower emission technologies and substituting products and services with lower emission alternatives.

Opportunities17

Efforts to mitigate and adapt to climate change also produce opportunities for issuers. These include resource efficiency and cost savings, the enhancement of existing processes or adoption of low- emission energy sources, the development of new products and services, access to new markets, and building resilience along the supply chain.

16 Derived from SN 51-333 and the TCFD Recommendations. 17 Derived from the TCFD Recommendations. -12-

How can climate change-related risks affect an issuer’s business?

The climate change-related risks that an issuer is exposed to may have a variety of financial impacts on its business.

The following chart, while not an exhaustive list, outlines some categories of risks that may be associated with climate change and gives examples of risks that may fit into each category18 and the potential financial impacts on an issuer’s business of those risks. We encourage issuers to carefully consider whether other climate change-related risks may apply in their particular circumstances and the impacts of those risks on their business.

18 In developing examples of climate change-related risks, we have referred to SN 51-333, SN 51-354, and a variety of international initiatives including the TCFD Recommendations, the SASB Framework, survey results published by the Carbon Disclosure Project and the Global Standards for Sustainability Reporting published by the Global Reporting Initiative. -13-

Climate Change-related Risks and Potential Risks

Risks Potential Impacts on Potential Financial Impacts Operations and Business

Physical Risks Impacts of Physical Risks Balance Sheet • Acute • damage to assets Assets valuation/impairment • Chronic • supply chain and operational disruptions stranded assets

• availability and quality of water Liabilities • availability of insurance and contingent liabilities financing legal claims regulatory sanctions or penalties reclamation liabilities

Transition Risks Impacts of Transition Risks Income Statement • Reputational • increased costs in a variety of Decreased revenue due to: areas, including GHG emissions • Market decreased demand • restrictions on licenses regulatory restrictions • Regulatory • increased regulation and supply chain and operational • Policy litigation interruptions • Legal • shifts in customer perceptions Increased expenses due to: and preferences • Technology higher costs (water, energy, • stigmatization of the issuer's insurance, cost of capital, capital market sector or industry expenditures) • increased shareholder concern or legal claims, penalties, fin negative shareholder feedback regulatory costs (carbon tax) -14-

Questions for management in assessing the materiality of climate change-related risks and impacts

In assessing the materiality of climate change-related risks, an issuer’s management should consider the above-noted categories of risk as well as any other categories of risk that may be applicable to the issuer’s specific business or industry sector. Below are select questions for management to consider when assessing the extent to which applicable categories of climate change-related risks affect their issuer.

Select Questions for Climate Change-Related Risk Assessments19

Physical Risk

• What is the issuer's exposure to the potential effects of extreme weather events?

• How does the issuer ensure the reliability and resilience of its networks and services to the impact of severe weather events?

• What is the exposure of the issuer's properties to risks, such as flooding or fires?

• What are the major risks associated with the issuer's water use, particularly in water stressed regions?

• What is the issuer's exposure to supply chain disruption climate change-related risks?

Transition Risk

• What is the issuer's exposure to emissions-limiting regulations? How does the geography of the issuer's operations factor into this analysis?

• How does the issuer incorporate emissions regulations and climate change considerations into its asset valuations?

• How does pricing and demand for the issuer’s product/services and/or climate change regulation impact capital expenditure strategy for exploration and development of assets?

• What are the issuer's largest risks associated with environmental compliance, disposal and recycling costs, increased capex requirements, etc.?

• How does the issuer limit and manage risks associated with air emissions of pollutants in or near areas of dense population?

19 In developing examples of questions management should ask themselves when assessing climate change-related risks, we have referred to the TCFD Recommendations. -15-

• What water quality permits, standards, and regulations apply to the issuer? How does the issuer work to maintain compliance with these requirements?

• How is the issuer managing energy consumption and related price and supply risks?

Climte Forward- Why this Board and Voluntary Materiality Change- looking Guidance? Management Disclosure related Risks Information

Voluntary disclosure

In addition to the disclosure required by securities legislation, issuers may choose to voluntarily disclose climate change-related information in their continuous disclosure or in other publications such as sustainability reports, survey responses, corporate citizenship reports, carbon disclosure surveys and information published on an issuer’s website and social media posts. If issuers provide such voluntary disclosure, there may be certain additional requirements and factors to consider.

Voluntary disclosure can provide useful information to investors outside of issuers’ regulatory filings and should be prepared with the same rigour as the issuer’s regulatory filings. Issuers should consider the following:

• Material information in regulatory filings – Material information required to be disclosed under securities legislation must be disclosed in regulatory filings. It is not sufficient for this information to be contained only in voluntary disclosure. Boards and management should ensure that the materiality of information contained in any voluntary disclosure is assessed and, if the information is material, it must be disclosed in the issuer’s regulatory filings. In addition, voluntary disclosure should be consistent with the information included in continuous disclosure filings.

• No misrepresentations – Voluntary disclosure should not contain any misrepresentations. Voluntary disclosure may also be subject to the provisions in securities legislation regarding civil liability for secondary market disclosure. Boards and management should have a robust process for reviewing voluntary disclosure prior to its public release to ensure that the information is reliable and accurate.

• Obscuring of material information – Voluntary disclosure should not obscure material information. -16-

Climte Forward- Why this Board and Voluntary Materiality Change- looking Guidance? Management Disclosure related Risks Information

Forward-looking information

Issuers may choose to include certain forward-looking information (FLI) in their continuous disclosure or in voluntary disclosure. FLI related to climate change could include, for example, a target to reduce GHG emissions or disclosure of an issuer’s assessment of the potential business implications of climate change-related risks and opportunities under various scenarios.

If an issuer discloses FLI, they must comply with the requirements set out in Part 4A, Part 4B and section 5.8 of NI 51-102. Those requirements include:

• identifying the information as FLI,

• providing cautionary language,

• stating the material factors or assumptions used to develop the FLI, and

• updating certain previously disclosed FLI and describing the issuer’s policy for updating FLI.

Guidance on those requirements can be found in Part 4A of Companion Policy 51-102CP Continuous Disclosure Obligations and CSA Staff Notice 51-330 Guidance Regarding the Application of Forward-Looking Information Requirements under NI 51-102 Continuous Disclosure Obligations.

The FLI requirements do not relieve issuers from disclosing material climate change-related risks even if they are expected to occur or crystallize over a longer time frame.

Conclusion

This notice is intended solely as an educational tool for issuers to support their compliance with their existing obligation to disclose material climate change-related risks. Investors, particularly institutional investors, are increasingly seeking entity-specific information regarding these risks. When issuers disclose better risk information, issuers and investors can better assess climate change-related risk and investors can make better informed decisions.

We will continue to monitor disclosure of climate change-related matters as part of our ongoing continuous disclosure review program. -17-

Questions

Please refer your questions to any of the following:

Cheryl McGillivray Tim Robson Manager, Corporate Finance Manager, Legal, Corporate Finance Alberta Securities Commission Alberta Securities Commission 403-297-3307 403-355-6297 [email protected] [email protected] Shannon Ward Jo-Anne Matear Legal Counsel, Corporate Finance Manager, Corporate Finance Alberta Securities Commission Ontario Securities Commission 403-355-6294 416 593 2323 [email protected] [email protected] Stephanie Tjon Oujala‐ Motala‐ Senior Legal Counsel, Corporate Finance Senior Accountant, Corporate Finance Ontario Securities Commission Ontario Securities Commission 416-593-3655 416-263-3770 [email protected] [email protected] Nazma Lee Victoria Yehl Senior Legal Counsel, Corporate Finance Senior Geologist, Corporate Finance British Columbia Securities Commission British Columbia Securities Commission 604-899-6867 604-899-6519 [email protected] [email protected] Heather Kuchuran Wayne Bridgeman Deputy Director, Corporate Finance Deputy Director, Corporate Finance Financial and Consumer Affairs Authority of Manitoba Securities Commission Saskatchewan 204-945-4905 306-787-1009 [email protected] [email protected] Michel Bourque Livia Alionte Senior Regulatory Advisor, Continuous Disclosure Analyst, Continuous Disclosure Continuous Disclosure Autorité des marchés financiers Autorité des marchés financiers 514-395-0337, ext. 4466 514-395-0337, ext. 4336 [email protected] [email protected] Ella-Jane Loomis Junjie (Jack) Jiang Senior Legal Counsel, Securities Securities Analyst, Corporate Finance Financial and Consumer Services Nova Scotia Securities Commission Commission (New Brunswick) 902-424-7059 506-459-6591 [email protected] [email protected]

Notices

1.2 Notices of Hearing

1.2.1. Sean Daley et al. – ss. 127(8), 127(1)

FILE NO.: 2019-28

IN THE MATTER OF SEAN DALEY; and SEAN DALEY carrying on business as the ASCENSION FOUNDATION, OTO.Money, SilentVault, and CryptoWealth; WEALTH DISTRIBUTED CORP.; CYBERVISION MMX INC.; KEVIN WILKERSON; and AUG ENTERPRISES INC.

NOTICE OF HEARING 127(8) and 127(1) of the Securities Act, RSO 1990, c. S.5.

PROCEEDING TYPE: Application for Extension of Temporary Order

HEARING DATE AND TIME: August 16, 2019 at 10:00 a.m.

LOCATION: 20 Queen Street West, 17th Floor, Toronto, Ontario

PURPOSE

The purpose of this proceeding is to consider whether the Commission should grant the Application filed by Staff of the Commission to extend the temporary order issued by the Commission on August 6, 2019.

REPRESENTATION

Any party to the proceeding may be represented by a representative at the hearing.

FAILURE TO ATTEND

IF A PARTY DOES NOT ATTEND, THE HEARING MAY PROCEED IN THE PARTY’S ABSENCE AND THE PARTY WILL NOT BE ENTITLED TO ANY FURTHER NOTICE IN THE PROCEEDING.

FRENCH HEARING

This Notice of Hearing is also available in French on request of a party. Participation may be in either French or English. Participants must notify the Secretary’s Office in writing as soon as possible if the participant is requesting a proceeding be conducted wholly or partly in French.

AVIS EN FRANÇAIS

L'avis d'audience est disponible en français sur demande d’une partie, que la participation à l'audience peut se faire en français ou en anglais et que les participants doivent aviser le Bureau du secrétaire par écrit dès que possible si le participant demande qu'une instance soit tenue entièrement ou partiellement en français.

Dated at Toronto this 6th day of August, 2019.

“Robert Blair” for: Grace Knakowski Secretary to the Commission

For more information

Please visit www.osc.gov.on.ca or contact the Registrar at [email protected].

August 8, 2019 (2019), 42 OSCB 6619

Notices

1.4 Notices from the Office of the Secretary

1.4.1 Sean Daley et al.

FOR IMMEDIATE RELEASE August 6, 2019

SEAN DALEY; and SEAN DALEY carrying on business as the ASCENSION FOUNDATION, OTO.Money, SilentVault, and CryptoWealth; WEALTH DISTRIBUTED CORP.; CYBERVISION MMX INC.; KEVIN WILKERSON; and AUG ENTERPRISES INC., File No. 2019-28

TORONTO – The Office of the Secretary issued a Notice of Hearing on August 6, 2019 setting the matter down to be heard on August 16, 2019 at 10:00 a.m. to consider whether the Commission should grant the Application filed by Staff of the Commission to extend the temporary order issued by the Commission on August 6, 2019.

A copy of the Notice of Hearing dated August 6, 2019, Application dated August 6, 2019 and Temporary Order dated August 6, 2019 are available at www.osc.gov.on.ca.

OFFICE OF THE SECRETARY GRACE KNAKOWSKI SECRETARY TO THE COMMISSION

For media inquiries: [email protected]

For investor inquiries:

OSC Contact Centre 416-593-8314 1-877-785-1555 (Toll Free)

August 8, 2019 (2019), 42 OSCB 6620

Chapter 2

Decisions, Orders and Rulings

2.1 Decisions

2.1.1 Foresters Asset Management Inc. et al.

Headnote

National Policy 11-203 Process for Exemptive Relief Applications in Multiple Jurisdictions – Approval granted for change of manager of investment funds – change of manager is not detrimental to securityholders or the public interest – change of manager to be approved by the funds' securityholders at a special meeting of the securityholders – National Instrument 81-102 Investment Funds.

Applicable Legislative Provisions

National Instrument 81-102 Investment Funds, s. 5.5(1)(a).

July 30, 2019

IN THE MATTER OF THE SECURITIES LEGISLATION OF ONTARIO (the Jurisdiction)

AND

IN THE MATTER OF THE PROCESS FOR EXEMPTIVE RELIEF APPLICATIONS IN MULTIPLE JURISDICTIONS

AND

IN THE MATTER OF FORESTERS ASSET MANAGEMENT INC. (the Filer or FAM)

AND

IN THE MATTER OF IMAXX SHORT TERM BOND FUND IMAXX CANADIAN BOND FUND IMAXX EQUITY GROWTH FUND IMAXX CANADIAN FIXED PAY FUND IMAXX CANADIAN DIVIDEND PLUS FUND IMAXX GLOBAL FIXED PAY FUND (collectively, the Funds)

DECISION

Background

The Ontario Securities Commission (the Commission) has received an application from the Filer for an order under the securities legislation of Ontario (the Legislation) for approval of the proposed change of manager of the Funds from the Filer to Fiera Capital Corporation (FCC) pursuant to section 5.5(1)(a) of National Instrument 81-102 Investment Funds (NI 81-102) (the Requested Approval).

August 8, 2019 (2019), 42 OSCB 6621

Decisions, Orders and Rulings

Under the Process for Exemptive Relief Applications in Multiple Jurisdictions (for a passport application):

a) the Ontario Securities Commission is the principal regulator (the Principal Regulator) for this application; and

b) the Filer has provided notice that section 4.7(1) of Multilateral Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon in British Columbia, Alberta, Saskatchewan, Manitoba, Quebec, New Brunswick, Nova Scotia, Prince Edward Island and Newfound-land and Labrador (together with Ontario, the Jurisdictions).

Interpretation

Terms defined in National Instrument 14-101 Definitions, MI 11-102, and NI 81-102 have the same meaning if used in this decision, unless otherwise defined.

Representations

This decision is based on the following facts represented by the Filer:

The Current Manager

1. The Filer is a corporation amalgamated under the laws of Canada. The Filer’s head office is located in Toronto, Ontario.

2. The Filer is registered as an investment fund manager in Ontario, Newfoundland and Labrador and Québec, as a portfolio manager in each of the provinces of Canada, and as an exempt market dealer in Ontario and Québec.

3. The Filer is the investment fund manager and portfolio manager of each of the Funds.

4. The Filer acts as exempt market dealer in respect of securities of Foresters Asset Management Canadian Bond Pool and in respect of non-prospectus-qualified securities of the Funds, and acts as portfolio manager in respect of discretionary-managed accounts for institutional investors.

5. The Filer is not in default of any requirements of applicable securities legislation.

The Funds

6. The Funds are open-end mutual funds structured as trusts established under the laws of Ontario and governed by an amended and restated master trust agreement dated February 21, 2017, as amended on May 18, 2017 and August 20, 2018.

7. RBC Investor Services Trust acts as trustee, registrar, custodian, record keeper and valuation agent of the Funds.

8. Each of the Funds is authorized to issue an unlimited number of transferrable, redeemable trust units of one or more classes.

9. Each of the Funds is a reporting issuer in each of the Jurisdictions and offers its securities to the public pursuant to a simplified prospectus, annual information form and fund facts, each dated May 15, 2019, as amended May 24, 2019.

10. None of the Funds is in default of any requirements of applicable securities legislation.

Fiera Capital Corporation

11. FCC is a corporation established under the laws of Ontario. FCC’s head office is located in , Québec.

12. FCC is a reporting issuer in each of the provinces of Canada. The common shares of FCC are listed for trading on the Toronto Stock Exchange under the symbol “FSZ”.

13. FCC is registered as an investment fund manager in Ontario, Newfoundland and Labrador and Québec, as a portfolio manager and an exempt market dealer in each of the provinces and territories of Canada, as an adviser in Manitoba, as a commodity trading manager in Ontario and as a derivatives portfolio manager in Québec.

14. FCC’s primary business is to act as portfolio manager in respect of institutional, retail and private wealth clients. It acts as manager and portfolio manager of various pooled funds sold pursuant to exemptions from the prospectus

August 8, 2019 (2019), 42 OSCB 6622

Decisions, Orders and Rulings

requirement, as portfolio manager in respect of discretionary managed account clients, as manager and, in some cases, portfolio manager of certain closed-end funds and as manager and portfolio manager of a commodity pool (that will shortly convert to an alternative mutual fund).

15. FCC is not in default of any requirements of applicable securities legislation.

Details of the Proposed Transaction

16. On May 15, 2019, FCC announced that it had entered into a definitive purchase agreement with Foresters Life Insurance Company (FLIC), the parent company of the Filer, pursuant to which FCC will acquire all of the outstanding shares of the Filer from FLIC (the Proposed Transaction).

17. Following closing of the Proposed Transaction (the Closing), FCC will incorporate the FAM business into its existing Canadian operations, including by effecting certain changes to FAM’s senior officers and directors and portfolio managers, as well as by way of an amalgamation of FCC and FAM to be completed prior to December 31, 2019. Accordingly, the Proposed Transaction will result in a change of investment fund manager of the Funds (the Change of Manager).

18. Pursuant to paragraph 5.1(1)(b) of NI 81-102, special meetings of the unitholders of the Funds will be held on or about August 9, 2019 for the purpose of seeking approval of the Proposed Transaction (the Meetings). The notice of Meetings and the management information circular in respect of the Meetings (the Circular) will be mailed to unitholders of the Fund and copies thereof will be filed on SEDAR in accordance with applicable securities legislation. The Circular contains sufficient information regarding the business, management and operations of FCC, including details of its officers and directors, and all information necessary to allow unitholders to make an informed decision about the Proposed Transaction. All other information and documents necessary to comply with applicable proxy solicitation requirements of securities legislation for the Meetings will be mailed to unitholders of the Funds.

Impact of the Change of Manager

19. Following Closing, the directors and officers of FAM will be as listed below, each of whom is currently an officer of FCC other than Pamela Brenman, who is currently the Chief Compliance Officer of FAM:

(i) Jean-Philippe Lemay - Chief Executive Officer, Ultimate Designated Person and Director;

(ii) Vincent Duhamel - President and Director;

(iii) Dominic Grimard - Chief Financial Officer and Director; and

(iv) Pamela Brenman - Chief Compliance Officer.

20. Following Closing the portfolio managers responsible for management of the Funds’ assets will be as follows:

Fund Post-Closing Portfolio Managers

imaxx Short Term Bond Fund Imran Chaudhry Kon-Yu Lau

imaxx Canadian Bond Fund Imran Chaudhry Kon-Yu Lau

imaxx Canadian Fixed Pay Fund Imran Chaudhry Kon-Yu Lau Nessim Mansoor

imaxx Canadian Dividend Plus Fund Nessim Mansoor Nadim Rizk

imaxx Equity Growth Fund Nessim Mansoor Nadim Rizk

imaxx Global Fixed Pay Fund Imran Chaudhry Kon-Yu Lau Nadim Rizk

August 8, 2019 (2019), 42 OSCB 6623

Decisions, Orders and Rulings

21. Following Closing, FCC may also make adjustments to the investment strategies of the Funds to align with its investment approach. FCC has no current intention to change the investment objectives of the Funds.

22. At the Meetings, unitholders of the Funds will be asked to approve an amendment to the relevant trust agreement to allow the manager to effect a change of auditor without unitholder approval (the Trust Agreement Amendment) and, for any Funds where unitholders do not approve the Trust Agreement Amendment, unitholders of such Funds will be asked to approve a change in auditor from Ernst & Young LLP to PricewaterhouseCoopers LLP, (the Change of Auditor). As a result, following Closing, it is proposed that the auditor of the Funds will change from Ernst & Young LLP to PricewaterhouseCoopers LLP, subject to delivery of all necessary notices.

23. Following Closing, FCC intends to have RBC Investor Services Trust continue as trustee, registrar, custodian, record keeper and valuation agent of the Funds.

24. The Filer referred the Proposed Transaction to the Independent Review Committee (IRC) of the Funds on May 6, 2019 and the Trust Agreement Amendment and the Change of Auditor to the IRC on June 20, 2019, in each case pursuant to Section 5.1(2) of National Instrument 81-107 – Independent Review Committee for Investment Funds (NI 81-107). The IRC determined that the Proposed Transaction, the Trust Agreement Amendment and the Change of Auditor would each achieve a fair and reasonable result for each of the Funds.

25. The Filer and FCC, and not the Funds, will bear all costs and expenses associated with calling and holding the Meetings and implementing the Proposed Transaction, including legal fees, filing fees and other expenses associated with preparing, printing and mailing the meeting materials and obtaining necessary regulatory approvals.

26. The Proposed Transaction will not adversely affect FCC’s financial position or its ability to fulfill its regulatory obligations.

27. Upon Closing, the individuals that comprise the IRC of the Funds will cease to be members by operation of section 3.10(1)(c) of NI 81-107. Immediately following Closing, the new members of the imaxx Funds’ IRC will be the same individuals that comprise the IRC for the pooled funds managed by FCC, namely: Robert F. Kay (Chair), Charles R. Moses and Jerry Patava.

28. Upon Closing, the individuals that will be principally responsible for the investment fund management of the Funds will have the requisite integrity and experience as contemplated under section 5.7(1)(a)(v) of NI 81-102.

29. Closing of the Proposed Transaction is expected to be completed in or about the third quarter of 2019. Closing is subject to the satisfaction of certain closing conditions, including:

(i) customary conditions of closing; and

(ii) the Requested Approval.

30. The Requested Approval will not be detrimental to the protection of investors in the Funds or prejudice the public interest.

Decision

The Principal Regulator is satisfied that the decision meets the test set out in the Legislation for the Principal Regulator to make the decision.

The decision of the Principal Regulator under the Legislation is that the Requested Approval is granted, provided that the Filer obtains the prior approval of securityholders of the Funds for the Proposed Transaction.

“Darren McKall” Manager, Investment Funds and Structured Products Branch Ontario Securities Commission

August 8, 2019 (2019), 42 OSCB 6624

Decisions, Orders and Rulings

2.1.2 Freedom International Brokerage Company et Instrument 31-103 Registration Requirements, Exemptions al. and Ongoing Registrant Obligations (NI 31-103), providing for the following exemptions (collectively, the Exemptions Headnote Sought):

Under paragraph 4.1(1)(a) of National Instrument 31-103 (a) an exemption from the requirement Registration Requirements, Exemptions and Ongoing contained in paragraph 4.1(1)(a) of NI Registrant Obligations a registered firm must not permit an 31-103 to allow RBC to permit Ms. individual to act as a dealing, advising or associate Harleen Bains to act as a dealing advising representative of the registered firm if the representative of RBC while also acting individual acts as an officer, partner or director of another as a director of Freedom (the RBC registered firm that is not an affiliate of the first-mentioned Exemption Sought); and firm. The Filers have sought relief from that prohibition. Each of the firms employing an individual as a registered (b) an exemption from the requirement representative is an owner of the second registered firm contained in paragraph 4.1(1)(a) of NI and entitled to appoint a director to its board. The individual 31-103 to allow TDSI to permit Ms. Alison representatives will have sufficient time to adequately serve (Dickson) Perdue to act as a dealing both firms. The potential for conflicts of interest is representative of TDSI while also acting significantly reduced compared to other similar as a director of Freedom (the TDSI arrangements because the second firm operates as an Exemption Sought). inter-dealer bond broker and does not compete with any of the shareholder firms. The filers have policies in place to Under the Process for Exemptive Relief Applications in handle potential conflicts of interest. Relief from the Multiple Jurisdictions (for a passport application): prohibition has been granted. (a) the Ontario Securities Commission (the Applicable Legislative Provisions OSC) is the principal regulator for this joint application; and Multilateral Instrument 11-102 Passport System, s. 4.7. National Instrument 31-103 Registration Requirements, (b) in the case of the RBC Exemption Exemptions and Ongoing Registrant Obligations, Sought, RBC has provided notice that ss. 4.1, 13.4 and 15.1. section 4.7(1) of Multilateral Instrument 11-102 Passport System (MI 11-102) is July 25, 2019 intended to be relied upon in each of the provinces and territories of Canada IN THE MATTER OF (collectively, the Jurisdictions) other THE SECURITIES LEGISLATION OF than the Principal Jurisdiction; and ONTARIO (the Principal Jurisdiction) (c) in the case of the TDSI Exemption Sought, TDSI has provided notice that AND section 4.7(1) of MI 11-102 is intended to be relied upon in each of the IN THE MATTER OF Jurisdictions other than the Principal THE PROCESS FOR EXEMPTIVE RELIEF Jurisdiction. APPLICATIONS IN MULTIPLE JURISDICTIONS Interpretation

AND Terms defined in National Instrument 14-101 Definitions and MI 11-102 have the same meaning if used in these IN THE MATTER OF decisions, unless otherwise defined. FREEDOM INTERNATIONAL BROKERAGE COMPANY (FREEDOM), Representations RBC DOMINION SECURITIES INC. (RBC), AND TD SECURITIES INC. (TDSI) These decisions are based on the following facts represented by each of the Filers insofar as such facts DECISION relate to the corresponding Filer:

Background Freedom

The regulator in the Principal Jurisdiction (the Decision 1. Freedom is an unlimited liability company Maker) has received a joint application from Freedom, incorporated under the laws of Nova Scotia. RBC and TDSI (each a Filer) for a decision under the securities legislation of the Principal Jurisdiction (the Legislation), pursuant to section 15.1 of National

August 8, 2019 (2019), 42 OSCB 6625

Decisions, Orders and Rulings

2. The principal regulator of Freedom is the OSC each a member of IIROC. RBC is indirectly owned because Freedom’s principal office is located in by the Royal Bank of Canada and TDSI is directly Toronto, Ontario. owned by The Toronto-Dominion Bank.

3. Freedom is registered as an exempt market dealer 13. The principal regulator of each Shareholder- in Ontario and Québec, and has been approved Dealer is the OSC because each Shareholder- as an inter-dealer bond broker by the Investment Dealer’s principal office is located in Toronto, Industry Organization of Canada (IIROC). Ontario.

4. As an inter-dealer bond broker, Freedom provides 14. Ms. Bains is registered, among other things, as a an integrated voice and electronic brokerage dealing representative (investment dealer) of RBC service to its clients in accordance with the in each of the Jurisdictions. RBC wants to appoint requirements of IIROC Dealer Member Rule 2100 Ms. Bains as its representative on the Board. Inter-Dealer Bond Brokerage Systems (Rule 2100). 15. Ms. Bains is the Managing Director and Head FICC Canada Sales at RBC and is responsible for 5. Pursuant to Rule 2100, all of Freedom’s clients strengthening RBC’s client relationships across are typically Canadian investment dealers, asset classes and driving an innovative coverage Canadian chartered banks and/or an affiliated model across fixed income, currencies and entity. commodity (FICC) products.

6. As an inter-dealer bond broker, Freedom acts as 16. Ms. Perdue is registered as a dealing an agent for its customers in allowing a customer representative (investment dealer) of TDSI in to buy and/or sell domestic and international Ontario, and TDSI wants to appoint Ms. Perdue as corporate and government bonds, derivatives and its representative on the Board. other related securities (collectively, Debt Securities) to another customer of Freedom. 17. Ms. Perdue is the Managing Director, Head of Canadian Interest Rate Trading at TDSI and is 7. Freedom never acts as principal in effecting a responsible for managing the Canadian rates trade with a client (i.e., Freedom only matches an trading team, which is comprised of trading desks order by a buyer with a seller and vice versa). in Toronto and Montreal. The business is divided into three market making desks - government / 8. Freedom is owned (i) indirectly by a wholly-owned provincial bond trading, interest rate swaps and subsidiary of BGC Partners Inc. (BGC), a leading interest rate options (trading under the name of global brokerage company servicing the financial TD Bank), and primarily provides liquidity for and real estate markets with its head office in institutional clients. London, England, and (ii) directly by, or indirectly by a wholly-owned subsidiary of, BMO Nesbitt 18. Each Shareholder-Dealer uses the services of Burns Inc., CIBC World Markets Inc., Merrill Lynch Freedom to effect trades of Debt Securities on Canada Inc., RBC, Scotia Capital Inc. and TDSI behalf of their clients from time to time. (collectively, the Shareholders). Dual Registration 9. The board of directors of Freedom (the Board) consists of five representatives from BGC and one 19. Because each of Ms. Bains and Ms. Perdue (each representative from each of the other a Representative) has extensive knowledge Shareholders for a total of 11 directors. The about fixed income securities and the marketplace members of the Board do not receive any in which Freedom operates, Freedom wants each compensation for acting as a director of Freedom. Representative to be a director of Freedom and a member of its Board. Appointing the 10. BGC and the other Shareholders have entered Representatives to be directors of Freedom will into a unanimous shareholders agreement which help Freedom remain competitive and be effectively limits the ability of the directors of responsive to its clients’ interests. Freedom to oversee the operations of Freedom and imposes restraints on what Freedom can do 20. Each Shareholder-Dealer has determined that its without shareholder approval. Representative is the appropriate person to sit on the Board and that it does not have another 11. Neither RBC or TDSI (each a Shareholder- individual that is not registered in the Jurisdictions Dealer) is an affiliate of Freedom. who has the necessary expertise.

Shareholder-Dealers 21. Each Representative will be supervised by the applicable Shareholder-Dealer. 12. RBC and TDSI are each, among other things, an investment dealer in all of the Jurisdictions, and is

August 8, 2019 (2019), 42 OSCB 6626

Decisions, Orders and Rulings

22. The day-to-day operations of Freedom are carried Representative to be made aware of the out by the executive management and employees nature of the Information, the of Freedom. The Representatives will not have Representative will not be notified of the any role in the day-to-day operations of Freedom. nature of the Information.

23. No Representative or Shareholder-Dealer will 29. To further protect Freedom, the Freedom Policy have access to Freedom’s systems, which access contains guidelines relating to: would enable the Representative or Shareholder- Dealer to influence the actions of a client of (a) the circumstances in which the Freedom to the benefit of that Representative or Information may be passed on by a Shareholder-Dealer in relation to a trade. director to the Shareholder-Dealer who nominated them; 24. At no time will the interests of any Shareholder- Dealer be favoured over the other clients of (b) the right of Freedom to place an embargo Freedom as a result of the Representative of that on the Information which must not be Shareholder-Dealer being a member of Freedom’s passed on because of its sensitivity; and Board. (c) acceptance by each Shareholder-Dealer 25. It is anticipated that each Representative will of the obligation of confidentiality in spend between four to six hours per quarter on relation to any Information received. their duties as a director of Freedom. 30. Each of the Shareholder-Dealers has appropriate 26. The directors of Freedom are subject to a detailed compliance and supervisory policies and policy governing conflicts of interest (the Freedom procedures to deal with any conflicts of interest Policy). The Freedom Policy specifically that may arise as a result of their Representative addresses the situation where a Representative, being a director of Freedom. that is a director appointed by a Shareholder- Dealer, has a conflict of interest or duty arising 31. The potential for conflicts of interest or client from the concurrent fiduciary duties they owe to confusion due to a Representative acting as a Freedom and their Shareholder-Dealer. director of Freedom and a dealing representative of their Shareholder-Dealer is mitigated by the 27. The Freedom Policy proceeds from the principle following: that a Representative owes an unqualified fiduciary duty to Freedom. The Freedom Policy (a) none of the Shareholder-Dealers enforces that principle by providing that where a competes with Freedom; director or the Board identifies a conflict of interest, the Board will adopt a protocol for (b) members of the Board serve without managing the conflict which must include remuneration; provisions relating to: (c) the Representatives will not be involved (a) whether the conflicted director must in the day-to-day operations of withdraw from the Board meeting for the Freedom’s operations; duration of any discussion on a relevant matter, and whether the Board may (d) no Representative or Shareholder-Dealer waive such a requirement; will have access to Freedom’s systems, which access would enable the (b) whether, in light of applicable law or other Representative or Shareholder-Dealer to relevant circumstances, the conflicted influence the actions of a client of director may vote in connection with any Freedom to the benefit of that Board decision on that matter; and Representative or Shareholder-Dealer in relation to a trade; and (c) whether, subject to such restrictions as the Board may impose, the conflicted (e) at no time will Freedom favour the director may receive Board papers or interests of any Shareholder-Dealer as a other information which relates in any result of their Representative being a way to the subject-matter that gives rise member of its Board. to the conflict (the Information). Where the Board decides that the 32. None of the Filers is in default of securities, Representative may not receive the commodities or derivatives legislation in any Information, and the Board further Jurisdiction. decides that the conflict of duty is of such nature or sensitivity that it is not 33. In the absence of the Exemptions Sought, each of appropriate for the conflicted the Shareholder-Dealers would be prohibited

August 8, 2019 (2019), 42 OSCB 6627

Decisions, Orders and Rulings

under paragraph 4.1(1)(a) of NI 31-103 from 2.2 Orders permitting its respective Representative to act as a dealing representative of the Shareholder-Dealer 2.2.1 Delivra Corp. while also acting as a director of Freedom. Headnote Decisions National Policy 11-206 Process for Cease to be a The Decision Maker is satisfied that the following decisions Reporting Issuer Applications – The issuer ceased to be a meet the test set out in the Legislation for the Decision reporting issuer under securities legislation. Maker to make the decisions. Applicable Legislative Provisions The RBC Exemption Sought Securities Act, R.S.O. 1990, c.S.5, as am., s. 1(10)(a)(ii). The decision of the Decision Maker under the Legislation is that the RBC Exemption Sought is granted, provided that July 30, 2019 the circumstances described above, insofar as they relate to RBC and Freedom, remain in place. IN THE MATTER OF THE SECURITIES LEGISLATION OF The TDSI Exemption Sought ONTARIO (the Jurisdiction) The decision of the Decision Maker under the Legislation is that the TDSI Exemption Sought is granted, provided that AND the circumstances described above, insofar as they relate to TDSI and Freedom, remain in place. IN THE MATTER OF THE PROCESS FOR CEASE TO BE A “Elizabeth King” REPORTING ISSUER APPLICATIONS Deputy Director AND

IN THE MATTER OF DELIVRA CORP. (the Filer)

ORDER

Background

The principal regulator in the Jurisdiction has received an application from the Filer for an order under the securities legislation of the Jurisdiction of the principal regulator (the Legislation) that the Filer has ceased to be a reporting issuer in all jurisdictions of Canada in which it is a reporting issuer (the Order Sought).

Under the Process for Cease to be a Reporting Issuer Applications (for a passport application):

(a) the Ontario Securities Commission is the principal regulator for this application, and

(b) the Filer has provided notice that subsection 4C.5(1) of Multilateral Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon in British Columbia and Alberta.

Interpretation

Terms defined in National Instrument 14-101 Definitions, and MI 11-102 have the same meaning if used in this order, unless otherwise defined.

August 8, 2019 (2019), 42 OSCB 6628

Decisions, Orders and Rulings

Representations

This order is based on the following facts represented by the Filer:

1. the Filer is not an OTC reporting issuer under Multilateral Instrument 51-105 Issuers Quoted in the U.S. Over-the- Counter Markets;

2. the outstanding securities of the Filer, including debt securities, are beneficially owned, directly or indirectly, by fewer than 15 securityholders in each of the jurisdictions of Canada and fewer than 51 securityholders in total worldwide;

3. no securities of the Filer, including debt securities, are traded in Canada or another country on a marketplace as defined in National Instrument 21-101 Marketplace Operation or any other facility for bringing together buyers and sellers of securities where trading data is publicly reported;

4. the Filer is applying for an order that the Filer has ceased to be a reporting issuer in all of the jurisdictions of Canada in which it is a reporting issuer; and

5. the Filer is not in default of securities legislation in any jurisdiction.

Order

The principal regulator is satisfied that the order meets the test set out in the Legislation for the principal regulator to make the order.

The decision of the principal regulator under the Legislation is that the Order Sought is granted.

“Jo-Anne Matear” Manager, Corporate Finance Ontario Securities Commission

August 8, 2019 (2019), 42 OSCB 6629

Decisions, Orders and Rulings

2.2.2 Sean Daley et al. – ss. 127(1), 127(5)

IN THE MATTER OF SEAN DALEY; and SEAN DALEY carrying on business as the ASCENSION FOUNDATION, OTO.Money, SilentVault, and CryptoWealth; WEALTH DISTRIBUTED CORP.; CYBERVISION MMX INC.; KEVIN WILKERSON; and AUG ENTERPRISES INC.

TEMPORARY ORDER (Subsections 127(1) & 127(5))

WHEREAS:

1. it appears to the Ontario Securities Commission (the “Commission”) that:

(a) Sean Daley (“Daley”); Daley carrying on business as the Ascension Foundation, OTO.Money, SilentVault and CryptoWealth; Wealth Distributed Corp.; Cybervision MMX Inc.; Kevin Wilkerson; and Aug Enterprises Inc. (collectively “the Respondents”) may have traded securities without registration and without an exemption to the registration requirement contrary to section 25 of the Securities Act, R.S.O. 1990, c. S.5 (the “Act”); and

(b) The Respondents may have traded securities without a prospectus having been filed and receipted by the Director contrary to section 53 of the Act;

2. the Commission is of the opinion that the time required to conclude a hearing could be prejudicial to the public interest as set out in subsection 127(5) of the Act;

3. the Commission is of the opinion that it is in the public interest to make this order; and

4. by Authorization Order made on April 30, 2019, pursuant to subsection 3.5(3) of the Act, the Commission authorized each of Maureen Jensen, D. Grant Vingoe, Timothy Moseley, Mary Anne de Monte-Whelan, Garnet W. Fenn, Lawrence P. Haber, Craig Hayman, Raymond Kindiak, Poonam Puri, M. Cecilia Williams, and Heather Zordel acting alone, to exercise the powers of the Commission to make orders under section 127 of the Act;

IT IS ORDERED pursuant to section 127 of the Act that:

1. pursuant to clause 2 of subsection 127(1) of the Act, all trading in any securities by the Respondents shall cease;

2. pursuant to clause 2 of subsection 127(1) of the Act, all trading in ‘overcome the odds’ vouchers, also known as OTO Vouchers, and Lyra shall cease;

3. pursuant to clause 3 of subsection 127(1) of the Act, that the exemptions contained in Ontario securities law do not apply to the Respondents; and

4. pursuant to subsection 127(6) of the Act, this order shall take effect immediately and shall expire on the 15th day after its making unless extended by order of the Commission.

Dated at Toronto this “6th” day of August, 2019.

“T. Moseley”

August 8, 2019 (2019), 42 OSCB 6630

Chapter 4

Cease Trading Orders

4.1.1 Temporary, Permanent & Rescinding Issuer Cease Trading Orders

Company Name Date of Temporary Date of Hearing Date of Date of Order Permanent Order Lapse/Revoke

THERE IS NOTHING TO REPORT THIS WEEK.

Failure to File Cease Trade Orders

Date of Company Name Date of Order Revocation

Highvista Gold Inc. August 2, 2019

Jeotex Inc. August 2, 2019 Maclos Capital Inc. August 2, 2019

Border Petroleum Limited August 2, 2019

Evolving Gold Corp. August 2, 2019

Portage Biotech Inc. August 2, 2019

SBD Capital Corp. August 2, 2019 Environmental Waste International Inc. May 6, 2019 August 1, 2019

Waseco Resources Inc. July 5, 2019 August 1, 2019

4.2.1 Temporary, Permanent & Rescinding Management Cease Trading Orders

Company Name Date of Order Date of Lapse

BetterU Education Corp. August 2, 2019

4.2.2 Outstanding Management & Insider Cease Trading Orders

Date of Date of Order or Date of Date of Issuer Company Name Date of Hearing Temporary Order Permanent Order Lapse/ Expire Temporary Order

Performance Sports 19 October 2016 31 October 2016 31 October 2016 Group Ltd.

Company Name Date of Order Date of Lapse

Peeks Social Ltd. 04 July 2019

August 8, 2019 (2019), 42 OSCB 6631

Cease Trading Orders

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August 8, 2019 (2019), 42 OSCB 6632

Chapter 7

Insider Reporting

The following is a weekly summary of insider transactions by insiders of Ontario reporting issuers in SEDI® (the System for Electronic Disclosure by Insiders).1 The weekly summary contains insider transactions reported during the 7-day period ending Sunday at 11:59 p.m. (i.e. the Sunday prior to the Bulletin Issue date).2

Guide to Codes Relationship of Insider to Issuer (Rel=n)

1 Issuer 2 Subsidiary of Issuer 3 10% Security Holder of Issuer 4 Director of Issuer 5 Senior Officer of Issuer 6 Director or Senior Officer of 10% Security Holder 7 Director or Senior Officer of Insider or Subsidiary of Issuer (other than in 4,5,6) 8 Deemed Insider – 6 Months before becoming Insider

Nature of Transaction (T/O)

00 Opening Balance-Initial SEDI Report 10 Acquisition or disposition in the public market 11 Acquisition or disposition carried out privately 15 Acquisition or disposition under a prospectus 16 Acquisition or disposition under a prospectus exemption 22 Acquisition or disposition pursuant to a take-over bid, merger or acquisition 30 Acquisition or disposition under a purchase/ ownership plan 35 Stock dividend 36 Conversion or exchange 37 Stock split or consolidation 38 Redemption, retraction, cancellation, repurchase 40 Short sale 45 Compensation for property 46 Compensation for services 47 Acquisition or disposition by gift 48 Acquisition by inheritance or disposition by bequest 50 Grant of options 51 Exercise of options 52 Expiration of options 53 Grant of warrants 54 Exercise of warrants 55 Expiration of warrants 56 Grant of rights 57 Exercise of rights 59 Exercise for cash 70 Acquisition or disposition (writing) of third party derivative 71 Exercise of third party derivative 72 Other settlement of third party 73 Expiration of third party derivative 90 Change in nature of ownership 97 Other 99 Correction of Information

Note: The asterisk in the “Date/Month End Holding” column indicates the insider disagreed with the system calculated balance when the transaction was reported.

1 SEDI® is a registered trademark owned by CDS INC. 2 ©CDS INC.

August 8, 2019 (2019), 42 OSCB 6633

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed 01 Communique Common Shares Cheung, Andrew 4 2019-07-29 11 0.12 939,667 416,667 Laboratory Inc. 01 Communique Options Cheung, Andrew 4 2019-07-29 53 0.15 208,334 Laboratory Inc. 01 Communique Warrants Cheung, Andrew 4 1992-10-07 00 Laboratory Inc. 01 Communique Warrants Cheung, Andrew 4 2019-07-29 53 0.15 208,334 208,334 Laboratory Inc. 4Front Ventures Corp. Options - Class A CROOM, DAVID 5 2019-07-31 00 600,000 Subordinate Voting Shares 4Front Ventures Corp. Options - Class A Dutton, Anthony John 4 2019-07-31 00 900,000 Subordinate Voting Guy Shares 4Front Ventures Corp. Subordinate Voting Dutton, Anthony John 4 2019-07-31 00 6,245,000 Shares (Class A Guy Subordinate Voting Shares) A&W Revenue Trust Units Mindell, David Allen 4 2019-07-31 10 43.76 42,210 148 Royalties Income Fund Accord Financial Corp. Common Shares Keating, Terry 5 2019-08-01 10 7 4,920 380 Ackroo Inc. Common Shares Jacmat Holdings Ltd. 3 2019-07-29 16 0.11 2,508,046 -12,232,362 Ackroo Inc. Options Levely, Stephen 5 2019-01-11 52 0.25 2,975,000 -100,000 Alexander Ackroo Inc. Options Levely, Stephen 5 2019-07-15 52 0.26 2,775,000 -200,000 Alexander Ackroo Inc. Common Shares Moore, Jacqueline 3 2019-07-29 16 0.11 2,508,046 -12,232,362 Marjorie Ackroo Inc. Common Shares Moore, Matthew 6 2019-07-29 16 0.11 2,508,046 -12,232,362 Acreage Holdings, Inc. Options MacDonald, James 5 2019-04-19 00 83,333 (formerly Applied Tyson Inventions Management Corp.) Acreage Holdings, Inc. Rights Restricted MacDonald, James 5 2019-04-19 00 116,667 (formerly Applied Shares Units (RSU) Tyson Inventions Management Corp.) Acreage Holdings, Inc. Subordinate Voting MacDonald, James 5 2019-04-19 00 38,834 (formerly Applied Shares Tyson Inventions Management Corp.) Acreage Holdings, Inc. Proportionate Voting Van Faasen, William, 4 2018-11-14 00 4,973 (formerly Applied Shares Cornelius Inventions Management Corp.) Acreage Holdings, Inc. Subordinate Voting Van Faasen, William, 4 2018-11-14 00 8,000 (formerly Applied Shares Cornelius Inventions Management Corp.) Advantage Oil & Gas Rights Deferred Share Angevine, Jill Terilee 4 2019-07-31 56 60,414 2,878 Ltd. Units Advantage Oil & Gas Rights Deferred Share Balog, Stephen 4 2019-07-31 56 69,532 2,877 Ltd. Units Advantage Oil & Gas Rights Deferred Share Fagerheim, Grant 4 2019-07-31 56 63,075 1,439 Ltd. Units Bradley Advantage Oil & Gas Rights Deferred Share Haggis, Paul 4 2019-07-31 56 77,326 3,165 Ltd. Units Advantage Oil & Gas Rights Deferred Share McIntosh, Ronald A 4 2019-07-31 56 106,435 4,374 Ltd. Units AEX Gold Inc. Options Ménard, Martin 5 2019-07-10 00 AEX Gold Inc. Options Ménard, Martin 5 2019-07-10 00 AEX Gold Inc. Options Ménard, Martin 5 2019-07-10 50 0.38 500,000 500,000 AGF Management Common Shares Class AGF EMPLOYEE 2 2019-07-04 10 5.2 379,607 -12,485 Limited B BENEFIT PLAN TRUST Agnico Eagle Mines Common Shares Allan, Don 5 2019-07-29 51 36.37 55,566 16,000 Limited Agnico Eagle Mines Common Shares Allan, Don 5 2019-07-29 10 70.82 39,566 -16,000 Limited

August 8, 2019 (2019), 42 OSCB 6634

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Agnico Eagle Mines Common Shares Allan, Don 5 2019-07-29 10 70.76 34,566 -5,000 Limited Agnico Eagle Mines Options Allan, Don 5 2019-07-29 51 36.37 114,000 -16,000 Limited Agnico Eagle Mines Common Shares Blackburn, Alain 5 2019-08-01 51 28.92 8,215 2,000 Limited Agnico Eagle Mines Common Shares Blackburn, Alain 5 2019-08-01 10 71.9 6,215 -2,000 Limited Agnico Eagle Mines Options Blackburn, Alain 5 2019-08-01 51 28.92 148,000 -2,000 Limited Agnico Eagle Mines Common Shares Grondin, Louise 5 2019-07-30 51 28.92 55,019 6,000 Limited Agnico Eagle Mines Common Shares Grondin, Louise 5 2019-07-30 51 36.37 60,019 5,000 Limited Agnico Eagle Mines Common Shares Grondin, Louise 5 2019-07-30 51 56.45 70,019 10,000 Limited Agnico Eagle Mines Common Shares Grondin, Louise 5 2019-07-30 10 71.6 49,019 -21,000 Limited Agnico Eagle Mines Options Grondin, Louise 5 2019-07-30 51 28.92 107,700 -6,000 Limited Agnico Eagle Mines Options Grondin, Louise 5 2019-07-30 51 36.37 102,700 -5,000 Limited Agnico Eagle Mines Options Grondin, Louise 5 2019-07-30 51 56.45 92,700 -10,000 Limited Agnico Eagle Mines Common Shares Legault, Marc 5 2019-07-30 51 58.04 61,355 8,500 Limited Agnico Eagle Mines Common Shares Legault, Marc 5 2019-07-30 10 71.57 52,855 -8,500 Limited Agnico Eagle Mines Options Legault, Marc 5 2019-07-30 51 58.04 155,500 -8,500 Limited Agnico Eagle Mines Common Shares Robitaille, Jean 5 2019-08-01 51 28.92 68,230 4,000 Limited Agnico Eagle Mines Common Shares Robitaille, Jean 5 2019-08-01 10 72.12 64,230 -4,000 Limited Agnico Eagle Mines Options Robitaille, Jean 5 2019-08-01 51 28.92 185,000 -4,000 Limited Agnico Eagle Mines Common Shares Smith, David 5 2019-07-30 51 36.37 73,150 10,000 Limited Agnico Eagle Mines Common Shares Smith, David 5 2019-07-30 10 71.8 63,150 -10,000 Limited Agnico Eagle Mines Options Smith, David 5 2019-07-30 51 36.37 157,000 -10,000 Limited Agnico Eagle Mines Common Shares Sylvestre, Yvon 5 2019-08-01 51 36.37 7,832 5,000 Limited Agnico Eagle Mines Common Shares Sylvestre, Yvon 5 2019-08-01 10 72 2,832 -5,000 Limited Agnico Eagle Mines Options Sylvestre, Yvon 5 2019-08-01 51 36.37 151,000 -5,000 Limited Agrios Global Holdings Common Shares Skyline Corporate 8 2002-08-01 11 62,500 31,250 Ltd. Communications Group, LLC Aimia Inc. Common Shares Mittleman Investment 3 2019-07-29 97 27,585,313 -60,000 Management, LLC Air Canada Class B Voting Shares Air Canada 1 2019-07-29 38 44.925 25,000 25,000 Air Canada Class B Voting Shares Air Canada 1 2019-07-29 38 0 -25,000 Air Canada Class B Voting Shares Air Canada 1 2019-07-30 38 44.957 3,800 3,800 Air Canada Class B Voting Shares Air Canada 1 2019-07-30 38 0 -3,800 Air Canada Class B Voting Shares Air Canada 1 2019-07-31 38 44.974 8,500 8,500 Air Canada Class B Voting Shares Air Canada 1 2019-07-31 38 0 -8,500 Air Canada Class B Voting Shares Guillemette, Lucie 5 2019-08-01 51 2.49 29,311 10,000 Air Canada Class B Voting Shares Guillemette, Lucie 5 2019-08-01 10 44.584 19,311 -10,000 Air Canada Class B Voting Shares Guillemette, Lucie 5 2019-08-01 51 5.39 31,467 12,156 Air Canada Class B Voting Shares Guillemette, Lucie 5 2019-08-01 10 44.5 19,311 -12,156 Air Canada Class B Voting Shares Guillemette, Lucie 5 2019-08-01 51 5.39 25,389 6,078 Air Canada Class B Voting Shares Guillemette, Lucie 5 2019-08-01 10 44.507 19,311 -6,078

August 8, 2019 (2019), 42 OSCB 6635

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Air Canada Options (Long-Term Guillemette, Lucie 5 2019-08-01 51 2.49 204,245 -10,000 Incentive Plan) Air Canada Options (Long-Term Guillemette, Lucie 5 2019-08-01 51 5.39 192,089 -12,156 Incentive Plan) Air Canada Options (Long-Term Guillemette, Lucie 5 2019-08-01 51 5.39 186,011 -6,078 Incentive Plan) Air Canada Class B Voting Shares Landry, Craig 5 2019-08-01 51 3.04 17,653 7,978 Air Canada Class B Voting Shares Landry, Craig 5 2019-08-01 10 44.739 9,675 -7,978 Air Canada Class B Voting Shares Landry, Craig 5 2019-08-01 51 5.39 17,588 7,913 Air Canada Class B Voting Shares Landry, Craig 5 2019-08-01 10 44.743 9,675 -7,913 Air Canada Options (Long-Term Landry, Craig 5 2019-08-01 51 3.04 128,440 -7,978 Incentive Plan) Air Canada Options (Long-Term Landry, Craig 5 2019-08-01 51 5.39 120,527 -7,913 Incentive Plan) Air Canada Class B Voting Shares Meloul-Wechsler, 5 2019-08-01 51 12.64 9,184 6,000 Arielle Air Canada Class B Voting Shares Meloul-Wechsler, 5 2019-08-01 10 44.748 3,184 -6,000 Arielle Air Canada Class B Voting Shares Meloul-Wechsler, 5 2019-08-01 51 12.64 6,184 3,000 Arielle Air Canada Class B Voting Shares Meloul-Wechsler, 5 2019-08-01 10 44.757 3,184 -3,000 Arielle Air Canada Class B Voting Shares Meloul-Wechsler, 5 2019-08-01 51 9.23 7,226 4,042 Arielle Air Canada Class B Voting Shares Meloul-Wechsler, 5 2019-08-01 10 44.75 3,184 -4,042 Arielle Air Canada Options (Long-Term Meloul-Wechsler, 5 2019-08-01 51 12.64 86,767 -6,000 Incentive Plan) Arielle Air Canada Options (Long-Term Meloul-Wechsler, 5 2019-08-01 51 12.64 83,767 -3,000 Incentive Plan) Arielle Air Canada Options (Long-Term Meloul-Wechsler, 5 2019-08-01 51 9.23 79,725 -4,042 Incentive Plan) Arielle Air Canada Class B Voting Shares Nasr, Mark Youssef 5 2019-08-01 51 19.18 912 625 Air Canada Class B Voting Shares Nasr, Mark Youssef 5 2019-08-01 10 44.841 287 -625 Air Canada Options (Long-Term Nasr, Mark Youssef 5 2019-08-01 51 19.18 42,389 -625 Incentive Plan) Alamos Gold Inc. Rights Deferred Share Prichard, John Robert 4 2019-07-31 30 17,291 401 Units Stobo Alaris Royalty Corp. Common Shares FRAZER, AMANDA 5 2019-07-26 10 21.16 8,038 -4,172 MAI Alaska Hydro Common Shares Grandison, Clifford 4, 5 2019-07-29 10 0.02 5,431,030 18,000 Corporation Allan Alaska Hydro Common Shares Grandison, Clifford 4, 5 2019-08-01 10 0.02 5,463,030 32,000 Corporation Allan Alba Minerals Ltd. Common Shares Arias, Carlos 4 2017-12-01 16 0.06 660,000 300,000 Alba Minerals Ltd. Options Arias, Carlos 4 2018-09-05 50 0.065 200,000 200,000 Alba Minerals Ltd. Options Arias, Carlos 4 2018-12-31 50 0.065 300,000 100,000 Alba Minerals Ltd. Warrants Arias, Carlos 4 2017-11-09 00 Alba Minerals Ltd. Warrants Arias, Carlos 4 2017-12-01 15 0.06 300,000 300,000 Alba Minerals Ltd. Options Born, Peter 4 2018-09-05 50 0.065 100,000 100,000 Alba Minerals Ltd. Common Shares Brown, Arthur 4, 5 2017-12-01 16 0.06 2,791,000 2,000,000 Alba Minerals Ltd. Options Brown, Arthur 4, 5 2017-11-11 50 0.09 450,000 450,000 Alba Minerals Ltd. Warrants Brown, Arthur 4, 5 2016-11-17 00 Alba Minerals Ltd. Warrants Brown, Arthur 4, 5 2017-12-01 16 0.06 2,000,000 2,000,000 Alba Minerals Ltd. Options MacDougall, Sandy 4 2016-10-05 00 James Alba Minerals Ltd. Options MacDougall, Sandy 4 2017-11-11 50 0.09 450,000 450,000 James Alba Minerals Ltd. Options MacDougall, Sandy 4 2018-12-31 50 0.065 650,000 200,000 James Alianza Minerals Ltd. Options Blythe, Marc Girthon 4 2019-07-30 50 0.1 450,000 150,000 (formerly Tarsis Resources Ltd.)

August 8, 2019 (2019), 42 OSCB 6636

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Alianza Minerals Ltd. Options Brown, Mark Thomas 4 2019-07-30 50 0.1 750,000 300,000 (formerly Tarsis Resources Ltd.) Alianza Minerals Ltd. Options Wilson, John R. 4 2019-07-30 50 0.1 400,000 150,000 (formerly Tarsis Resources Ltd.) Alianza Minerals Ltd. Options Wong, Winnie Sze 5 2019-07-30 50 0.1 650,000 250,000 (formerly Tarsis Wan Resources Ltd.) Alimentation Couche- Unité d'action fictive Anderton, Niall 5 2019-08-01 00 Tard Inc. Alimentation Couche- Unité d'action fictive Anderton, Niall 5 2019-08-01 46 4,907 4,907 Tard Inc. Alimentation Couche- Unité d'action différée Bourque, Nathalie 4 2019-08-01 35 81.92 19,999 30 Tard Inc. Alimentation Couche- Unité d'action différée Boyko, Éric 4 2019-08-01 35 81.92 3,835 6 Tard Inc. Alimentation Couche- Unité d'action différée D'Amours, Jacques 4 2019-08-01 35 81.92 8,648 13 Tard Inc. Alimentation Couche- Unité d'action différée Élie, Jean André 4 2019-08-01 35 81.92 34,722 53 Tard Inc. Alimentation Couche- Unité d'action différée Fortin, Richard 4, 6, 7, 5 2019-08-01 35 81.92 22,484 35 Tard Inc. Alimentation Couche- Unité d'action différée Kau, Mélanie 4 2019-08-01 35 81.92 70,943 108 Tard Inc. Alimentation Couche- Unité d'action différée Leroux, Monique F. 4 2019-08-01 35 81.92 7,398 12 Tard Inc. Alimentation Couche- Unité d'action différée Plourde, Réal 4, 6, 7, 5 2019-08-01 35 81.92 8,607 13 Tard Inc. Alimentation Couche- Unité d'action différée Rabinowicz, Daniel 5 2019-08-01 35 81.92 6,451 10 Tard Inc. Alternate Health Corp. Common Shares Chidgey, Robert 5 2019-07-30 10 0.1803 950 400 American Creek Common Shares Pownall, Sean Patrick 4 2016-01-01 00 Resources Ltd. American Creek Common Shares Pownall, Sean Patrick 4 2019-01-28 46 0.05 3,291,441 3,291,441 Resources Ltd. American Creek Common Shares Pownall, Sean Patrick 4 2019-07-30 10 0.075 2,341,441 -950,000 Resources Ltd. American Hotel Units O'Neill, John 5 2019-07-29 30 6.6793 413,249 3,876 Income Properties Christopher REIT LP American Manganese Options Skoda, Edward 4 2019-08-02 50 0.21 800,000 300,000 Inc. Franklin American Manganese Options Skoda, Edward 4 2019-08-02 50 0.21 850,000 50,000 Inc. Franklin ANC Capital Ventures Common Shares Clifford, John 3, 4, 5 2019-07-26 00 700,000 Inc. Randolph ANC Capital Ventures Options Clifford, John 3, 4, 5 2019-07-26 00 185,000 Inc. Randolph ARC Resources Ltd. Common Shares Pinder, Herbert 4 2019-08-02 10 6.9172 103,800 9,800 Arctic Star Exploration Common Shares Power, Patrick Edward 4, 5 2019-07-25 10 0.04 2,811,362 -10,000 Corp. Arctic Star Exploration Common Shares Power, Patrick Edward 4, 5 2019-07-31 10 0.035 2,773,362 -38,000 Corp. Arctic Star Exploration Common Shares Power, Patrick Edward 4, 5 2019-07-31 10 0.04 2,773,162 -200 Corp. Aritzia Inc. Subordinate Voting Bensadoun, Aldo 4 2019-07-26 47 500,000 500,000 Shares Aritzia Inc. Subordinate Voting Bensadoun, Aldo 4 2019-07-26 47 533,316 -500,000 Shares Artemis Gold Inc. Common Shares Armstrong, William 4 2019-07-19 00 10,000 Paul Artemis Gold Inc. Common Shares Beedie, Ryan K 4 2019-07-19 00 Artemis Gold Inc. Common Shares Beedie, Ryan K 4 2019-07-19 00 3,267,662 Artemis Gold Inc. Common Shares Black, W. David 4 2019-07-19 00 53,140 Asanko Gold Inc. Options Zvaipa, Josephat 5 2019-07-31 00 810,000

August 8, 2019 (2019), 42 OSCB 6637

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Asanko Gold Inc. Rights Restricted Zvaipa, Josephat 5 2019-07-31 00 454,050 Share Units Ascendant Resources Common Shares Shefsky, Stephen 4 2019-07-31 54 0.25 468,233 100,000 Inc. Ascendant Resources Warrants Shefsky, Stephen 4 2019-07-31 54 0.25 214,700 -100,000 Inc. ATCO LTD. Non-Voting Shares Beattie, Adam M. 7 2018-01-04 00 Class I ATCO LTD. Non-Voting Shares Beattie, Adam M. 7 2019-07-30 30 44.381 10,000 10,000 Class I ATCO LTD. Non-Voting Shares Constantinescu, M. 5 2019-07-30 30 44.381 4,000 2,000 Class I George ATCO LTD. Rights 43.39 (Phantom Creaghan, Patrick 7 2013-12-01 00 AMTIP 2019-07-30) ATCO LTD. Rights 43.39 (Phantom Creaghan, Patrick 7 2019-07-30 56 43.39 4,000 4,000 AMTIP 2019-07-30) ATCO LTD. Non-Voting Shares DeChamplain, Dennis 7 2019-07-30 30 44.381 40,000 20,000 Class I A ATCO LTD. Rights 43.39 (Phantom Green, Stevan R. 7 2018-08-08 00 AMTIP 2019-07-30) ATCO LTD. Rights 43.39 (Phantom Green, Stevan R. 7 2019-07-30 56 43.39 2,000 2,000 AMTIP 2019-07-30) ATCO LTD. Rights 43.39 (Phantom Ivulich, John Vincent 7 2014-08-01 00 AMTIP 2019-07-30) ATCO LTD. Rights 43.39 (Phantom Ivulich, John Vincent 7 2019-07-30 56 43.39 4,000 4,000 AMTIP 2019-07-30) ATCO LTD. Non-Voting Shares Kiefer, Siegfried W. 7, 5 2019-07-30 30 44.381 60,000 20,000 Class I ATCO LTD. Non-Voting Shares Lidgett, George J. 7 2019-07-30 30 44.381 25,000 5,000 Class I ATCO LTD. Non-Voting Shares Patrick, Katherine- 7 2019-07-30 30 44.381 4,500 2,000 Class I Jane ATCO LTD. Non-Voting Shares Southern, Nancy C. 4, 6, 7, 5 2019-07-30 30 44.381 40,000 15,000 Class I ATCO LTD. Non-Voting Shares Stensby, Wayne K. 7 2019-07-30 30 44.381 25,000 5,000 Class I Athabasca Minerals Common Shares Smith, Mark Gregory 5 2018-11-19 16 0.2 75,000 Inc. Edward Athabasca Minerals Common Shares Smith, Mark Gregory 5 2018-11-19 16 0.2 75,000 Inc. Edward Athabasca Minerals Common Shares Smith, Mark Gregory 5 2019-07-29 54 0.35 112,500 37,500 Inc. Edward Athabasca Minerals Warrants Smith, Mark Gregory 5 2018-11-19 16 0.35 37,500 Inc. Edward Athabasca Minerals Warrants Smith, Mark Gregory 5 2018-11-19 16 0.35 37,500 Inc. Edward Athabasca Minerals Warrants Smith, Mark Gregory 5 2019-07-29 54 0.35 0 -37,500 Inc. Edward Atlantic Power Preferred Shares Atlantic Power 1 2019-07-18 38 18.3 12,000 12,000 Corporation Series 2 Corporation Atlantic Power Preferred Shares Atlantic Power 1 2019-07-31 38 0 -12,000 Corporation Series 2 Corporation Avicanna Inc. Common Shares Giesselman, Janet 4 2019-07-29 00 Avicanna Inc. Common Shares Giesselman, Janet 4 2019-07-29 10 4.66 5,800 5,800 Avicanna Inc. Common Shares Giesselman, Janet 4 2019-07-29 10 4.65 7,100 1,300 Ayr Strategies Inc. Subordinate Voting Burggraeve, Chris 4 2018-12-17 00 (formerly, Cannabis Shares Roger Strategies Acquisition Corp.) Ayr Strategies Inc. Subordinate Voting Burggraeve, Chris 4 2019-07-30 10 10.9 1,000 1,000 (formerly, Cannabis Shares Roger Strategies Acquisition Corp.) Ayr Strategies Inc. Exchangeable Shares Menzies, Steve Scott 4 2019-05-24 00 (formerly, Cannabis Strategies Acquisition Corp.)

August 8, 2019 (2019), 42 OSCB 6638

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Ayr Strategies Inc. Exchangeable Shares Menzies, Steve Scott 4 2019-05-24 00 2,238,807 (formerly, Cannabis Strategies Acquisition Corp.) Ayr Strategies Inc. Exchangeable Shares Smith, Mark Austin 4, 5 2019-06-07 22 449,369 16,036 (formerly, Cannabis Strategies Acquisition Corp.) Badger Daylighting Common Shares Badger Daylighting 1 2019-07-02 38 48.563 11,800 1,800 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-03 38 48.853 16,800 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-04 38 48.845 21,800 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-05 38 48.616 26,800 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-05 38 10,000 -16,800 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-08 38 48.705 13,900 3,900 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-09 38 48.84 14,600 700 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-10 38 48.812 19,600 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-11 38 47.961 24,600 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-12 38 47.538 29,600 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-12 38 10,000 -19,600 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-15 38 48.122 15,000 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-16 38 48.674 17,400 2,400 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-17 38 48.749 19,100 1,700 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-18 38 48.545 24,100 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-19 38 48.353 29,100 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-19 38 10,000 -19,100 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-22 38 48.773 15,000 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-23 38 48.369 20,000 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-24 38 48.349 23,500 3,500 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-25 38 48.704 28,500 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-26 38 48.565 33,500 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-26 38 10,000 -23,500 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-29 38 47.365 15,000 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-30 38 47.314 20,000 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-31 38 47.703 25,000 5,000 Ltd. Ltd. Badger Daylighting Common Shares Badger Daylighting 1 2019-07-31 38 10,000 -15,000 Ltd. Ltd. Bank of Nova Scotia, Rights Director Aufreiter, Nora Anne 4 2019-07-29 56 70.8 11,219 918 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Aufreiter, Nora Anne 4 2019-07-29 30 70.8 11,346 127 The Deferred Stock Units (DDSU)

August 8, 2019 (2019), 42 OSCB 6639

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Bank of Nova Scotia, Rights Director Babatz, Guillermo 4 2019-07-29 56 70.8 11,365 512 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Babatz, Guillermo 4 2019-07-29 30 70.8 11,498 133 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Bonham, Scott Barclay 4 2019-07-29 56 70.8 11,543 830 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Bonham, Scott Barclay 4 2019-07-29 30 70.8 11,675 132 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Dallara, Charles Harry 4 2019-07-29 56 70.8 11,597 512 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Dallara, Charles Harry 4 2019-07-29 30 70.8 11,733 136 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Macklem, Richard 4 2019-07-29 56 70.8 14,922 971 The Deferred Stock Units Tiffany (DDSU) Bank of Nova Scotia, Rights Director Macklem, Richard 4 2019-07-29 30 70.8 171 The Deferred Stock Units Tiffany (DDSU) Bank of Nova Scotia, Rights Director Macklem, Richard 4 2019-07-29 30 70.8 15,094 172 The Deferred Stock Units Tiffany (DDSU) Bank of Nova Scotia, Rights Director Penner, Michael D. 5 2019-07-29 56 70.8 6,709 830 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Penner, Michael D. 5 2019-07-29 30 70.8 6,781 72 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Power, Una Marie 4 2019-07-29 56 70.8 11,955 1,007 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Power, Una Marie 4 2019-07-29 30 70.8 12,090 135 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Regent, Aaron William 4 2019-07-29 56 70.8 25,304 1,589 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Regent, Aaron William 4 2019-07-29 30 70.8 25,596 292 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Samarasekera, Indira 4 2019-07-29 56 70.8 38,340 512 The Deferred Stock Units Vasanti (DDSU) Bank of Nova Scotia, Rights Director Samarasekera, Indira 4 2019-07-29 30 70.8 38,805 465 The Deferred Stock Units Vasanti (DDSU) Bank of Nova Scotia, Rights Director Segal, Susan Louise 4 2019-07-29 56 70.8 28,834 830 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Segal, Susan Louise 4 2019-07-29 30 70.8 29,178 344 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Thomson, Scott 4 2019-07-29 56 70.8 10,960 1,006 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Thomson, Scott 4 2019-07-29 30 70.8 11,082 122 The Deferred Stock Units (DDSU) Bank of Nova Scotia, Rights Director Warmbold, Benita 4 2019-07-29 56 70.8 2,353 795 The Deferred Stock Units Marie (DDSU) Bank of Nova Scotia, Rights Director Warmbold, Benita 4 2019-07-29 30 70.8 2,372 19 The Deferred Stock Units Marie (DDSU) Barkerville Gold Mines Options Masse, Sean 5 2019-05-13 00 Ltd.

August 8, 2019 (2019), 42 OSCB 6640

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Barkerville Gold Mines Options Masse, Sean 5 2019-07-28 50 600,000 600,000 Ltd. Barkerville Gold Mines Options Tremblay, Eric 4 2019-06-17 00 Ltd. Barkerville Gold Mines Options Tremblay, Eric 4 2019-07-28 50 400,000 400,000 Ltd. Barkerville Gold Mines Options Zaritsky, Blair David 6 2016-08-15 00 Ltd. Barkerville Gold Mines Options Zaritsky, Blair David 6 2019-07-28 50 400,000 400,000 Ltd. BARRIAN MINING Common Shares Sali, Maximilian 4, 5 2019-07-31 10 0.14 2,691,500 50,000 CORP. Baylin Technologies Deferred Share Units Davis, Janice 4 2019-07-31 56 3.45 2,050 725 Inc. Baylin Technologies Deferred Share Units Reiter, Barry 4 2019-07-31 56 3.45 92,045 966 Inc. Baylin Technologies Deferred Share Units Saska, David 4 2019-07-31 56 3.45 6,394 725 Inc. Baylin Technologies Deferred Share Units SIMMONDS, DONALD 4 2019-07-31 56 3.45 65,757 725 Inc. E. Baylin Technologies Deferred Share Units Wolkin, Harold Morton 4 2019-07-31 56 3.45 107,398 1,812 Inc. Bengal Energy Ltd. Common Shares Chakrabarty, Chayan 4, 5 2019-07-26 30 0.095 1,056,922 20,119 Bengal Energy Ltd. Common Shares Moorman, Matthew 5 2019-07-26 30 0.095 274,364 15,746 Joseph Black Mammoth Common Shares Henderson, Dustin 4, 5 2019-07-31 10 0.04 1,808,253 1,000 Metals Corporation Christopher Blackhawk Resource Options Antony, David Michael 4, 5 2019-07-29 50 0.1 1,200,000 500,000 Corp. Blackhawk Resource Options Antony, Raymond 4 2019-07-29 52 0.1 200,000 -100,000 Corp. Peter Blackhawk Resource Options Antony, Raymond 4 2019-07-29 50 0.1 400,000 200,000 Corp. Peter Blackhawk Resource Options Lazorko, Charidy Ada 5 2019-07-29 50 0.1 500,000 300,000 Corp. Leah Blackhawk Resource Options Ogle, Kelly 4 2015-08-24 00 300,000 Corp. Blackhawk Resource Options Ogle, Kelly 4 2019-07-24 50 0.1 500,000 200,000 Corp. Blackhawk Resource Options OWEN, DALE 4 2019-02-25 00 Corp. Blackhawk Resource Options OWEN, DALE 4 2019-07-29 50 200,000 200,000 Corp. Blackhawk Resource Common Shares Pels, Frederick 5 2019-08-01 00 5,000,000 Corp. Blackhawk Resource Options Pels, Frederick 5 2019-08-01 00 300,000 Corp. Blackhawk Resource Options Smith, Michael James 4 2019-07-29 50 0.1 600,000 200,000 Corp. Arthur Blackhawk Resource Options Smith, Michael James 4 2019-07-31 52 0.1 400,000 -200,000 Corp. Arthur Blackhawk Resource Options Wong-Chor, Trevor 5 2019-07-29 50 266,666 100,000 Corp. Block X Capital Corp. Common Shares Johannson, Arni 5 2019-07-29 10 0.03 1,388,000 3,000 (formerly Lions Gate Thomas Metals Inc.) Blok Technologies Inc. Common Shares Hyland, James 4, 5 2017-12-17 00 (formerly Aida Minerals Corp.) Blok Technologies Inc. Common Shares Hyland, James 4, 5 2018-03-02 11 0.9 200,000 200,000 (formerly Aida Minerals Corp.) Blok Technologies Inc. Common Shares Hyland, James 4, 5 2018-11-02 11 0.5 233,000 33,000 (formerly Aida Minerals Corp.) Braveheart Resources Common Shares Berzins, Ian Martin 4, 5 2019-07-31 10 0.17 2,403,500 -16,000 Inc.

August 8, 2019 (2019), 42 OSCB 6641

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Braveheart Resources Warrants Keele, Philip Abbott 4, 5 2019-07-25 11 1,000,000 -2,000,000 Inc. Braveheart Resources Common Shares Matlock, Aaron 4, 5 2019-07-29 54 0.12 6,322,001 983,334 Inc. Braveheart Resources Warrants Matlock, Aaron 4, 5 2019-07-29 54 2,550,000 -983,334 Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-24 38 48.705 18,508 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-24 38 48.705 1,157,903 18,508 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-24 38 1,139,395 -18,508 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-24 38 63.942 1,198,795 59,400 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-24 38 1,139,395 -59,400 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-25 38 48.978 1,143,495 4,100 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-25 38 1,139,395 -4,100 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-25 38 64.368 1,146,995 7,600 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-25 38 1,139,395 -7,600 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-30 38 48.983 1,139,695 300 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-30 38 1,139,395 -300 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-31 38 64.338 1,178,795 39,400 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-31 38 1,139,395 -39,400 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-31 38 48.904 1,165,463 26,068 Management Inc. A Limited Voting Management Inc. Brookfield Asset Common Shares Class Brookfield Asset 1 2019-07-31 38 1,139,395 -26,068 Management Inc. A Limited Voting Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-29 38 16.3 2,264 1,132 Management Inc. Class A Series 38 Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-29 38 1,132 -1,132 Management Inc. Class A Series 38 Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-31 38 16.3 2,232 1,100 Management Inc. Class A Series 38 Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-31 38 1,132 -1,100 Management Inc. Class A Series 38 Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-22 38 17.5 2,800 1,400 Management Inc. Class A Series 42 Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-22 38 1,400 -1,400 Management Inc. Class A Series 42 Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-23 38 17.481 2,800 1,400 Management Inc. Class A Series 42 Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-23 38 1,400 -1,400 Management Inc. Class A Series 42 Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-24 38 17.5 1,600 200 Management Inc. Class A Series 42 Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-24 40 1,400 -200 Management Inc. Class A Series 42 Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-31 38 17.5 2,700 1,300 Management Inc. Class A Series 42 Management Inc. Brookfield Asset Preferred Shares Brookfield Asset 1 2019-07-31 38 1,400 -1,300 Management Inc. Class A Series 42 Management Inc. Brookfield Property Deferred Units (Global) Stelzl, Robert L. 7 2019-06-19 36 0 -43,545 Partners L.P. BURCON Common Shares Schweizer, Martin 5 2019-08-01 90 1.39 157,794 -5,554 NUTRASCIENCE Hans CORPORATION

August 8, 2019 (2019), 42 OSCB 6642

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed BURCON Common Shares Schweizer, Martin 5 2019-08-01 90 1.39 11,700 5,554 NUTRASCIENCE Hans CORPORATION Camrova Resources Promissory Notes Ogryzlo, Charles 4 2012-05-07 00 Inc. Thomas Camrova Resources Promissory Notes Ogryzlo, Charles 4 2019-07-30 11 $17,000 $17,000 Inc. Thomas Camrova Resources Promissory Notes Seidler, Wolf K 4 2012-05-07 00 Inc. Camrova Resources Promissory Notes Seidler, Wolf K 4 2019-07-30 11 $10,000 $10,000 Inc. Canacol Energy Ltd. Restricted Share Units Baena, Luis Alfredo 5 2019-07-28 59 41,500 -31,500 Canacol Energy Ltd. Restricted Share Units Bednar, Jason Michael 5 2019-07-28 59 41,500 -31,500 Canacol Energy Ltd. Restricted Share Units Carvajal, Diego 5 2019-07-28 59 32,250 -28,500 Alfonso Canacol Energy Ltd. Restricted Share Units Cisneros Fajardo, 4 2019-07-28 59 6,250 -4,750 Oswaldo Jesus Canacol Energy Ltd. Restricted Share Units Diaz Salazar, 4 2019-07-28 59 6,250 -4,750 Francisco Canacol Energy Ltd. Restricted Share Units Elliott, Greg 4 2019-07-28 59 6,250 -4,750 Canacol Energy Ltd. Restricted Share Units Fernandez-Tinoco, 4 2019-07-28 59 4,750 -4,750 Gonzalo Canacol Energy Ltd. Restricted Share Units Flick, Kevin James 5 2019-07-28 59 8,750 -6,250 Canacol Energy Ltd. Restricted Share Units Gamba, Charle 4, 5 2019-07-28 59 52,500 -42,500 Canacol Energy Ltd. Restricted Share Units Hibberd, Michael John 4 2019-07-28 59 4.83 8,333 -6,334 Canacol Energy Ltd. Restricted Share Units Sharma, Ravi 5 2019-07-28 59 41,500 -31,500 Canacol Energy Ltd. Restricted Share Units Teare, Mark Reginald 5 2019-07-28 59 41,500 -31,500 Canacol Energy Ltd. Restricted Share Units Whitmore, Tracy Lynn 5 2019-07-28 59 44,137 -7,750 Canacol Energy Ltd. Restricted Share Units Winter, David A 4 2019-07-28 59 6,250 -4,750 Canacol Energy Ltd. Restricted Share Units Zaidi, Anthony Amar 5 2019-07-28 59 41,500 -31,500 Canada Goose Options Brook, Penelope 7, 5 2019-07-25 51 4.6159 99,953 -14,814 Holdings Inc. Canada Goose Subordinate Voting Brook, Penelope 7, 5 2019-07-25 51 4.6159 14,814 14,814 Holdings Inc. Shares Canada Goose Subordinate Voting Brook, Penelope 7, 5 2019-07-25 10 60 0 -14,814 Holdings Inc. Shares Canada Jetlines Ltd. Options Surintas, Zygimantas 4 2019-01-20 00 Canada Jetlines Ltd. Options Surintas, Zygimantas 4 2019-07-29 50 0.445 225,000 225,000 CanadaBis Capital Inc. Common Shares Ryan, Shawn Michael 5 2019-05-18 90 0.5 221,000 -12,000 CanadaBis Capital Inc. Common Shares Ryan, Shawn Michael 5 2019-04-26 00 CanadaBis Capital Inc. Common Shares Ryan, Shawn Michael 5 2019-05-18 90 0.5 12,000 12,000 Canadian Metals Inc. Common Shares Panneton, Gerald 4 2019-07-29 10 0.045 1,200,000 200,000 Canadian Metals Inc. Common Shares Panneton, Gerald 4 2019-07-29 10 0.051 1,400,000 200,000 Canadian Metals Inc. Common Shares Panneton, Gerald 4 2019-07-30 10 0.055 922,000 57,000 Canadian Orebodies Common Shares Cudney, Robert 3 2019-07-24 10 0.2 9,857,750 35,000 Inc. Douglas Canadian Tire C.T.C. Dealer Holdings Hatch, Robert 6 2019-07-26 16 167 3,037 25 Corporation, Limited Interest Canadian Tire C.T.C. Dealer Holdings Leroux, Sylvain 6 2019-07-26 16 167 2,986 86 Corporation, Limited Interest Canadian Tire C.T.C. Dealer Holdings Weinbrecht, Markus 6 2019-07-26 16 167 2,804 8 Corporation, Limited Interest Canadian Utilities Non-Voting Shares Berger, Valerie P. 7 2019-07-30 30 39.973 5,000 2,000 Limited Class A Canadian Utilities Non-Voting Shares Constantinescu, M. 5 2019-07-30 30 39.973 4,000 2,000 Limited Class A George Canadian Utilities Non-Voting Shares Cook, P. Derek 6, 5 2019-07-30 30 39.973 6,000 4,000 Limited Class A Canadian Utilities Non-Voting Shares DeChamplain, Dennis 7 2019-07-30 30 39.973 42,000 20,000 Limited Class A A Canadian Utilities Non-Voting Shares Goguen, Paul G. 7 2019-07-30 30 39.973 10,000 3,000 Limited Class A Canadian Utilities Non-Voting Shares Kiefer, Siegfried W. 7, 5 2019-07-30 30 39.973 68,000 20,000 Limited Class A

August 8, 2019 (2019), 42 OSCB 6643

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Canadian Utilities Non-Voting Shares Lidgett, George J. 7 2019-07-30 30 39.973 30,000 10,000 Limited Class A Canadian Utilities Non-Voting Shares Patrick, Katherine- 7 2019-07-30 30 39.973 6,500 4,000 Limited Class A Jane Canadian Utilities Non-Voting Shares Piepgrass, Steven R. 7 2019-07-30 30 39.973 10,000 3,000 Limited Class A Canadian Utilities Non-Voting Shares Sharpe, D Jason 7 2019-07-30 30 39.973 12,000 4,000 Limited Class A Canadian Utilities Non-Voting Shares Shkrobot, Brian P. 7 2019-07-30 30 39.973 12,000 6,000 Limited Class A Canadian Utilities Non-Voting Shares Southern, Nancy C. 4, 6, 7, 5 2019-07-30 30 39.973 58,000 15,000 Limited Class A Canadian Utilities Non-Voting Shares Stensby, Wayne K. 7 2019-07-30 30 39.973 30,000 10,000 Limited Class A Canadian Western Common Shares Graham, Carolyn Joan 5 2019-07-26 51 26.134 19,176 3,430 Bank Canadian Western Options Graham, Carolyn Joan 5 2019-07-26 51 64,519 -28,296 Bank Canadian Western Options Shore, Lester 5 2019-03-15 50 45,605 5,878 Bank Canadian Western Options Shore, Lester 5 2019-06-12 52 39.418 39,762 -5,843 Bank Canadian Western Rights Performance Shore, Lester 5 2019-07-31 30 3,440 97 Bank Share Units Canadian Western Rights Restricted Shore, Lester 5 2019-07-31 56 9,190 3,381 Bank Share Units Canadian Western Rights Restricted Shore, Lester 5 2019-07-31 59 5,825 -3,365 Bank Share Units Candente Gold Corp. Common Shares Melnyk, Matthew 4 2019-06-09 00 Candente Gold Corp. Options Melnyk, Matthew 4 2019-06-09 00 Candente Gold Corp. Options Melnyk, Matthew 4 2019-07-29 50 0.05 250,000 250,000 Canfor Pulp Products Common Shares Yuen, Brian Yan Pong 5 2019-01-18 00 2,211 Inc. Cannabis One Subordinate Voting Mann, Josh 4 2019-02-25 00 Holdings Inc. (formerly, Shares Class "A" Metropolitan Energy subordinate voting Corp.) shares Cannabis One Subordinate Voting Mann, Josh 4 2019-07-26 10 0.47 500 500 Holdings Inc. (formerly, Shares Class "A" Metropolitan Energy subordinate voting Corp.) shares Cannabis One Subordinate Voting Mann, Josh 4 2019-07-26 10 0.425 10,500 10,000 Holdings Inc. (formerly, Shares Class "A" Metropolitan Energy subordinate voting Corp.) shares Cannabix Common Shares Clarke, Thomas 4 2019-07-29 10 0.83 31,980 -1,320 Technologies Inc William Cannvas MedTech Inc. Options Hamelin, Lindsay 4 2019-07-30 50 0.23 75,000 50,000 Cannvas MedTech Inc. Options Loutskou, Steve 3, 4, 5 2019-07-30 50 0.23 900,000 400,000 Cannvas MedTech Inc. Options Moniz, Shawn 3, 4, 5 2019-07-30 50 0.23 900,000 400,000 Canopy Rivers Inc. Subordinated Voting Alexandrian, Narbe 5 2018-07-30 00 Shares Canopy Rivers Inc. Subordinated Voting Alexandrian, Narbe 5 2019-07-29 10 2.8795 5,000 5,000 Shares Capital Power Common Shares Capital Power 1 2019-07-02 38 30.237 211,706 40,302 Corporation Corporation Capital Power Common Shares Capital Power 1 2019-07-05 38 0 -211,706 Corporation Corporation Cardero Resource Common Shares Kopple, Robert 3 2019-07-31 10 0.035 22,384,823 46,000 Corp. Charles Cardero Resource Common Shares Kopple, Robert 3 2019-07-31 10 0.03 22,389,823 5,000 Corp. Charles Cardinal Energy Ltd. Common Shares Ratushny, M. Scott 4, 5 2019-08-02 10 2.39 22,000 7,000 Cenovus Energy Inc. Common Shares McKenzie, Jonathan 5 2019-08-01 10 12.05 86,758 10,000 Michael Ceres Global Ag Corp. Common Shares Vanasek, James 3, 4 2019-07-30 10 4.78 12,169,646 9,500 Thomas

August 8, 2019 (2019), 42 OSCB 6644

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed CHAR Technologies Common Shares Anderson, Ian 4 2019-07-29 10 0.16 946,809 3,000 Ltd. Chemesis International Common Shares Parmar, Amandeep 4 2019-07-22 10 1.47 10,000 Inc. Singh Chemesis International Common Shares Parmar, Amandeep 4 2019-07-22 10 1.47 10,000 Inc. Singh Chemesis International Common Shares Parmar, Amandeep 4 2019-07-22 10 1.47 20,000 10,000 Inc. Singh Chemtrade Logistics Rights Deferred Trust Di Clemente, Lucio 4 2019-07-31 56 10.22 36,618 1,101 Income Fund Units Chemtrade Logistics Rights Deferred Trust Gee, David 4 2019-07-31 56 10.22 72,060 1,101 Income Fund Units Chemtrade Logistics Rights Deferred Trust McArthur, Susan J. 4 2019-07-31 56 10.22 42,352 2,752 Income Fund Units Chemtrade Logistics Rights Deferred Trust Muzyka, Douglas 7 2019-07-31 56 10.22 19,808 3,669 Income Fund Units Chemtrade Logistics Rights Deferred Trust Rethy, Katherine Anne 4 2019-07-31 56 10.22 32,458 3,669 Income Fund Units Chemtrade Logistics Rights Deferred Trust Waisberg, Lorie 4 2019-07-31 56 10.22 71,442 2,874 Income Fund Units CIBT Education Group Common Shares CIBT Education Group 1 2019-07-26 10 0.66 1,496,500 7,500 Inc. Inc CIBT Education Group Common Shares CIBT Education Group 1 2019-07-29 10 0.6987 1,696,500 200,000 Inc. Inc Citation Growth Corp. Common Shares Mohamed, Rahim 4 2018-08-12 00 Citation Growth Corp. Common Shares Mohamed, Rahim 4 2019-04-22 56 900,000 900,000 Citation Growth Corp. Common Shares Mohamed, Rahim 4 2019-04-22 56 1,800,000 900,000 Citation Growth Corp. Common Shares Mohamed, Rahim 4 2019-04-22 56 3,600,000 1,800,000 Citation Growth Corp. Common Shares Mohamed, Rahim 4 2019-06-10 37 2,925,000 -675,000 Citation Growth Corp. Common Shares Mohamed, Rahim 4 2019-06-10 37 -675,000 Citation Growth Corp. Common Shares Mohamed, Rahim 4 2019-06-10 37 -675,000 Citation Growth Corp. Common Shares Mohamed, Rahim 4 2019-06-10 37 900,000 -2,025,000 Citation Growth Corp. Common Shares Mohamed, Rahim 4 2019-07-22 46 225,000 Citation Growth Corp. Common Shares Mohamed, Rahim 4 2019-07-22 46 225,000 Citation Growth Corp. Common Shares Mohamed, Rahim 4 2019-07-22 46 225,000 Citation Growth Corp. Options Mohamed, Rahim 4 2018-08-12 00 Citation Growth Corp. Options Mohamed, Rahim 4 2018-10-04 50 745,000 745,000 Citation Growth Corp. Options Mohamed, Rahim 4 2019-03-03 50 2,745,000 2,000,000 Citation Growth Corp. Options Mohamed, Rahim 4 2019-06-10 37 2,186,250 -558,750 Citation Growth Corp. Options Mohamed, Rahim 4 2019-06-10 37 686,250 -1,500,000 Citation Growth Corp. Warrants Mohamed, Rahim 4 2018-08-12 00 Citation Growth Corp. Warrants Mohamed, Rahim 4 2018-09-25 53 3,033,225 3,033,225 Citation Growth Corp. Warrants Mohamed, Rahim 4 2019-06-10 37 758,306 -2,274,919 City View Green Common Shares Quinsam Capital 3 2019-07-30 11 28,776,796 2,693,460 Holdings Inc. Corporation Clairvest Group Inc. Options Non-Voting Castellarin, Michael 5 2016-06-30 50 57.44 33,632 Lawrence Clairvest Group Inc. Options Non-Voting Castellarin, Michael 5 2016-06-30 50 57.44 33,632 33,632 Lawrence Clairvest Group Inc. Options Non-Voting Castellarin, Michael 5 2017-06-30 50 72.42 12,031 Lawrence Clairvest Group Inc. Options Non-Voting Castellarin, Michael 5 2017-06-30 50 72.42 45,663 12,031 Lawrence Clairvest Group Inc. Options Non-Voting Castellarin, Michael 5 2018-06-30 50 94.02 6,686 Lawrence Clairvest Group Inc. Options Non-Voting Castellarin, Michael 5 2018-06-30 50 94.02 52,349 6,686 Lawrence Clairvest Group Inc. Options Non-Voting Castellarin, Michael 5 2019-05-28 50 96.7 8,403 Lawrence Clairvest Group Inc. Options Non-Voting Castellarin, Michael 5 2019-05-28 50 96.7 60,752 8,403 Lawrence Clairvest Group Inc. Options Non-Voting Cheng, Daniel 5 2016-06-30 50 57.44 2,973 Clairvest Group Inc. Options Non-Voting Cheng, Daniel 5 2016-06-30 50 57.44 2,973 2,973 Clairvest Group Inc. Options Non-Voting Cheng, Daniel 5 2017-06-30 50 72.42 4,591

August 8, 2019 (2019), 42 OSCB 6645

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Clairvest Group Inc. Options Non-Voting Cheng, Daniel 5 2017-06-30 50 72.42 7,564 4,591 Clairvest Group Inc. Options Non-Voting Cheng, Daniel 5 2018-06-30 50 94.02 1,250 Clairvest Group Inc. Options Non-Voting Cheng, Daniel 5 2018-06-30 50 94.02 8,814 1,250 Clairvest Group Inc. Options Non-Voting Cheng, Daniel 5 2019-05-28 50 96.7 6,072 Clairvest Group Inc. Options Non-Voting Cheng, Daniel 5 2019-05-28 50 96.7 14,886 6,072 Clairvest Group Inc. Options Non Voting Cole, Angus 5 2017-06-30 50 72.42 8,441 Clairvest Group Inc. Options Non Voting Cole, Angus 5 2017-06-30 50 72.42 8,441 8,441 Clairvest Group Inc. Options Non Voting Cole, Angus 5 2018-06-30 50 94.02 7,987 Clairvest Group Inc. Options Non Voting Cole, Angus 5 2018-06-30 50 94.02 16,428 7,987 Clairvest Group Inc. Options Non Voting Cole, Angus 5 2019-05-28 50 96.7 11,939 Clairvest Group Inc. Options Non Voting Cole, Angus 5 2019-05-28 50 96.7 28,367 11,939 Clairvest Group Inc. Options Non Voting Cole, Angus 5 2019-06-26 50 100.66 2,070 Clairvest Group Inc. Options Non Voting Cole, Angus 5 2019-06-26 50 100.66 30,437 2,070 Clairvest Group Inc. Options Non-Voting Dhonte, Sebastien 7 2016-06-30 50 57.44 8,411 Clairvest Group Inc. Options Non-Voting Dhonte, Sebastien 7 2016-06-30 50 57.44 8,411 8,411 Clairvest Group Inc. Options Non-Voting Dhonte, Sebastien 7 2017-06-30 50 72.42 23,146 Clairvest Group Inc. Options Non-Voting Dhonte, Sebastien 7 2017-06-30 50 72.42 31,557 23,146 Clairvest Group Inc. Options Non-Voting Dhonte, Sebastien 7 2018-06-30 50 94.02 3,173 Clairvest Group Inc. Options Non-Voting Dhonte, Sebastien 7 2018-06-30 50 94.02 34,730 3,173 Clairvest Group Inc. Options Non-Voting Dhonte, Sebastien 7 2019-05-28 50 96.7 10,693 Clairvest Group Inc. Options Non-Voting Dhonte, Sebastien 7 2019-05-28 50 96.7 45,423 10,693 Clairvest Group Inc. Options Non-Voting Green, Mitchell Seth 5 2016-06-30 50 57.44 35,087 Clairvest Group Inc. Options Non-Voting Green, Mitchell Seth 5 2016-06-30 50 57.44 35,087 35,087 Clairvest Group Inc. Options Non-Voting Green, Mitchell Seth 5 2017-06-30 50 72.42 9,789 Clairvest Group Inc. Options Non-Voting Green, Mitchell Seth 5 2017-06-30 50 72.42 44,876 9,789 Clairvest Group Inc. Options Non-Voting Green, Mitchell Seth 5 2018-06-30 50 94.02 4,441 Clairvest Group Inc. Options Non-Voting Green, Mitchell Seth 5 2018-06-30 50 94.02 49,317 4,441 Clairvest Group Inc. Options Non-Voting Green, Mitchell Seth 5 2019-05-28 50 96.7 9,963 Clairvest Group Inc. Options Non-Voting Green, Mitchell Seth 5 2019-05-28 50 96.7 59,280 9,963 Clairvest Group Inc. Options Non-Voting Heffernan, Joseph 4 2016-06-30 50 57.44 29,563 John Clairvest Group Inc. Options Non-Voting Heffernan, Joseph 4 2016-06-30 50 57.44 29,563 29,563 John Clairvest Group Inc. Options Non-Voting Horn, Douglas 5 2019-05-28 50 96.7 8,278 Clairvest Group Inc. Options Non-Voting Horn, Douglas 5 2019-05-28 50 96.7 8,278 8,278 Clairvest Group Inc. Options Non-Voting Isenberg, Robert 7 2016-06-30 50 57.44 11,285 Clairvest Group Inc. Options Non-Voting Isenberg, Robert 7 2016-06-30 50 57.44 11,285 11,285 Clairvest Group Inc. Options Non-Voting Isenberg, Robert 7 2017-06-30 50 72.42 30,574 Clairvest Group Inc. Options Non-Voting Isenberg, Robert 7 2017-06-30 50 72.42 41,859 30,574 Clairvest Group Inc. Options Non-Voting Isenberg, Robert 7 2018-06-30 50 94.02 2,443 Clairvest Group Inc. Options Non-Voting Isenberg, Robert 7 2018-06-30 50 94.02 44,302 2,443 Clairvest Group Inc. Options Non-Voting Isenberg, Robert 7 2019-05-28 50 96.7 8,109 Clairvest Group Inc. Options Non-Voting Isenberg, Robert 7 2019-05-28 50 96.7 52,411 8,109 Clairvest Group Inc. Options Non-Voting Kansal, Mohit 5 2019-05-28 50 96.7 10,348 Clairvest Group Inc. Options Non-Voting Kansal, Mohit 5 2019-05-28 50 96.7 10,348 10,348 Clairvest Group Inc. Options Non-Voting Miller, James 5 2016-06-30 50 57.44 3,642 Clairvest Group Inc. Options Non-Voting Miller, James 5 2016-06-30 50 57.44 3,642 3,642 Clairvest Group Inc. Options Non-Voting Miller, James 5 2017-06-30 50 72.42 1,266 Clairvest Group Inc. Options Non-Voting Miller, James 5 2017-06-30 50 72.42 4,908 1,266 Clairvest Group Inc. Options Non-Voting Miller, James 5 2018-06-30 50 94.02 1,250 Clairvest Group Inc. Options Non-Voting Miller, James 5 2018-06-30 50 94.02 6,158 1,250 Clairvest Group Inc. Options Non-Voting Miller, James 5 2019-05-28 50 96.7 1,250 Clairvest Group Inc. Options Non-Voting Miller, James 5 2019-05-28 50 96.7 7,408 1,250 Clairvest Group Inc. Options Non-Voting Parr, Benjamin Jeffrey 4, 5 2016-06-30 50 57.44 24,102 Clairvest Group Inc. Options Non-Voting Parr, Benjamin Jeffrey 4, 5 2016-06-30 50 57.44 24,102 24,102 Clairvest Group Inc. Options Non-Voting Parr, Benjamin Jeffrey 4, 5 2017-06-30 50 72.42 50,396 Clairvest Group Inc. Options Non-Voting Parr, Benjamin Jeffrey 4, 5 2017-06-30 50 72.42 74,498 50,396 Clairvest Group Inc. Options Non-Voting Pasricha, Adrian 5 2016-06-30 50 57.44 11,600 Clairvest Group Inc. Options Non-Voting Pasricha, Adrian 5 2016-06-30 50 57.44 11,600 11,600

August 8, 2019 (2019), 42 OSCB 6646

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Clairvest Group Inc. Options Non-Voting Pasricha, Adrian 5 2017-06-30 50 72.42 3,250 Clairvest Group Inc. Options Non-Voting Pasricha, Adrian 5 2017-06-30 50 72.42 14,850 3,250 Clairvest Group Inc. Options Non-Voting Pasricha, Adrian 5 2018-06-30 50 94.02 10,592 Clairvest Group Inc. Options Non-Voting Pasricha, Adrian 5 2018-06-30 50 94.02 25,442 10,592 Clairvest Group Inc. Options Non-Voting Pasricha, Adrian 5 2019-05-28 50 96.7 10,144 Clairvest Group Inc. Options Non-Voting Pasricha, Adrian 5 2019-05-28 50 96.7 35,586 10,144 Clairvest Group Inc. Options Non-Voting Wagman, Michael 5 2016-06-30 50 57.44 33,480 Adam Clairvest Group Inc. Options Non-Voting Wagman, Michael 5 2016-06-30 50 57.44 33,480 33,480 Adam Clairvest Group Inc. Options Non-Voting Wagman, Michael 5 2017-06-30 50 72.42 25,345 Adam Clairvest Group Inc. Options Non-Voting Wagman, Michael 5 2017-06-30 50 72.42 58,825 25,345 Adam Clairvest Group Inc. Options Non-Voting Wagman, Michael 5 2018-06-30 50 94.02 11,290 Adam Clairvest Group Inc. Options Non-Voting Wagman, Michael 5 2018-06-30 50 94.02 70,115 11,290 Adam Clairvest Group Inc. Options Non-Voting Wagman, Michael 5 2019-05-28 50 96.7 15,560 Adam Clairvest Group Inc. Options Non-Voting Wagman, Michael 5 2019-05-28 50 96.7 85,675 15,560 Adam Clarke Inc. Common Shares Clarke Inc. 1 2019-07-02 38 13 1,000 1,000 Clarke Inc. Common Shares Clarke Inc. 1 2019-07-04 38 13 1,900 900 Clarke Inc. Common Shares Clarke Inc. 1 2019-07-12 38 13.1 6,900 5,000 Clarke Inc. Common Shares Clarke Inc. 1 2019-07-22 38 13.15 7,900 1,000 Clarke Inc. Common Shares Clarke Inc. 1 2019-07-23 38 13.05 8,900 1,000 Clarke Inc. Common Shares Clarke Inc. 1 2019-07-24 38 13.14 9,900 1,000 Clarke Inc. Common Shares Clarke Inc. 1 2019-07-25 38 13.1 10,900 1,000 Clarke Inc. Common Shares Clarke Inc. 1 2019-07-26 38 13.14 11,900 1,000 Clarke Inc. Common Shares Clarke Inc. 1 2019-07-29 38 13.087 12,900 1,000 Clarke Inc. Common Shares Clarke Inc. 1 2019-07-30 38 13.09 13,200 300 Clarke Inc. Common Shares Clarke Inc. 1 2019-07-31 38 13.2 14,200 1,000 Clarke Inc. Common Shares Clarke Inc. 1 2019-08-01 38 0 -14,200 Clean Seed Capital Common Shares Anderson, Gary Keith 4 2019-07-26 10 0.1732 3,440,667 250,000 Group Ltd. Clean Seed Capital Common Shares Anderson, Gary Keith 4 2019-07-29 10 0.1895 3,690,667 250,000 Group Ltd. Cloud Nine Education Common Shares Lee, Peter 4 2019-08-01 10 0.125 272,000 -15,500 Group Ltd. Co-operators General Preferred Shares Daniel, Kevin 7 2019-07-31 30 100 1,790 1 Insurance Company Class A Series B Co-operators General Preferred Shares Daniel, Kevin 7 2019-08-01 30 100 1,806 16 Insurance Company Class A Series B Co-operators General Preferred Shares Guglietti, Lisa 5 2019-08-01 30 100 2,346 43 Insurance Company Class A Series B Co-operators General Preferred Shares Hanna, Paul 7 2019-07-31 30 100 994 1 Insurance Company Class A Series B Co-operators General Preferred Shares Hanna, Paul 7 2019-08-01 30 100 1,003 9 Insurance Company Class A Series B Co-operators General Preferred Shares Higgins, Karen 5 2019-08-01 30 100 517 2 Insurance Company Class A Series B CO2 GRO Inc. Common Shares GAGE, ROSE MARIE 4 2019-04-29 00 CO2 GRO Inc. Common Shares GAGE, ROSE MARIE 4 2019-04-29 00 CO2 GRO Inc. Common Shares GAGE, ROSE MARIE 4 2019-04-29 00 102,200 CO2 GRO Inc. Common Shares GAGE, ROSE MARIE 4 2019-04-29 00 CO2 GRO Inc. Common Shares GAGE, ROSE MARIE 4 2019-04-29 00 148,000 CO2 GRO Inc. Common Shares GAGE, ROSE MARIE 4 2019-07-25 10 0.32 180,000 32,000 CO2 GRO Inc. Common Shares Gledhill, Stephen Mark 5 2019-07-25 10 0.355 21,741 -8,000 Colabor Group Inc. Common Shares Briscoe, Robert John 3, 4, 5 2019-07-31 51 0.88 4,085,214 500,000

August 8, 2019 (2019), 42 OSCB 6647

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Colabor Group Inc. Common Shares The Article 6 Marital 3 2019-07-31 10 1.014 2,082,723 -467,500 Trust created under the First Amended and Restated Jerry Zucker Revocable Trust dated 4-2-07 Colabor Group Inc. Common Shares The Article 6 Marital 3 2019-08-01 10 1 1,600,323 -482,400 Trust created under the First Amended and Restated Jerry Zucker Revocable Trust dated 4-2-07 Colabor Group Inc. Common Shares The Article 6 Marital 3 2019-08-02 10 1 1,059,460 -540,863 Trust created under the First Amended and Restated Jerry Zucker Revocable Trust dated 4-2-07 Colibri Resource Common Shares McGavney, Ian 5 2019-07-29 10 0.04 585,000 25,000 Corporation COLLIERS Subordinate Voting McLernon, C.R. 2 2019-08-01 10 95.5 77,237 -4,990 INTERNATIONAL Shares GROUP INC. Commerce Resources Common Shares Hodge, David 4, 5 2019-07-31 10 0.045 94,310 -388,215 Corp. Commerce Resources Common Shares Hodge, David 4, 5 2019-07-31 99 0.045 0 -94,310 Corp. Commerce Resources Common Shares Hodge, David 4, 5 2019-07-31 10 0.045 0 -100,000 Corp. Condor Gold plc Ordinary Shares Martin, James Randall 4 2019-07-2900 Condor Gold plc Ordinary Shares Martin, James Randall 4 2019-07-29 11 9,842,520 9,842,520 Condor Gold plc Warrants Martin, James Randall 4 2019-07-29 00 Condor Gold plc Warrants Martin, James Randall 4 2019-07-29 11 0.25 3,280,840 3,280,840 Conifex Timber Inc. Restricted Shares Infanti, Adam 5 2019-07-25 56 235,000 150,000 Conifex Timber Inc. Restricted Shares Lewis, Yuri 7, 5 2019-07-25 56 287,500 175,000 Conifex Timber Inc. Restricted Shares Neeser, Jordan 5 2019-07-25 56 85,000 50,000 Conifex Timber Inc. Restricted Shares Shields, Kenneth A. 4, 5 2019-07-25 56 590,000 400,000 Constellation Software Common Shares Leonard, Mark Henri 4, 5 2019-07-29 30 1277.6 3,900 -100 Inc. Copper Mountain Common Shares Aunger, Bruce William 4 2019-07-30 54 0.75 368,800 50,000 Mining Corporation Copper Mountain Warrants Aunger, Bruce William 4 2019-07-30 54 0.75 0 -50,000 Mining Corporation Copper Mountain Common Shares Renzoni, Carl 4 2019-07-31 54 0.75 330,000 50,000 Mining Corporation Copper Mountain Warrants Renzoni, Carl 4 2019-07-31 54 0.75 0 -50,000 Mining Corporation Copper Mountain Common Shares Shier, Rodney 4 2019-08-01 54 0.75 1,933,400 100,000 Mining Corporation Copper Mountain Warrants Shier, Rodney 4 2019-08-01 54 0.75 0 -100,000 Mining Corporation Covalon Technologies Common Shares Goldfarb Ventures 3 2019-07-22 54 1,020,408 510,204 Ltd. Corp. Covalon Technologies Warrants Goldfarb Ventures 3 2019-07-22 54 0 -510,204 Ltd. Corp. Crest Resources Inc. Warrants Wong, Sandra 5 2019-04-18 00 Crest Resources Inc. Warrants Wong, Sandra 5 2019-07-25 16 0.075 250,000 250,000 Crown Capital Common Shares Crown Capital 1 2019-07-31 10 8.2301 7,500 7,500 Partners Inc. Partners Inc. Crown Capital Common Shares Crown Capital 1 2019-08-02 38 0 -7,500 Partners Inc. Partners Inc. Cuba Ventures Corp. Common Shares Lonis, Bernard Jean 4 2018-02-22 00 Jacques Cuba Ventures Corp. Common Shares Lonis, Bernard Jean 4 2018-02-22 00 Jacques Cuba Ventures Corp. Common Shares Lonis, Bernard Jean 4 2018-02-22 16 0.055 9,000,000 Jacques

August 8, 2019 (2019), 42 OSCB 6648

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Cuba Ventures Corp. Common Shares Lonis, Bernard Jean 4 2018-02-22 16 0.055 15,140,000 9,000,000 Jacques Cuba Ventures Corp. Warrants Lonis, Bernard Jean 4 2018-02-22 00 Jacques Cuba Ventures Corp. Warrants Lonis, Bernard Jean 4 2018-02-22 00 Jacques Cuba Ventures Corp. Warrants Lonis, Bernard Jean 4 2018-02-22 53 0.075 9,000,000 Jacques Cuba Ventures Corp. Warrants Lonis, Bernard Jean 4 2018-02-22 53 0.075 15,140,000 9,000,000 Jacques Cuda Oil and Gas Inc. Common Shares Bushell, Timothy 5 2019-07-30 16 279,862 50,000 (formerly Junex Inc.) Cuda Oil and Gas Inc. Warrants Bushell, Timothy 5 2019-07-30 16 0.6 49,273 25,000 (formerly Junex Inc.) Cuda Oil and Gas Inc. Common Shares Dawson, Alan Scott 4 2019-07-30 16 321,916 200,000 (formerly Junex Inc.) Cuda Oil and Gas Inc. Warrants Dawson, Alan Scott 4 2019-07-30 16 0.6 113,282 100,000 (formerly Junex Inc.) Cuda Oil and Gas Inc. Common Shares DAWSON, ROBERT 4, 5 2019-07-30 16 600000 1,201,078 600,000 (formerly Junex Inc.) GLENN Cuda Oil and Gas Inc. Warrants DAWSON, ROBERT 4, 5 2019-07-30 16 0.6 367,193 300,000 (formerly Junex Inc.) GLENN Cuda Oil and Gas Inc. Common Shares Frommer, Richard Neil 4 2019-07-30 16 238,942 100,000 (formerly Junex Inc.) Cuda Oil and Gas Inc. Warrants Frommer, Richard Neil 4 2019-07-30 16 0.6 66,147 50,000 (formerly Junex Inc.) Cuda Oil and Gas Inc. Common Shares Gutor, Chad 5 2019-07-30 16 200000 251,600 200,000 (formerly Junex Inc.) Cuda Oil and Gas Inc. Warrants Gutor, Chad 5 2019-07-30 16 0.6 166,782 100,000 (formerly Junex Inc.) Cuda Oil and Gas Inc. Common Shares Purvis, Ronald 5 2019-07-30 16 50000 94,820 50,000 (formerly Junex Inc.) Cuda Oil and Gas Inc. Warrants Purvis, Ronald 5 2019-07-30 16 0.6 30,209 25,000 (formerly Junex Inc.) Curaleaf Holdings, Inc. Subordinate Voting Jordan, Boris Alexis 3, 4, 5 2019-07-24 16 7.4 13,400,843 1,900,843 (formerly Lead Shares Ventures Inc.) Curaleaf Holdings, Inc. Subordinate Voting Jordan, Boris Alexis 3, 4, 5 2019-07-24 16 7.4 0 -1,900,843 (formerly Lead Shares Ventures Inc.) CUV Ventures Corp. Common Shares Lonis, Bernard Jean 4 2019-07-10 11 0.13 -4,300,000 Jacques CUV Ventures Corp. Common Shares Lonis, Bernard Jean 4 2018-02-22 00 6,140,000 Jacques CUV Ventures Corp. Common Shares Lonis, Bernard Jean 4 2019-07-10 11 0.13 10,840,000 -4,300,000 Jacques CUV Ventures Corp. Warrants Lonis, Bernard Jean 4 2018-02-22 00 6,140,000 Jacques CUV Ventures Corp. Warrants Lonis, Bernard Jean 4 2019-04-26 11 0.075 6,140,000 -9,000,000 Jacques CUV Ventures Corp. Warrants Lonis, Bernard Jean 4 2019-04-26 11 0.075 1,840,000 -4,300,000 Jacques CUV Ventures Corp. Warrants Lonis, Bernard Jean 4 2019-04-26 11 0.075 0 -1,840,000 Jacques CWC Energy Services Common Shares CWC Energy Services 1 2019-07-29 10 0.145 185,000 5,500 Corp. Corp. CWC Energy Services Common Shares CWC Energy Services 1 2019-07-30 10 0.145 186,000 1,000 Corp. Corp. CWC Energy Services Common Shares CWC Energy Services 1 2019-07-31 10 0.145 199,500 13,500 Corp. Corp. CWC Energy Services Common Shares CWC Energy Services 1 2019-08-01 10 0.145 217,000 17,500 Corp. Corp. DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-25 57 1.8939 4,220,594 3,657 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-25 30 1.8939 4,221,173 579 Shares

August 8, 2019 (2019), 42 OSCB 6649

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 1.9729 4,214,173 -7,000 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 1.9605 4,211,269 -2,904 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 1.96 4,206,871 -4,398 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 1.9737 4,199,569 -7,302 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 1.97 4,196,169 -3,400 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 1.98 4,190,869 -5,300 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 1.99 4,186,354 -4,515 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 2.0129 4,186,154 -200 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 1.9802 4,185,954 -200 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 2.0002 4,181,169 -4,785 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 2.02 4,180,769 -400 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 2 4,178,569 -2,200 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 2.03 4,164,617 -13,952 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 2.0001 4,158,417 -6,200 Shares DHX Media Ltd. Common Voting Donovan, Michael 4 2019-07-29 10 2.0067 4,157,917 -500 Shares DHX Media Ltd. Rights Performance Donovan, Michael 4 2019-06-30 58 - Expiration of rights 7,123 Share Units (Common Voting) DHX Media Ltd. Rights Performance Donovan, Michael 4 2019-07-25 57 1.8939 0 -7,123 Share Units (Common Voting) DHX Media Ltd. Common Voting Gosine, Mark Gregory 5 2019-07-25 57 1.8939 69,859 1,482 Shares DHX Media Ltd. Common Voting Gosine, Mark Gregory 5 2019-07-25 30 1.8939 70,149 290 Shares DHX Media Ltd. Rights Performance Gosine, Mark Gregory 5 2019-06-30 58 - Expiration of rights 3,562 Share Units (Common Voting) DHX Media Ltd. Rights Performance Gosine, Mark Gregory 5 2019-07-25 57 1.8939 0 -3,562 Share Units (Common Voting) DHX Media Ltd. Common Voting Loi, Anne H. 5 2019-07-25 57 1.8939 218,235 1,500 Shares DHX Media Ltd. Common Voting Loi, Anne H. 5 2019-07-25 30 1.8939 218,525 290 Shares DHX Media Ltd. Rights Performance Loi, Anne H. 5 2019-07-25 57 1.8939 0 -3,562 Share Units (Common Voting) DHX Media Ltd. Common Voting Regan, David A. 5 2019-07-25 57 1.8939 92,901 1,482 Shares DHX Media Ltd. Common Voting Regan, David A. 5 2019-07-25 30 1.8939 93,191 290 Shares DHX Media Ltd. Rights Performance Regan, David A. 5 2019-06-30 58 - Expiration of rights 3,562 Share Units (Common Voting) DHX Media Ltd. Rights Performance Regan, David A. 5 2019-07-25 57 1.8939 0 -3,562 Share Units (Common Voting) DHX Media Ltd. Common Voting Scherba, Joshua 5 2019-07-25 57 1.8939 91,254 1,500 Shares Charles DHX Media Ltd. Common Voting Scherba, Joshua 5 2019-07-25 30 1.8939 91,544 290 Shares Charles

August 8, 2019 (2019), 42 OSCB 6650

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed DHX Media Ltd. Rights Performance Scherba, Joshua 5 2019-07-25 57 1.8939 0 -3,562 Share Units (Common Charles Voting) DHX Media Ltd. Common Voting Tedesco, Joseph 5 2019-07-25 57 1.8939 5,862 1,500 Shares DHX Media Ltd. Common Voting Tedesco, Joseph 5 2019-07-25 30 1.8939 6,152 290 Shares DHX Media Ltd. Rights Performance Tedesco, Joseph 5 2019-06-30 58 - Expiration of rights 3,562 Share Units (Common Voting) DHX Media Ltd. Rights Performance Tedesco, Joseph 5 2019-07-25 57 1.8939 0 -3,562 Share Units (Common Voting) Diamond Estates Common Shares Lassonde Industries 3 2019-07-29 00 36,900,000 Wines & Spirits Inc. Inc. Diamond Fields Common Shares Gourley, Albert Carlisle 4 2019-07-25 10 0.155 1,675,000 10,500 Resources Inc. Diamond Fields Common Shares Gourley, Albert Carlisle 4 2019-07-31 10 0.165 1,676,000 1,000 Resources Inc. Diamond Fields Common Shares Gourley, Albert Carlisle 4 2019-07-31 10 0.17 1,696,000 20,000 Resources Inc. Diamond Fields Common Shares Gourley, Albert Carlisle 4 2019-07-31 10 0.17 1,896,000 200,000 Resources Inc. Digital Consumer Trust Units Brasseur, Jeremy 6 2019-07-29 10 9.85 22,500 500 Dividend Fund Digital Consumer Trust Units Brasseur, Jeremy 6 2019-07-30 10 9.85 23,500 1,000 Dividend Fund Digital Consumer Trust Units Digital Consumer 1 2019-07-29 00 Dividend Fund Dividend Fund Digital Consumer Trust Units Digital Consumer 1 2019-07-29 38 9.8528 1,800 1,800 Dividend Fund Dividend Fund Digital Consumer Trust Units Digital Consumer 1 2019-07-30 38 9.8038 6,000 4,200 Dividend Fund Dividend Fund DionyMed Brands Inc. Series F Compressed Fields, Daniel 3 2019-07-25 97 1,039 -85 (formerly Sixonine Shares Raymond Fields Ventures Corp.) Diversified Royalty Common Shares Ciampi, Johnny 4 2019-07-31 90 2.89 0 -10,700 Corp. Diversified Royalty Common Shares Ciampi, Johnny 4 2019-07-31 90 2.89 37,500 10,700 Corp. Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-02 38 23.724 85,014 37,757 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-03 38 24.291 320,914 283,157 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-04 38 283,157 -37,757 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-04 38 24.59 308,314 25,157 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-05 38 25,157 -283,157 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-05 38 24.441 73,414 48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-08 38 48,257 -25,157 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-08 38 24.48 96,514 48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-09 38 48,257 -48,257 Estate Investment Estate Investment Trust Trust

August 8, 2019 (2019), 42 OSCB 6651

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-09 38 24.553 87,614 39,357 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-10 38 39,357 -48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-10 38 24.478 87,614 48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-11 38 48,257 -39,357 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-11 38 24.548 91,414 43,157 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-12 38 43,157 -48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-12 38 24.57 345,714 302,557 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-15 38 302,557 -43,157 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-15 38 24.194 350,814 48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-16 38 48,257 -302,557 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-16 38 24.079 88,314 40,057 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-17 38 40,057 -48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-17 38 24.238 153,407 113,350 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-18 38 113,350 -40,057 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-18 38 24.334 161,607 48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-19 38 48,257 -113,350 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-19 38 24.2 96,514 48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-22 38 48,257 -48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-22 38 24.172 95,114 46,857 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-23 38 46,857 -48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-23 38 24.315 95,114 48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-24 38 48,257 -46,857 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-24 38 24.41 96,514 48,257 Estate Investment Estate Investment Trust Trust

August 8, 2019 (2019), 42 OSCB 6652

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-25 38 48,257 -48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-25 38 24.25 256,014 207,757 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-26 38 207,757 -48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-26 38 24.322 256,014 48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-29 38 48,257 -207,757 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-29 38 24.455 96,514 48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-30 38 48,257 -48,257 Estate Investment Estate Investment Trust Trust Dream Office Real Trust Units Series A Dream Office Real 1 2019-07-31 38 0 -48,257 Estate Investment Estate Investment Trust Trust EarthRenew Inc. Options Best, Christopher 4 2019-07-08 00 (Formerly known as William Valencia Ventures Inc.) EarthRenew Inc. Options Best, Christopher 4 2019-07-08 50 0.1 200,000 200,000 (Formerly known as William Valencia Ventures Inc.) East Coast Investment Units Arrow Capital 7 2019-07-29 10 9.3356 991,300 -7,500 Grade Income Fund Management Inc. East Coast Investment Units Arrow Capital 7 2019-07-30 10 9.4 991,200 -100 Grade Income Fund Management Inc. East Coast Investment Units Arrow Capital 7 2019-07-31 10 9.4 985,000 -6,200 Grade Income Fund Management Inc. Electrovaya Inc. Options Hansson, Carolyn 4 2019-07-31 50 0.3 70,000 30,000 Mary Electrovaya Inc. Options McLean, Alexander 4 2019-07-31 50 0.3 139,000 30,000 Emerald Bay Energy Common Shares Rice, Michael 5 2019-07-29 10 0.015 8,495,500 4,940,000 Inc. Empire Company Non-Voting Shares Gagne, Simon 5 2019-07-29 57 14,043 2,321 Limited Class A Empire Company Non-Voting Shares Gagne, Simon 5 2019-07-30 51 34,586 20,543 Limited Class A Empire Company Non-Voting Shares Gagne, Simon 5 2019-07-30 10 35.1 34,286 -300 Limited Class A Empire Company Non-Voting Shares Gagne, Simon 5 2019-07-30 10 35.11 34,086 -200 Limited Class A Empire Company Non-Voting Shares Gagne, Simon 5 2019-07-30 10 35.12 23,486 -10,600 Limited Class A Empire Company Non-Voting Shares Gagne, Simon 5 2019-07-30 10 35.15 19,786 -3,700 Limited Class A Empire Company Non-Voting Shares Gagne, Simon 5 2019-07-30 10 35.2 14,986 -4,800 Limited Class A Empire Company Non-Voting Shares Gagne, Simon 5 2019-07-30 10 35.21 14,786 -200 Limited Class A Empire Company Non-Voting Shares Gagne, Simon 5 2019-07-30 10 35.22 14,186 -600 Limited Class A Empire Company Non-Voting Shares Gagne, Simon 5 2019-07-30 10 35.17 14,043 -143 Limited Class A Empire Company Options Gagne, Simon 5 2019-07-30 51 373,347 -41,550 Limited Empire Company Options Gagne, Simon 5 2019-07-30 51 331,797 -41,550 Limited Empire Company Rights DSU (Executive Gagne, Simon 5 2019-06-27 58 - Expiration of rights -3,605 Limited Deferred Share Units)

August 8, 2019 (2019), 42 OSCB 6653

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Empire Company Rights DSU (Executive Gagne, Simon 5 2019-06-27 58 - Expiration of rights -3,605 Limited Deferred Share Units) Empire Company Rights DSU (Executive Gagne, Simon 5 2019-06-27 58 - Expiration of rights 51,298 Limited Deferred Share Units) Empire Company Rights PSU Gagne, Simon 5 2019-07-29 57 4,750 -4,751 Limited (Performance Share Units) Empire Company Rights DSU (Executive Medline, Michael 4, 5 2019-06-27 58 - Expiration of rights 215,371 Limited Deferred Share Units) Bennett Empire Company Rights DSU (Executive Sood, Vivek 5 2019-06-27 58 - Expiration of rights 38,837 Limited Deferred Share Units) Empire Company Rights DSU (Executive St-Laurent, Pierre 5 2019-06-27 58 - Expiration of rights 53,295 Limited Deferred Share Units) Encana Corporation Common Shares Mayson, Howard John 4 2019-08-01 10 4.495 50,488 5,000 Endeavour Mining Performance Share Irvine, Louis 5 2019-08-01 00 127,280 Corporation Units Endeavour Mining Deferred Share Units Morcombe, Mark Keith 5 2019-05-06 00 Corporation (Cash payment on Redemption) Endeavour Mining Deferred Share Units Morcombe, Mark Keith 5 2019-05-06 00 Corporation (Cash payment on Redemption) Endeavour Mining Performance Share Morcombe, Mark Keith 5 2019-05-06 00 Corporation Units Endeavour Mining Performance Share Morcombe, Mark Keith 5 2019-05-06 00 71,315 Corporation Units Endeavour Silver Common Shares Castro, Luis Renato 5 2019-07-19 51 2.65 175,000 150,000 Corp. Endeavour Silver Common Shares Castro, Luis Renato 5 2019-07-19 10 3.0633 100,000 -75,000 Corp. Endeavour Silver Common Shares Castro, Luis Renato 5 2019-07-22 10 3.1974 25,000 -75,000 Corp. Endeavour Silver Options Castro, Luis Renato 5 2019-07-19 51 2.65 504,000 -150,000 Corp. Enterprise Group, Inc. Common Shares Enterprise Group, Inc. 1 2019-07-10 38 0.17 5,000 5,000 Enterprise Group, Inc. Common Shares Enterprise Group, Inc. 1 2019-07-10 38 0.17 9,000 4,000 Enterprise Group, Inc. Common Shares Enterprise Group, Inc. 1 2019-07-10 38 0.17 4,000 -5,000 Enterprise Group, Inc. Common Shares Enterprise Group, Inc. 1 2019-07-10 38 0.17 0 -4,000 Enterprise Group, Inc. Common Shares Enterprise Group, Inc. 1 2019-07-19 38 0.165 9,000 9,000 Enterprise Group, Inc. Common Shares Enterprise Group, Inc. 1 2019-07-19 38 0.165 0 -9,000 Enterprise Group, Inc. Common Shares Enterprise Group, Inc. 1 2019-07-29 38 0.17 3,500 3,500 Enterprise Group, Inc. Common Shares Enterprise Group, Inc. 1 2019-07-29 38 0.17 0 -3,500 Epsilon Energy Ltd. Common Shares Epsilon Energy Ltd. 1 2019-07-29 38 3.8399 292,301 25,100 EQ Inc. Options Hill, Paul 4 2019-08-01 50 0.72 150,000 75,000 Equinox Gold Corp. Options Breen, Timothy 4 2019-08-01 00 (formerly Trek Mining Graham Inc.) Equinox Gold Corp. Options Breen, Timothy 4 2019-08-01 50 1.3 54,545 54,545 (formerly Trek Mining Graham Inc.) Equinox Gold Corp. Rights Restricted Breen, Timothy 4 2019-08-01 00 (formerly Trek Mining Share Units - Time Graham Inc.) Based Equinox Gold Corp. Rights Restricted Breen, Timothy 4 2019-08-01 56 30,000 30,000 (formerly Trek Mining Share Units - Time Graham Inc.) Based Equitable Group Inc. Common Shares Braude, Aviva 7 2019-08-01 51 36.11 1,069 Equitable Group Inc. Common Shares Braude, Aviva 7 2019-08-01 51 36.11 1,069 Equitable Group Inc. Common Shares Braude, Aviva 7 2019-08-01 10 91.33 -1,069 Equitable Group Inc. Common Shares Braude, Aviva 7 2019-08-01 10 91.33 -1,069 Equitable Group Inc. Common Shares Braude, Aviva 7 2019-08-01 51 36.11 3,068 1,069 Equitable Group Inc. Common Shares Braude, Aviva 7 2019-08-01 10 91.33 1,999 -1,069 Equitable Group Inc. Options Options Braude, Aviva 7 2019-08-01 51 36.11 -1,069 granted Equitable Group Inc. Options Options Braude, Aviva 7 2019-08-01 51 36.11 -1,069 granted

August 8, 2019 (2019), 42 OSCB 6654

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Equitable Group Inc. Options Options Braude, Aviva 7 2019-08-01 51 36.11 -1,069 granted Equitable Group Inc. Options Options Braude, Aviva 7 2019-08-01 51 36.11 -1,069 granted Equitable Group Inc. Options Options Braude, Aviva 7 2019-08-01 51 36.11 9,348 -1,069 granted Equitable Group Inc. Common Shares Farella, Isabelle 5 2019-08-01 51 71.68 1,846 697 Equitable Group Inc. Common Shares Farella, Isabelle 5 2019-08-01 10 91.24 1,149 -697 Equitable Group Inc. Options Options Farella, Isabelle 5 2019-08-01 51 71.68 4,606 -697 granted Equitable Group Inc. Common Shares Kukulowicz, Kimberly 7 2019-08-01 51 53.07 4,422 Equitable Group Inc. Common Shares Kukulowicz, Kimberly 7 2019-08-01 51 53.07 4,422 Equitable Group Inc. Common Shares Kukulowicz, Kimberly 7 2019-08-01 10 90.9 -3,359 -4,422 Equitable Group Inc. Common Shares Kukulowicz, Kimberly 7 2019-08-01 51 52.9 -1,147 2,212 Equitable Group Inc. Common Shares Kukulowicz, Kimberly 7 2019-08-01 51 53.15 1,063 2,210 Equitable Group Inc. Options Options Kukulowicz, Kimberly 7 2019-08-01 51 52.9 13,731 -2,212 granted Equitable Group Inc. Options Options Kukulowicz, Kimberly 7 2019-08-01 51 53.15 11,521 -2,210 granted Equitable Group Inc. Common Shares Mignardi, Michael Paul 7, 5 2019-08-01 51 53.15 1,266 973 Equitable Group Inc. Common Shares Mignardi, Michael Paul 7, 5 2019-08-01 10 91.46 293 -973 Equitable Group Inc. Options Options Mignardi, Michael Paul 7, 5 2019-08-01 51 53.15 6,919 -973 granted Equitable Group Inc. Common Shares Wilson, Timothy 5 2019-08-01 51 36.11 25,540 2,000 James Equitable Group Inc. Common Shares Wilson, Timothy 5 2019-08-01 10 90.62 23,540 -2,000 James Equitable Group Inc. Options Options Wilson, Timothy 5 2019-08-01 51 36.11 50,181 -2,000 granted James European Focused Trust Units European Focused 1 2019-07-25 38 8.0236 964,800 4,400 Dividend Fund Dividend Fund European Focused Trust Units European Focused 1 2019-08-01 38 8.05 965,400 600 Dividend Fund Dividend Fund Experion Holdings Ltd. Common Shares Echino, Deni Mario 4 2019-07-26 10 0.215 448,583 1,500 (formerly Viridium Pacific Group Ltd.) Experion Holdings Ltd. Common Shares Echino, Deni Mario 4 2019-07-29 10 0.215 548,583 100,000 (formerly Viridium Pacific Group Ltd.) Experion Holdings Ltd. Common Shares Ironclad Projects Inc. 4 2019-07-01 00 (formerly Viridium Pacific Group Ltd.) Experion Holdings Ltd. Common Shares Ironclad Projects Inc. 4 2019-07-30 10 0.215 100,000 (formerly Viridium Pacific Group Ltd.) Experion Holdings Ltd. Common Shares Ironclad Projects Inc. 4 2019-07-30 10 0.215 70,000 70,000 (formerly Viridium Pacific Group Ltd.) Falcon Gold Corp. Common Shares Farley, James Donald 4 2019-07-26 10 0.045 1,787,400 50,000 First Majestic Silver Rights Restricted SHAW, DAVID 4 2005-01-12 00 Corp. Share Units ANDREW First Majestic Silver Rights Restricted SHAW, DAVID 4 2019-07-24 56 10.32 5,000 5,000 Corp. Share Units ANDREW First Quantum Common Shares Meyer, Hannes 5 2019-07-10 57 11.55 7,459 Minerals Ltd First Quantum Common Shares Meyer, Hannes 5 2019-07-10 57 11.55 73,425 10,767 Minerals Ltd FIRSTSERVICE Common Shares Natale, Michael 7 2019-07-29 10 138.5 4,500 -500 CORPORATION Fortress Global Common Shares Class Wasilenkoff, Chadwick 3 2019-07-29 10 0.45 2,110,802 -213,500 Enterprises Inc. A voting without par James (formerly Fortress value Paper Ltd.) Fortress Global Common Shares Class Wasilenkoff, Chadwick 3 2019-07-31 10 0.445 2,105,302 -5,500 Enterprises Inc. A voting without par James (formerly Fortress value Paper Ltd.)

August 8, 2019 (2019), 42 OSCB 6655

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Frankly Inc. (formerly Common Shares Gray Television, Inc. 3 2019-07-26 10 0 -547,325 WB III Acquisition Corp.) Frankly Inc. (formerly Warrants Gray Television, Inc. 3 2019-07-26 10 0 -871,160 WB III Acquisition Corp.) Frankly Inc. (formerly Common Shares Raycom Media, Inc. 3 2019-07-26 10 0 -547,325 WB III Acquisition Corp.) Frankly Inc. (formerly Warrants Raycom Media, Inc. 3 2019-07-26 10 0 -871,160 WB III Acquisition Corp.) Gabriella's Kitchen Inc. Common Shares Corriente Master Fund 3 2019-07-29 10 0.373 16,018,717 483,000 II, LP Gabriella's Kitchen Inc. Common Shares Corriente Master Fund 3 2019-07-30 10 0.38 16,500,217 481,500 II, LP Gabriella's Kitchen Inc. Common Shares Corriente Master Fund 3 2019-07-31 10 0.35 16,503,717 3,500 II, LP Gabriella's Kitchen Inc. Common Shares Corriente Master Fund 3 2019-08-01 10 0.36 16,530,217 26,500 II, LP Gaia Grow Corp. Common Shares Lowenstein, Marc 4 2019-07-23 00 170,000 (formerly "Spirit Bear Adam Capital Corp") Gaia Grow Corp. Common Shares Pels, Frederick 4 2019-07-23 00 (formerly "Spirit Bear Capital Corp") Gaia Grow Corp. Common Shares Pels, Frederick 4 2019-07-23 00 (formerly "Spirit Bear Capital Corp") Gaia Grow Corp. Common Shares Pels, Frederick 4 2019-07-23 00 (formerly "Spirit Bear Capital Corp") Gaia Grow Corp. Common Shares Pels, Frederick 4 2019-07-23 00 38,823,529 (formerly "Spirit Bear Capital Corp") Galway Metals Inc. Common Shares Hinchcliffe, Robert 3, 4, 5 2019-08-01 10 0.305 12,505,119 15,000 Gatekeeper Systems Options Chin, Kelsey 4, 5 2019-07-31 50 0.12 600,000 100,000 Inc. Gatekeeper Systems Options Dyment, Douglas 3, 5 2019-07-31 50 0.12 2,500,000 500,000 Inc. Gatekeeper Systems Options Fraser, Douglas 5 2019-07-31 50 0.12 400,000 100,000 Inc. Gatekeeper Systems Options Gruban, Jeffrey Alan 5 2019-03-22 00 Inc. Gatekeeper Systems Options Gruban, Jeffrey Alan 5 2019-07-31 50 100,000 100,000 Inc. Genesis Metals Corp Common Shares Sundar, Jeffrey Rohit 4, 5 2019-07-29 10 0.075 1,849,500 5,000 (formerly Entourage Metals Ltd.) Genesis Metals Corp Common Shares Sundar, Jeffrey Rohit 4, 5 2019-08-01 10 0.065 1,854,500 5,000 (formerly Entourage Metals Ltd.) Genesis Metals Corp Common Shares Sundar, Jeffrey Rohit 4, 5 2019-08-02 10 0.065 1,859,500 5,000 (formerly Entourage Metals Ltd.) George Weston Common Shares Currie, Gordon Andrew 5 2019-08-01 51 73.73 31,815 11,537 Limited McDonald George Weston Common Shares Currie, Gordon Andrew 5 2019-08-01 10 106.62 20,278 -11,537 Limited McDonald George Weston Options Currie, Gordon Andrew 5 2019-08-01 51 73.73 242,776 -11,537 Limited McDonald GFG Resources Inc. Options Booth, Brian 4 2019-08-01 00 GFG Resources Inc. Options Booth, Brian 4 2019-08-01 50 0.22 178,048 178,048 Gitennes Exploration Common Shares booth, kenneth david 4, 5 2019-07-31 10 0.035 3,720,000 25,000 Inc. Global Battery Metals Warrants Brown, Gary Duncan 4 2019-05-18 55 300,000 -109,375 Ltd. (formerly, Redzone Resources Ltd.)

August 8, 2019 (2019), 42 OSCB 6656

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Global Innovation Trust Units Global Innovation 1 2019-07-29 38 10.26 880,300 100 Dividend Fund Dividend Fund Global Innovation Trust Units Global Innovation 1 2019-07-30 38 10.266 882,700 2,400 Dividend Fund Dividend Fund Global Innovation Trust Units Global Innovation 1 2019-08-01 38 10.238 884,800 2,100 Dividend Fund Dividend Fund Global Real Estate & Trust Units Global Real Estate & 1 2019-07-25 38 10.52 320,400 1,300 E-Commerce Dividend E-Commerce Dividend Fund Fund Global Real Estate & Trust Units Global Real Estate & 1 2019-07-26 38 10.498 323,700 3,300 E-Commerce Dividend E-Commerce Dividend Fund Fund Global Real Estate & Trust Units Global Real Estate & 1 2019-07-29 38 10.5 324,500 800 E-Commerce Dividend E-Commerce Dividend Fund Fund GlobeX Data Ltd. Common Shares Ghiai Chamlou, Alain 4, 5 2019-07-29 10 0.25 28,927,001 2,000 Mehdi goeasy Ltd. (formerly, Restricted Share Unit Anzini, Sabrina 5 2019-07-12 56 53.02 6,778 39 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Appel, David Harry 4 2019-07-12 56 53.02 62,839 365 easyhome Ltd.) Plan goeasy Ltd. (formerly, Deferred Share Unit Appel, David Harry 4 2019-07-31 56 54.2 62,900 61 easyhome Ltd.) Plan goeasy Ltd. (formerly, Restricted Share Unit Appel, Jason 5 2019-07-12 56 53.02 14,598 84 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Basian, Karen 4 2019-07-12 56 53.02 21,406 124 easyhome Ltd.) Plan goeasy Ltd. (formerly, Deferred Share Unit Basian, Karen 4 2019-07-31 56 54.2 21,467 61 easyhome Ltd.) Plan goeasy Ltd. (formerly, Restricted Share Unit Cooper, David Thomas 4 2019-07-12 56 53.02 6,699 38 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Doniz, Susan 4 2019-07-12 56 53.02 4,174 24 easyhome Ltd.) Plan goeasy Ltd. (formerly, Deferred Share Unit Doniz, Susan 4 2019-07-31 56 54.2 4,235 61 easyhome Ltd.) Plan goeasy Ltd. (formerly, Restricted Share Unit Fiederer, Andrea 5 2019-07-12 56 53.02 24,254 142 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Ingram, David 4, 5 2019-07-12 56 53.02 314 easyhome Ltd.) Plan goeasy Ltd. (formerly, Deferred Share Unit Ingram, David 4, 5 2019-07-12 56 53.02 46,049 268 easyhome Ltd.) Plan goeasy Ltd. (formerly, Restricted Share Unit Ingram, David 4, 5 2019-07-12 56 53.02 68,762 400 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Johnson, Donald 3, 4 2019-07-12 56 53.02 71,569 416 easyhome Ltd.) Plan Kenneth goeasy Ltd. (formerly, Deferred Share Unit Johnson, Donald 3, 4 2019-07-31 56 54.2 71,630 61 easyhome Ltd.) Plan Kenneth goeasy Ltd. (formerly, Restricted Share Unit Khatib, Shadi 5 2019-07-12 56 53.02 14,064 82 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Morrison, Sean 4 2019-07-12 56 53.02 8,555 50 easyhome Ltd.) Plan goeasy Ltd. (formerly, Deferred Share Unit Morrison, Sean 4 2019-07-31 56 54.2 8,616 61 easyhome Ltd.) Plan goeasy Ltd. (formerly, Restricted Share Unit Mullins, Jason 5 2019-07-12 56 53.02 70,019 405 easyhome Ltd.) goeasy Ltd. (formerly, Restricted Share Unit Pennell, Shane 5 2019-07-12 56 53.02 11,192 65 easyhome Ltd.) goeasy Ltd. (formerly, Restricted Share Unit Poole, Steven Donald 5 2019-07-12 56 53.02 8,827 49 easyhome Ltd.) goeasy Ltd. (formerly, Deferred Share Unit Thomson, David J. 4 2019-07-12 56 53.02 26,333 153 easyhome Ltd.) Plan goeasy Ltd. (formerly, Deferred Share Unit Thomson, David J. 4 2019-07-31 56 54.2 26,394 61 easyhome Ltd.) Plan goeasy Ltd. (formerly, Restricted Share Unit Yeilding, David 5 2019-07-12 56 53.02 12,377 73 easyhome Ltd.) Gold Standard Common Shares Awde, Jonathan 4, 6, 5 2019-07-31 15 1.22 877,194 82,000 Ventures Corp. Charles Timothy

August 8, 2019 (2019), 42 OSCB 6657

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Golden Leaf Holdings Common Shares Millar, Phillip 7 2017-10-27 00 Ltd. Golden Leaf Holdings Common Shares Millar, Phillip 7 2017-10-27 00 Ltd. Golden Leaf Holdings Common Shares Millar, Phillip 7 2017-10-27 00 23,471,420 Ltd. Goldgroup Mining Inc. Warrants Reyes, Javier 4 2019-07-15 55 0 -3,500,000 GoldMining Inc. Common Shares Dhaliwal, Herb 4 2019-07-25 10 1 40,400 -9,600 (formerly Brazil Resources Inc.) GoldMining Inc. Common Shares Dhaliwal, Herb 4 2019-07-25 10 0.99 30,000 -10,400 (formerly Brazil Resources Inc.) Goldmoney Inc. Common Shares Fray, steve 5 2019-07-24 10 2.5 21,657 -2,500 (formerly BitGold Inc.) Goldspot Discoveries Common Shares Inwentash, Sheldon 6 2019-07-26 10 0.3 13,250,323 50,000 Corp. (formerly, Duckworth Capital Corp.) Goldspot Discoveries Common Shares Inwentash, Sheldon 6 2019-07-31 10 0.29 13,260,323 10,000 Corp. (formerly, Duckworth Capital Corp.) Goldspot Discoveries Common Shares Inwentash, Sheldon 6 2019-08-01 10 0.283 13,312,823 52,500 Corp. (formerly, Duckworth Capital Corp.) Goldspot Discoveries Common Shares ThreeD Capital Inc. 3 2019-07-26 10 0.3 13,250,323 50,000 Corp. (formerly, Duckworth Capital Corp.) Goldspot Discoveries Common Shares ThreeD Capital Inc. 3 2019-07-31 10 0.29 13,260,323 10,000 Corp. (formerly, Duckworth Capital Corp.) Goldspot Discoveries Common Shares ThreeD Capital Inc. 3 2019-08-01 10 0.283 13,312,823 52,500 Corp. (formerly, Duckworth Capital Corp.) Gran Colombia Gold Options Davies, Michael 5 2019-07-21 52 27.6 405,000 -4,000 Corp. Monier Gran Colombia Gold 2024 Gold-Linked De La Campa, Miguel 4, 5 2019-07-31 38 1 -$51,789 Corp. Notes Angel Gran Colombia Gold 2024 Gold-Linked De La Campa, Miguel 4, 5 2019-07-31 38 1 $782,140 -$51,789 Corp. Notes Angel Gran Colombia Gold Options De La Campa, Miguel 4, 5 2019-07-21 55 27.6 -6,000 Corp. Angel Gran Colombia Gold Options De La Campa, Miguel 4, 5 2019-07-21 52 27.6 171,666 -6,000 Corp. Angel Gran Colombia Gold Warrants Gran Colombia Gold 1 2019-07-31 38 2.3503 61,000 61,000 Corp. Corp. Gran Colombia Gold 2024 Gold-Linked Iacono, Serafino 4, 5 2019-07-31 38 1 $6,801,502 -$450,355 Corp. Notes Gran Colombia Gold Options Iacono, Serafino 4, 5 2019-07-21 52 27.6 171,666 -6,000 Corp. Gran Colombia Gold Options Martinez, Hernan 4 2019-07-21 55 27.6 -3,000 Corp. Gran Colombia Gold Options Martinez, Hernan 4 2019-07-21 52 27.6 107,100 -3,000 Corp. Gran Colombia Gold Options Metcalfe, Robert 4 2019-07-21 52 27.6 150,000 -3,000 Corp. Gran Colombia Gold Options NOGUERA, JOSE 5 2019-07-21 55 27.6 -1,000 Corp. Gran Colombia Gold Options NOGUERA, JOSE 5 2019-07-21 52 27.6 122,500 -1,000 Corp. Gran Colombia Gold Common Shares Paredes Arenas, 5 2019-07-23 51 3.16 76,000 76,000 Corp. Lombardo Gran Colombia Gold Common Shares Paredes Arenas, 5 2019-07-23 10 4.9489 40,800 -35,200 Corp. Lombardo

August 8, 2019 (2019), 42 OSCB 6658

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Gran Colombia Gold Common Shares Paredes Arenas, 5 2019-07-24 10 4.9762 200 -40,600 Corp. Lombardo Gran Colombia Gold Common Shares Paredes Arenas, 5 2019-07-25 10 4.91 0 -200 Corp. Lombardo Gran Colombia Gold Options Paredes Arenas, 5 2019-07-21 52 27.6 320,000 -6,000 Corp. Lombardo Gran Colombia Gold Options Paredes Arenas, 5 2019-07-23 51 3.16 244,000 -76,000 Corp. Lombardo Gran Colombia Gold 2024 Gold-Linked Perez, Jaime 4 2019-07-31 38 1 $117,208 -$7,761 Corp. Notes Gran Colombia Gold Options Perez, Jaime 4 2019-07-21 52 27.6 150,000 -6,000 Corp. Great Bear Resources Common Shares Scott, Robert James 5 2019-08-01 54 0.35 363,982 38,500 Ltd. Great Bear Resources Warrants Scott, Robert James 5 2019-08-01 54 0.35 42,241 -38,500 Ltd. Great-West Lifeco Inc. Deferred Share Units Bolotin, Andra Sloane 7 2019-06-03 56 31.42 43,384 31,827 Green 2 Blue Energy Common Shares CM-Equity AG 4 2018-12-19 00 Corp. Green 2 Blue Energy Common Shares CM-Equity AG 4 2019-07-25 16 0.05 800,000 800,000 Corp. Green 2 Blue Energy Warrants CM-Equity AG 4 2018-12-19 00 Corp. Green 2 Blue Energy Warrants CM-Equity AG 4 2019-07-25 16 0.1 400,000 400,000 Corp. Grown Rogue Common Shares Strickler, J. Obie 3, 4, 5 2019-07-26 10 0.25 28,677,766 4,000 International Inc. Gungnir Resources Common Shares Robbins, Christopher 4 2019-07-26 11 1,377,084 -44,143 Inc. Charles H-SOURCE Common Shares Hubbes, Martin 4 2019-07-26 10 0.05 1,427,712 100,000 HOLDINGS LTD. H-SOURCE Common Shares Hubbes, Martin 4 2019-07-29 10 0.04 1,444,712 17,000 HOLDINGS LTD. Hammond Power Options Plan July 22 Baldwin, Douglas 4 2019-07-31 52 13.64 45,000 -5,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 Baldwin, Douglas 4 2019-07-31 52 10.55 35,000 -10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 Baldwin, Douglas 4 2019-07-31 52 11.7 25,000 -10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 Baldwin, Douglas 4 2019-07-31 52 9.74 15,000 -10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 David, FitzGibbon 4 2019-07-31 52 11.7 40,000 -10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 David, FitzGibbon 4 2019-07-31 52 9.74 30,000 -10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 GRANOVSKY, 4 2019-07-31 52 9.74 30,000 -10,000 Solutions Inc. 2005 DAHRA Hammond Power Options Plan July 22 HAMMOND, BILL 6 2019-07-31 52 13.64 189,500 -15,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 HAMMOND, BILL 6 2019-07-31 52 5.91 179,500 -10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 HAMMOND, BILL 6 2019-07-31 52 10.55 149,500 -30,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 HAMMOND, BILL 6 2019-07-31 52 11.7 119,500 -30,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 HAMMOND, BILL 6 2019-07-31 52 9.74 90,000 -29,500 Solutions Inc. 2005 Hammond Power Common Shares Class HUETHER, CHRIS 5 2019-07-25 51 6.62 22,353 10,000 Solutions Inc. A Hammond Power Options Plan July 22 HUETHER, CHRIS 5 2019-07-25 10 6.62 10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 HUETHER, CHRIS 5 2019-07-25 10 6.62 10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 HUETHER, CHRIS 5 2019-07-25 10 6.62 10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 HUETHER, CHRIS 5 2019-07-31 52 13.64 144,500 -7,500 Solutions Inc. 2005

August 8, 2019 (2019), 42 OSCB 6659

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Hammond Power Options Plan July 22 HUETHER, CHRIS 5 2019-07-31 52 5.91 139,500 -5,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 HUETHER, CHRIS 5 2019-07-31 52 10.55 109,500 -30,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 HUETHER, CHRIS 5 2019-07-31 52 11.7 79,500 -30,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 HUETHER, CHRIS 5 2019-07-31 52 9.74 50,000 -29,500 Solutions Inc. 2005 Hammond Power Options Plan July 22 MACADAM, DON 4 2019-07-31 52 13.64 65,000 -5,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 MACADAM, DON 4 2019-07-31 52 5.91 60,000 -5,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 MACADAM, DON 4 2019-07-31 52 10.55 50,000 -10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 MACADAM, DON 4 2019-07-31 52 11.7 40,000 -10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 MACADAM, DON 4 2019-07-31 52 9.74 30,000 -10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 Robinson, Grant 4 2019-07-31 52 13.64 65,000 -10,000 Solutions Inc. 2005 Cameron Hammond Power Options Plan July 22 Robinson, Grant 4 2019-07-31 52 5.91 60,000 -5,000 Solutions Inc. 2005 Cameron Hammond Power Options Plan July 22 Robinson, Grant 4 2019-07-31 52 10.55 50,000 -10,000 Solutions Inc. 2005 Cameron Hammond Power Options Plan July 22 Robinson, Grant 4 2019-07-31 52 11.7 40,000 -10,000 Solutions Inc. 2005 Cameron Hammond Power Options Plan July 22 Robinson, Grant 4 2019-07-31 52 9.74 30,000 -10,000 Solutions Inc. 2005 Cameron Hammond Power Options Plan July 22 Simo, Zoltan D. 4 2019-07-31 38 13.64 35,000 -5,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 Simo, Zoltan D. 4 2019-07-31 38 10.55 25,000 -10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 Simo, Zoltan D. 4 2019-07-31 38 11.7 15,000 -10,000 Solutions Inc. 2005 Hammond Power Options Plan July 22 Simo, Zoltan D. 4 2019-07-31 38 9.74 5,000 -10,000 Solutions Inc. 2005 Happy Creek Minerals Common Shares blann, David 5 2019-07-26 10 0.125 4,734,001 10,000 Ltd. Happy Creek Minerals Common Shares blann, David 5 2019-07-26 10 0.12 4,738,001 4,000 Ltd. Happy Creek Minerals Common Shares blann, David 5 2019-08-01 10 0.125 4,742,001 4,000 Ltd. Happy Creek Minerals Common Shares Cathro, Mike 4 2019-07-29 10 0.11 300,000 20,000 Ltd. Hardwoods Common Shares Hardwoods 1 2019-07-02 38 12.596 44,300 3,000 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-03 38 12.648 46,800 2,500 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-03 38 5,500 -41,300 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-04 38 12.585 10,500 5,000 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-05 38 12.483 11,700 1,200 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-08 38 12.626 16,200 4,500 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-09 38 12.813 18,400 2,200 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-10 38 12.736 19,700 1,300 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-11 38 12.792 22,100 2,400 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-12 38 12.972 27,100 5,000 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-15 38 5,000 -22,100 Distribution Inc. Distribution Inc.

August 8, 2019 (2019), 42 OSCB 6660

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Hardwoods Common Shares Hardwoods 1 2019-07-16 38 12.995 5,400 400 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-17 38 12.964 7,000 1,600 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-19 38 13 7,200 200 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-22 38 13 7,600 400 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-23 38 12.986 8,100 500 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-24 38 12.963 10,000 1,900 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-25 38 12.902 11,100 1,100 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-26 38 12.861 12,900 1,800 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-29 38 12.967 17,900 5,000 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-30 38 12.893 18,300 400 Distribution Inc. Distribution Inc. Hardwoods Common Shares Hardwoods 1 2019-07-31 38 12.707 22,100 3,800 Distribution Inc. Distribution Inc. Hemisphere Energy Common Shares Duncan, Ian 5 2019-07-26 10 0.11 1,746,196 40,000 Corporation HEXO Corp. Options Bourque, Nathalie 4 2019-07-26 50 5.88 408,332 50,000 HEXO Corp. Options Chiara, Vincent 4 2019-07-26 50 5.88 450,000 50,000 HEXO Corp. Options Ewart, Jason 4 2019-07-26 50 5.88 655,000 50,000 HEXO Corp. Options Miron, Adam 4, 5 2019-07-26 50 5.88 450,000 50,000 HEXO Corp. Options Munzar, Michael R. 4 2019-07-26 50 5.88 910,000 50,000 High Tide Inc. Common Shares Posen, Binyomin 4 2019-07-24 00 3,500 Yehuda Hill Street Beverage Common Shares Shergill, Parvinder 5 2019-07-30 10 0.195 278,514 -50,000 Company Inc. (formerly Avanco Capital Corp.) Hill Street Beverage Common Shares Shergill, Parvinder 5 2019-07-31 10 0.2 323,514 45,000 Company Inc. (formerly Avanco Capital Corp.) Hill Street Beverage Common Shares Shergill, Parvinder 5 2019-07-23 10 0.2 301,012 -500 Company Inc. (formerly Avanco Capital Corp.) Hill Street Beverage Common Shares Shergill, Parvinder 5 2019-07-30 10 0.195 251,012 -50,000 Company Inc. (formerly Avanco Capital Corp.) Hill Street Beverage Common Shares Shergill, Parvinder 5 2019-07-30 10 0.2 246,512 -4,500 Company Inc. (formerly Avanco Capital Corp.) Hill Street Beverage Common Shares Shergill, Parvinder 5 2019-07-31 10 0.2 269,512 23,000 Company Inc. (formerly Avanco Capital Corp.) Hudbay Minerals Inc. Common Shares GMT Capital Corp 3 2019-07-30 10 4.91 7,245,290 -52,100 (formerly HudBay Minerals Inc.) Hudbay Minerals Inc. Common Shares GMT Capital Corp 3 2019-07-30 10 4.91 8,293,320 -59,700 (formerly HudBay Minerals Inc.) Hudbay Minerals Inc. Common Shares GMT Capital Corp 3 2019-07-30 10 4.91 11,997,290 -86,400 (formerly HudBay Minerals Inc.) Hudbay Minerals Inc. Common Shares GMT Capital Corp 3 2019-07-30 10 4.91 252,420 -1,800 (formerly HudBay Minerals Inc.)

August 8, 2019 (2019), 42 OSCB 6661

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Hudbay Minerals Inc. Common Shares GMT Capital Corp 3 2019-07-30 10 4.91 1,083,800 -7,800 (formerly HudBay Minerals Inc.) HUSKY ENERGY INC. Common Shares Hinkel, Robert Martin 7 2019-07-30 10 9.88 42,912 32,912 HUSKY ENERGY INC. Common Shares PEABODY, ROBERT 4, 5 2019-07-29 10 10.01 195,213 10,000 JOHN Hyduke Energy Common Shares Harradence, Milton 4 2019-07-24 00 57,559 Services Inc. Keith iA Financial Common Shares iA Financial 1 2019-07-03 38 53.492 25,600 600 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-04 38 53.443 26,700 1,100 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-05 38 1,100 -600 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-05 38 53.5 1,200 100 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-08 38 53.491 4,500 3,300 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-09 38 53.338 6,100 1,600 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-10 38 53.492 15,400 9,300 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-11 38 53.358 27,900 12,500 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-12 38 12,500 -15,400 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-12 38 53.364 25,000 12,500 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-15 38 53.383 37,500 12,500 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-17 38 53.311 50,000 12,500 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-18 38 53.464 56,500 6,500 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-19 38 6,500 -50,000 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-19 38 53.412 8,700 2,200 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-24 38 53.462 18,400 9,700 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-25 38 53.309 30,900 12,500 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-26 38 12,500 -18,400 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-26 38 53.436 21,100 8,600 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-29 38 53.429 33,600 12,500 Corporation Inc. Corporation Inc. iA Financial Common Shares iA Financial 1 2019-07-31 38 0 -33,600 Corporation Inc. Corporation Inc. IGM Financial Inc. Executive Asman, Todd 7 2019-07-31 30 36.46 8,296 126 Performance Share Units IGM Financial Inc. Restricted Share Units Asman, Todd 7 2019-07-31 30 36.46 2,165 32 IGM Financial Inc. Executive Bast, Esther 7 2019-07-31 30 36.46 2,865 44 Performance Share Units IGM Financial Inc. Restricted Share Units Bast, Esther 7 2019-07-31 30 36.46 2,307 35 IGM Financial Inc. Senior Executive Bast, Esther 7 2019-07-31 30 36.46 14,190 215 Share Units IGM Financial Inc. Executive Carney, Jeffrey 4, 5 2019-07-31 30 36.46 96,601 1,467 Performance Share Units IGM Financial Inc. Senior Executive Carney, Jeffrey 4, 5 2019-07-31 30 36.46 10,089 153 Share Units

August 8, 2019 (2019), 42 OSCB 6662

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed IGM Financial Inc. Executive Dibden, Michael 7 2019-07-31 30 36.46 15,449 235 Performance Share William Units IGM Financial Inc. Restricted Share Units Dibden, Michael 7 2019-07-31 30 36.46 6,179 93 William IGM Financial Inc. Executive Elavia, Tony 7 2019-07-31 30 36.46 21,917 333 Performance Share Units IGM Financial Inc. Restricted Share Units Elavia, Tony 7 2019-07-31 30 36.46 16,412 249 IGM Financial Inc. Senior Executive Elavia, Tony 7 2019-07-31 30 36.46 4,428 67 Share Units IGM Financial Inc. Executive Goldberg, Rhonda 5 2019-07-31 30 36.46 5,999 91 Performance Share Units IGM Financial Inc. Restricted Share Units Goldberg, Rhonda 5 2019-07-31 30 36.46 2,298 34 IGM Financial Inc. Executive Gould, J. Luke 5 2019-07-31 30 36.46 10,213 155 Performance Share Units IGM Financial Inc. Restricted Share Units Gould, J. Luke 5 2019-07-31 30 36.46 3,465 53 IGM Financial Inc. Equity Forward - IGM IGM Financial Inc. 1 2019-07-31 30 36.46 6 1 13 IGM Financial Inc. Equity Forward - IGM Financial Inc. 1 2019-07-31 30 36.46 3 1 IGM17 IGM Financial Inc. Equity Forward - IGM7 IGM Financial Inc. 1 2019-07-31 30 36.46 9 1 IGM Financial Inc. Equity Swap - IGM15 IGM Financial Inc. 1 2019-07-31 30 36.46 5 1 IGM Financial Inc. Equity Swap - IGM15 IGM Financial Inc. 1 2019-07-31 30 36.46 0 -5 IGM Financial Inc. Equity Swap - IGM16 IGM Financial Inc. 1 2019-07-31 30 36.46 3 1 IGM Financial Inc. Equity Swap - IGM16 IGM Financial Inc. 1 2019-07-31 30 36.46 0 -3 IGM Financial Inc. Equity Swap - IGM18 IGM Financial Inc. 1 2019-07-31 30 36.46 1 IGM Financial Inc. Equity Swap - IGM18 IGM Financial Inc. 1 2019-07-31 30 36.46 1 IGM Financial Inc. Equity Swap - IGM18 IGM Financial Inc. 1 2019-07-31 30 36.46 2 1 IGM Financial Inc. Equity Swap - IGM19 IGM Financial Inc. 1 2004-04-02 00 IGM Financial Inc. Equity Swap - IGM19 IGM Financial Inc. 1 2019-07-31 70 36.46 1 1 IGM Financial Inc. Executive Kinzel, Mark Richard 7 2019-07-31 30 36.46 11,884 181 Performance Share Units IGM Financial Inc. Restricted Share Units Kinzel, Mark Richard 7 2019-07-31 30 36.46 3,107 47 IGM Financial Inc. Executive Lawrence, Ian 7 2019-07-31 30 36.46 3,136 47 Performance Share Units IGM Financial Inc. Restricted Share Units Lawrence, Ian 7 2019-07-31 30 36.46 1,884 28 IGM Financial Inc. Executive McInerney, Barry 7 2019-07-31 30 36.46 80,204 1,218 Performance Share Units IGM Financial Inc. Executive Milne, Douglas 7 2019-07-31 30 36.46 5,235 79 Performance Share Units IGM Financial Inc. Restricted Share Units Milne, Douglas 7 2019-07-31 30 36.46 2,094 32 IGM Financial Inc. Executive Sen, Subhas 7 2019-07-31 30 36.46 5,048 76 Performance Share Units IGM Financial Inc. Restricted Share Units Sen, Subhas 7 2019-07-31 30 36.46 2,032 31 IGM Financial Inc. Executive Shewchuk, Blaine 7 2019-07-31 30 36.46 5,855 89 Performance Share Units IGM Financial Inc. Restricted Share Units Shewchuk, Blaine 7 2019-07-31 30 36.46 2,107 32 IGM Financial Inc. Senior Executive Tretiak, Gregory 4, 6 2019-07-31 30 36.46 8,758 133 Share Units Dennis iLOOKABOUT Corp. Common Shares StableView Asset 3 2019-07-18 00 20,802,094 Management iLOOKABOUT Corp. Convertible StableView Asset 3 2019-07-18 00 $7,868,618 Debentures Management iLOOKABOUT Corp. Warrants StableView Asset 3 2019-07-18 00 17,184,338 Management IMAX Corporation Common Shares IMAX Corporation 1 2019-07-26 30 66,860 -124 IMAX Corporation Common Shares IMAX Corporation 1 2019-07-29 30 66,747 -113

August 8, 2019 (2019), 42 OSCB 6663

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed IMAX Corporation Common Shares IMAX Corporation 1 2019-07-29 30 66,142 -605 IMPACT Silver Corp. Common Shares Mazur, Richard James 4 2019-07-26 10 0.44 228,500 -41,500 Imperial Metals Common Shares Fairholme Capital 3 2019-07-24 10 2.74 -9,400 Corporation Management, L.L.C. Imperial Metals Common Shares Fairholme Capital 3 2019-07-24 10 2.74 9,337,921 -9,400 Corporation Management, L.L.C. Imperial Metals Common Shares Fairholme Capital 3 2019-07-25 10 2.68 9,324,221 -13,700 Corporation Management, L.L.C. Imperial Metals Common Shares Fairholme Capital 3 2019-07-25 10 2.6 9,288,621 -35,600 Corporation Management, L.L.C. Imperial Metals Common Shares Fairholme Capital 3 2019-07-29 10 2.51 9,286,721 -1,900 Corporation Management, L.L.C. Imperial Metals Common Shares Fairholme Capital 3 2019-07-30 10 2.49 9,254,621 -32,100 Corporation Management, L.L.C. Imperial Metals Common Shares Fairholme Capital 3 2019-07-31 10 2.51 9,246,421 -8,200 Corporation Management, L.L.C. Imperial Metals Common Shares Fairholme Capital 3 2019-08-01 10 2.49 9,222,529 -23,892 Corporation Management, L.L.C. Imperial Metals Common Shares Muraro, Theodore 4 2019-07-19 30 2.58 35,399 2,697 Corporation William Imperial Oil Limited Common Shares Exxon Mobil 3 2019-07-25 38 36.11 528,935,983 -108,550 Corporation Imperial Oil Limited Common Shares Exxon Mobil 3 2019-07-26 38 35.96 528,827,433 -108,550 Corporation Imperial Oil Limited Common Shares Exxon Mobil 3 2019-07-29 38 36 528,718,882 -108,551 Corporation Imperial Oil Limited Common Shares Exxon Mobil 3 2019-07-30 38 36.39 528,610,332 -108,550 Corporation Imperial Oil Limited Common Shares Exxon Mobil 3 2019-07-31 38 36.14 528,501,781 -108,551 Corporation Imperial Oil Limited Common Shares Giglio, Amy Michelle 7 2019-08-01 00 6,273 Imperial Oil Limited Rights Giglio, Amy Michelle 7 2019-08-01 00 Imperial Oil Limited Rights Giglio, Amy Michelle 7 2019-08-01 00 Imperial Oil Limited Rights Giglio, Amy Michelle 7 2019-08-01 00 16,675 Inca One Gold Corp. Common Shares Kelly, Edward John 4 2019-07-30 11 0.035 115,000 Inca One Gold Corp. Common Shares Kelly, Edward John 4 2019-07-30 10 0.035 4,003,127 115,000 Ionic Brands Corp. Common Shares Gorst, John Phillip 3, 4, 5 2019-07-24 10 0.185 16,446,641 1,000 Ionic Brands Corp. Common Shares Gorst, John Phillip 3, 4, 5 2019-07-24 10 0.185 16,466,141 19,500 Ionic Brands Corp. Common Shares Gorst, John Phillip 3, 4, 5 2019-07-24 10 0.185 16,470,641 4,500 Ionic Brands Corp. Common Shares Gorst, John Phillip 3, 4, 5 2019-07-26 10 0.195 16,480,641 10,000 Ionic Brands Corp. Common Shares Gorst, John Phillip 3, 4, 5 2019-07-26 10 0.195 16,484,641 4,000 Ionic Brands Corp. Common Shares Gorst, John Phillip 3, 4, 5 2019-07-26 10 0.195 16,492,641 8,000 Ionic Brands Corp. Common Shares Gorst, John Phillip 3, 4, 5 2019-07-26 10 0.19 16,495,641 3,000 Ionic Brands Corp. Common Shares Gorst, John Phillip 3, 4, 5 2019-07-26 10 0.19 16,500,141 4,500 Ionic Brands Corp. Common Shares Gorst, John Phillip 3, 4, 5 2019-07-26 10 0.19 16,520,141 20,000 Ionic Brands Corp. Common Shares Gorst, John Phillip 3, 4, 5 2019-07-26 10 0.19 16,520,641 500 Ionic Brands Corp. Common Shares Schell, Andrew Wayne 3, 4, 5 2019-04-24 10 0.765 15,979,641 -100,000 Ionic Brands Corp. Common Shares Schell, Andrew Wayne 3, 4, 5 2019-05-15 10 0.6255 15,914,641 -65,000 Ionic Brands Corp. Common Shares Schell, Andrew Wayne 3, 4, 5 2019-05-21 10 0.4583 15,815,641 -99,000 Ionic Brands Corp. Common Shares Schell, Andrew Wayne 3, 4, 5 2019-07-24 10 0.205 15,890,641 75,000 Itafos (formerly, MBAC Restricted Share Units Cina, Anthony 4 2015-04-23 00 Fertilizer Corp.) Itafos (formerly, MBAC Restricted Share Units Cina, Anthony 4 2019-02-01 56 64,286 64,286 Fertilizer Corp.) Itafos (formerly, MBAC Restricted Share Units de Jong, Brent 4 2019-02-01 56 230,971 128,571 Fertilizer Corp.) Itafos (formerly, MBAC Restricted Share Units Delaney, George 4 2019-02-01 56 169,486 64,286 Fertilizer Corp.) David Itafos (formerly, MBAC Restricted Share Units Ibnabdeljalil, Mohamed 4, 5 2019-02-01 56 169,486 64,286 Fertilizer Corp.) Itafos (formerly, MBAC Restricted Share Units Iorich, Evgenij 4 2019-02-01 56 169,486 64,286 Fertilizer Corp.) Itafos (formerly, MBAC Restricted Share Units Wilkinson, Ronald A. 4 2019-02-01 56 115,486 64,286 Fertilizer Corp.)

August 8, 2019 (2019), 42 OSCB 6664

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Jervois Mining Limited Common Shares Hean, Scott Bradbury 4 2019-07-24 00 381,150 Ordinary Shares Jervois Mining Limited Common Shares Hean, Scott Bradbury 4 2019-07-24 00 240,900 Ordinary Shares Jervois Mining Limited Common Shares Hean, Scott Bradbury 4 2019-07-24 00 51,150 Ordinary Shares Jervois Mining Limited Common Shares Hean, Scott Bradbury 4 2019-07-24 00 143,550 Ordinary Shares Jervois Mining Limited Common Shares Hean, Scott Bradbury 4 2019-07-24 00 8,250 Ordinary Shares Jervois Mining Limited Options Hean, Scott Bradbury 4 2019-07-24 00 1,128,600 Jervois Mining Limited Warrants Hean, Scott Bradbury 4 2019-07-24 00 338,250 Jervois Mining Limited Warrants Hean, Scott Bradbury 4 2019-07-24 00 16,500 Jervois Mining Limited Warrants Hean, Scott Bradbury 4 2019-07-24 00 4,125 Jewett-Cameron Common Shares Nasser, Michael 5 2019-07-25 10 8.3 335,568 -3,500 Trading Company Ltd. Charles Jewett-Cameron Common Shares Nasser, Michael 5 2019-08-01 10 8.3299 333,789 -1,779 Trading Company Ltd. Charles Josemaria Resources Options Vitaller, Alfredo 5 2019-02-25 50 1 400,000 150,000 Inc. Jubilee Gold Common Shares Becker, Jeffrey 3, 4, 5 2014-11-25 36 0 -6,853,915 Exploration Ltd. Jonathan Jushi Holdings Inc. Warrants Arsenault, Denis 3 2019-06-06 00 6,750,000 Jushi Holdings Inc. Warrants Arsenault, Denis 3 2019-06-06 00 998,611 Jushi Holdings Inc. Options Bambach, Kimberly 5 2019-06-06 00 250,000 Jushi Holdings Inc. Warrants Bambach, Kimberly 5 2019-06-06 00 62,500 Jushi Holdings Inc. Options Barack, Louis 3, 5 2019-06-06 00 793,000 (Jonathan) Jushi Holdings Inc. Warrants Barack, Louis 3, 5 2019-06-06 00 50,000 (Jonathan) Jushi Holdings Inc. Warrants Barack, Louis 3, 5 2019-06-06 00 1,500,000 (Jonathan) Jushi Holdings Inc. Options Cacioppo, James 3, 4, 5 2019-06-06 00 2,385,000 Jushi Holdings Inc. Warrants Cacioppo, James 3, 4, 5 2019-06-06 00 1,439,814 Jushi Holdings Inc. Warrants Cacioppo, James 3, 4, 5 2019-06-06 00 12,775,000 Jushi Holdings Inc. Subordinate Voting Cohen, Joseph (Max) 4, 5 2019-06-06 00 Shares Jushi Holdings Inc. Subordinate Voting Cohen, Joseph (Max) 4, 5 2019-06-06 00 2,742,500 Shares Jushi Holdings Inc. Warrants Cross, Benjamin 4 2019-06-06 00 50,000 Jushi Holdings Inc. Options Mauff, Erich 3, 4, 5 2019-06-06 00 1,670,000 Jushi Holdings Inc. Warrants Mauff, Erich 3, 4, 5 2019-06-06 00 473,842 Jushi Holdings Inc. Warrants Mauff, Erich 3, 4, 5 2019-06-06 00 2,000,000 Kanadario Gold Inc. Common Shares Meagher, Patrick 4, 5 2019-07-25 00 350,000 Joseph Kanadario Gold Inc. Options Meagher, Patrick 4, 5 2019-07-25 00 200,000 Joseph Kanadario Gold Inc. Common Shares Oliver, Karly 4 2019-07-25 00 350,000 Kanadario Gold Inc. Options Oliver, Karly 4 2019-07-25 00 100,000 Kanadario Gold Inc. Common Shares Verdejo, Dominic 4, 5 2019-07-25 00 350,000 Kanadario Gold Inc. Options Verdejo, Dominic 4, 5 2019-07-25 00 100,000 Khiron Life Sciences Restricted Share Units Fox Quesada, Vicente 4 2018-07-17 00 Corp. Khiron Life Sciences Restricted Share Units Fox Quesada, Vicente 4 2019-05-31 56 2,000,000 2,000,000 Corp. Kontrol Energy Corp. Common Shares Kontrol Energy Corp. 1 2019-08-01 38 0 -85,000 Kootenay Silver Inc. Common Shares Kang, Rajwant 5 2019-07-22 10 0.155 416,500 5,000 KWG Resources Inc. Convertible Flett, Douglas Melville 4 2019-07-30 11 $30,000 -$18,000 Debentures (4 Multiple Voting Shares and 4 Warrants (MVS)) Lakefield Marketing Common Shares Bridgman, Jon 4, 5 2005-11-15 00 Corporation

August 8, 2019 (2019), 42 OSCB 6665

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Lakefield Marketing Common Shares Bridgman, Jon 4, 5 2019-07-29 11 2,000 2,000 Corporation Lakefield Marketing Common Shares Bridgman, Jon 4, 5 2005-11-15 00 Corporation Lakefield Marketing Common Shares Bridgman, Jon 4, 5 2019-07-29 11 2,000 2,000 Corporation LeoNovus Inc. Options Willis, Daniel 5 2019-07-03 50 0.06 2,575,000 300,000 Leucrotta Exploration Common Shares Disbrow, Robert 3 2019-07-29 10 0.69 10,639,500 16,500 Inc. Leucrotta Exploration Common Shares Disbrow, Robert 3 2019-07-30 10 0.68 10,714,500 75,000 Inc. Leucrotta Exploration Common Shares GMT Capital Corp 3 2019-07-31 10 0.57 8,236,550 100 Inc. Leucrotta Exploration Common Shares GMT Capital Corp 3 2019-07-31 10 0.57 9,392,060 200 Inc. Leucrotta Exploration Common Shares GMT Capital Corp 3 2019-07-31 10 0.57 14,931,760 200 Inc. LGC Capital Ltd. Common Shares McMullen, John A. D. 5 2019-07-26 10 0.08 3,568,588 74,000 LGC Capital Ltd. Common Shares McMullen, John A. D. 5 2019-07-26 10 0.085 3,594,588 26,000 Liht Cannabis Corp. Common Shares Mohamed, Rahim 4 2018-08-12 00 Liht Cannabis Corp. Common Shares Mohamed, Rahim 4 2018-08-12 00 Liht Cannabis Corp. Common Shares Mohamed, Rahim 4 2018-08-12 00 Liht Cannabis Corp. Options Mohamed, Rahim 4 2019-03-03 50 0.27 2,000,000 Liht Cannabis Corp. Options Mohamed, Rahim 4 2019-03-03 50 0.27 2,000,000 Liht Cannabis Corp. Options Mohamed, Rahim 4 2019-03-03 50 0.27 500,000 Liht Cannabis Corp. Options Mohamed, Rahim 4 2019-03-03 50 0.27 500,000 Linamar Corporation Common Shares Linamar Corporation 1 2019-07-31 38 0 -40,000 Lite Access Options Wong, Chui 5 2019-07-29 00 300,000 Technologies Inc. Logistec Corporation Common Shares Class LOGISTEC 1 2019-07-18 38 41 100 100 A CORPORATION Logistec Corporation Common Shares Class LOGISTEC 1 2019-07-26 38 0 -100 A CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-02 38 41.26 300 300 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-05 38 0 -300 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-08 38 40.67 100 100 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-08 38 40.5 1,000 900 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-09 38 40.25 1,100 100 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-11 38 40.5 1,500 400 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-12 38 40.25 2,200 700 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-12 38 1,100 -1,100 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-16 38 39.8 2,100 1,000 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-18 38 39.25 2,200 100 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-18 38 39.94 3,100 900 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-19 38 1,000 -2,100 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-25 38 39.75 1,600 600 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-26 38 39.4 1,700 100 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-26 38 700 -1,000 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-31 38 39 900 200 Shares Class B CORPORATION

August 8, 2019 (2019), 42 OSCB 6666

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Logistec Corporation Subordinate Voting LOGISTEC 1 2019-07-31 38 200 -700 Shares Class B CORPORATION Logistec Corporation Subordinate Voting LOGISTEC 1 2019-08-02 38 0 -200 Shares Class B CORPORATION Lundin Mining Common Shares Stefan, Catherine Jean 4 2019-07-30 10 6.52 56,400 1,400 Corporation Garrett Macarthur Minerals Common Shares McCall, Cameron 4 2019-07-29 10 5,539,804 -200,000 Limited Hugh Major Drilling Group Deferred Share Units Burzynski, John Feliks 4 2019-08-01 56 4.4 8,257 4,744 International Inc. Major Drilling Group Deferred Share Units Gignac, Louis-Pierre 4 2019-08-01 30 4,699 1,186 International Inc. Major Drilling Group Deferred Share Units Rennie, Janice Gaye 4 2019-08-01 56 4.4 19,257 1,399 International Inc. Marapharm Ventures Options Mohamed, Rahim 4 2018-08-12 00 Inc. Marapharm Ventures Options Mohamed, Rahim 4 2018-08-12 00 Inc. Marapharm Ventures Options Mohamed, Rahim 4 2018-08-12 00 Inc. Marapharm Ventures Options Mohamed, Rahim 4 2018-08-12 00 Inc. Marapharm Ventures Options Mohamed, Rahim 4 2018-08-12 00 Inc. Matachewan Common Shares McCloskey, Richard 4, 5 2019-07-25 10 0.13 4,089,500 2,000 Consolidated Mines, Duncan Limited MBN Corporation Common Shares MBN Corporation 1 2019-07-25 38 6.5 3,200 3,200 Equity Shares MBN Corporation Common Shares MBN Corporation 1 2019-07-25 38 0 -3,200 Equity Shares MBN Corporation Common Shares MBN Corporation 1 2019-07-29 38 6.4765 1,700 1,700 Equity Shares MBN Corporation Common Shares MBN Corporation 1 2019-07-29 38 0 -1,700 Equity Shares MBN Corporation Common Shares MBN Corporation 1 2019-07-30 38 6.5125 1,600 1,600 Equity Shares MBN Corporation Common Shares MBN Corporation 1 2019-07-30 38 0 -1,600 Equity Shares MBN Corporation Common Shares MBN Corporation 1 2019-07-31 38 6.525 1,600 1,600 Equity Shares MBN Corporation Common Shares MBN Corporation 1 2019-07-31 38 0 -1,600 Equity Shares MBN Corporation Common Shares MBN Corporation 1 2019-08-01 38 6.463 7,600 7,600 Equity Shares MBN Corporation Common Shares MBN Corporation 1 2019-08-01 38 0 -7,600 Equity Shares MCAN Mortgage Common Shares Pinto, Sylvia 5 2019-06-28 30 15.8 2,777 55 Corporation MCAN Mortgage Common Shares Pinto, Sylvia 5 2019-06-28 30 15.8 3,706 73 Corporation MCAN Mortgage Common Shares Pinto, Sylvia 5 2019-06-28 30 15.8 6,041 119 Corporation MCAN Mortgage Common Shares Pinto, Sylvia 5 2019-06-03 30 16.04 10,888 36 Corporation MCAN Mortgage Common Shares Pinto, Sylvia 5 2019-06-13 30 15.85 10,925 37 Corporation MCAN Mortgage Common Shares Pinto, Sylvia 5 2019-06-28 30 15.478 11,150 225 Corporation MCAN Mortgage Common Shares Pinto, Sylvia 5 2019-06-28 30 15.84 11,187 37 Corporation MCAN Mortgage Common Shares Pinto, Sylvia 5 2019-07-16 30 15.994 11,224 37 Corporation MCAN Mortgage Performance Deferred Pinto, Sylvia 5 2019-06-28 30 15.776 8,226 36 Corporation Share Units MCAN Mortgage Performance Deferred Pinto, Sylvia 5 2019-06-28 30 15.776 8,292 66 Corporation Share Units

August 8, 2019 (2019), 42 OSCB 6667

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed MCAN Mortgage Performance Deferred Pinto, Sylvia 5 2019-06-28 30 15.776 8,332 40 Corporation Share Units MCAN Mortgage Performance Deferred Pinto, Sylvia 5 2019-06-28 30 15.776 8,356 24 Corporation Share Units MCAN Mortgage Restricted Share Units Pinto, Sylvia 5 2019-06-28 30 15.776 2,251 45 Corporation MDC Partners Inc. Common Shares Class Goldberg, Daniel S. 4 2019-07-28 97 2.44 171,000 5,000 A Subordinate Voting Shares MDC Partners Inc. Common Shares Class Goldberg, Daniel S. 4 2019-07-28 97 169,282 -1,718 A Subordinate Voting Shares MDC Partners Inc. Restricted Stock Goldberg, Daniel S. 4 2019-07-28 97 2.44 10,990 -5,000 Medcolcanna Organics Options Mora, Jose Joaquin 4 2019-06-11 00 Inc. Medcolcanna Organics Options Mora, Jose Joaquin 4 2019-07-25 50 700,000 700,000 Inc. Melcor Real Estate Trust Units Melcor Real Estate 1 2019-07-31 38 7.6 0 -15,924 Investment Trust Investment Trust Melcor Real Estate Trust Units Pollock, Laurence 4 2019-08-01 10 7.6448 85,000 5,000 Investment Trust Malcolm Metallic Minerals Corp. Common Shares Hamilton, Gregor John 4 2017-01-10 00 Metallic Minerals Corp. Common Shares Hamilton, Gregor John 4 2017-01-10 00 Metallic Minerals Corp. Common Shares Hamilton, Gregor John 4 2019-07-30 54 0.1 1,000,000 Metallic Minerals Corp. Common Shares Hamilton, Gregor John 4 2019-07-30 54 0.1 1,000,000 Metallic Minerals Corp. Warrants Hamilton, Gregor John 4 2017-03-23 16 0.6 1,027,966 27,966 Metallic Minerals Corp. Warrants Hamilton, Gregor John 4 2019-07-30 54 0.1 -1,000,000 Metallic Minerals Corp. Warrants Hamilton, Gregor John 4 2019-07-30 54 0.1 27,966 -1,000,000 Metallic Minerals Corp. Common Shares Harris, William Glen 4 2019-07-30 54 0.1 2,938,200 1,200,000 Metallic Minerals Corp. Warrants Harris, William Glen 4 2019-07-30 54 0.1 125,000 -700,000 Metallic Minerals Corp. Warrants Harris, William Glen 4 2019-07-30 54 0.1 0 -1,300,000 Metallic Minerals Corp. Common Shares Johnson, Gregory 4, 5 2019-07-30 54 0.1 6,520,000 3,000,000 Shawn Metallic Minerals Corp. Warrants Johnson, Gregory 4, 5 2019-07-30 54 0.1 125,000 -3,000,000 Shawn Metallic Minerals Corp. Common Shares Petsel, Scott Alan 5 2019-07-30 54 0.1 304,100 100,000 Metallic Minerals Corp. Warrants Petsel, Scott Alan 5 2019-07-30 54 0.1 17,050 -100,000 Metalo Manufacturing Common Shares Hennigar, David John 4, 5 2019-08-01 45 0.2915 2,601,797 85,749 Inc. (formerly Muskrat Minerals Incorporated) Millrock Resources Common Shares EMX Royalty 3 2019-07-30 16 0.075 8,442,857 1,300,000 Inc. Corporation Millrock Resources Warrants EMX Royalty 3 2019-04-25 00 Inc. Corporation Millrock Resources Warrants EMX Royalty 3 2019-04-25 00 7,142,857 Inc. Corporation Millrock Resources Warrants EMX Royalty 3 2019-07-30 15 8,442,857 1,300,000 Inc. Corporation Minera Alamos Inc. Options Chadder, Christopher 5 2019-07-30 50 0.16 1,500,000 500,000 Robert Minera Alamos Inc. Options Durham, Robert Bruce 4 2019-07-30 50 1,850,000 500,000 Minera Alamos Inc. Options Ramshaw, Douglas 4, 5 2019-07-30 50 0.16 3,175,000 2,225,000 William MINT Income Fund Trust Units MINT Income Fund 1 2019-07-30 38 6.1731 71,549,951 1,300 MINT Income Fund Trust Units MINT Income Fund 1 2019-07-31 38 6.15 71,550,551 600 MJ Innovation Capital Common Shares Altshuler, Sherri 4 2019-07-29 00 50,000 Corp. Martine MJ Innovation Capital Common Shares Kimel, Richard Michael 4 2019-07-29 00 50,000 Corp. MJ Innovation Capital Common Shares Mallick, Jennifer 3 2019-07-29 00 450,000 Corp. MJ Innovation Capital Common Shares Thoren, Marissa 3 2019-07-29 00 225,000 Corp. MJ Innovation Capital Common Shares Van Engelen, Bryan 4, 5 2019-07-29 00 225,000 Corp.

August 8, 2019 (2019), 42 OSCB 6668

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed MONARCH ENERGY Options Edwards, Gerard 4 2014-06-30 22 -2,000,000 LIMITED MONARCH ENERGY Options Edwards, Gerard 4 2014-06-30 22 0 -2,000,000 LIMITED MONARCH ENERGY Options Edwards, Gerard 4 2014-06-30 22 -2,000,000 LIMITED Morien Resources Common Shares Morien Resources 1 2019-07-02 38 0.47 238,000 16,500 Corp. Corp Morien Resources Common Shares Morien Resources 1 2019-07-05 38 0.4 17,500 1,000 Corp. Corp Morien Resources Common Shares Morien Resources 1 2019-07-05 38 0.43 67,500 50,000 Corp. Corp Morien Resources Common Shares Morien Resources 1 2019-07-29 38 0.42 76,500 9,000 Corp. Corp Morien Resources Common Shares Morien Resources 1 2019-08-01 38 0.47 60,000 -16,500 Corp. Corp Morien Resources Common Shares Morien Resources 1 2019-08-01 38 0.4 59,000 -1,000 Corp. Corp Morien Resources Common Shares Morien Resources 1 2019-08-01 38 0.43 9,000 -50,000 Corp. Corp Morien Resources Common Shares Morien Resources 1 2019-08-01 38 0.42 0 -9,000 Corp. Corp Mullen Group Ltd. Common Shares McGinley, Christine 4 2019-08-01 10 9.88 290 Ellen Mullen Group Ltd. Common Shares McGinley, Christine 4 2019-08-01 10 9.88 8,792 129 Ellen Mullen Group Ltd. Common Shares McGinley, Christine 4 2019-08-01 10 9.9 9,077 285 Ellen Must Capital Inc. Common Shares Marrandino, Michele 4, 5 2019-07-30 46 0.787 2,479,366 1,923,810 (formerly Intrinsic4D Inc.) Must Capital Inc. Common Shares RANJAN, VIKAS 4 2018-02-07 00 (formerly Intrinsic4D Inc.) Must Capital Inc. Common Shares RANJAN, VIKAS 4 2019-07-29 46 0.0787 2,652,064 2,652,064 (formerly Intrinsic4D Inc.) Must Capital Inc. Common Shares RANJAN, VIKAS 4 2018-02-07 00 (formerly Intrinsic4D Inc.) Must Capital Inc. Common Shares RANJAN, VIKAS 4 2019-07-29 36 0.0787 930,073 930,073 (formerly Intrinsic4D Inc.) Must Capital Inc. Common Shares Scharfe, Bradley Nixon 3, 4 2019-07-30 10 0.0788 4,526,494 2,065,526 (formerly Intrinsic4D Inc.) Nabis Holdings Inc. Common Shares Krytiuk, Mark 5 2019-07-25 10 0.32 2,366,500 25,000 (formerly, Innovative Properties Inc.) Nabis Holdings Inc. Warrants Krytiuk, Mark 5 2018-11-09 00 (formerly, Innovative Properties Inc.) Nabis Holdings Inc. Warrants Krytiuk, Mark 5 2019-07-29 10 0.005 872,000 872,000 (formerly, Innovative Properties Inc.) Nabis Holdings Inc. Warrants Krytiuk, Mark 5 2019-07-29 10 0.005 872,000 (formerly, Innovative Properties Inc.) Nabis Holdings Inc. Warrants Krytiuk, Mark 5 2019-07-29 10 0.005 872,000 (formerly, Innovative Properties Inc.) NanoXplore Inc. Common Shares Farrell, Liam 5 2019-04-10 00 NanoXplore Inc. Common Shares Farrell, Liam 5 2019-04-10 00 36,550 NanoXplore Inc. Common Shares Marinaccio, Rocco 5 2019-04-11 00 NanoXplore Inc. Common Shares Marinaccio, Rocco 5 2019-04-11 00 15,500 NanoXplore Inc. Common Shares Martinrea International 3 2019-07-31 54 0.7 20,199,800 2,750,000 Inc.

August 8, 2019 (2019), 42 OSCB 6669

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed NanoXplore Inc. Warrants Martinrea International 3 2019-07-31 54 205,900 -2,750,000 Inc. Neptune Wellness Common Shares Galloway, Peter 7 2019-07-24 00 Solutions Inc. (formerly Macgregor Neptune Technologies & Bioressources Inc.) Neptune Wellness Common Shares Galloway, Peter 7 2019-07-24 00 Solutions Inc. (formerly Macgregor Neptune Technologies & Bioressources Inc.) Neptune Wellness Common Shares Galloway, Peter 7 2019-07-24 45 3.78 1,587,301 1,587,301 Solutions Inc. (formerly Macgregor Neptune Technologies & Bioressources Inc.) Neptune Wellness Options Galloway, Peter 7 2019-07-24 00 Solutions Inc. (formerly Macgregor Neptune Technologies & Bioressources Inc.) Nevada Sunrise Gold Common Shares Stanyer, Warren 4, 5 2019-07-25 16 0.05 1,421,633 200,000 Corporation William Nevada Sunrise Gold Warrants Stanyer, Warren 4, 5 2019-07-25 16 0.1 789,916 200,000 Corporation William Nextleaf Solutions Ltd. Common Shares Pedersen, Erik Paul 4, 5 2019-07-29 10 0.425 7,279,657 12,000 NGEx Resources Inc. Options Vitaller, Alfredo 5 2016-09-16 97 175,000 NGEx Resources Inc. Options Vitaller, Alfredo 5 2016-09-16 97 175,000 NGEx Resources Inc. Options Vitaller, Alfredo 5 2016-09-16 97 250,000 NGEx Resources Inc. Options Vitaller, Alfredo 5 2016-09-16 97 250,000 North American Common Shares Brookfield Business 3 2019-04-04 15 13 47,689,128 -5,770,000 Palladium Ltd. Partners L.P. North Bud Farms Inc. Common Shares Brown, Ryan 4, 5 2019-07-26 10 0.27 1,526,141 2,500 Northern Dynasty Common Shares Keep, Gordon 4 2019-07-31 10 1.18 9,250 -2,500 Minerals Ltd. Northfield Capital Common Shares Northfield Capital 1 2019-07-26 38 35.25 18,600 17,200 Corporation CLASS A Corporation RESTRICTED VOTING Northfield Capital Common Shares Northfield Capital 1 2019-07-29 38 35.25 23,600 5,000 Corporation CLASS A Corporation RESTRICTED VOTING NOVAGOLD Common Shares Lang, Gregory 5 2019-08-01 51 3.18 254,804 100,000 RESOURCES INC. Anthony NOVAGOLD Common Shares Lang, Gregory 5 2019-08-01 38 8.38 216,849 -37,955 RESOURCES INC. Anthony NOVAGOLD Common Shares Lang, Gregory 5 2019-08-01 10 8.36 158,873 -57,976 RESOURCES INC. Anthony NOVAGOLD Options Lang, Gregory 5 2019-08-01 51 3.18 5,546,750 -100,000 RESOURCES INC. Anthony NOVAGOLD Common Shares Williams, Richard 5 2019-07-29 51 3.18 316,824 40,000 RESOURCES INC. NOVAGOLD Common Shares Williams, Richard 5 2019-07-29 38 8.45 301,770 -15,054 RESOURCES INC. NOVAGOLD Common Shares Williams, Richard 5 2019-07-29 10 8.45 276,824 -24,946 RESOURCES INC. NOVAGOLD Options Williams, Richard 5 2019-07-29 51 3.18 961,509 -40,000 RESOURCES INC. Novoheart Holdings Common Shares Topham, James 4 2017-09-27 00 Inc. Novoheart Holdings Common Shares Topham, James 4 2017-09-27 00 Inc. Novoheart Holdings Options Topham, James 4 2017-09-27 00 Inc. Novoheart Holdings Options Topham, James 4 2017-09-27 00 Inc. Novoheart Holdings Options Topham, James 4 2017-09-27 00 Inc. Novoheart Holdings Options Topham, James 4 2019-03-06 50 0.34 125,000 Inc.

August 8, 2019 (2019), 42 OSCB 6670

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Novoheart Holdings Options Topham, James 4 2019-03-06 50 0.34 125,000 Inc. Novoheart Holdings Common Shares Topham, James 4 2017-09-27 00 Inc. Walter Novoheart Holdings Options Topham, James 4 2017-09-27 00 260,000 Inc. Walter Novoheart Holdings Options Topham, James 4 2019-03-06 50 0.34 385,000 125,000 Inc. Walter NRG Metals Inc. Common Shares Cherry, Christopher 4, 5 2019-07-31 16 0.12 754,625 700,000 NRG Metals Inc. Warrants on Cherry, Christopher 4, 5 2014-11-26 00 placements NRG Metals Inc. Warrants on Cherry, Christopher 4, 5 2019-07-31 16 0.16 700,000 700,000 placements NRG Metals Inc. Common Shares hobkirk, adrian 4, 5 2019-07-31 16 0.12 1,207,196 900,000 frederick NRG Metals Inc. Warrants on hobkirk, adrian 4, 5 2019-07-31 16 0.16 900,000 900,000 placements frederick NRG Metals Inc. Common Shares Urata, Jan 5 2019-07-31 16 0.12 200,000 200,000 NRG Metals Inc. Warrants on Urata, Jan 5 2019-07-31 16 0.16 200,000 200,000 placements NRG Metals Inc. Common Shares Villarroel Alcocer, 4, 5 2019-07-31 16 0.12 510,625 350,000 Fernando Erik NRG Metals Inc. Warrants on Villarroel Alcocer, 4, 5 2017-03-03 00 placements Fernando Erik NRG Metals Inc. Warrants on Villarroel Alcocer, 4, 5 2019-07-31 16 0.16 350,000 350,000 placements Fernando Erik Nutrien Ltd. Common Shares Kirkpatrick, Robert 7 2019-07-31 51 52.18 8,214 6,396 Nutrien Ltd. Common Shares Kirkpatrick, Robert 7 2019-07-31 10 71.73 7,218 -996 Nutrien Ltd. Common Shares Kirkpatrick, Robert 7 2019-07-31 10 71.72 6,918 -300 Nutrien Ltd. Common Shares Kirkpatrick, Robert 7 2019-07-31 10 71.71 6,818 -100 Nutrien Ltd. Common Shares Kirkpatrick, Robert 7 2019-07-31 10 71.7 1,818 -5,000 Nutrien Ltd. Options Kirkpatrick, Robert 7 2019-07-31 51 52.18 58,630 -6,396 Nutrien Ltd. Options O'Donoghue, Leslie 5 2019-08-01 51 54.99 638,679 -10,000 Nutrien Ltd. Rights Stock O'Donoghue, Leslie 5 2019-08-01 56 54.99 10,000 10,000 Appreciation Rights (SARs) Nutrien Ltd. Rights Stock O'Donoghue, Leslie 5 2019-08-01 59 54.99 0 -10,000 Appreciation Rights (SARs) ONEX Rights Deferred Share Casey, Daniel C. 4 2019-07-31 56 79.75 96,259 121 CORPORATION Units (cash settled) ONEX Rights Deferred Share Daly, Andrea Elizabeth 5 2019-07-31 56 79.75 13,185 17 CORPORATION Units (cash settled) ONEX Rights Deferred Share Etherington, William 4 2019-07-31 56 79.75 69,604 87 CORPORATION Units (cash settled) ONEX Rights Deferred Share Goldhar, Mitchell 4 2019-07-31 56 79.75 12,149 15 CORPORATION Units (cash settled) ONEX Rights Deferred Share Gouin, Serge 4 2019-07-31 56 79.75 98,764 124 CORPORATION Units (cash settled) ONEX Rights Deferred Share Govan, Christopher 5 2019-07-31 56 79.73 116,456 146 CORPORATION Units (cash settled) Allan ONEX Rights Deferred Share Heersink, Ewout R. 4, 5 2019-07-31 56 79.73 314,556 394 CORPORATION Units (cash settled) ONEX Rights Deferred Share Huffington, Arianna 4 2019-07-31 56 79.75 22,400 28 CORPORATION Units (cash settled) ONEX Rights Deferred Share McCoy, John Bonnet 4 2019-07-31 56 79.75 90,346 113 CORPORATION Units (cash settled) ONEX Rights Deferred Share Mersky, Seth Mitchell 5 2019-07-31 56 79.73 102,906 129 CORPORATION Units (cash settled) ONEX Rights Deferred Share Munk, Anthony 7 2019-07-31 56 79.73 23,953 30 CORPORATION Units (cash settled) ONEX Rights Deferred Share Popatia, Tawfiq 5 2019-07-31 56 79.73 18,942 24 CORPORATION Units (cash settled) ONEX Rights Deferred Share Prichard, John Robert 4 2019-07-31 56 79.75 92,963 116 CORPORATION Units (cash settled) Stobo

August 8, 2019 (2019), 42 OSCB 6671

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed ONEX Rights Deferred Share Reisman, Heather M. 4 2019-07-31 56 79.75 83,868 105 CORPORATION Units (cash settled) ONEX Rights Deferred Share Thorsteinson, Arni 4 2019-07-31 56 79.75 121,494 152 CORPORATION Units (cash settled) Clayton ONEX Rights Deferred Share Wilkinson, Beth Ann 4 2019-07-31 56 79.75 7,783 10 CORPORATION Units (cash settled) ONEX Rights Deferred Share Wright, Nigel Stewart 7 2019-07-31 56 79.73 54,985 69 CORPORATION Units (cash settled) Organto Foods Inc. Common Shares Langner, Ralf 5 2019-07-29 10 0.025 1,173,000 60,000 Orla Mining Ltd. Common Shares Lassonde, Pierre 3 2019-07-12 54 0.62 20,953,500 1,440,000 Orla Mining Ltd. Warrants Lassonde, Pierre 3 2019-07-12 54 60,000 -1,440,000 Orla Mining Ltd. Warrants Lassonde, Pierre 3 2019-07-12 53 1,500,000 1,440,000 OutdoorPartner Media Common Shares Keyser Söze Services 3 2016-11-04 90 0 -57,556,408 Corporation Limited Pacific Empire Common Shares Peters, Bradley 4, 5 2019-08-01 10 0.065 1,149,500 30,000 Minerals Corp. Partners Value Limited Partnership Lawson, Brian 4 2019-08-01 11 82,062 -56,647 Investments LP Units Class A Preferred, Series 1 Partners Value Limited Partnership Lawson, Brian 4 2019-08-01 11 0 -8,434 Investments LP Units Class A Preferred, Series 1 Partners Value Limited Partnership Pollock, Sam JB 4 2019-08-01 11 530,272 -89,665 Investments LP Units Class A Preferred, Series 1 Partners Value Limited Partnership Pollock, Sam JB 4 2019-08-01 11 59,310 -9,716 Investments LP Units Class A Preferred, Series 1 Pasinex Resources Options Gottwald, Andrew 5 2019-07-09 00 Limited Pasinex Resources Options Gottwald, Andrew 5 2019-07-25 50 500,000 500,000 Limited Patagonia Gold Corp. Options Argarate, Matias 5 2019-07-24 00 653,132 Francisco Patagonia Gold Corp. Common Shares Harper, Alexander 4 2019-07-22 00 James Christopher Patagonia Gold Corp. Common Shares Harper, Alexander 4 2019-07-24 00 James Christopher Patagonia Gold Corp. Common Shares Harper, Alexander 4 2019-07-24 22 924,531 924,531 James Christopher Patagonia Gold Corp. Common Shares Harper, Alexander 4 2019-07-24 00 James Christopher Patagonia Gold Corp. Common Shares Harper, Alexander 4 2019-07-24 22 353,864 353,864 James Christopher Patagonia Gold Corp. Common Shares lopez saubidet, cristian 4 2019-07-22 00 Patagonia Gold Corp. Common Shares lopez saubidet, cristian 4 2019-07-24 00 Patagonia Gold Corp. Options lopez saubidet, cristian 4 2019-07-24 00 2,152,000 Patagonia Gold Corp. Common Shares Martinis Tiplisky, 5 2019-07-22 00 Antonio Luis Patagonia Gold Corp. Common Shares Martinis Tiplisky, 5 2019-07-24 00 Antonio Luis Patagonia Gold Corp. Common Shares Martinis Tiplisky, 5 2019-07-24 00 Antonio Luis Patagonia Gold Corp. Options Martinis Tiplisky, 5 2019-07-24 00 435,780 Antonio Luis Patagonia Gold Corp. Common Shares Miguens, Carlos Jose 3, 4 2019-07-24 00 Patagonia Gold Corp. Common Shares Miguens, Carlos Jose 3, 4 2019-07-24 22 135,281,991 135,281,991 Patagonia Gold Corp. Common Shares Miguens, Carlos Jose 3, 4 2019-07-24 00 Patagonia Gold Corp. Common Shares Miguens, Carlos Jose 3, 4 2019-07-24 22 1,837,866 1,837,866 Patagonia Gold Corp. Options Miguens, Carlos Jose 3, 4 2019-07-24 00 2,690,000 Patagonia Gold Corp. Common Shares van Tienhoven, 5 2019-07-22 00 Christopher Patagonia Gold Corp. Common Shares van Tienhoven, 5 2019-07-24 00 Christopher Patagonia Gold Corp. Common Shares van Tienhoven, 5 2019-07-24 22 250,278 250,278 Christopher

August 8, 2019 (2019), 42 OSCB 6672

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Patagonia Gold Corp. Options van Tienhoven, 5 2019-07-22 00 Christopher Patagonia Gold Corp. Options van Tienhoven, 5 2019-07-22 00 Christopher Patagonia Gold Corp. Options van Tienhoven, 5 2019-07-22 00 Christopher Patagonia Gold Corp. Options van Tienhoven, 5 2019-07-24 00 2,690,000 Christopher Peloton Minerals Common Shares ELLWOOD, EDWARD 5 2019-07-29 10 0.1 3,680,796 1,000 Corporation LEITH Peloton Minerals Common Shares ELLWOOD, EDWARD 5 2019-07-29 10 0.105 3,685,796 5,000 Corporation LEITH Peloton Minerals Common Shares ELLWOOD, EDWARD 5 2019-07-29 10 0.11 3,705,796 20,000 Corporation LEITH Peloton Minerals Common Shares ELLWOOD, EDWARD 5 2019-07-30 10 0.11 43,000 Corporation LEITH Peloton Minerals Common Shares ELLWOOD, EDWARD 5 2019-07-30 10 0.11 3,735,796 30,000 Corporation LEITH Peloton Minerals Common Shares ELLWOOD, EDWARD 5 2019-07-30 10 0.11 3,748,796 13,000 Corporation LEITH Peloton Minerals Common Shares ELLWOOD, EDWARD 5 2019-08-01 10 0.11 3,753,796 5,000 Corporation LEITH Peloton Minerals Common Shares ELLWOOD, EDWARD 5 2019-08-02 10 0.11 3,765,796 12,000 Corporation LEITH Peruvian Metals Corp. Common Shares Reeder, Jeffrey 4 2019-07-30 10 0.035 3,227,191 -200,000 (Formerly Duran Unlimited, No Par Ventures Inc.) Value Peruvian Metals Corp. Common Shares Reeder, Jeffrey 4 2019-07-30 10 0.035 2,794,602 -1,300,000 (Formerly Duran Unlimited, No Par Ventures Inc.) Value PetroShale Inc. Common Shares Chernoff, M. Bruce 3, 4 2019-07-25 10 0.66 48,647,203 1,500,000 PetroShale Inc. Performance Bonus Izzo, Antonio Vincenzo 5 2013-11-25 00 Awards PetroShale Inc. Performance Bonus Izzo, Antonio Vincenzo 5 2019-07-31 56 187,200 187,200 Awards PetroShale Inc. Restricted Bonus Izzo, Antonio Vincenzo 5 2019-07-31 56 180,134 46,800 Awards PetroShale Inc. Performance Bonus Morgret, Caleb George 5 2018-12-03 00 22,400 Awards PetroShale Inc. Restricted Bonus Morgret, Caleb George 5 2019-07-31 56 355,600 5,600 Awards PetroShale Inc. Common Shares PetroShale Inc 1 2019-07-24 38 0.685 1,000 1,000 PetroShale Inc. Common Shares PetroShale Inc 1 2019-07-24 38 0.685 0 -1,000 PetroShale Inc. Common Shares PetroShale Inc 1 2019-07-30 38 0.74 2,000 2,000 PetroShale Inc. Common Shares PetroShale Inc 1 2019-07-30 38 0.74 0 -2,000 PetroShale Inc. Common Shares PetroShale Inc 1 2019-07-31 38 0.7543 3,500 3,500 PetroShale Inc. Common Shares PetroShale Inc 1 2019-07-31 38 0.7543 0 -3,500 PHX Energy Services Common Shares Buker, Michael Leslie 5 2019-08-02 10 2.47 0 -5,850 Corp. PHX Energy Services Common Shares PHX Energy Services 1 2019-07-12 10 2.8987 276,100 276,100 Corp. Corp PHX Energy Services Common Shares PHX Energy Services 1 2019-07-19 10 2.8969 612,800 336,700 Corp. Corp PHX Energy Services Common Shares PHX Energy Services 1 2019-07-24 38 0 -612,800 Corp. Corp Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-07-25 10 0.15 18,461,191 50,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-07-26 10 0.15 18,511,191 50,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-07-30 10 0.135 18,761,191 250,000 Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2019-07-31 10 0.135 18,873,191 112,000 Pivot Technology Common Shares Olson, Matthew 5 2018-10-12 00 7,340 Solutions, Inc. (formerly Acme Capital Corporation) POSaBIT Systems Common Shares Sweet, Andrew Paul 5 2019-07-31 10 0.17 20,000 10,000 Corporation

August 8, 2019 (2019), 42 OSCB 6673

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Premier Health Group Common Shares Beshay, Mena 5 2019-07-29 10 0.275 126,000 10,000 Inc. Project One Common Shares Shenton, Ronald 4, 5 2019-08-01 10 0.2 9,000 Resources Ltd. Gordon Project One Common Shares Shenton, Ronald 4, 5 2019-08-01 10 0.2 2,569,777 19,000 Resources Ltd. Gordon Prophecy Options Drozd, Michael 5 2019-07-29 50 0.2 350,000 100,000 Development Corp. Prophecy Options Echegaray, Rocio del 5 2019-07-29 50 0.2 80,000 60,000 Development Corp. Carmen Prophecy Options Espell, Ronald Allen 5 2019-07-26 52 0.65 -200,000 Development Corp. Prophecy Options Espell, Ronald Allen 5 2019-07-26 38 0.65 0 -200,000 Development Corp. Prophecy Options Espell, Ronald Allen 5 2019-07-29 50 0.2 200,000 200,000 Development Corp. Prophecy Options Hall, Greg 4 2019-07-26 52 0.5 -60,000 Development Corp. Prophecy Options Hall, Greg 4 2019-07-26 38 0.5 322,000 -60,000 Development Corp. Prophecy Options Hall, Greg 4 2019-07-26 52 0.5 -20,000 Development Corp. Prophecy Options Hall, Greg 4 2019-07-26 38 0.5 302,000 -20,000 Development Corp. Prophecy Options Hall, Greg 4 2019-07-29 50 0.2 422,000 120,000 Development Corp. Prophecy Options IGATA, MASATERU 4 2019-07-26 52 0.5 -30,000 Development Corp. Prophecy Options IGATA, MASATERU 4 2019-07-26 38 0.5 400,000 -30,000 Development Corp. Prophecy Options IGATA, MASATERU 4 2019-07-26 52 0.5 -20,000 Development Corp. Prophecy Options IGATA, MASATERU 4 2019-07-26 38 0.5 380,000 -20,000 Development Corp. Prophecy Options IGATA, MASATERU 4 2019-07-29 50 0.2 480,000 100,000 Development Corp. Prophecy Options LEDUC, MARC PAUL 4 2019-07-23 00 Development Corp. FRANCOIS Prophecy Options LEDUC, MARC PAUL 4 2019-07-29 50 0.2 150,000 150,000 Development Corp. FRANCOIS Prophecy Common Shares Lee, John 4, 5 2019-07-31 10 0.17 13,752,901 -51,714 Development Corp. without par value Prophecy Common Shares Lee, John 4, 5 2019-08-01 10 0.175 13,972,901 220,000 Development Corp. without par value Prophecy Common Shares Lee, John 4, 5 2019-08-01 10 0.17 47,000 Development Corp. without par value Prophecy Common Shares Lee, John 4, 5 2019-08-02 10 0.17 14,019,901 47,000 Development Corp. without par value Prophecy Options Lee, John 4, 5 2019-07-26 52 0.5 -235,000 Development Corp. Prophecy Options Lee, John 4, 5 2019-07-26 38 0.5 2,913,980 -235,000 Development Corp. Prophecy Options Lee, John 4, 5 2019-07-26 52 0.5 -134,000 Development Corp. Prophecy Options Lee, John 4, 5 2019-07-26 38 0.5 2,779,980 -134,000 Development Corp. Prophecy Options Lee, John 4, 5 2019-07-29 50 0.2 3,479,980 700,000 Development Corp. Prophecy Options Miranda, Gustavo 7 2019-07-26 52 0.5 -25,000 Development Corp. Adolfo Prophecy Options Miranda, Gustavo 7 2019-07-26 38 0.5 110,000 -25,000 Development Corp. Adolfo Prophecy Options Miranda, Gustavo 7 2019-07-26 52 0.5 -10,000 Development Corp. Adolfo Prophecy Options Miranda, Gustavo 7 2019-07-26 38 0.5 100,000 -10,000 Development Corp. Adolfo

August 8, 2019 (2019), 42 OSCB 6674

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Prophecy Options Miranda, Gustavo 7 2019-07-29 50 0.2 135,000 35,000 Development Corp. Adolfo Prophecy Options Molor, Nargil 7 2019-07-26 52 0.5 -10,000 Development Corp. Prophecy Options Molor, Nargil 7 2019-07-26 38 0.5 190,000 -10,000 Development Corp. Prophecy Options Molor, Nargil 7 2019-07-29 50 0.2 210,000 20,000 Development Corp. Prophecy Options Oosterman, Danniel 5 2019-07-29 50 0.2 370,000 100,000 Development Corp. Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2019-07-25 10 0.02 3,036,465 50,000 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2019-08-01 10 0.015 3,121,465 85,000 Quinsam Capital Common Shares Szustak, Eric 3 2019-07-25 10 0.1 480,500 380,000 Corporation Quinsam Capital Options Szustak, Eric 3 2019-07-25 51 900,000 -380,000 Corporation Range Energy Common Shares bezanson, allan james 4 2011-04-04 00 Resources Inc. Range Energy Common Shares bezanson, allan james 4 2019-07-31 16 0.02 609,351,075 609,351,075 Resources Inc. Range Energy Promissory Notes bezanson, allan james 4 2011-04-04 00 Resources Inc. Range Energy Promissory Notes bezanson, allan james 4 2019-07-31 97 0.02 $15,982,472 $15,982,472 Resources Inc. Range Energy Options CHAHINE, TOUFIC 4 2019-07-31 52 0 -2,000,000 Resources Inc. Range Energy Common Shares Gulf LNG America, 3 2019-07-31 16 0 -608,051,075 Resources Inc. LLC Range Energy Promissory Notes Gulf LNG America, 3 2019-07-31 16 -$15,982,472 Resources Inc. LLC Range Energy Promissory Notes Gulf LNG America, 3 2019-07-31 16 -$15,982,472 Resources Inc. LLC Range Energy Promissory Notes Gulf LNG America, 3 2019-07-31 97 $0 -$15,982,472 Resources Inc. LLC Range Energy Warrants Gulf LNG America, 3 2019-07-31 38 0 -477,651,075 Resources Inc. LLC Range Energy Options UPTON, MICHELLE 4 2019-07-31 52 0 -2,000,000 Resources Inc. Razor Energy Corp. Common Shares Braun, Kevin Edward 5 2019-07-31 30 1.9758 35,082 220 Razor Energy Corp. Common Shares Braun, Kevin Edward 5 2019-07-31 30 1.9758 9,026 41 Razor Energy Corp. Common Shares Mueller, Lisa Ann 5 2019-07-31 30 1.9758 91,937 468 Razor Energy Corp. Common Shares Mueller, Lisa Ann 5 2019-07-31 30 1.9758 48,212 69 Razor Energy Corp. Common Shares Mueller, Lisa Ann 5 2019-07-31 30 1.9758 24,041 134 Razor Energy Corp. Common Shares Muller, Frank Peter 4, 5 2019-07-31 30 1.9758 1,001,955 821 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-07-29 10 0.145 1,939,500 12,500 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-07-31 10 0.16 1,949,500 10,000 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-07-30 10 0.145 3,460,500 34,500 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-07-30 10 0.15 3,526,000 65,500 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-07-30 10 0.15 3,576,000 50,000 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-07-31 10 0.15 3,616,000 40,000 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-08-01 10 0.16 3,635,000 19,000 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-08-01 10 0.165 3,645,000 10,000 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-08-01 10 0.165 3,650,000 5,000 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-08-01 10 0.165 3,655,000 5,000 Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2019-08-01 10 0.17 3,665,000 10,000 Reko International Options CROWLEY, Marilyn 5 2019-07-30 52 3.9 5,000 -10,000 Group Inc. Joan-Marie Reko International Options CROWLEY, Marilyn 5 2019-07-30 52 2.9 0 -5,000 Group Inc. Joan-Marie Reko International Common Shares Reko International 1 2019-07-26 38 3.69 4,100 4,100 Group Inc. Group Inc. Reko International Common Shares Reko International 1 2019-07-26 38 3.69 0 -4,100 Group Inc. Group Inc.

August 8, 2019 (2019), 42 OSCB 6675

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Reservoir Capital Common Shares Mathonnet, Vianney 4 2019-07-19 10 0.055 2,121,000 2,000 Corp. Stéphane Marie Nicolas Richards Packaging Deferred Share Units Allen, Susan Lynn 4 2017-05-05 00 Income Fund Richards Packaging Deferred Share Units Allen, Susan Lynn 4 2019-07-25 46 43.6 287 287 Income Fund Richards Packaging Deferred Share Units Younes, Rami 4 2005-10-13 00 Income Fund Richards Packaging Deferred Share Units Younes, Rami 4 2019-07-25 46 43.6 258 258 Income Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-07-26 10 15.75 9,535,912 2,525 Investment Grade Asset Management Bond Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-07-26 10 15.75 9,533,372 -2,540 Investment Grade Asset Management Bond Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-07-29 10 15.75 9,535,737 2,365 Investment Grade Asset Management Bond Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-07-29 10 15.75 9,535,558 -179 Investment Grade Asset Management Bond Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-07-30 10 15.771 2,277 Investment Grade Asset Management Bond Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-07-30 10 15.81 -790 Investment Grade Asset Management Bond Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-07-30 10 15.75 9,537,243 1,685 Investment Grade Asset Management Bond Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-07-30 10 15.75 9,536,704 -539 Investment Grade Asset Management Bond Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-07-31 10 15.771 9,538,981 2,277 Investment Grade Asset Management Bond Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-07-31 10 15.81 9,538,191 -790 Investment Grade Asset Management Bond Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-08-01 10 15.75 9,539,785 1,594 Investment Grade Asset Management Bond Fund Ridgewood Canadian Units Ridgewood Capital 3 2019-08-01 10 15.75 9,539,182 -603 Investment Grade Asset Management Bond Fund Rockcliff Metals Common Shares Ross, Alistair Gavin 4, 5 2019-07-29 10 0.1 902,500 99,000 Corporation (formerly Rockcliff Copper Corporation) Rockcliff Metals Common Shares Ross, Alistair Gavin 4, 5 2019-07-30 10 0.1 952,500 50,000 Corporation (formerly Rockcliff Copper Corporation) Rockcliff Metals Common Shares Ross, Alistair Gavin 4, 5 2019-07-31 10 0.105 1,000,500 48,000 Corporation (formerly Rockcliff Copper Corporation) Rockcliff Metals Common Shares Ross, Alistair Gavin 4, 5 2019-08-01 10 0.1 1,050,500 50,000 Corporation (formerly Rockcliff Copper Corporation) Rocky Mountain Liquor Common Shares Byrne, Joan 3 2019-07-26 10 0.015 9,593,000 193,000 Inc. Rocky Mountain Liquor Common Shares Byrne, Peter 3, 5 2019-07-26 10 0.015 9,593,000 193,000 Inc. Rogers Non-Voting Shares Brooks, Bonnie 4 2019-07-24 46 5,100 157 Communications Inc. Class B

August 8, 2019 (2019), 42 OSCB 6676

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Rogers Non-Voting Shares Clappison, John 4 2019-07-24 46 3,481 82 Communications Inc. Class B Rogers Non-Voting Shares Rogers, Edward 4, 6, 7, 5 2019-07-24 46 9,648 886 Communications Inc. Class B Rogers Non-Voting Shares Rogers, Loretta A. 4, 6 2019-07-24 46 54,066 273 Communications Inc. Class B Rogers Non-Voting Shares Rogers, Martha 4, 6 2019-07-24 46 5,015 273 Communications Inc. Class B Rogers Non-Voting Shares Rogers, Melinda M. 4, 6, 7 2019-07-24 46 5,460 443 Communications Inc. Class B Rogers Non-Voting Shares Staffieri, Anthony 5 2019-07-30 30 71.06 740 528 Communications Inc. Class B Rogers Non-Voting Shares Staffieri, Anthony 5 2019-07-30 10 68.76 166 -574 Communications Inc. Class B Rokmaster Resources Common Shares Mirko, John Martin 4, 5 2019-07-29 10 0.04 3,396,560 -100,000 Corp. Route1 Inc. Common Shares Doolan, Michael 4 2019-07-31 10 4,114,300 58,727 Frederick Route1 Inc. Common Shares Fraser, David 4 2019-07-31 10 0.0483 63,908 Route1 Inc. Common Shares Fraser, David 4 2019-07-31 10 0.0483 1,979,639 63,908 Route1 Inc. Common Shares Harris, Michael Deane 4 2019-07-31 10 0.0483 94,999 Route1 Inc. Common Shares Harris, Michael Deane 4 2019-07-31 10 0.0483 4,927,116 94,999 Route1 Inc. Common Shares Marino, John 4 2019-07-31 10 0.05 56,660 Route1 Inc. Common Shares Marino, John 4 2019-07-31 10 0.05 717,901 56,660 Route1 Inc. Common Shares Reeder, Edward 4 2019-07-31 10 0.05 102,760 Route1 Inc. Common Shares Reeder, Edward 4 2019-07-31 10 0.05 212,759 102,760 Roxgold Inc. Deferred Share Units Colterjohn, Richard 4 2019-07-26 56 1.074 111,731 Mark Roxgold Inc. Deferred Share Units Colterjohn, Richard 4 2019-07-26 56 1.084 989,092 110,701 Mark Roxgold Inc. Deferred Share Units Pitcher, Norman 4 2019-07-23 56 435,624 110,701 Royal Nickel Rights Restricted Huet, Paul André 4 2019-05-31 56 25,317 Corporation Share Units Royal Nickel Rights Restricted Huet, Paul André 4 2019-05-31 56 431,102 25,317 Corporation Share Units Royal Nickel Rights Restricted Huet, Paul André 4 2019-06-30 56 53,093 Corporation Share Units Royal Nickel Rights Restricted Huet, Paul André 4 2019-06-30 56 484,195 53,093 Corporation Share Units Rubicon Minerals Common Shares Bukacheva, 4 2019-07-26 16 0.77 14,000 6,000 Corporation Aleksandra (Sasha) Rubicon Minerals Common Shares Burns, Daniel Allan 4 2019-07-26 16 0.77 10,000 10,000 Corporation Rubicon Minerals Common Shares Jones, Peter Rhys 4 2019-07-26 16 0.77 10,000 10,000 Corporation Rubicon Minerals Common Shares Nikolakakis, Nick 5 2019-07-26 16 0.77 17,458 6,500 Corporation Rubicon Minerals Common Shares Ogilvie, George O'Neil 4, 5 2019-07-26 16 0.77 482,440 6,500 Corporation Rubicon Minerals Common Shares Palmer, David 4 2019-07-26 16 0.77 75,000 25,000 Corporation Alexander Stephen Rubicon Organics Inc. Common Shares Savics, Eric 3 2019-07-26 10 2.9967 32,800 6,000 Rubicon Organics Inc. Common Shares Savics, Eric 3 2019-07-29 10 3 42,800 10,000 Rubicon Organics Inc. Common Shares Savics, Eric 3 2019-07-31 10 3 52,800 10,000 Rugby Mining Limited Common Shares Adams, Alejandro 5 2019-03-22 11 0.18 96,133 35,000 Rugby Mining Limited Options Adams, Alejandro 5 2019-07-31 50 0.16 550,000 100,000 Rugby Mining Limited Warrants Adams, Alejandro 5 2019-03-22 11 0.3 55,833 17,500 Rupert Resources Ltd. Common Shares Brimacombe, Alan 3 2019-07-29 10 0.8 19,615,900 -15,000 Douglas Rupert Resources Ltd. Common Shares Brimacombe, Alan 3 2019-07-30 10 0.8 19,600,900 -15,000 Douglas Sanatana Resources Common Shares Miles, Peter Leighton 3, 4, 5 2019-08-01 10 0.04 12,013,886 420,000 Inc. ScoZinc Mining Ltd. Common Shares Lazarovici, Victor 4 2019-08-02 46 143,750 93,750 Seahawk Ventures Inc. Options Ekholm, Ian Jack 3 2019-07-30 50 500,000

August 8, 2019 (2019), 42 OSCB 6677

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Seahawk Ventures Inc. Options Ekholm, Ian Jack 3 2018-01-15 00 Seahawk Ventures Inc. Options Ekholm, Ian Jack 3 2019-07-30 50 500,000 500,000 Seahawk Ventures Inc. Options Giantomaso, Salvatore 4 2019-07-30 50 50,000 50,000 Seahawk Ventures Inc. Options Holliday, Alan Blair 4 2018-10-01 00 Seahawk Ventures Inc. Options Holliday, Alan Blair 4 2019-07-30 50 25,000 25,000 Secure Energy Common Shares Secure Energy 1 2019-07-05 38 -157,300 Services Inc. Services Inc. Secure Energy Common Shares Secure Energy 1 2019-07-05 38 -157,300 Services Inc. Services Inc. Secure Energy Common Shares Secure Energy 1 2019-07-05 38 0 -157,300 Services Inc. Services Inc. Secure Energy Common Shares Secure Energy 1 2019-07-12 38 7.183 73,900 73,900 Services Inc. Services Inc. Secure Energy Common Shares Secure Energy 1 2019-07-15 38 7.216 167,300 93,400 Services Inc. Services Inc. Secure Energy Common Shares Secure Energy 1 2019-07-18 38 6.8726 229,100 61,800 Services Inc. Services Inc. Secure Energy Common Shares Secure Energy 1 2019-07-19 38 6.9781 293,600 64,500 Services Inc. Services Inc. Secure Energy Common Shares Secure Energy 1 2019-07-22 38 -167,300 Services Inc. Services Inc. Secure Energy Common Shares Secure Energy 1 2019-07-22 38 -167,300 Services Inc. Services Inc. Secure Energy Common Shares Secure Energy 1 2019-07-22 38 126,300 -167,300 Services Inc. Services Inc. Secure Energy Common Shares Secure Energy 1 2019-07-26 38 -126,300 Services Inc. Services Inc. Secure Energy Common Shares Secure Energy 1 2019-07-26 38 0 -126,300 Services Inc. Services Inc. Security Devices Convertible Ganz, Bryan 4, 5 2019-07-22 11 1000 $183,088 $50,000 International Inc. Debentures Security Devices Convertible Ganz, Bryan 4, 5 2019-07-22 46 1000 $223,088 $40,000 International Inc. Debentures Security Devices Warrants Ganz, Bryan 4, 5 2019-05-20 46 665,686 50,000 International Inc. Security Devices Warrants Ganz, Bryan 4, 5 2019-07-22 11 865,686 200,000 International Inc. Security Devices Warrants Ganz, Bryan 4, 5 2019-07-22 46 1,025,686 160,000 International Inc. Security Devices Convertible Levantin, Donald 4 2019-04-22 11 1000 $201,667 $35,000 International Inc. Debentures Security Devices Convertible Levantin, Donald 4 2019-07-22 11 1000 $226,667 $25,000 International Inc. Debentures Security Devices Warrants Levantin, Donald 4 2019-07-22 11 617,756 100,000 International Inc. Security Devices Convertible Wager, Lisa 5 2019-07-22 11 1000 $72,500 $30,000 International Inc. Debentures Security Devices Warrants Wager, Lisa 5 2019-01-23 00 International Inc. Security Devices Warrants Wager, Lisa 5 2019-05-20 11 170,000 170,000 International Inc. Security Devices Warrants Wager, Lisa 5 2019-07-22 46 290,000 120,000 International Inc. SHAW Non-Voting Shares Estate of James R. 3 2019-07-30 30 25.352 394 9 COMMUNICATIONS Class "B" Shaw INC. SHAW Non-Voting Shares Shaw, Bradley 4, 5 2019-07-30 30 25.352 4,738 41 COMMUNICATIONS Class "B" INC. SHAW Non-Voting Shares Shaw, Bradley 4, 5 2019-07-30 30 25.352 3,315 51 COMMUNICATIONS Class "B" INC. SHAW Non-Voting Shares Shaw, Bradley 4, 5 2019-07-30 30 25.352 3,315 51 COMMUNICATIONS Class "B" INC.

August 8, 2019 (2019), 42 OSCB 6678

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed SHAW Non-Voting Shares Shaw, Bradley 4, 5 2019-07-30 30 25.352 3,315 51 COMMUNICATIONS Class "B" INC. SHAW Non-Voting Shares Shaw, Bradley 4, 5 2019-07-30 30 25.352 132 2 COMMUNICATIONS Class "B" INC. SHAW Non-Voting Shares Shaw, JR 3, 4, 5 2019-07-30 30 25.352 61,824 343 COMMUNICATIONS Class "B" INC. SHAW Non-Voting Shares Shaw, JR 3, 4, 5 2019-06-27 30 26.427 2,911,286 186 COMMUNICATIONS Class "B" INC. SHAW Non-Voting Shares Shaw, Julie 5 2019-07-30 30 25.352 29,805 125 COMMUNICATIONS Class "B" INC. Shopify Inc. Multiple Voting Shares Finkelstein, Harley 5 2019-07-25 51 0.152 2,459 2,459 Class B Multiple Voting Michael Shares Shopify Inc. Multiple Voting Shares Finkelstein, Harley 5 2019-07-25 36 0 -2,459 Class B Multiple Voting Michael Shares Shopify Inc. Multiple Voting Shares Finkelstein, Harley 5 2019-08-01 51 0.152 2,459 2,459 Class B Multiple Voting Michael Shares Shopify Inc. Multiple Voting Shares Finkelstein, Harley 5 2019-08-01 36 0 -2,459 Class B Multiple Voting Michael Shares Shopify Inc. Options Finkelstein, Harley 5 2019-07-25 51 0.152 53,359 -2,459 Michael Shopify Inc. Options Finkelstein, Harley 5 2019-08-01 51 0.152 50,900 -2,459 Michael Shopify Inc. Subordinate Voting Finkelstein, Harley 5 2019-07-25 36 2,588 2,459 Shares Class A Michael Subordinate Voting Shares Shopify Inc. Subordinate Voting Finkelstein, Harley 5 2019-07-25 30 328.94 129 -2,459 Shares Class A Michael Subordinate Voting Shares Shopify Inc. Subordinate Voting Finkelstein, Harley 5 2019-08-01 36 2,588 2,459 Shares Class A Michael Subordinate Voting Shares Shopify Inc. Subordinate Voting Finkelstein, Harley 5 2019-08-01 30 332.36 129 -2,459 Shares Class A Michael Subordinate Voting Shares Shopify Inc. Multiple Voting Shares Frasca, Joseph 5 2019-07-29 51 6.22 4,335 4,335 Class B Multiple Voting Andrew Shares Shopify Inc. Multiple Voting Shares Frasca, Joseph 5 2019-07-29 36 0 -4,335 Class B Multiple Voting Andrew Shares Shopify Inc. Options Frasca, Joseph 5 2019-07-29 51 6.22 0 -4,335 Andrew Shopify Inc. Subordinate Voting Frasca, Joseph 5 2019-07-29 36 5,810 4,335 Shares Class A Andrew Subordinate Voting Shares Shopify Inc. Subordinate Voting Frasca, Joseph 5 2019-07-29 30 334.81 1,475 -4,335 Shares Class A Andrew Subordinate Voting Shares Shopify Inc. Subordinate Voting Lutke, Tobias Albin 4, 5 2019-07-29 30 320.26 76,000 -4,000 Shares Class A Subordinate Voting Shares Shopify Inc. Options Shapero, Amy 5 2019-07-29 51 137.72 63,310 -782 Elizabeth

August 8, 2019 (2019), 42 OSCB 6679

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Shopify Inc. Subordinate Voting Shapero, Amy 5 2019-07-29 51 137.72 5,853 782 Shares Class A Elizabeth Subordinate Voting Shares Shopify Inc. Subordinate Voting Shapero, Amy 5 2019-07-29 30 336.35 5,071 -782 Shares Class A Elizabeth Subordinate Voting Shares Shopify Inc. Subordinate Voting Shapero, Amy 5 2019-07-29 30 336.35 4,661 -410 Shares Class A Elizabeth Subordinate Voting Shares Shopify Inc. Subordinate Voting Weiser, Jeffrey Kane 5 2019-07-26 30 333 1,218 -325 Shares Class A Subordinate Voting Shares Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-05-28 38 1.7714 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-05-28 38 1.7714 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-06-27 38 1.6927 1,100 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-06-27 38 1.6927 1,100 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-06-27 38 1.6927 1,100 1,100 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-06-28 38 1.7714 5,314 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-02 38 1.8275 9,528 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-03 38 1.8117 13,742 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-04 38 1.81 14,742 1,000 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-05 38 1.7893 18,942 4,200 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-08 38 1.7061 23,156 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-09 38 1.7 27,370 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-10 38 1.6563 31,584 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-11 38 1.6814 35,798 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-12 38 1.6421 40,012 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-15 38 1.5962 44,226 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-16 38 1.598 48,440 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-17 38 1.6047 52,654 4,214 (formerly Dia Bras Exploration Inc.)

August 8, 2019 (2019), 42 OSCB 6680

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-18 38 1.6521 56,868 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-19 38 1.7355 61,082 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-22 38 1.7401 158,182 97,100 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-23 38 1.9514 162,396 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-24 38 1.9889 166,610 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-25 38 2.0409 170,824 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-26 38 1.9469 174,324 3,500 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-29 38 1.9622 178,538 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-30 38 0 -178,538 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-30 38 1.9805 1,900 1,900 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Common Shares Sierra Metals Inc. 1 2019-07-31 38 1.9972 6,114 4,214 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Restricted Share Unit Yamamoto, Koko 4 2019-07-15 00 (formerly Dia Bras Exploration Inc.) Sierra Metals Inc. Restricted Share Unit Yamamoto, Koko 4 2019-07-31 56 33,263 33,263 (formerly Dia Bras Exploration Inc.) Sierra Wireless, Inc. Common Shares Link, Rene Fernando 5 2019-02-12 57 14,691 1,307 Sierra Wireless, Inc. Common Shares Link, Rene Fernando 5 2019-02-12 10 15.69 13,384 -1,307 Sierra Wireless, Inc. Common Shares Link, Rene Fernando 5 2019-02-13 57 16,151 1,132 Sierra Wireless, Inc. Common Shares Link, Rene Fernando 5 2019-02-13 10 15.5 15,019 -1,132 Sierra Wireless, Inc. Common Shares Link, Rene Fernando 5 2019-05-09 57 25,540 1,049 Sierra Wireless, Inc. Common Shares Link, Rene Fernando 5 2019-05-09 10 13.06 24,491 -1,049 Sierra Wireless, Inc. Restricted Share Units Link, Rene Fernando 5 2019-02-12 57 15.69 17,643 -1,307 Sierra Wireless, Inc. Restricted Share Units Link, Rene Fernando 5 2019-02-13 57 15.5 14,876 -1,132 Sierra Wireless, Inc. Restricted Share Units Link, Rene Fernando 5 2019-05-09 57 13.06 50,703 -1,049 Sierra Wireless, Inc. Common Shares Osgoodby, Marc 5 2019-05-14 10 13.33 0 -2,034 Hubbard Sierra Wireless, Inc. Common Shares Overton, Marc Anthony 5 2019-02-12 57 6,733 1,639 John McHardy Sierra Wireless, Inc. Common Shares Overton, Marc Anthony 5 2019-02-12 10 15.69 5,094 -1,639 John McHardy Sierra Wireless, Inc. Common Shares Overton, Marc Anthony 5 2019-02-28 10 12.75 3,246 -1,848 John McHardy Sierra Wireless, Inc. Restricted Share Units Overton, Marc Anthony 5 2019-02-12 57 15.69 22,712 -1,639 John McHardy Sierra Wireless, Inc. Restricted Share Units Overton, Marc Anthony 5 2019-03-12 57 15.69 -1,639 John McHardy Sierra Wireless, Inc. Common Shares Schieler, August 7 2019-02-12 57 21,103 1,663 Daniel Sierra Wireless, Inc. Common Shares Schieler, August 7 2019-02-12 10 15.69 19,440 -1,663 Daniel Sierra Wireless, Inc. Common Shares Schieler, August 7 2019-02-13 57 23,313 1,432 Daniel Sierra Wireless, Inc. Common Shares Schieler, August 7 2019-02-13 10 15.5 21,881 -1,432 Daniel

August 8, 2019 (2019), 42 OSCB 6681

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Sierra Wireless, Inc. Restricted Share Units Schieler, August 7 2019-02-12 57 15.69 19,951 -1,663 Daniel Sierra Wireless, Inc. Restricted Share Units Schieler, August 7 2019-02-13 57 15.5 16,078 -1,432 Daniel Sierra Wireless, Inc. Common Shares Thexton, Kent Paul 4, 5 2019-05-31 10 16.32 54,595 -5,000 Sierra Wireless, Inc. Common Shares Thexton, Kent Paul 4, 5 2019-05-31 10 16.31 44,595 -10,000 Silver Viper Minerals Common Shares Cope, Gary Gordon 4 2019-07-29 10 0.25 2,601,000 42,500 Corp. Silver Viper Minerals Common Shares Cope, Gary Gordon 4 2019-07-29 10 0.235 2,618,500 17,500 Corp. Sintana Energy Inc. Common Shares Austin, Sean 5 2019-07-30 10 0.07 1,291,912 100,000 SITKA GOLD CORP. Common Shares Coe, Corwin 4, 5 2019-07-30 10 0.12 1,190,000 2,500 SITKA GOLD CORP. Common Shares Coe, Corwin 4, 5 2019-07-30 10 0.12 1,191,500 1,500 SITKA GOLD CORP. Common Shares COE, RYAN 4 2019-07-30 10 0.12 1,902,500 3,000 Skyharbour Resources Common Shares Trimble, Jordan 4 2019-07-31 10 0.29 606,250 10,000 Ltd. SmartCentres Real Class B Series 2 Units Goldhar, Mitchell 3 2003-10-31 00 Estate Investment of ONR Limited Trust (formerly, Smart Partnership I Real Estate Investment Trust) SmartCentres Real Class B Series 2 Units Goldhar, Mitchell 3 2019-07-30 11 33.65 2,193 Estate Investment of ONR Limited Trust (formerly, Smart Partnership I Real Estate Investment Trust) SmartCentres Real Class B Series 2 Units Goldhar, Mitchell 3 2019-07-30 11 33.65 2,193 Estate Investment of ONR Limited Trust (formerly, Smart Partnership I Real Estate Investment Trust) SmartCentres Real Class B Series 2 Units Goldhar, Mitchell 3 2019-07-30 90 33.64 -2,193 Estate Investment of ONR Limited Trust (formerly, Smart Partnership I Real Estate Investment Trust) SmartCentres Real Class B Series 2 Units Goldhar, Mitchell 3 2019-07-30 90 33.64 -2,193 Estate Investment of ONR Limited Trust (formerly, Smart Partnership I Real Estate Investment Trust) SmartCentres Real Class B Series 2 Units Goldhar, Mitchell 3 2019-07-30 11 33.64 2,193 Estate Investment of ONR Limited Trust (formerly, Smart Partnership I Real Estate Investment Trust) SmartCentres Real Class B Series 2 Units Goldhar, Mitchell 3 2019-07-30 11 33.64 2,193 Estate Investment of ONR Limited Trust (formerly, Smart Partnership I Real Estate Investment Trust) SmartCentres Real Class B Series 2 Units Goldhar, Mitchell 3 2019-07-30 11 33.64 2,193 2,193 Estate Investment of ONR Limited Trust (formerly, Smart Partnership I Real Estate Investment Trust) SmartCentres Real Class B Series 2 Units Goldhar, Mitchell 3 2019-07-30 90 33.64 0 -2,193 Estate Investment of ONR Limited Trust (formerly, Smart Partnership I Real Estate Investment Trust) SmartCentres Real Class B Series 2 Units Goldhar, Mitchell 3 2019-07-30 90 33.64 139,302 2,193 Estate Investment of ONR Limited Trust (formerly, Smart Partnership I Real Estate Investment Trust) SmartCentres Real Class C Series 2 Units Goldhar, Mitchell 3 2019-07-30 11 4.53 498,295 -1,482 Estate Investment of ONR Limited Trust (formerly, Smart Partership I Real Estate Investment Trust)

August 8, 2019 (2019), 42 OSCB 6682

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed SmartCentres Real Class C Series 2 Units Goldhar, Mitchell 3 2019-07-30 11 4.53 -16,209 Estate Investment of ONR Limited Trust (formerly, Smart Partership I Real Estate Investment Trust) SmartCentres Real Class C Series 2 Units Goldhar, Mitchell 3 2019-07-30 11 4.53 -16,209 Estate Investment of ONR Limited Trust (formerly, Smart Partership I Real Estate Investment Trust) SmartCentres Real Class C Series 2 Units Goldhar, Mitchell 3 2019-07-30 11 4.55 482,086 -16,209 Estate Investment of ONR Limited Trust (formerly, Smart Partership I Real Estate Investment Trust) SmartCentres Real Special Voting Units Goldhar, Mitchell 3 2019-07-30 11 9,109 2,193 Estate Investment Trust (formerly, Smart Real Estate Investment Trust) SmartCentres Real Special Voting Units Goldhar, Mitchell 3 2019-07-30 90 6,916 -2,193 Estate Investment Trust (formerly, Smart Real Estate Investment Trust) SmartCentres Real Special Voting Units Goldhar, Mitchell 3 2019-07-30 90 7,750,422 2,193 Estate Investment Trust (formerly, Smart Real Estate Investment Trust) Société d'exploration Common Shares Fedosiewich, Mark 5 2019-07-25 10 0.1 5,294,000 10,000 minière Vior Inc. Brian Société d'exploration Common Shares Fedosiewich, Mark 5 2019-07-26 10 0.1 5,304,000 10,000 minière Vior Inc. Brian Société d'exploration Common Shares Fedosiewich, Mark 5 2019-07-30 10 0.095 5,309,000 5,000 minière Vior Inc. Brian Société d'exploration Common Shares Fedosiewich, Mark 5 2019-07-30 10 0.1 5,313,000 4,000 minière Vior Inc. Brian SoftLab9 Software Common Shares Mohamed, Rahim 5 2019-03-06 37 3,094,247 -1,547,124 Solutions Inc. Solaris Copper Inc. Common Shares Hardie, Peter Jeremie 6 2018-12-31 57 40,523 1,250 Solaris Copper Inc. Common Shares Hardie, Peter Jeremie 6 2019-01-10 57 44,273 3,750 Solaris Copper Inc. Common Shares Hardie, Peter Jeremie 6 2019-03-15 57 47,864 3,591 Solaris Copper Inc. Rights Restricted Hardie, Peter Jeremie 6 2018-12-31 57 18,432 -1,250 Share Units (Time Based) Solaris Copper Inc. Rights Restricted Hardie, Peter Jeremie 6 2019-01-10 57 14,682 -3,750 Share Units (Time Based) Solaris Copper Inc. Rights Restricted Hardie, Peter Jeremie 6 2019-03-15 57 11,091 -3,591 Share Units (Time Based) Solaris Copper Inc. Options Koval, Marshall 6 2018-12-27 52 0.18 20,954 -2,849 Solaris Copper Inc. Common Shares Milau, Christian 6 2018-12-31 57 117,886 1,625 Solaris Copper Inc. Common Shares Milau, Christian 6 2019-01-10 57 122,386 4,500 Solaris Copper Inc. Common Shares Milau, Christian 6 2019-02-15 57 127,911 5,525 Solaris Copper Inc. Rights Restricted Milau, Christian 6 2018-12-31 57 17,775 -1,625 Share Units (Time Based) Solaris Copper Inc. Rights Restricted Milau, Christian 6 2019-01-10 57 13,275 -4,500 Share Units (Time Based) Solaris Copper Inc. Rights Restricted Milau, Christian 6 2019-03-15 57 7,750 -5,525 Share Units (Time Based) Solaris Copper Inc. Options Smith, Gregory 4, 5 2019-01-23 52 3.31 42,297 -3,101 Sonoro Metals Corp. Common Shares Darch, John Michael 4 2019-07-31 10 0.15 576,500 25,500 Sonoro Metals Corp. Common Shares Darch, John Michael 4 2019-07-31 10 0.15 578,000 1,500 Sonoro Metals Corp. Common Shares Herdrick, Melvin Allen 5 2019-08-01 16 0.18 854,507 110,000

August 8, 2019 (2019), 42 OSCB 6683

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Sonoro Metals Corp. Warrants Herdrick, Melvin Allen 5 2019-08-01 16 257,500 55,000 Sonoro Metals Corp. Common Shares Kenwood, Stephen 4 2019-08-02 16 0.18 456,916 110,000 Sonoro Metals Corp. Warrants Kenwood, Stephen 4 2019-08-02 16 0.27 155,000 55,000 Sonoro Metals Corp. Common Shares MacLeod, Kenneth 4, 5 2019-08-01 16 0.18 4,436,723 91,056 Sonoro Metals Corp. Warrants MacLeod, Kenneth 4, 5 2019-08-01 16 125,528 45,528 Sonoro Metals Corp. Common Shares Maedel, Neil Herman 8, 4 2019-08-02 16 0.18 515,000 200,000 Junior Sonoro Metals Corp. Warrants Maedel, Neil Herman 8, 4 2019-08-02 16 0.27 242,500 100,000 Junior Sonoro Metals Corp. Common Shares Regan, Katharine 8 2019-08-02 16 0.18 81,000 56,000 Elizabeth Sonoro Metals Corp. Warrants Regan, Katharine 8 2019-02-11 00 25,000 Elizabeth Sonoro Metals Corp. Warrants Regan, Katharine 8 2019-08-02 16 0.27 53,000 28,000 Elizabeth Spin Master Corp. Subordinate Voting Gadbois, Benoit 4, 5 2019-08-02 10 40.5 684,373 -108,000 Shares Spot Coffee (Canada) Common Shares AYOUB, ANTON 4, 5 2019-07-31 10 0.105 2,145,958 2,000 Ltd. MICHEL Spot Coffee (Canada) Common Shares AYOUB, ANTON 4, 5 2019-08-01 10 0.105 2,147,958 2,000 Ltd. MICHEL Spot Coffee (Canada) Common Shares AYOUB, ANTON 4, 5 2019-08-02 10 0.105 2,151,958 4,000 Ltd. MICHEL Spot Coffee (Canada) Common Shares Lorenzo, John Michael 4 2019-07-26 10 0.11 9,173,400 10,000 Ltd. Spot Coffee (Canada) Common Shares Lorenzo, John Michael 4 2019-07-30 10 0.105 9,183,400 10,000 Ltd. Spot Coffee (Canada) Common Shares Lorenzo, John Michael 4 2019-07-31 10 0.105 9,193,400 10,000 Ltd. St-Georges Eco- Common Shares Billings, Mark Anthony 4 2009-12-30 00 Mining Corp. St-Georges Eco- Common Shares Billings, Mark Anthony 4 2019-07-24 10 100,000 100,000 Mining Corp. St-Georges Eco- Common Shares Billings, Mark Anthony 4 2019-07-17 10 -100,000 Mining Corp. St-Georges Eco- Common Shares Billings, Mark Anthony 4 2019-07-24 10 3,976,895 -100,000 Mining Corp. Stans Energy Corp. Common Shares Stevens, Olga 5 2019-07-29 97 0.095 909,000 -20,000 Stans Energy Corp. Common Shares Stevens, Olga 5 2019-07-31 97 0.095 904,000 -5,000 Stans Energy Corp. Common Shares Stevens, Olga 5 2019-07-31 97 0.1 879,000 -25,000 Steppe Gold Ltd. Common Shares Marrelli, Carmelo 5 2017-02-06 00 30,072 Steppe Gold Ltd. Common Shares Marrelli, Carmelo 5 2018-05-03 00 Steppe Gold Ltd. Common Shares Marrelli, Carmelo 5 2018-05-03 00 Steppe Gold Ltd. Common Shares Marrelli, Carmelo 5 2018-07-11 00 Steppe Gold Ltd. Common Shares Marrelli, Carmelo 5 2017-02-06 00 Steppe Gold Ltd. Common Shares Marrelli, Carmelo 5 2018-05-03 00 Steppe Gold Ltd. Common Shares Marrelli, Carmelo 5 2018-05-03 00 Steppe Gold Ltd. Common Shares Marrelli, Carmelo 5 2018-07-11 00 Steppe Gold Ltd. Options Marrelli, Carmelo 5 2017-02-06 00 Steppe Gold Ltd. Options Marrelli, Carmelo 5 2018-05-03 00 Steppe Gold Ltd. Options Marrelli, Carmelo 5 2018-07-11 00 Steppe Gold Ltd. Warrants Marrelli, Carmelo 5 2017-02-06 00 Steppe Gold Ltd. Warrants Marrelli, Carmelo 5 2018-05-03 00 Steppe Gold Ltd. Warrants Marrelli, Carmelo 5 2018-07-11 00 Steppe Gold Ltd. Common Shares Waraich, Aneel Singh 4, 5 2019-07-24 10 1 542,875 1,380 Suncor Energy Inc. Common Shares MacDonald, Brian 4 2019-08-01 10 28.73 11,000 3,000 Patrick Suncor Energy Inc. Common Shares MacDonald, Brian 4 2019-08-02 10 28.27 13,000 2,000 Patrick Surge Energy Inc. Common Shares DUCS, JARED 5 2019-06-17 30 1.08 34,852 906 ANDREW RENTON Surge Energy Inc. Common Shares DUCS, JARED 5 2019-07-02 30 1.26 35,571 719 ANDREW RENTON

August 8, 2019 (2019), 42 OSCB 6684

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed SustainCo Inc. Common Shares Hazelton, Chris 5 2019-07-24 10 0.12 1,114,532 -15,500 SustainCo Inc. Common Shares Hazelton, Chris 5 2019-07-24 10 0.11 1,108,032 -6,500 SustainCo Inc. Common Shares Hazelton, Chris 5 2019-07-25 10 0.08 1,107,032 -1,000 SustainCo Inc. Common Shares Hazelton, Chris 5 2019-07-25 10 0.11 1,099,032 -8,000 TAG Oil Ltd Common Shares TAG Oil Ltd. 1 2019-07-24 10 0.34 16,500 TAG Oil Ltd Common Shares TAG Oil Ltd. 1 2019-07-24 10 0.34 13,500 13,500 TAG Oil Ltd Common Shares TAG Oil Ltd. 1 2019-07-24 38 -16,500 TAG Oil Ltd Common Shares TAG Oil Ltd. 1 2019-07-24 38 0 -13,500 TAG Oil Ltd Common Shares TAG Oil Ltd. 1 2019-07-29 10 0.335 500 500 TAG Oil Ltd Common Shares TAG Oil Ltd. 1 2019-07-29 38 0 -500 Taiga Gold Corp. Common Shares Jordan, Norman 1 2019-07-30 10 0 -12,500 Edward Talon Metals Corp. Common Shares Newfield, Warren Eric 4 2019-07-29 11 0.2166 14,021,415 300,000 Tamarack Valley Common Shares Christensen, David 5 2019-08-01 30 2.16 121,919 2,880 Energy Ltd. Keith Tamarack Valley Common Shares Cruikshank, Ken 5 2019-08-01 30 2.39 122,037 8,296 Energy Ltd. Tamarack Valley Common Shares GMT Capital Corp 3 2019-07-30 10 1.42 11,785,440 12,200 Energy Ltd. Tamarack Valley Common Shares GMT Capital Corp 3 2019-08-01 10 1.53 11,810,440 25,000 Energy Ltd. Tamarack Valley Common Shares GMT Capital Corp 3 2019-07-30 10 1.42 13,818,690 17,500 Energy Ltd. Tamarack Valley Common Shares GMT Capital Corp 3 2019-08-01 10 1.53 13,854,490 35,800 Energy Ltd. Tamarack Valley Common Shares GMT Capital Corp 3 2019-07-30 10 1.42 21,177,230 22,600 Energy Ltd. Tamarack Valley Common Shares GMT Capital Corp 3 2019-08-01 10 1.53 21,223,630 46,400 Energy Ltd. Tamarack Valley Common Shares GMT Capital Corp 3 2019-07-30 10 1.42 722,440 400 Energy Ltd. Tamarack Valley Common Shares GMT Capital Corp 3 2019-08-01 10 1.53 723,340 900 Energy Ltd. Tamarack Valley Common Shares GMT Capital Corp 3 2019-07-30 10 1.42 1,933,100 2,400 Energy Ltd. Tamarack Valley Common Shares GMT Capital Corp 3 2019-08-01 10 1.53 1,938,000 4,900 Energy Ltd. Tamarack Valley Common Shares Hozjan, Ronald Steve 5 2019-08-01 30 5417 2,495 Energy Ltd. Tamarack Valley Common Shares Hozjan, Ronald Steve 5 2019-08-01 30 2.17 322,444 2,495 Energy Ltd. Tamarack Valley Common Shares Reimond, Scott 5 2019-08-01 30 2.16 260,152 2,580 Energy Ltd. William Tamarack Valley Common Shares Schmidt, Brian Leslie 5 2019-08-01 30 2.16 662,793 4,252 Energy Ltd. Tamarack Valley Common Shares Screen, Kevin 5 2019-08-01 30 2.16 354,831 2,967 Energy Ltd. Teck Resources Class B Subordinate Pickering, Kenneth 4 2019-08-02 10 24.41 12,800 2,000 Limited Voting Shares William Tesoro Minerals Corp. Warrants Elliott, David Brian 3 2019-07-30 55 2,100 -90,720 Tethys Petroleum Common Shares Wells, William Paul 3, 4 2019-07-29 10 0.6 11,780,607 2,500 Limited Wells Tethys Petroleum Common Shares Wells, William Paul 3, 4 2019-07-30 10 0.6 11,785,607 5,000 Limited Wells Tetra Bio-Pharma Inc. Common Shares Bechard, Robert 5 2019-08-02 11 0.3 141,800 66,800 Tetra Bio-Pharma Inc. Warrants Bechard, Robert 5 2017-05-10 00 Tetra Bio-Pharma Inc. Warrants Bechard, Robert 5 2019-08-02 11 0.4 66,800 66,800 Tetra Bio-Pharma Inc. Common Shares Chamberland, Guy 5 2019-08-02 16 0.3 85,000 84,000 Tetra Bio-Pharma Inc. Warrants Chamberland, Guy 5 2016-04-01 00 Tetra Bio-Pharma Inc. Warrants Chamberland, Guy 5 2019-08-02 16 84,000 84,000 Tetra Bio-Pharma Inc. Common Shares CHELIAK, WILLIAM 4 2019-08-02 16 0.3 1,542,300 66,800 Tetra Bio-Pharma Inc. Warrants CHELIAK, WILLIAM 4 2017-07-10 00 Tetra Bio-Pharma Inc. Warrants CHELIAK, WILLIAM 4 2019-08-02 16 0.4 66,800 66,800 Tetra Bio-Pharma Inc. Common Shares Néron, Steve 5 2019-08-02 11 0.3 70,100 50,000

August 8, 2019 (2019), 42 OSCB 6685

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Tetra Bio-Pharma Inc. Warrant Néron, Steve 5 2018-08-20 00 50,000 Tetra Bio-Pharma Inc. Warrants Néron, Steve 5 2018-08-20 00 Tetra Bio-Pharma Inc. Warrants Néron, Steve 5 2019-08-02 16 0.4 50,000 50,000 TFI International Inc. Common Shares Bédard, Alain 4, 5 2019-07-30 51 16.46 4,106,668 50,000 TFI International Inc. Common Shares Bédard, Alain 4, 5 2019-07-30 10 41.83 4,056,668 -50,000 TFI International Inc. Options Bédard, Alain 4, 5 2019-07-30 51 2,509,457 -50,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-02 38 40.26 90,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-03 38 40.06 120,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-04 38 40.67 150,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-05 38 39.96 180,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-08 38 39.4 210,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-09 38 39.12 240,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-10 38 38.92 270,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-11 38 38.69 300,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-12 38 38.6 330,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-15 38 39.35 360,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-16 38 39.91 390,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-17 38 38.83 420,000 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-18 38 38.42 438,246 18,246 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-30 38 41.84 468,246 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-07-31 38 41.47 498,246 30,000 TFI International Inc. Common Shares TFI International Inc. 1 2019-08-01 38 60,000 -438,246 THC BIOMED INTL Options Chun, Hee Jung 3, 4, 5 2019-07-25 52 0.385 1,000,000 -500,000 LTD. THC BIOMED INTL Options Dave, Ashish 4 2019-07-25 52 0.385 1,000,000 -400,000 LTD. THC BIOMED INTL Options Miller, John 3, 4 2019-07-25 52 0.385 1,000,000 -500,000 LTD. The Supreme Common Shares Moore, Colin William 4 2018-05-15 00 Cannabis Company, Inc. The Supreme Common Shares Moore, Colin William 4 2019-08-01 10 1.38 10,000 10,000 Cannabis Company, Inc. The Supreme Common Shares Moore, Colin William 4 2019-08-01 10 1.39 20,000 10,000 Cannabis Company, Inc. The Toronto-Dominion Rights Deferred Share Bennett, William E. 4, 7 2019-07-31 46 77.1 106,970 85 Bank Units (DSU) The Toronto-Dominion Rights Deferred Share Brinkley, Amy Woods 4, 7 2019-07-31 46 77.1 51,903 478 Bank Units (DSU) The Toronto-Dominion Rights Deferred Share Brinkley, Amy Woods 4, 7 2019-07-31 46 77.1 52,098 195 Bank Units (DSU) The Toronto-Dominion Rights Deferred Share Ferguson, Brian 4 2019-07-31 46 77.1 17,542 430 Bank Units (DSU) Charles The Toronto-Dominion Rights Deferred Share Goggins, Colleen 4 2019-07-31 46 77.1 33,353 430 Bank Units (DSU) The Toronto-Dominion Rights Deferred Share Haddad, Mary Jo 4 2019-07-31 46 77.1 15,461 219 Bank Units (DSU) The Toronto-Dominion Rights Deferred Share Halde, Jean-Rene 4 2019-07-31 46 77.1 13,600 397 Bank Units (DSU) The Toronto-Dominion Rights Deferred Share Levitt, Brian 4 2019-07-31 46 77.1 95,479 722 Bank Units (DSU) The Toronto-Dominion Rights Deferred Share MacGibbon, Alan 4, 7 2019-07-31 46 77.1 30,641 450 Bank Units (DSU) The Toronto-Dominion Rights Deferred Share Maidment, Karen 4 2019-07-31 46 77.1 42,168 584 Bank Units (DSU) The Toronto-Dominion Rights Deferred Share Miller, Irene Ruth 4 2019-07-31 46 77.1 83,173 430 Bank Units (DSU) The Toronto-Dominion Rights Deferred Share Mohamed, Nadir 4 2019-07-31 46 77.1 58,055 365 Bank Units (DSU) The Toronto-Dominion Rights Deferred Share Mongeau, Claude 4 2019-07-31 46 77.1 16,860 397 Bank Units (DSU)

August 8, 2019 (2019), 42 OSCB 6686

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-02 38 77.02 450,000 450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-02 38 77.02 0 -450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-03 38 77.02 450,000 450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-03 38 77.02 0 -450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-04 38 77.02 450,000 450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-04 38 77.02 0 -450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-05 38 77.02 450,000 450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-05 38 77.02 0 -450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-09 38 77.02 450,000 450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-09 38 77.02 0 -450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-10 38 77.02 450,000 450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-10 38 77.02 0 -450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-11 38 77.02 450,000 450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-11 38 77.02 0 -450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-12 38 77.02 450,000 450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-12 38 77.02 0 -450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-15 38 77.02 450,000 450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-15 38 77.02 0 -450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-16 38 77.02 450,000 450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-16 38 77.02 0 -450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-17 38 77.02 450,000 450,000 Bank CUSIP 891160 50 9 Bank The Toronto-Dominion Common Shares The Toronto-Dominion 1 2019-07-17 38 77.02 0 -450,000 Bank CUSIP 891160 50 9 Bank The Yield Growth Common Shares Green, Penny Olga 3, 4, 5 2019-07-30 10 0.3 488,000 7,000 Corp. The Yield Growth Common Shares Green, Penny Olga 3, 4, 5 2019-07-30 10 0.305 498,000 10,000 Corp. The Yield Growth Common Shares Green, Penny Olga 3, 4, 5 2019-07-30 10 0.31 502,000 4,000 Corp. The Yield Growth Common Shares Green, Penny Olga 3, 4, 5 2019-07-30 10 0.315 504,000 2,000 Corp. The Yield Growth Common Shares Green, Penny Olga 3, 4, 5 2019-07-30 10 0.325 506,000 2,000 Corp. Theratechnologies Inc. Unités d'actions Frame, Sheila 4 2019-07-30 56 5.674 2,644 2,644 différées (DSU) ThreeD Capital Common Shares 1313366 Ontario Inc. 3 2019-08-01 10 0.0608 5,891,281 -660,000 Inc.(formerly Brownstone Energy Inc.) ThreeD Capital Common Shares Factor, Lynn 3 2019-07-31 10 0.07 3,650,000 -500,000 Inc.(formerly Brownstone Energy Inc.) ThreeD Capital Common Shares Kopman, Jeff 6 2019-08-01 10 0.0608 5,891,281 -660,000 Inc.(formerly Brownstone Energy Inc.)

August 8, 2019 (2019), 42 OSCB 6687

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed TMX Group Limited Rights Performance Fortin, Luc 5 2019-07-31 59 91.22 5,408 -440 Share Units TMX Group Limited Rights Restricted Fortin, Luc 5 2019-07-31 59 91.22 4,929 -440 Share Units Toromont Industries Common Shares Casson, Randall 7, 2 2019-07-29 51 26.52 130,000 10,000 Ltd. Toromont Industries Common Shares Casson, Randall 7, 2 2019-07-29 10 65.92 129,600 -400 Ltd. Toromont Industries Common Shares Casson, Randall 7, 2 2019-07-29 10 65.86 129,400 -200 Ltd. Toromont Industries Common Shares Casson, Randall 7, 2 2019-07-29 10 65.85 129,300 -100 Ltd. Toromont Industries Common Shares Casson, Randall 7, 2 2019-07-29 10 65.81 128,900 -400 Ltd. Toromont Industries Common Shares Casson, Randall 7, 2 2019-07-29 10 65.8 120,100 -8,800 Ltd. Toromont Industries Common Shares Casson, Randall 7, 2 2019-07-29 10 65.83 120,000 -100 Ltd. Toromont Industries Options Casson, Randall 7, 2 2019-07-29 51 26.52 193,500 -10,000 Ltd. Toromont Industries Common Shares Chisholm, Jeffrey Scott 4 2019-07-30 51 20.76 26,560 1,880 Ltd. Toromont Industries Options Chisholm, Jeffrey Scott 4 2019-07-30 51 20.76 0 -4,000 Ltd. Toromont Industries Common Shares Hill, Wayne S. 4 2019-07-29 51 20.76 32,650 10,000 Ltd. Toromont Industries Common Shares Hill, Wayne S. 4 2019-07-30 10 66.25 27,650 -5,000 Ltd. Toromont Industries Common Shares Hill, Wayne S. 4 2019-07-30 10 66.3 22,650 -5,000 Ltd. Toromont Industries Common Shares Hill, Wayne S. 4 2019-07-30 10 66.28 160,100 -5,000 Ltd. Toromont Industries Options Hill, Wayne S. 4 2019-07-29 51 20.76 0 -10,000 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 51 26.52 10,000 10,000 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.71 9,900 -100 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.69 9,700 -200 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.66 9,300 -400 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.65 7,600 -1,700 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.61 7,400 -200 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.6 4,600 -2,800 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.695 4,500 -100 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.67 4,000 -500 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.56 3,700 -300 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.55 2,000 -1,700 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.51 1,900 -100 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-30 10 65.5 0 -1,900 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-31 51 26.52 5,000 5,000 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-31 10 66.25 4,600 -400 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-31 10 66.24 4,500 -100 Ltd.

August 8, 2019 (2019), 42 OSCB 6688

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-31 10 66.23 3,900 -600 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-31 10 66.22 3,700 -200 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-31 10 66.21 3,400 -300 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-07-31 10 66.2 0 -3,400 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-08-01 51 26.52 5,000 5,000 Ltd. Toromont Industries Common Shares Jewer, Paul Randolph 5 2019-08-01 10 66.1 0 -5,000 Ltd. Toromont Industries Options Jewer, Paul Randolph 5 2019-07-30 51 26.52 220,000 -10,000 Ltd. Toromont Industries Options Jewer, Paul Randolph 5 2019-07-31 51 26.52 215,000 -5,000 Ltd. Toromont Industries Options Jewer, Paul Randolph 5 2019-08-01 51 26.52 210,000 -5,000 Ltd. Toromont Industries Common Shares Medhurst, Scott 4, 5 2019-08-01 51 23.4 15,500 Ltd. Toromont Industries Common Shares Medhurst, Scott 4, 5 2019-08-01 51 23.4 15,500 Ltd. Toromont Industries Common Shares Medhurst, Scott 4, 5 2019-08-01 51 23.4 163,494 6,813 Ltd. Toromont Industries Common Shares Medhurst, Scott 4, 5 2019-08-01 51 23.4 166,494 3,000 Ltd. Toromont Industries Common Shares Medhurst, Scott 4, 5 2019-08-01 10 65.57 163,494 -3,000 Ltd. Toromont Industries Options Medhurst, Scott 4, 5 2019-08-01 51 23.4 633,000 -15,500 Ltd. Toromont Industries Options Medhurst, Scott 4, 5 2019-08-01 51 23.4 630,000 -3,000 Ltd. Torrent Capital Ltd. Common Shares Dawe, Wade K. 5 2019-07-29 10 0.35 2,817,000 27,500 Torrent Capital Ltd. Common Shares Dawe, Wade K. 5 2019-07-30 10 0.375 2,835,000 18,000 Total Energy Services Common Shares Total Energy Services 1 2019-07-31 38 0 -8,100 Inc. Inc TransAlta Renewables DSU (Deferred Share Drinkwater, David 4 2019-07-31 56 13.69 24,276 138 Inc. Units) William TransAlta Renewables DSU (Deferred Share Hagerman, Allen R. 4 2019-07-31 56 13.69 26,362 150 Inc. Units) TransAlta Renewables DSU (Deferred Share McQuade, Kathryn 4 2019-07-31 56 13.69 28,260 161 Inc. Units) Ann Bova TransAlta Renewables DSU (Deferred Share TAYLOR, PAUL H. E. 4 2019-07-31 56 13.69 29,366 167 Inc. Units) TransCanada Common Shares TC Energy Corporation 3 2019-07-31 11 64.62 898,389,570 3,681,383 PipeLines Limited Transcanna Holdings Common Shares Johannson, Arni 4 2019-07-31 10 1.29 1,859,000 10,000 Inc. Thomas Transcontinental Inc. Participation Units Brues, Peter 4 2019-07-28 56 14.6 6,189 2,175 d'actions différées (UAD-administrateurs) / (DSU-directors) Transcontinental Inc. Participation Units Cote, Jacynthe 4 2019-07-28 56 14.6 17,935 2,637 d'actions différées (UAD-administrateurs) / (DSU-directors) Transcontinental Inc. Participation Units Leduc, Yves 4 2019-07-28 56 14.6 9,039 1,713 d'actions différées (UAD-administrateurs) / (DSU-directors) Transcontinental Inc. Participation Units Marcoux, Nathalie 4, 6 2019-07-28 56 14.6 28,166 1,541 d'actions différées (UAD-administrateurs) / (DSU-directors) Transcontinental Inc. Participation Units Martini, Anna 4 2019-07-28 56 14.6 50,346 1,969 d'actions différées (UAD-administrateurs) / (DSU-directors)

August 8, 2019 (2019), 42 OSCB 6689

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Transcontinental Inc. Participation Units Plourde, Mario 4 2019-07-28 56 14.6 21,438 1,849 d'actions différées (UAD-administrateurs) / (DSU-directors) Transcontinental Inc. Participation Units Raymond, Jean 4 2019-07-28 56 14.6 12,135 2,603 d'actions différées (UAD-administrateurs) / (DSU-directors) Transcontinental Inc. Participation Units Thabet, Annie 4 2019-07-28 56 14.6 13,795 1,224 d'actions différées (UAD-administrateurs) / (DSU-directors) Treasury Metals Inc. Common Shares Vereecke, Christophe 4 2019-07-30 10 0.35 806,000 56,000 TREE OF Common Shares Caridi, Michael 4 2018-05-02 00 11,074,270 KNOWLEDGE INTERNATIONAL CORP. TREE OF Common Shares Caridi, Michael 4 2018-12-19 36 0.22 12,255,429 1,181,159 KNOWLEDGE INTERNATIONAL CORP. Tricon Capital Group Common Shares Tricon Capital Group 1 2019-07-17 38 9.99 39,100 39,100 Inc. Inc. Tricon Capital Group Common Shares Tricon Capital Group 1 2019-07-18 38 10 43,100 4,000 Inc. Inc. Tricon Capital Group Common Shares Tricon Capital Group 1 2019-07-19 38 9.99 125,702 82,602 Inc. Inc. Tricon Capital Group Common Shares Tricon Capital Group 1 2019-07-22 38 9.96 156,702 31,000 Inc. Inc. Tricon Capital Group Common Shares Tricon Capital Group 1 2019-07-24 38 9.99 223,602 66,900 Inc. Inc. Tricon Capital Group Common Shares Tricon Capital Group 1 2019-07-25 38 9.94 256,752 33,150 Inc. Inc. Tricon Capital Group Common Shares Tricon Capital Group 1 2019-07-26 38 9.95 280,052 23,300 Inc. Inc. Tricon Capital Group Common Shares Tricon Capital Group 1 2019-07-29 38 9.99 289,852 9,800 Inc. Inc. Tricon Capital Group Common Shares Tricon Capital Group 1 2019-07-30 38 9.99 313,152 23,300 Inc. Inc. Tricon Capital Group Common Shares Tricon Capital Group 1 2019-07-31 38 0 -313,152 Inc. Inc. TriStar Gold Inc. Options Jones, III, Mark E. 4 2019-06-07 52 0.15 1,500,000 -200,000 TriStar Gold Inc. Options Krol, Leendert G. 4 2019-06-07 52 0.15 975,000 -175,000 TriStar Gold Inc. Options Vilhena, Carlos A. 4 2019-06-07 52 0.15 375,000 -175,000 TruTrace Technologies Options Carter, James 4 2019-07-30 50 400,000 100,000 Inc. TruTrace Technologies Options Chell, Cameron 4 2019-07-30 50 0.25 900,000 100,000 Inc. TruTrace Technologies Options Galarza, Robert 4, 5 2019-07-30 50 975,000 175,000 Inc. TruTrace Technologies Options Kakumanu, Swapan 4, 5 2019-07-30 50 0.25 400,000 100,000 Inc. TruTrace Technologies Options Kraft, Michael 4 2019-07-30 50 900,000 100,000 Inc. TruTrace Technologies Options Stephenson, Thomas 5 2019-07-30 50 975,000 175,000 Inc. Dermonte UGE International Ltd. Options Varrone, Crescent 4 2019-06-24 52 0.78 450,000 -36,000 Richard UGE International Ltd. Options Varrone, Crescent 4 2019-06-24 52 0.36 330,000 -120,000 Richard Uniserve Common Shares Morley, Owen Stewart 3 2019-07-30 00 6,250,000 Communications Corporation Uniserve Warrants Scholz, Michael Curt 4 2019-07-30 97 0.12 11,298,041 -491,244 Communications Corporation Uranium Energy Corp. Common Shares ABRAHAM, Edward 4 2019-08-01 46 0.9904 145,321 3,282 Spencer

August 8, 2019 (2019), 42 OSCB 6690

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Uranium Energy Corp. Common Shares ABRAHAM, Edward 4 2019-08-01 46 0.9904 146,836 1,515 Spencer Uranium Energy Corp. Options ABRAHAM, Edward 4 2019-07-30 50 1,370,000 100,000 Spencer Uranium Energy Corp. Rights Restricted ABRAHAM, Edward 4 2015-10-14 00 Stock Units Spencer Uranium Energy Corp. Rights Restricted ABRAHAM, Edward 4 2019-07-30 56 20,000 20,000 Stock Units Spencer Uranium Energy Corp. Options Adnani, Amir 4, 5 2019-07-30 50 2,915,000 550,000 Uranium Energy Corp. Rights Performance Adnani, Amir 4, 5 2005-12-05 00 Based Restricted Stock Units Uranium Energy Corp. Rights Performance Adnani, Amir 4, 5 2019-07-30 56 600,000 600,000 Based Restricted Stock Units Uranium Energy Corp. Rights Restricted Adnani, Amir 4, 5 2005-12-05 00 Stock Units Uranium Energy Corp. Rights Restricted Adnani, Amir 4, 5 2019-07-30 56 300,000 300,000 Stock Units Uranium Energy Corp. Common Shares Ballesta, Gloria 4 2019-07-30 46 0.9421 37,630 35,000 Uranium Energy Corp. Common Shares Ballesta, Gloria 4 2019-08-01 46 0.9904 38,803 1,173 Uranium Energy Corp. Options Ballesta, Gloria 4 2019-07-30 50 210,000 50,000 Uranium Energy Corp. Common Shares Della Volpe, Vincent 4 2019-07-30 46 0.9421 183,487 35,000 Uranium Energy Corp. Common Shares Della Volpe, Vincent 4 2019-08-01 46 0.9904 185,002 1,515 Uranium Energy Corp. Options Della Volpe, Vincent 4 2019-07-30 50 365,000 50,000 Uranium Energy Corp. Common Shares Kong, David 4 2019-07-30 46 0.9421 106,260 35,000 Uranium Energy Corp. Common Shares Kong, David 4 2019-08-01 46 0.9904 107,757 1,497 Uranium Energy Corp. Options Kong, David 4 2019-07-30 50 375,000 50,000 Uranium Energy Corp. Common Shares MANI, GANPAT 4 2019-07-30 46 0.9421 110,443 35,000 Uranium Energy Corp. Common Shares MANI, GANPAT 4 2019-08-01 46 0.9904 111,958 1,515 Uranium Energy Corp. Options MANI, GANPAT 4 2019-07-30 50 275,000 50,000 Uranium Energy Corp. Common Shares Melbye, Scott Eric 5 2019-08-01 46 0.9904 273,224 4,065 Uranium Energy Corp. Options Melbye, Scott Eric 5 2019-07-30 50 925,000 125,000 Uranium Energy Corp. Rights Performance Melbye, Scott Eric 5 2014-09-08 00 Based Restricted Stock Units Uranium Energy Corp. Rights Performance Melbye, Scott Eric 5 2019-07-30 56 90,000 90,000 Based Restricted Stock Units Uranium Energy Corp. Rights Restricted Melbye, Scott Eric 5 2014-09-08 00 Stock Units Uranium Energy Corp. Rights Restricted Melbye, Scott Eric 5 2019-07-30 56 45,000 45,000 Stock Units Uranium Energy Corp. Common Shares Obara, Pat 5 2019-08-01 46 0.9904 354,402 1,975 Uranium Energy Corp. Options Obara, Pat 5 2019-07-30 50 868,000 200,000 Uranium Energy Corp. Rights Performance Obara, Pat 5 2015-10-29 00 Based Restricted Stock Units Uranium Energy Corp. Rights Performance Obara, Pat 5 2019-07-30 56 200,000 200,000 Based Restricted Stock Units Uranium Energy Corp. Rights Restricted Obara, Pat 5 2015-10-29 00 Stock Units Uranium Energy Corp. Rights Restricted Obara, Pat 5 2019-07-30 56 100,000 100,000 Stock Units Valens Groworks Common Shares Fretwell, Gordon 5 2019-08-02 10 3.6735 183,265 -3,233 Corp. (formerly Genovation Capital Corp.) VALEO PHARMA INC. Common Shares Class 100079 Canada Inc. 3 2019-07-25 15 0.5 8,020,965 50,000 A VALEO PHARMA INC. Common Shares Class 100079 Canada Inc. 3 2019-07-25 15 0.5 8,070,965 50,000 A VALEO PHARMA INC. Warrants 100079 Canada Inc. 3 2019-07-25 15 0.5 452,204 50,000 VALEO PHARMA INC. Warrants 100079 Canada Inc. 3 2019-07-25 15 0.5 502,204 50,000

August 8, 2019 (2019), 42 OSCB 6691

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed VALEO PHARMA INC. Common Shares Class Allard, Guy Paul 6, 5 2019-07-29 10 0.4 368,969 2,500 A VALEO PHARMA INC. Common Shares Class Allard, Guy Paul 6, 5 2019-07-29 10 0.4 372,969 4,000 A VALEO PHARMA INC. Common Shares Class MacKay, Richard J. 4, 6 2019-07-25 15 0.5 8,020,965 50,000 A VALEO PHARMA INC. Common Shares Class MacKay, Richard J. 4, 6 2019-07-25 15 0.5 8,070,965 50,000 A VALEO PHARMA INC. Warrants MacKay, Richard J. 4, 6 2019-07-25 15 0.5 452,204 50,000 VALEO PHARMA INC. Warrants MacKay, Richard J. 4, 6 2019-07-25 15 0.5 502,204 50,000 VALEO PHARMA INC. Common Shares Class Manitex Capital Inc. 3 2019-07-25 16 0.5 1,613,482 A VALEO PHARMA INC. Common Shares Class Manitex Capital Inc. 3 2019-07-25 16 0.5 21,780,130 1,613,842 A VALEO PHARMA INC. Warrants Manitex Capital Inc. 3 2019-07-25 16 1,613,482 VALEO PHARMA INC. Warrants Manitex Capital Inc. 3 2019-07-25 16 1,613,842 1,613,842 VALEO PHARMA INC. Common Shares Class Saviuk, Steve 4, 6, 5 2019-07-25 16 0.5 1,613,482 A VALEO PHARMA INC. Common Shares Class Saviuk, Steve 4, 6, 5 2019-07-25 16 0.5 21,780,130 1,613,842 A VALEO PHARMA INC. Warrants Saviuk, Steve 4, 6, 5 2019-07-25 16 1,613,482 VALEO PHARMA INC. Warrants Saviuk, Steve 4, 6, 5 2019-07-25 16 1,613,842 1,613,842 Velocity Minerals Ltd. Common Shares Artemis Gold Inc. 3 2019-07-19 00 18,600,000 Velocity Minerals Ltd. Convertible Artemis Gold Inc. 3 2019-07-19 00 $5,094,000 Debentures Velocity Minerals Ltd. Warrants Artemis Gold Inc. 3 2019-07-19 00 9,300,000 Vermilion Energy Inc. Common Shares Preston, Kyle 5 2019-07-25 00 23,281 Vermilion Energy Inc. Common Shares Preston, Kyle 5 2019-07-25 00 10,000 Vermilion Energy Inc. Rights Share Awards Preston, Kyle 5 2019-07-25 00 23,640 Versus Systems Inc. Common Shares Peymani, Keyvan 4 2019-07-29 11 0.2 1,250,000 1,250,000 Versus Systems Inc. Warrants Peymani, Keyvan 4 2016-06-30 00 Versus Systems Inc. Warrants Peymani, Keyvan 4 2019-07-29 11 1,250,000 1,250,000 Vista Gold Corp. Phantom Stock Earnest, Frederick H. 5 2019-07-25 59 76,000 -38,000 Vista Gold Corp. Phantom Stock Rozelle, John W. 5 2019-07-25 59 21,333 -10,667 Walcott Resources Common Shares Farris, Marshall 3, 4, 5 2019-07-30 00 1,500,000 Ltd. Walcott Resources Common Shares Mabone, Tracy 4, 5 2019-07-30 00 820,000 Ltd. Walcott Resources Common Shares Mirko, John Martin 4 2019-07-30 00 1,200,000 Ltd. Wall Financial Common Shares Redekop, Michael 4 2019-08-01 10 22.2 340,000 -400 Corporation. Clare Wescan Goldfields Inc. Common Shares MacNeill, Sharon 3 2019-06-12 00 5,960,450 Western Forest Common Shares Western Forest 1 2019-07-02 38 1.6223 50,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-03 38 1.6289 100,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-04 38 1.6563 150,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-05 38 1.6411 200,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-08 38 1.6113 250,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-09 38 1.5321 300,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-10 38 1.52 350,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-11 38 1.4951 400,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-12 38 1.4863 450,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-15 38 1.4532 500,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-16 38 1.4636 550,000 50,000 Products Inc. Products Inc.

August 8, 2019 (2019), 42 OSCB 6692

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Western Forest Common Shares Western Forest 1 2019-07-17 38 1.4249 600,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-18 38 1.4543 650,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-19 38 1.4706 700,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-22 38 1.4293 750,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-23 38 1.4708 800,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-24 38 1.5051 850,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-25 38 1.4751 900,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-26 38 1.4411 950,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-29 38 1.4253 1,000,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-30 38 1.4286 1,050,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-31 38 1.42 1,100,000 50,000 Products Inc. Products Inc. Western Forest Common Shares Western Forest 1 2019-07-31 38 100,000 -1,000,000 Products Inc. Products Inc. Westleaf Inc. Common Shares Church, Cody 4 2019-04-07 00 258,823 White Metal Common Shares Strashin, Elliot Phillip 3, 4, 5 2019-08-01 10 0.055 2,893,617 50,000 Resources Corp. White Metal Common Shares Strashin, Elliot Phillip 3, 4, 5 2019-08-02 10 0.057 2,961,617 68,000 Resources Corp. White Metal Common Shares Strashin, Elliot Phillip 3, 4, 5 2019-07-30 10 0.045 15,000 Resources Corp. White Metal Common Shares Strashin, Elliot Phillip 3, 4, 5 2019-07-30 10 0.045 15,000 Resources Corp. White Metal Common Shares Strashin, Elliot Phillip 3, 4, 5 2019-07-30 10 0.035 5,000 Resources Corp. White Metal Common Shares Strashin, Elliot Phillip 3, 4, 5 2019-07-30 10 0.035 5,000 Resources Corp. White Metal Common Shares Strashin, Elliot Phillip 3, 4, 5 2019-07-31 10 0.04 50,000 Resources Corp. White Metal Common Shares Strashin, Elliot Phillip 3, 4, 5 2019-07-31 10 0.04 50,000 Resources Corp. White Metal Common Shares Strashin, Elliot Phillip 3, 4, 5 2019-08-02 10 0.04 62,000 Resources Corp. White Metal Common Shares Strashin, Elliot Phillip 3, 4, 5 2019-08-02 10 0.04 62,000 Resources Corp. Willow Biosciences Common Shares Archibald, Donald 4 2019-05-17 37 571,429 -13,714,285 Inc. Willow Biosciences Options Archibald, Donald 4 2019-05-17 37 200,000 -4,800,000 Inc. Willow Biosciences Warrants Archibald, Donald 4 2019-05-17 37 571,429 -13,714,285 Inc. Willow Biosciences Common Shares Doupe, Travis 5 2019-05-17 37 258,408 -6,201,792 Inc. Willow Biosciences Options Doupe, Travis 5 2019-05-17 37 512,400 -12,297,600 Inc. Willow Biosciences Warrants Doupe, Travis 5 2019-05-17 37 200,000 -4,800,000 Inc. Willow Biosciences Common Shares Ericsson, Jerry Daniel 5 2019-05-17 37 1,460,200 -35,044,800 Inc. Willow Biosciences Common Shares Facchini, Peter James 5 2019-05-17 37 6,069,025 -145,656,605 Inc. Willow Biosciences Warrants Facchini, Peter James 5 2019-05-17 37 5,714 -137,143 Inc. Willow Biosciences Common Shares Hagel, Jillian Marie 5 2019-05-17 37 3,383,191 -81,196,573 Inc. Willow Biosciences Warrants Hagel, Jillian Marie 5 2019-05-17 37 5,714 -137,143 Inc.

August 8, 2019 (2019), 42 OSCB 6693

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Willow Biosciences Common Shares KALANTZIS, FOTIS 4 2019-05-17 37 491,371 -11,792,912 Inc. Willow Biosciences Options KALANTZIS, FOTIS 4 2019-05-17 37 200,000 -4,800,000 Inc. Willow Biosciences Warrants KALANTZIS, FOTIS 4 2019-05-17 37 491,371 -11,792,912 Inc. Willow Biosciences Common Shares Lalani, Sadiq 4 2019-07-31 10 0.75 300,000 20,000 Inc. Willow Biosciences Common Shares Lalani, Sadiq 4 2019-08-01 10 0.75 20,000 Inc. Willow Biosciences Common Shares Lalani, Sadiq 4 2019-08-01 10 0.68 320,000 20,000 Inc. Willow Biosciences Options Lalani, Sadiq 4 2019-05-21 37 0.07 200,000 -4,800,000 Inc. Willow Biosciences Warrants Lalani, Sadiq 4 2019-05-21 37 0.035 280,000 -6,720,000 Inc. Willow Biosciences Common Shares Peters, Trevor Anthony 4, 5 2019-05-17 37 2,804,582 -67,309,960 Inc. Willow Biosciences Common Shares Peters, Trevor Anthony 4, 5 2019-07-12 10 0.85 2,909,582 5,000 Inc. Willow Biosciences Common Shares Peters, Trevor Anthony 4, 5 2019-07-15 10 0.8 2,914,582 5,000 Inc. Willow Biosciences Common Shares Peters, Trevor Anthony 4, 5 2019-07-24 10 0.88 2,919,582 5,000 Inc. Willow Biosciences Common Shares Peters, Trevor Anthony 4, 5 2019-07-25 10 0.86 2,924,582 5,000 Inc. Willow Biosciences Common Shares Peters, Trevor Anthony 4, 5 2019-07-29 10 0.77 2,925,082 500 Inc. Willow Biosciences Warrants Peters, Trevor Anthony 4, 5 2019-05-17 37 745,700 -17,896,792 Inc. Willow Biosciences Common Shares Schuetz, Mathias 5 2019-05-17 37 1,471,629 -35,319,085 Inc. Maximilian Willow Biosciences Warrants Schuetz, Mathias 5 2019-05-17 37 11,429 -274,285 Inc. Maximilian Willow Biosciences Common Shares Seufer-Wasserthal, 4 2019-05-17 37 274,571 -6,589,715 Inc. Peter Willow Biosciences Options Seufer-Wasserthal, 4 2019-05-17 37 200,000 -4,800,000 Inc. Peter Willow Biosciences Warrants Seufer-Wasserthal, 4 2019-05-17 37 274,571 -6,589,715 Inc. Peter Willow Biosciences Common Shares Talkkari, Troy Tapan 5 2019-05-02 00 Inc. Willow Biosciences Common Shares Talkkari, Troy Tapan 5 2019-07-30 10 0.855 25,000 25,000 Inc. Willow Biosciences Options Talkkari, Troy Tapan 5 2019-05-17 37 200,000 -4,800,000 Inc. Willow Biosciences Common Shares Tucker, Joseph 4, 5 2019-05-17 37 3,050,980 -73,223,530 Inc. Edward Lovell Willow Biosciences Warrants Tucker, Joseph 4, 5 2019-05-17 37 30,000 -720,000 Inc. Edward Lovell X-Terra Resources Common Shares Champagne, Sylvain 4, 5 2019-07-29 10 0.09 500,000 90,000 Inc. Xanadu Mines Ltd Ordinary Shares Shao Ming, Tan 6 2019-06-10 97 0 -87,962,715 Xanadu Mines Ltd Ordinary Shares Shao Ming, Tan 6 2019-06-10 97 0 -66,756,241 Xanadu Mines Ltd Ordinary Shares Welch, Mathew Nevil 6 2019-07-15 57 0.0477 2,075,306 191,391 Ximen Mining Corp. Warrants Anderson, Christopher 4 2019-07-26 11 1,400,694 240,385 Ross Ximen Mining Corp. Warrants Anderson, Christopher 4 2019-07-26 11 1,623,908 223,214 Ross Ximen Mining Corp. Common Shares Warthe-Anderson, 4 2018-07-26 51 444,100 50,000 Wesley Ximen Mining Corp. Options Warthe-Anderson, 4 2018-02-14 50 110,000 50,000 Wesley Ximen Mining Corp. Options Warthe-Anderson, 4 2018-07-26 50 60,000 -50,000 Wesley Ximen Mining Corp. Options Warthe-Anderson, 4 2018-12-27 50 0.3 135,000 75,000 Wesley

August 8, 2019 (2019), 42 OSCB 6694

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Price Date/Month Acquired/ Date End Holdings Disposed Xtierra Inc. Common Shares Gallagher, Timothy 3, 4, 5 2019-07-25 10 0.055 6,907,000 395,000 David Xtierra Inc. Common Shares Gallagher, Timothy 3, 4, 5 2019-07-26 10 0.055 9,394,000 400,000 David Xtra-Gold Resources Common Shares Xtra-Gold Resources 1 2019-08-02 38 0.385 62,500 62,500 Corp. Corp. Xtra-Gold Resources Common Shares Xtra-Gold Resources 1 2019-08-02 38 0 -62,500 Corp. Corp. YDX Innovation Corp. Common Shares Garcia, Jamil 5 2019-07-19 00 Fernando ZEN Graphene Common Shares Fenton, Gregory 4 2019-07-31 10 0.3 674,500 200,000 Solutions Ltd.

August 8, 2019 (2019), 42 OSCB 6695

Insider Reporting

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August 8, 2019 (2019), 42 OSCB 6696

Chapter 11

IPOs, New Issues and Secondary Financings

INVESTMENT FUNDS

Issuer Name: Issuer Name: Discovery 2019 Short Duration LP Mackenzie Broad Risk Premia Collection Fund Principal Regulator - Alberta (ASC) Mackenzie Enhanced Equity Risk Premia Fund Type and Date: Mackenzie Enhanced Fixed Income Risk Premia Fund Preliminary Long Form Prospectus dated August 2, 2019 Mackenzie Multi-Strategy Absolute Return Fund Received on August 2, 2019 Principal Regulator - Ontario Offering Price and Description: Type and Date: - Amendment #1 to Final Annual Information Form dated Underwriter(s) or Distributor(s): August 1, 2019 N/A Received on August 2, 2019 Promoter(s): Offering Price and Description: N/A - Project #2947213 Underwriter(s) or Distributor(s): N/A ______Promoter(s): Issuer Name: Mackenzie Financial Corporation Emerge ARK AI & Big Data ETF (formerly, Emerge ARK Project #2883862 Artificial Intelligence ETF) Emerge ARK Autonomous Tech & Robotics ETF (formerly, ______Emerge ARK Autonomous Technology ETF) Issuer Name: Emerge ARK Genomics & Biotech ETF (formerly, Emerge Mackenzie Canadian Resource Fund ARK Genomic Revolution ETF) Principal Regulator - Ontario Emerge ARK Global Disruptive Innovation ETF Type and Date: Emerge ARK Israel Innovative Technology Index ETF Amendment #3 to Final Simplified Prospectus and Principal Regulator - Ontario Amendment #4 to Annual Information Form dated August Type and Date: 2, 2019 Amended and Restated to Final Long Form Prospectus Received on August 2, 2019 dated July 31, 2019 Offering Price and Description: Received on July 31, 2019 - Offering Price and Description: Underwriter(s) or Distributor(s): - LBC Financial Services Inc. Underwriter(s) or Distributor(s): Promoter(s): N/A Mackenzie Financial Corporation Promoter(s): Project #2827888 Emerge Canada Inc. Project #2873690 ______Issuer Name: ______Mackenzie Global Macro Fund Principal Regulator - Ontario Type and Date: Amendment #1 to Final Annual Information Form dated August 1, 2019 Received on August 2, 2019 Offering Price and Description: - Underwriter(s) or Distributor(s): N/A Promoter(s): Mackenzie Financial Corporation Project #2853423

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August 8, 2019 (2019), 42 OSCB 6697

IPOs, New Issues and Secondary Financings

Issuer Name: Issuer Name: Mackenzie Global Growth Balanced Fund Mackenzie Balanced ETF Portfolio Principal Regulator - Ontario Mackenzie Canadian Balanced Fund Type and Date: Mackenzie Canadian Growth Balanced Class Amendment #1 to Final Annual Information Form dated Mackenzie Canadian Growth Balanced Fund August 1, 2019 Mackenzie Conservative ETF Portfolio Received on August 2, 2019 Mackenzie Conservative Income ETF Portfolio Offering Price and Description: Mackenzie Cundill Canadian Balanced Fund - Mackenzie Global Sustainability and Impact Balanced Fund Underwriter(s) or Distributor(s): Mackenzie Growth ETF Portfolio N/A Mackenzie Ivy Canadian Balanced Class Promoter(s): Mackenzie Ivy Canadian Balanced Fund Mackenzie Financial Corporation Mackenzie Ivy Global Balanced Class Project #2853426 Mackenzie Ivy Global Balanced Fund Mackenzie Moderate Growth ETF Portfolio ______Mackenzie Monthly Income Balanced Portfolio Issuer Name: Mackenzie Monthly Income Conservative Portfolio AGF U.S. Small-Mid Cap Fund (formerly, AGF Aggressive Mackenzie Private Canadian Focused Equity Pool U.S. Growth Fund) Mackenzie Private Canadian Focused Equity Pool Class Principal Regulator - Ontario Mackenzie Private Global Conservative Income Balanced Type and Date: Pool Amendment #2 to Final Simplified Prospectus dated July Mackenzie Private Global Equity Pool 26, 2019 Mackenzie Private Global Equity Pool Class NP 11-202 Receipt dated July 30, 2019 Mackenzie Private Global Income Balanced Pool Offering Price and Description: Mackenzie Private Income Balanced Pool - Mackenzie Private Income Balanced Pool Class Underwriter(s) or Distributor(s): Mackenzie Private US Equity Pool AGF Funds Inc. Mackenzie Private US Equity Pool Class Promoter(s): Symmetry Balanced Portfolio N/A Symmetry Balanced Portfolio Class Project #2885099 Symmetry Conservative Income Portfolio Symmetry Conservative Income Portfolio Class ______Symmetry Conservative Portfolio Issuer Name: Symmetry Conservative Portfolio Class Emerge ARK AI & Big Data ETF (formerly, Emerge ARK Symmetry Equity Portfolio Class Artificial Intelligence ETF) Symmetry Fixed Income Portfolio Emerge ARK Autonomous Tech & Robotics ETF (formerly, Symmetry Growth Portfolio Emerge ARK Autonomous Technology ETF) Symmetry Growth Portfolio Class Emerge ARK Genomics & Biotech ETF (formerly, Emerge Symmetry Moderate Growth Portfolio ARK Genomic Revolution ETF) Symmetry Moderate Growth Portfolio Class Emerge ARK Global Disruptive Innovation ETF Principal Regulator - Ontario Emerge ARK Israel Innovative Technology Index ETF Type and Date: Principal Regulator - Ontario Amendment #5 to Final Annual Information Form dated Type and Date: July 29, 2019 Amended and restated to Final Long Form Prospectus NP 11-202 Receipt dated July 31, 2019 dated July 31, 2019 Offering Price and Description: NP 11-202 Receipt dated July 31, 2019 - Offering Price and Description: Underwriter(s) or Distributor(s): - Quadrus Investment Services Ltd. Underwriter(s) or Distributor(s): LBC Financial Services Inc N/A Promoter(s): Promoter(s): Mackenzie Financial Corporation Emerge Canada Inc. Project #2804068 Project #2873690 ______

August 8, 2019 (2019), 42 OSCB 6698

IPOs, New Issues and Secondary Financings

Issuer Name: Issuer Name: Mackenzie Canadian Growth Balanced Class Balanced Portfolio Mackenzie Canadian Growth Balanced Fund Conservative Portfolio Mackenzie Monthly Income Balanced Portfolio Growth Portfolio Mackenzie Monthly Income Conservative Portfolio High Growth Portfolio Mackenzie Private Canadian Focused Equity Pool Invesco 1-5 Year Laddered Corporate Bond Index ETF Mackenzie Private Canadian Focused Equity Pool Class Fund (formerly, PS 1-5 Year Laddered Corporate Bond Mackenzie Private Global Conservative Income Balanced Index Fund) Pool Invesco Active Multi-Sector Credit Fund (formerly, Invesco Mackenzie Private Global Equity Pool Advantage Bond Fund) Mackenzie Private Global Equity Pool Class Invesco Allocation Fund Mackenzie Private Global Income Balanced Pool Invesco Balanced Portfolio Mackenzie Private Income Balanced Pool Invesco Canada Money Market Fund Mackenzie Private Income Balanced Pool Class Invesco Canadian Class (formerly, Trimark Canadian Mackenzie Private US Equity Pool Class) Mackenzie Private US Equity Pool Class Invesco Canadian Core Plus Bond Class (formerly, Invesco Symmetry Balanced Portfolio Canadian Bond Class) Symmetry Balanced Portfolio Class Invesco Canadian Core Plus Bond Fund (formerly, Invesco Symmetry Conservative Income Portfolio Canadian Bond Fund) Symmetry Conservative Income Portfolio Class Invesco Canadian Dividend Index ETF Class (formerly, Symmetry Conservative Portfolio PowerShares Canadian Dividend Index Class) Symmetry Conservative Portfolio Class Invesco Canadian Endeavour Fund (formerly, Trimark Symmetry Equity Portfolio Class Canadian Endeavour Fund) Symmetry Fixed Income Portfolio Invesco Canadian Fund (formerly, Trimark Canadian Fund) Symmetry Growth Portfolio Invesco Canadian Interest Fund (formerly, Trimark Interest Symmetry Growth Portfolio Class Fund) Symmetry Moderate Growth Portfolio Invesco Canadian Opportunity Class (formerly, Trimark Symmetry Moderate Growth Portfolio Class Canadian Opportunity Class) Principal Regulator - Ontario Invesco Canadian Opportunity Fund (formerly, Trimark Type and Date: Canadian Opportunity Fund) Amendment #3 to Final Annual Information Form dated Invesco Canadian Plus Dividend Class (formerly, Trimark July 29, 2019 Canadian Plus Dividend Class) NP 11-202 Receipt dated July 30, 2019 Invesco Canadian Preferred Share Index ETF Class Offering Price and Description: (formerly, PowerShares Canadian Preferred Share Index - Class) Underwriter(s) or Distributor(s): Invesco Canadian Premier Balanced Fund (formerly, LBC Financial Services Inc. Invesco Canadian Balanced Fund) Promoter(s): Invesco Canadian Premier Growth Class Mackenzie Financial Corporation Invesco Canadian Premier Growth Fund Project #2827888 Invesco Canadian Real Return Bond Index Fund (formerly, PowerShares Real Return Bond Index Fund) Invesco Canadian Short-Term Bond Fund (formerly, ______Invesco Short-Term Bond Fund) Invesco Canadian Small Companies Fund (formerly, Trimark Canadian Small Companies Fund) Invesco Conservative Portfolio Invesco Core Canadian Balanced Class Invesco Diversified Yield Class (formerly, Trimark Diversified Yield Class) Invesco Emerging Markets Class (formerly, Trimark Emerging Markets Class) Invesco Emerging Markets Select Pool Invesco Energy Class (formerly, Trimark Energy Class) Invesco European Growth Class Invesco Europlus Fund (formerly, Trimark Europlus Fund) Invesco Floating Rate Income Fund Invesco FTSE RAFI Canadian Index ETF Class (formerly, PowerShares FTSE RAFI® Canadian Fundamental Index Class) Invesco FTSE RAFI Emerging Markets ETF Class (formerly, PowerShares FTSE RAFI® Emerging Markets Fundamental Class)

August 8, 2019 (2019), 42 OSCB 6699

IPOs, New Issues and Secondary Financings

Invesco FTSE RAFI Global+ ETF Fund (formerly, Invesco S&P/TSX Composite Low Volatility Index ETF PowerShares FTSE RAFI® Global+ Fundamental Fund) Class (formerly, PowerShares Canadian Low Volatility Invesco FTSE RAFI U.S. ETF Fund (formerly, Index Class) PowerShares FTSE RAFI® U.S. Fundamental Fund) Invesco Select Balanced Fund (formerly, Trimark Select Invesco Global Balanced Class (formerly, Trimark Global Balanced Fund) Balanced Class) Invesco Select Canadian Equity Fund Invesco Global Balanced Fund (formerly, Trimark Global Invesco Short-Term Income Class Balanced Fund) Invesco Strategic Yield Fund Invesco Global Bond Fund Invesco Tactical Bond ETF Fund (formerly, PowerShares Invesco Global Companies Fund (formerly, Trimark Fund) Tactical Bond Fund) Invesco Global Diversified Companies Class (formerly, Invesco U.S. Companies Class (formerly, Trimark U.S. Trimark Global Fundamental Equity Class) Companies Class) Invesco Global Diversified Companies Fund (formerly, Invesco U.S. Companies Fund (formerly, Trimark U.S. Trimark Global Fundamental Equity Fund) Companies Fund) Invesco Global Diversified Income Fund (formerly, Trimark Invesco U.S. High Yield Bond Index Fund (formerly, Global Diversified Income Fund) PowerShares High Yield Corporate Bond Index Fund) Invesco Global Dividend Achievers ETF Fund (formerly, Invesco U.S. Money Market Fund (formerly, Trimark U.S. PowerShares Global Dividend Achievers Fund) Money Market Fund) Invesco Global Dividend Class (formerly, Trimark Global Invesco U.S. Small Companies Class (formerly, Trimark Dividend Class) U.S. Small Companies Class) Invesco Global Dividend Income Fund Moderate Portfolio Invesco Global Endeavour Class (formerly, Trimark Global Principal Regulator - Ontario Endeavour Class) Type and Date: Invesco Global Endeavour Fund (formerly, Trimark Global Combined Preliminary and Pro Forma Simplified Endeavour Fund) Prospectus dated Jul 26, 2019 Invesco Global Growth Class NP 11-202 Final Receipt dated Aug 1, 2019 Invesco Global High Yield Bond Fund Offering Price and Description: Invesco Global Monthly Income Fund Series T6 units Invesco Global Real Estate Fund Series T4CAP shares Invesco Global Small Companies Class (formerly, Trimark Series PFH shares Global Small Companies Class) Series PH shares Invesco Growth Portfolio Series T8 shares Invesco High Growth Portfolio Series F6 units Invesco Income Growth Fund (formerly, Trimark Income Series B shares Growth Fund) Series F shares Invesco Indo-Pacific Fund Series F6 shares Invesco Intactive 2023 Portfolio Series PF shares Invesco Intactive 2028 Portfolio Series PF4 shares Invesco Intactive 2033 Portfolio Series F4 shares Invesco Intactive 2038 Portfolio Series A units Invesco Intactive Balanced Growth Portfolio Series D units Invesco Intactive Balanced Growth Portfolio Class Series T6 shares Invesco Intactive Balanced Income Portfolio Series T4 units Invesco Intactive Balanced Income Portfolio Class Series O units Invesco Intactive Diversified Income Portfolio Series I units Invesco Intactive Diversified Income Portfolio Class Series DCA Heritage units Invesco Intactive Growth Portfolio Class A shares Invesco Intactive Growth Portfolio Class Series PT4 shares Invesco Intactive Maximum Growth Portfolio Series D shares Invesco Intactive Maximum Growth Portfolio Class Series FH shares Invesco International Companies Class (formerly, Trimark Series T4 shares International Companies Class) Series PT4 units Invesco International Companies Fund (formerly, Trimark Series PF6 units International Companies Fund) Series PF units Invesco International Growth Class Series DSC units Invesco International Growth Fund Series PT6 shares Invesco Moderate Portfolio Series PF6 shares Invesco Monthly Income ETF Portfolio (formerly, Series T8CAP shares PowerShares Monthly Income Fund) Series PTFU units Invesco Resources Fund (formerly, Trimark Resources Series A shares Fund) Series I shares Invesco S&P 500 Low Volatility Index ETF Fund (formerly, Series PTFU shares PowerShares U.S. Low Volatility Index Fund) Series F units

August 8, 2019 (2019), 42 OSCB 6700

IPOs, New Issues and Secondary Financings

Series PF4 units Issuer Name: Series T8 units Horizons Balanced TRI ETF Portfolio Series PT6 units Horizons Conservative TRI ETF Portfolio Series F4 units Horizons Growth TRI ETF Portfolio Series PTF shares Principal Regulator – Ontario Series DCA units Principal Regulator - Ontario Series M units Type and Date: Series PT8 shares Combined Preliminary and Pro Forma Long Form Series PF8 shares Prospectus dated Jul 29, 2019 Series H shares NP 11-202 Final Receipt dated ul 31, 2019 Series SC units Offering Price and Description: Series P units Class A Units Series P shares Underwriter(s) or Distributor(s): Series H units N/A Series T6CAP shares Promoter(s): Series F8 shares N/A Series PTF units Project #2933375 Series ACAP shares Underwriter(s) or Distributor(s): ______N/A Issuer Name: Promoter(s): Purpose Structured Equity Yield Portfolio N/A Principal Regulator - Ontario Project #2921461 Type and Date: Preliminary Simplified Prospectus dated Aug 1, 2019 ______NP 11-202 Preliminary Receipt dated Aug 1, 2019 Issuer Name: Offering Price and Description: iShares Core Conservative Balanced ETF Portfolio Series F shares iShares Core Equity ETF Portfolio Series A shares iShares Core Income Balanced ETF Portfolio Series I shares Principal Regulator - Ontario Underwriter(s) or Distributor(s): Type and Date: N/A. Preliminary Long Form Prospectus dated Jul 30, 2019 Promoter(s): NP 11-202 Final Receipt dated Jul 31, 2019 N/A Offering Price and Description: Project #2946418 Units Underwriter(s) or Distributor(s): ______N/A Issuer Name: Promoter(s): Sentry Global Monthly Income Fund (formerly, Sentry N/A Global Balanced Income Fund) Project #2927163 Principal Regulator - Ontario Type and Date: ______Amendment #1 to Final Simplified Prospectus dated July Issuer Name: 31, 2019 iShares Edge MSCI USA Momentum Factor Index ETF NP 11-202 Receipt dated Aug 2, 2019 iShares Edge MSCI USA Quality Factor Index ETF Offering Price and Description: iShares Edge MSCI USA Value Factor Index ETF Series A securities, Series B securities, Series F securities, iShares S&P U.S. Small-Cap Index ETF Series I securities, Series P securities iShares S&P U.S. Small-Cap Index ETF (CAD-Hedged) Underwriter(s) or Distributor(s): Principal Regulator - Ontario N/A. Type and Date: Promoter(s): Preliminary Long Form Prospectus dated Jul 30, 2019 N/A NP 11-202 Final Receipt dated Jul 31, 2019 Project #2918575 Offering Price and Description: Units ______Underwriter(s) or Distributor(s): N/A Promoter(s): N/A Project #2932802

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August 8, 2019 (2019), 42 OSCB 6701

IPOs, New Issues and Secondary Financings

Issuer Name: Manulife Growth Opportunities Class Manulife Asia Equity Class Manulife Growth Opportunities Fund Manulife Balanced Equity Private Pool Manulife Growth Portfolio Manulife Balanced Income Private Trust Manulife Income Fund 2022 Manulife Balanced Portfolio Manulife Income Fund 2027 Manulife Bond Fund Manulife Income Fund 2032 Manulife Canadian Balanced Fund Manulife Income Fund 2037 Manulife Canadian Balanced Private Pool Manulife Income Fund 2042 Manulife Canadian Dividend Growth Class Manulife Income Fund 2047 Manulife Canadian Dividend Growth Fund Manulife Income Fund 2052 Manulife Canadian Equity Private Pool Manulife Income Fund 2057 Manulife Canadian Growth and Income Private Trust Manulife Income Fund 2062 Manulife Canadian Investment Class Manulife Income Fund 2067 Manulife Canadian Unconstrained Bond Fund Manulife International Equity Private Trust Manulife China Class Manulife Moderate Portfolio Manulife Conservative Portfolio Manulife Money Market Fund Manulife Corporate Bond Fund Manulife Monthly High Income Class Manulife Corporate Fixed Income Private Trust Manulife Monthly High Income Fund Manulife Covered Call U.S. Equity Class Manulife Quantitative Fixed Income Fund 2022 Manulife Covered Call U.S. Equity Fund Manulife Quantitative Fixed Income Fund 2027 Manulife Diversified Alpha Portfolio Manulife Quantitative Fixed Income Fund 2032 Manulife Diversified Investment Fund Manulife Quantitative Fixed Income Fund 2037 Manulife Dividend Income Class Manulife Quantitative Fixed Income Fund 2042 Manulife Dividend Income Fund Manulife Simplicity Balanced Portfolio Manulife Dividend Income Plus Class Manulife Simplicity Conservative Portfolio Manulife Dividend Income Plus Fund Manulife Simplicity Global Balanced Portfolio Manulife Dividend Income Private Pool Manulife Simplicity Growth Portfolio Manulife Dollar-Cost Averaging Fund Manulife Simplicity Moderate Portfolio Manulife EAFE Equity Fund (formerly Manulife International Manulife Strategic Balanced Yield Fund Focused Fund) Manulife Strategic Dividend Bundle Manulife Emerging Markets Fund Manulife Strategic Income Fund Manulife Floating Rate Income Fund Manulife Strategic Investment Grade Global Bond Fund Manulife Fundamental Balanced Class Manulife Tactical Income Fund Manulife Fundamental Dividend Class Manulife U.S. All Cap Equity Class Manulife Fundamental Dividend Fund Manulife U.S. All Cap Equity Fund Manulife Fundamental Equity Class Manulife U.S. Balanced Private Trust Manulife Fundamental Equity Fund Manulife U.S. Balanced Value Private Trust Manulife Fundamental Income Class Manulife U.S. Dividend Income Class Manulife Fundamental Income Fund Manulife U.S. Dividend Income Fund Manulife Global All Cap Focused Fund Manulife U.S. Dollar Strategic Balanced Yield Fund Manulife Global Balanced Fund Manulife U.S. Dollar Strategic Income Fund Manulife Global Balanced Private Trust Manulife U.S. Dollar U.S. All Cap Equity Fund Manulife Global Core Plus Bond Fund Manulife U.S. Equity Fund Manulife Global Dividend Class Manulife U.S. Equity Private Pool Manulife Global Dividend Fund Manulife U.S. Monthly High Income Fund Manulife Global Dividend Growth Class Manulife U.S. Opportunities Fund Manulife Global Dividend Growth Fund Manulife U.S. Unconstrained Bond Fund Manulife Global Equity Class Manulife Value Balanced Class Manulife Global Equity Private Pool Manulife Value Balanced Fund Manulife Global Fixed Income Private Trust Manulife World Investment Class Manulife Global Franchise Class (formerly Manulife Global Manulife World Investment Fund Equity Unconstrained Class) Manulife Yield Opportunities Fund Manulife Global Franchise Fund (formerly Manulife Global Principal Regulator - Ontario Equity Unconstrained Fund) Type and Date: Manulife Global Infrastructure Class Combined Preliminary and Pro Forma Simplified Manulife Global Infrastructure Fund Prospectuses dated Aug 1, 2019 Manulife Global Real Estate Unconstrained Fund NP 11-202 Final Receipt dated Aug 2, 2019 Manulife Global Small Cap Balanced Fund Offering Price and Description: Manulife Global Small Cap Fund Series HH securities, Series H securities, Series D Manulife Global Strategic Balanced Yield Fund securities, Series CT6 securities, Series N securities, Manulife Global Thematic Opportunities Class Series GF securities, Series T6 securities, Series GA Manulife Global Thematic Opportunities Fund securities, Series B securities, Advisor Series securities, Manulife Global Unconstrained Bond Fund Series L securities, Series LT6 securities, Series C

August 8, 2019 (2019), 42 OSCB 6702

IPOs, New Issues and Secondary Financings securities, Series FT6 securities, Series HE securities, Series F securities Underwriter(s) or Distributor(s): N/A. Promoter(s): N/A Project #2928268

______

August 8, 2019 (2019), 42 OSCB 6703

IPOs, New Issues and Secondary Financings

NON-INVESTMENT FUNDS

Issuer Name: Issuer Name: American Aires Inc. National Access Cannabis Corp. (formerly Brassneck Principal Regulator - Ontario Capital Corp.) Type and Date: Principal Regulator - Ontario Preliminary Long Form Prospectus dated July 30, 2019 Type and Date: NP 11-202 Preliminary Receipt dated July 31, 2019 Final Shelf Prospectus dated August 1, 2019 Offering Price and Description: NP 11-202 Receipt dated August 2, 2019 Minimum Offering: $7,200,000.00 Offering Price and Description: Maximum Offering: $7,560,000.00 $200,000,000 Minimum of 24,000,000 Common Shares and up to a COMMON SHARES Maximum of 25,200,000 Common Shares (the “Offering”) PREFERRED SHARES Price: C$0.30 Per Common Share WARRANTS SUBSCRIPTION RECEIPTS Underwriter(s) or Distributor(s): UNITS CANACCORD GENUITY CORP. DEBT SECURITIES Promoter(s): Underwriter(s) or Distributor(s): Dimitry Serov - Igor Serov Promoter(s): Project #2945289 - ______Project #2931298 Issuer Name: ______Green Growth Brands Inc. (formerly Xanthic Biopharma Issuer Name: Inc.) Northway Resources Corp. Principal Regulator - Ontario Principal Regulator - British Columbia Type and Date: Type and Date: Preliminary Short Form Prospectus dated July 29, 2019 Final Long Form Prospectus dated July 30, 2019 NP 11-202 Preliminary Receipt dated July 30, 2019 NP 11-202 Receipt dated August 1, 2019 Offering Price and Description: Offering Price and Description: $50,225,000.00 - 20,500,000 Units Minimum of 15,000,000 Common Shares and up to a Price: C$2.45 per Offered Unit Maximum of 20,000,000 Common Shares Underwriter(s) or Distributor(s): Price: $0.10 per Common Share CANACCORD GENUITY CORP. Minimum of $1,500,000.00 and up to a maximum of EIGHT CAPITAL $2,000,000.00 CORMARK SECURITIES INC. Underwriter(s) or Distributor(s): GMP SECURITIES L.P. HAYWOOD SECURITIES INC. PARADIGM CAPITAL INC. ECHELON WEALTH PARTNERS INC. BEACON SECURITIES LIMITED Promoter(s): HAYWOOD SECURITIES INC. Zachary Flood Promoter(s): Kenorland Minerals Ltd. ALL JS GREENSPACE LLC Project #2929159 CHIRON VENTURES INC. ______Project #2942612 Issuer Name: ______Sun Residential Real Estate Investment Trust Principal Regulator - Ontario Type and Date: Amended and Restated Final CPC Prospectus dated July 26, 2019 NP 11-202 Receipt dated July 31, 2019 Offering Price and Description: MINIMUM OFFERING: $250,000.00 (2,500,000 Trust Units) MAXIMUM OFFERING: $500,000.00 (5,000,000 Trust Units) Price: C$0.10 per Trust Unit Underwriter(s) or Distributor(s): Raymond James Ltd. Promoter(s): - Project #2903155 ______

August 8, 2019 (2019), 42 OSCB 6704

IPOs, New Issues and Secondary Financings

Issuer Name: Issuer Name: Sundial Growers Inc. Toronto Hydro Corporation Principal Regulator - Alberta Principal Regulator - Ontario Type and Date: Type and Date: Final Long Form Prospectus dated July 30, 2019 Final Shelf Prospectus dated July 30, 2019 NP 11-202 Receipt dated July 30, 2019 NP 11-202 Receipt dated July 30, 2019 Offering Price and Description: Offering Price and Description: 10,000,000 Common Shares $1,000,000,000.00 DEBENTURES (unsecured) Underwriter(s) or Distributor(s): Underwriter(s) or Distributor(s): BMO Nesbitt Burns Inc.. BMO NESBITT BURNS INC. RBC Dominion Securities Inc. CIBC WORLD MARKETS INC. Barclays Capital Canada Inc. NATIONAL BANK FINANCIAL INC. CIBC World Markets Inc. RBC DOMINION SECURITIES INC. Scotia Capital Inc.. SCOTIA CAPITAL INC. Promoter(s): TD SECURITIES INC. - Promoter(s): Project #2938509 - ______Project #2939739 Issuer Name: ______The Flowr Corporation (formerly The Needle Capital Corp.) Issuer Name: Principal Regulator - Ontario TransCanada PipeLines Limited Type and Date: Principal Regulator - Alberta Final Short Form Prospectus dated August 2, 2019 Type and Date: NP 11-202 Receipt dated August 2, 2019 Preliminary Shelf Prospectus dated August 2, 2019 Offering Price and Description: Received on August 2, 2019 $43,501,000.00 - 10,610,000 Units Offering Price and Description: Price: $4.10 per Unit $3,000,000,000.00 Underwriter(s) or Distributor(s): Medium Term Note Debentures GMP Securities L.P. (Unsecured) BMO Nesbitt Burns Inc. Underwriter(s) or Distributor(s): AltaCorp Capital Inc. BMO NESBITT BURNS INC. Clarus Securities Inc. CIBC WORLD MARKETS INC. Sprott Capital Partners LP NATIONAL BANK FINANCIAL INC. Promoter(s): RBC DOMINION SECURITIES INC. Thomas Flow SCOTIA CAPITAL INC. Steven Klein TD SECURITIES INC. Project #2942048 Promoter(s): ______- Issuer Name: Project #2947140 Tidewater Midstream and Infrastructure Ltd. ______Principal Regulator - Alberta Issuer Name: Type and Date: TransCanada Trust Final Short Form Prospectus dated August 1, 2019 Principal Regulator - Alberta NP 11-202 Receipt dated August 1, 2019 Type and Date: Offering Price and Description: Preliminary Short Form Prospectus dated August 1, 2019 $75,000,000.00 - 5.50% Convertible Unsecured NP 11-202 Preliminary Receipt dated August 1, 2019 Subordinated Debentures Offering Price and Description: Due September 30, 2024 U.S.$*.** Price: $1,000 per Debenture Trust Notes — Series 2019-A Due *, 2079 Underwriter(s) or Distributor(s): (Trust Notes — Series 2019-A) CIBC WORLD MARKETS INC. Underwriter(s) or Distributor(s): NATIONAL BANK FINANCIAL INC. - RBC DOMINION SECURITIES INC. Promoter(s): ALTACORP CAPITAL INC. TransCanada PipeLines Limited CORMARK SECURITIES INC. Project #2946679 SCOTIA CAPITAL INC. ______MACQUARIE CAPITAL MARKETS CANADA LTD. Promoter(s): - Project #2942581 ______

August 8, 2019 (2019), 42 OSCB 6705

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August 8, 2019 (2019), 42 OSCB 6706

Chapter 12

Registrations

12.1.1 Registrants

Type Company Category of Registration Effective Date From: Pentecostal Securities Corp. Name Change Restricted Dealer July 12, 2019 To: Covenant Securities Corp.

Driehaus Capital Voluntary Surrender Portfolio Manager July 31, 2019 Management LLC From: Portfolio Manager

Baskin Financial Services Change in Registration To: Investment Fund August 1, 2019 Inc. Manager and Portfolio Manager

From: Investment Fund Manager, Portfolio Manager, Change in Registration Equium Capital Management and Exempt Market Dealer August 2, 2019 Category Inc. To: Portfolio Manager and Exempt Market Dealer

August 8, 2019 (2019), 42 OSCB 6707

Registrations

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August 8, 2019 (2019), 42 OSCB 6708

Chapter 13

SROs, Marketplaces, Clearing Agencies and Trade Repositories

13.1 SROs

13.1.1 Investment Industry Regulatory Organization of Canada (IIROC) – Amendments Respecting Provision of Price Improvement by a Dark Order – Notice of Commission Approval

NOTICE OF COMMISSION APPROVAL

INVESTMENT INDUSTRY REGULATORY ORGANIZATION OF CANADA (IIROC)

AMENDMENTS RESPECTING PROVISION OF PRICE IMPROVEMENT BY A DARK ORDER

The Ontario Securities Commission has approved IIROC's proposed amendments to the Universal Market Integrity Rules respecting provision of price improvement by a dark order (the “Amendments”).

The Amendments modify the dark order price improvement requirements when trading against certain orders by adding a minimum order value of $30,000, in addition to the current threshold of 50 standard trading units. The combination of both a minimum dollar value and a minimum volume threshold will better capture small orders, especially those in low-price securities for the purposes of dark order price improvement requirements.

The Amendments were published for public comment on December 13, 2018. IIROC received ten comment letters on the Amendments and no changes have subsequently been made to the Amendments. A copy of the IIROC Notice, including the text of the Amendments, can be found at http://www.osc.gov.on.ca.

The Amendments will come into force on February 4, 2020, being 180 days after the publication of this Notice of Approval.

In addition, the Alberta Securities Commission; the Autorité des marchés financiers; the British Columbia Securities Commission; the Financial and Consumer Affairs Authority of Saskatchewan; the Financial and Consumer Services Commission of New Brunswick; the Legal Registries Division, Department of Justice (Northwest Territories); the Legal Registries Division, Department of Justice (Nunavut); the Manitoba Securities Commission; the Nova Scotia Securities Commission; the Office of the Superintendent of Securities, Service Newfoundland and Labrador; the Office of the Yukon Superintendent of Securities; and the Prince Edward Island Office of the Superintendent of Securities Office have approved or not objected to the Amendments.

August 8, 2019 (2019), 42 OSCB 6709

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13.2 Marketplaces

13.2.1 CSE – Amendments to Trading System Functionality & Features – Notice and Request for Comment

CANADIAN SECURITIES EXCHANGE

SIGNIFICANT CHANGE SUBJECT TO PUBLIC COMMENT

AMENDMENTS TO TRADING SYSTEM FUNCTIONALITY & FEATURES

NOTICE AND REQUEST FOR COMMENT

CNSX Markets Inc., (“CSE” or “the Exchange”) is filing this Notice in accordance with the process for the Review and Approval of Rules and Information Contained in Form 21-101F1 and the Exhibits Thereto attached as Appendices to the Exchange’s recognition orders (the “Protocol”). The Exchange intends to implement enhancements to its trading system in response to customer feedback. The proposed changes are described below.

A. Description of the Proposed Changes

CSE Closing Price (CCP) Session for CSE Listed

CSE is proposing a Closing Price Session (“CCP”) that will follow the close of continuous trading for CSE listed securities. A period between the close of continuous trading and the start of the CCP session will allow dealers an opportunity to remove orders from the book before the CCP session begins.

 The CSE Closing Price will be defined by the last CSE trade prior to the close at 4:00 p.m. that would have qualified for establishing a national last sale price (“NLSP”).

o If there are no qualifying trades during the current session, the CCP will continue to be the CCP from the previous trading day.

 The current ability to cancel orders between the close at 4:00 p.m. and system shutdown at 8:00 p.m. will remain in place.

 At 4:15 p.m. order entry will be enabled for the CCP which will continue until 5:00pm

o There will be no pre-open period prior to the CCP session. The market state will change directly from closed to continuous trading.

o Securities that are in a halted state as of the close at 4:00 p.m. will remain halted through the CCP session.

o At 5:00 p.m. the market will close and remain closed until the system is shutdown for the day.

 Board-lot orders and the board-lot portion of mixed-lot orders already in the book when the CCP begins can participate in the CCP session.

o Peg, on-stop, terms, odd-lot and the odd-lot portion of mixed-lot orders will not participate in the CCP session.

o All trades will occur at the CCP price with the exception of noted Specialty Price Crosses.

o Orders in the book with limits more aggressive than the CCP will be allowed to match at the CCP against incoming CCP limit orders.

o Iceberg orders in the book with limits more aggressive than the CCP will be allowed to match at the CCP against incoming CCP limit orders but if the iceberg order replenishes, the replenished visible volume will be priced at the CCP. Any volume not traded will be restored to the original limit price following the CCP session.

August 8, 2019 (2019), 42 OSCB 6710

SROs, Marketplaces, Clearing Agencies and Trade Repositories

 During the CCP session Regular, Internal, Basis, VWAP, Derivative-Related, CCP and Contingent Crosses may be entered.

o Board-lot, odd-lot and mix-lot cross volumes will be accepted.

o VWAP and Basis crosses will be accepted and may trade at any price, subject to regulatory restrictions, but will not change the CCP.

o All other Intentional crosses (with the exception of noted Specialty Price Crosses) will only be accepted if priced at the CCP but are subject to existing rules related to their price relative to the CSE BBO. If the CCP is outside the BBO this may require that orders more aggressive than the CCP be traded out at the CCP before an Intentional cross can be entered.

o Normal cross interference will apply to crosses in the CCP session as it does in continuous trading.

 Mixed-lot, odd-lot, on-stop, terms, peg and Seek Dark orders will not be accepted.

 During the CCP session board-lot orders may be entered.

o Only orders with a limit price of the CCP will be accepted.

o Durations of Day, IOC, GTD, FOK and GTC will be accepted. Unfilled portions of GTD and GTC orders will remain in the book until the next trading day unless cancelled prior to the system shutdown.

 Orders may be amended during the CCP session but price amendments will not be accepted.

 New orders subject to OPR Reprice protection that cannot trade or book at the CSE CCP price based on the NBBO at the time will be cancelled as opposed to being repriced.

 The GMF, participation and odd-lot auto-fill facilities will be inactive during the CCP session.

 Normal CSE matching priorities of price, broker then time will apply during the CCP session.

CSE CCP Session Cross Type

CSE will be adding a CSE Closing Price Session Cross type (“CCP Cross”) that will allow dealers to mark an Internal Cross as CCP type when entering the cross on behalf of a client during the CCP session.

 CCP Crosses may only be entered during the CCP session.

 CCP Crosses may only be priced at the CCP.

 Rules related to the Internal Cross price relative to the CSE BBO will apply.

 CCP Crosses will not be subject to cross interference.

B. Expected Implementation Date: Q1 2020

C. Rationale and Analysis

CSE is proposing the CSE Closing Price Session in response to customer demand for the ability to trade at the CSE closing price. In addition, the CCP Cross will permit the execution of Cross orders at the CSE closing price for ETF and other portfolio rebalancing. This additional functionality provides consistency with the other marketplaces in Canada that offered similar closing price sessions.

The use of the CSE Closing Price Session or the CSE Closing Price Cross is optional for participants.

August 8, 2019 (2019), 42 OSCB 6711

SROs, Marketplaces, Clearing Agencies and Trade Repositories

D. Expected Impact

The expected impact is minimal with a more seamless and simplified workflow for Industry stakeholders. The changes respond to customer demand and provide competition with the offerings of other marketplaces. The use of these order types and options is optional.

E. Compliance with Ontario and British Columbia Securities Laws

There will be no impact on the CSE’s compliance with Ontario and British Columbia securities laws. The changes do not alter any of the requirements for fair access or the maintenance of fair and orderly markets.

F. Technology Changes

Clients already support similar features on other Canadian marketplaces and therefore we do not anticipate there to be a material effort. The new functionality is optional and should require minimal effort to implement.

G. Other Markets or Jurisdictions

The table below identifies where the proposed functionality is new or currently available.

ORDER TYPE MARKETS AVAILABLE

Closing Price Session TMX, Aequitas

Closing Price Cross TMX

Comments

Please submit comments on the proposed amendments no later than September 10, 2019 to:

Mark Faulkner Market Regulation Branch Vice President, Listings and Regulation Ontario Securities Commission CNSX Markets Inc. 20 Queen Street West, 20th Floor 220 Bay Street, 9th Floor Toronto, ON, M5H 3S8 Toronto, ON, M5J 2W4 Fax: 416.595.8940 Fax: 416.572.4160 Email: [email protected] Email: [email protected] Vida Mehin Senior Legal Counsel, Capital Markets Regulation British Columbia Securities Commission 701 West Georgia Street P.O. Box 10142, Pacific Centre Vancouver, BC, V7Y 1L2 Email: [email protected]

August 8, 2019 (2019), 42 OSCB 6712

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13.2.2 CSE – Notice of Withdrawal of Proposed Amendments to Trading Rules

CANADIAN SECURITIES EXCHANGE

NOTICE OF WITHDRAWAL OF PROPOSED AMENDMENTS TO TRADING RULES

In accordance with the Process for the Review and Approval of Rules and the Information Contained in Form 21-101F1 and the Exhibits thereto (the "Protocol") in Appendix C of the Ontario Securities Commission's Recognition Order recognizing CNSX Markets Inc. (the “CSE”) as an exchange, the proposed “Pegged Order Max Qty” is deemed to have been withdrawn as provided in subsection 10(e) of the Protocol.

Proposed changes to CSE trading rules were published for comment on August 9, 2018 (see CSE Notice 2018-006). The proposed amendments would have introduced five new order types. Four of these order types were approved by the OSC on December 6, 2018; however the “Pegged Order Max Qty” was not addressed in that notice. To the extent the CSE decides to pursue this proposal again, it will be published for comment in accordance with the requirements of the Protocol.

August 8, 2019 (2019), 42 OSCB 6713

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13.3 Clearing Agencies

13.3.1 Banque Centrale De Compensation Carrying on Business as LCH SA – Application for Exemption from Recognition as a Clearing Agency – OSC Notice and Request for Comment

OSC NOTICE AND REQUEST FOR COMMENT

BANQUE CENTRALE DE COMPENSATION CARRYING ON BUSINESS AS LCH SA

APPLICATION FOR EXEMPTION FROM RECOGNITION AS A CLEARING AGENCY

A. Background

Banque Centrale de Compensation carrying on business as LCH SA (LCH SA) has applied to the Ontario Securities Commission (Commission) for an order pursuant to section 147 of the Securities Act (Ontario) (OSA) to exempt it from the requirement to be recognized as a clearing agency in subsection 21.2(0.1) of the OSA.

LCH SA is a registered central counterparty (CCP) authorized to offer clearing services in the European Union pursuant to Regulation (EU) No. 648/2012 of the European Parliament and the Council of 4 July 2012 on OTC derivatives, central counterparties (CCP) and trade repositories, the European Market Infrastructure Regulation (EMIR). As a CCP, LCH SA is regulated by the Autorité de Contrôle Prudentiel et de Résolution, the Banque de France and the Autorité des Marchés Financiers, collectively, the French National Competent Authorities (NCAs).

LCH proposes to offer its Fixed Income Clearing Service (RepoClear) and its Credit Default Swap Clearing Services (CDS Clear) to Ontario residents.

B. Proposed Regulatory Approach

Staff of the OSC (Staff) have reviewed the Application and other material required by National Instrument 24-102 Clearing Agency Requirements (NI 24-102). Subject to comments received, Staff propose to recommend to the Commission that it issue an exemption order to LCH SA in the form of the proposed draft order attached at Appendix A (Draft Order). This recommendation is based on the determination that LCH SA is not expected to pose significant risk to Ontario’s capital markets and is subject to a comparable regulatory and oversight regime in its home jurisdiction by its home regulators, the NCAs.

In determining whether a clearing agency poses significant risk to Ontario, we consider the level of activity of the clearing agency in Ontario (using indicators such as notional value and volume of transactions cleared for Ontario-based market participants) and other qualitative and quantitative factors, such as interconnectedness, size of obligations of the clearing members and the role and central importance of a clearing agency to a particular market.

C. Draft Order

Among other things, the Application describes LCH SA’s requirements under EMIR that are generally comparable or that achieve similar outcomes to the requirements of NI 24-102. A copy of LCH SA’s Application can be found on the Commission website at: https://www.osc.gov.on.ca/en/Marketplaces_clearing-agencies_index.htm.

The Draft Order if issued would require LCH SA to comply with the various terms and conditions in Schedule “A” to the Draft Order, including relating to:

1. Permitted scope of clearing activities in Ontario 2. Regulation of LCH SA 3. Governance 4. Reporting requirements 5. Information sharing

LCH SA has acknowledged in the Draft Order that the scope of and the terms and conditions imposed by the Commission, or the Commission’s determination of whether it is appropriate that LCH SA continue to be exempted from the requirement to be recognized as a clearing agency, may change as a result of the Commission’s monitoring of developments in international and domestic capital markets or LCH SA’s activities, or as a result of any changes to the laws in Ontario affecting the clearing and settlement of derivatives or securities.

August 8, 2019 (2019), 42 OSCB 6714

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D. Comment Process

The Commission is publishing for public comment the Application and Draft Order. We are seeking comment on all aspects of the Application and Draft Order.

Please provide your comments in writing, via e-mail and delivered on or before September 9, 2019 addressed to the attention of the Secretary of the Commission at e-mail: [email protected].

The confidentiality of submissions cannot be maintained as comments received during the comment period will be published.

Questions may be referred to:

Emily Sutlic Senior Legal Counsel, Market Regulation Tel: 416-593-2362 [email protected]

Stephanie Wakefield Senior Legal Counsel, Market Regulation Tel: 416-595-8771 [email protected]

Jalil El Moussadek Senior Advisor, Risk, Market Regulation Tel: 416-204-8995 [email protected]

August 8, 2019 (2019), 42 OSCB 6715

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APPENDIX “A” DRAFT ORDER

IN THE MATTER OF THE SECURITIES ACT, R.S.O. 1990, CHAPTER S. 5, AS AMENDED (THE OSA)

AND

IN THE MATTER OF BANQUE CENTRALE DE COMPENSATION

ORDER (Section 147 of the OSA)

WHEREAS Banque Centrale de Compensation which carries on business under the name LCH SA (hereinafter LCH SA) has submitted an application (Application) with the Ontario Securities Commission (Commission) pursuant to section 147 of the OSA requesting an order exempting LCH SA from the requirement to be recognized as a clearing agency under subsection 21.2(0.1) of the OSA (Order);

AND WHEREAS LCH SA has represented to the Commission that:

1.1. LCH SA is incorporated in France as a société anonyme (limited company) with a registered office based at 18 rue du Quatre Septembre 75002 Paris.

1.2. LCH SA is majority-owned (88.9%) by LCH Group Holdings Limited and indirectly owned (82.6%) by the London Stock Exchange (C) Limited a wholly owned subsidiary of London Stock Exchange Group plc.

1.3. LCH SA qualifies as a central counterparty (CCP) pursuant to Regulation (EU) No. 648/2012 of the European Parliament and of the Council of 4 July 2012 on OTC derivatives, central counterparties and trade repositories (EMIR), which sets out clearing and bilateral risk-management requirements for over-the-counter (OTC) derivative contracts, reporting requirements for derivative contracts, and uniform requirements for the performance of activities of CCPs and trade repositories. It was granted authorization as a CCP under EMIR effective from May 22, 2014.

1.4. LCH SA is of the opinion that it fully observes the international standards applicable to financial market infrastructures described in the April 2012 report Principles for financial market infrastructures (PFMI), having prepared a detailed assessment of its compliance against the PFMI and the associated disclosure framework as of 13 August 2018.

1.5. As an authorized CCP, LCH SA is regulated by three national competent authorities (NCAs): the Autorité de Contrôle Prudentiel et de Résolution (ACPR), the Banque de France (BDF) and the Autorité des Marchés Financiers (AMF). LCH SA is primarily regulated by the ACPR as a credit institution under the French Monetary and Financial Code (Comofi) and is a designated system under the Settlement Finality Directive 1998. LCH SA is indirectly supervised by the European Central Bank (ECB).

1.6. LCH SA is registered in the (i) as a Derivatives Clearing Organization with the U.S. Commodity Futures Trading Commission for its CDSClear service and (ii) as a clearing agency with the U.S. Securities and Exchange Commission.

1.7. LCH SA has to ensure the adequacy of its capital and risk management procedures and is required to provide its regulators with regular reports and information showing LCH SA clearing activities (including initial margin; default fund size; cash and non-cash collateral data; stress testing results; liquidity and capital adequacy; any significant changes in the organization, governance structure or ownership of LCH SA etc.).

1.8. LCH SA also provides its regulators with its annual financial statements and auditors’ reports. The LCH SA’s regulators may carry out on-site audits.

1.9 LCH SA anticipates that banks, investment dealers and any other legal entity resident in Ontario that fulfils the membership requirements duly defined in any applicable regulation and LCH SA Clearing Rules as defined below may be interested in participating in its offerings and becoming clearing members of LCH SA.

August 8, 2019 (2019), 42 OSCB 6716

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1.10 LCH SA provides clearing services for major exchanges and platforms as well as OTC markets. LCH SA clears a broad range of asset classes such as securities, exchange-traded derivatives, Credit Default Swaps (CDS) and Euro denominated bonds and repos.

1.10.1 RepoClear (the Fixed Income Clearing Service):

 LCH SA provides clearing services for cash and repos trades on Euro-denominated sovereign debts issued by French, Belgian, Italian, Spanish, German, Austrian, Dutch, Portuguese, Slovenian, Slovakian, Irish, Finnish governments as well as supranational bonds. LCH SA has implemented an interoperable link with Cassa di Compensazione e Garanzia SpA (CC&G), a subsidiary of the LSEG group on the Italian government bonds in compliance with the ESMA interoperability guidelines.

 LCH SA has launched €GCPlus, a central clearing service for the triparty repo market based on ECB eligible securities baskets in collaboration with the Central Securities Depository Euroclear and Banque de France. It uses pools of collateral managed by Euroclear, with Euroclear acting as triparty agent. €GCPlus has a dedicated default fund.

1.10.2 CDSClear (the CDS Clearing Service)

 LCH SA provides clearing services on European and North –American Indices and Single Names constituents, through MarkitSERV, Bloomberg and Tradeweb trade sources which includes:

 ITraxx Europe – Main, HiVol and CrossOver indices (3, 5, 7, 10-year tenors) – Senior Financials indices (5 and 10-year tenors) – from Series 6 onwards, Euro-denominated,

 Single Names on the reference entities composing the eligible indices, 25/100/300/500 bp coupons (quarterly maturities up to 10-year tenors), ‘Standard European Corporate’ or ‘Standard European Financial Corporate’ transaction types, Euro-denominated,

 CDX Investment-grade indices (3, 5, 7 and 10-year tenors) from Series 7 onwards, US dollar- denominated,

 Single Names on the reference entities composing the eligible indices, excluding monocline insurers, 100/500 bp coupons (quarterly maturities up to 10-year tenors), ‘Standard North American Corporate’ transaction types, Senior debt, US dollar-denominated.

 Options on CDS Index

1.11 An applicant to become a clearing member (Clearing Member) is required to have sufficient financial resources and operational capacity to meet the obligations arising from participation in LCH SA. The admission requirements are set forth in the documents entitled “CDS Clearing Rule Book” and “Procedures” regarding the CDSClear service and the “Clearing Rule Book” and “Instructions” regarding the RepoClear service. The CDS Clearing Rule Book, Procedures, the Clearing Rule Book and Instructions together being referred to as the “Clearing Rules”, are available on LCH SA’s website. LCH SA’s participation requirements are non-discriminatory and objective to ensure fair and open access. The admission requirements do not limit access on grounds other than risk (e.g., sufficient liable equity capital, compliance with technical requirements, and verification of the legal validity and enforceability of the Clearing Rules).

1.12 A Clearing Member is a legal entity that fulfils the membership requirements such as, among others, having sufficient financial resources and operational capacity to meet the obligations arising from participation in LCH SA. Such membership requirements are set out by LCH SA in the Clearing Rules.

1.13 Clearing Members may clear their own trades as well as those executed on behalf of their clients. A client is a legal entity that has entered into a client clearing agreement with a clearing member, thus allowing it to submit trades to its Clearing Member for clearing. Clients can have multiple Clearing Members.

1.14 A specific membership is required for CDSClear. Existing LCH SA Clearing Members (in LCH SA or its sister subsidiary LCH Ltd.) benefit from a fast-track membership program, subject to LCH SA risk management criteria. The LCH SA website includes further details of the general criteria that must be met to gain the Clearing Member status and the supplementary criteria for CDSClear participants.

August 8, 2019 (2019), 42 OSCB 6717

SROs, Marketplaces, Clearing Agencies and Trade Repositories

1.15 LCH SA plans to offer clearing activities to Ontario Clearing Members for the RepoClear and CDSClear services. This includes clients accessing the service through Ontario Clearing Members and Clearing Members from other jurisdictions.

1.16 The LCH SA Executive Risk Committee may approve an application to become a Clearing Member upon a determination that the applicant meets the membership criteria and after conducting a risk assessment and assigning an internal credit rating to the applicant.

1.17 The provisions of Article 2.1.1.2(5) of the LCH SA rulebook in compliance with article 541-16 of the Règlement general de l’AMF and article L 440-2 of the French Monetary Code provide that the French CCP membership of credit institutions (such as banks) and investment firms which are established in a country which is not part of the EEA such as Canada, is subject to a prior authorization from the AMF.

1.18 To achieve a balance between open access and risk, LCH SA continuously monitors a wide range of credit indicators for Clearing Members, including capital-to-risk ratios, and applies real-time risk management controls such as concentration limits and margin multipliers.

1.19 LCH SA’s Clearing Rules contain specific quality requirements for Clearing Members which include organisational, risk management systems and procedural requirements. LCH SA may impose additional risk-based conditions which may require Clearing Members to post additional collateral from time to time.

1.20 LCH SA collects collateral from its Clearing Members several times a day, so as to always have enough collateral to cover potential losses that the Clearing Members’ portfolios could suffer in a predefined period which varies from one clearing service to another.

1.21 Across LCH SA, mutualised default funds are calibrated monthly and tested daily to be sufficient to withstand the default of the two Clearing Members (at group level) giving rise to the largest losses calculated under scenarios of extreme conditions.

1.22 The LCH SA Rules (including in particular the default procedures stated in the rules) govern the processes that apply to Clearing Members in the case of a Clearing Member default; Clearing Members remain responsible for the credit risk of their clients.

1.23 LCH SA seeks an exemption from the clearing agency recognition requirement in relation to all transactions cleared by each of the LCH SA RepoClear and CDSClear services as described in representations 1.10.1 and 1.10.2.

1.24 LCH SA would provide its services to participants in Ontario without establishing an office or having a physical presence in Ontario or elsewhere in Canada.

1.25 LCH SA submits that it does not pose a significant risk to the Ontario capital markets and is subject to an appropriate regulatory and oversight regime in a foreign jurisdiction.

AND WHEREAS LCH SA has agreed to the respective terms and conditions as set out in Schedule “A” to this order;

AND WHEREAS based on the Application and the representations that LCH SA has made to the Commission, in the Commission’s opinion LCH SA is subject to regulatory requirements in France that are comparable to the requirements set out in National Instrument 24-102 Clearing Agency Requirements and is subject to the NCA’s supervision and granting an order to exempt LCH SA from the requirement to be recognized as a clearing agency would not be prejudicial to the public interest;

AND WHEREAS the Commission will monitor developments in international and domestic capital markets and LCH SA’s activities on an ongoing basis to determine whether it is appropriate that LCH SA continues to be exempted from the requirement to be recognized as a clearing agency and, if so, whether it is appropriate that it continue to be subject to the terms and conditions attached hereto as Schedule “A” to this order;

AND WHEREAS LCH SA has acknowledged to the Commission that the scope of and the terms and conditions imposed by the Commission attached hereto as Schedule “A” to this order, or the determination whether it is appropriate that LCH SA continue to be exempted from the requirement to be recognized as a clearing agency, may change as a result of the Commission's monitoring of developments in international and domestic capital markets or LCH SA’s activities, or as a result of any changes to the laws in Ontario affecting clearing and settlement of derivatives or securities;

August 8, 2019 (2019), 42 OSCB 6718

SROs, Marketplaces, Clearing Agencies and Trade Repositories

IT IS HEREBY ORDERED by the Commission that, pursuant to section 147 of the OSA, LCH SA is exempt from the requirement to be recognized as a clearing agency under subsection 21.2(0.1) of the OSA;

PROVIDED THAT LCH SA complies with the terms and conditions attached hereto as Schedule “A”

DATED this [….] day of […], 2019. [NAME] [NAME]

August 8, 2019 (2019), 42 OSCB 6719

SROs, Marketplaces, Clearing Agencies and Trade Repositories

SCHEDULE “A” Terms and Conditions

Definitions:

For the purposes of this Schedule “A”:

“client clearing” means the ability of a Clearing Member to clear transactions on LCH SA for and on behalf of a client. Unless the context requires otherwise, other terms used in this Schedule “A” shall have the meanings ascribed to them in Ontario securities law (including terms defined elsewhere in this order).

COMPLIANCE WITH ONTARIO LAW

1. LCH SA will comply with Ontario securities law (as defined in the OSA).

SCOPE OF PERMITTED CLEARING SERVICES IN ONTARIO

2. LCH SA’s activities in Ontario will be limited to the clearing of transactions in the RepoClear and CDSClear services as generally described in subsections 1.10.1 and 1.10.2 of LCH SA’s representations set out above in this order (Permitted Clearing Services).

3. LCH SA’s offering of the CDSClear service will comply with National Instrument 94-102 Derivatives: Customer Clearing and Protection of Customer Collateral and Positions.

4. For purposes of this order, Ontario Clearing Member means a Clearing Member resident in Ontario that uses the Permitted Clearing Services.

REGULATION OF LCH SA

5. LCH SA will maintain its status as an authorised CCP under EMIR and will continue to be subject to the regulatory oversight of its NCAs or any successor(s).

6. LCH SA will continue to comply with its ongoing regulatory requirements as a CCP under EMIR, and with the ongoing regulatory requirements of its NCAs.

GOVERNANCE

7. LCH SA will promote within LCH SA a governance structure that minimizes the potential for any conflict of interest between LCH SA and its shareholders that could adversely affect the Permitted Clearing Services or the effectiveness of LCH SA's risk management policies, controls and standards.

REPORTING REQUIREMENTS

Reporting with the NCAs

8. LCH SA will promptly provide staff of the Commission the following information, to the extent that it is required to provide or submit such information to NCAs or their successors:

(a) details of any material legal proceeding instituted against LCH SA;

(b) notification that LCH SA has failed to comply with an undisputed obligation to pay money or deliver property to an Ontario Clearing Member for a period of thirty days after receiving notice from the Ontario Clearing Member of LCH SA's past due obligation;

(c) notification that LCH SA has instituted a petition for a judgment of bankruptcy or insolvency or similar relief, or to wind up or liquidate LCH SA or has a proceeding for any such petition instituted against it;

(d) material changes to its bylaws and rules where such changes would impact the Permitted Clearing Services used by Ontario residents (whether as a Ontario Clearing Member or otherwise);

August 8, 2019 (2019), 42 OSCB 6720

SROs, Marketplaces, Clearing Agencies and Trade Repositories

(e) new services or clearing of new type of products in the Permitted Services to be offered to Ontario Clearing Members or services or types of products that will no longer be available to Ontario members; and

(f) any new category of membership in the Permitted Clearing Services if LCH SA expects that category of membership would be available to Ontario Clearing Members.

Prompt Notice

9. LCH SA will promptly notify staff of the Commission of any of the following:

(a) any material change to its business or operations;

(b) any material change or proposed material change in LCH SA’s status as a CCP under EMIR or in its regulatory oversight by NCAs or any successors;

(c) any material problem with the clearing and settlement of transactions that could materially affect the safety and soundness of LCH SA;

(d) the admission of any new Ontario Clearing Member;

(e) any event of default by, or removal from Permitted Clearing Services of, an Ontario Clearing Member;

(f) any material system failure of a Permitted Clearing Service utilized by an Ontario Clearing Member including cybersecurity breaches;

(g) initiation of LCH SA’s recovery plan;

(h) the appointment of a receiver or the making of any voluntary arrangement with creditors; and

(i) the entering of LCH SA into any resolution regime or the placing of LCH SA into resolution by a resolution authority.

Quarterly Reporting

10. LCH SA will maintain and submit the following information to the Commission in a manner and form acceptable to the Commission on a quarterly basis within 30 days of the end of each calendar quarter, and at any time promptly upon the request of staff of the Commission:

(a) a current list of all Ontario Clearing Members, and the legal entity identifier (LEI), if any, of each such Ontario Clearing Member;

(b) a list of all Ontario Clearing Members against whom disciplinary or legal action has been taken in the quarter by LCH SA with respect to activities at LCH SA, or to the best of LCH SA's knowledge, by its NCAs or any other authority in Europe or the United States that has or may have jurisdiction with respect to the relevant Ontario Clearing Members’ clearing activities at LCH SA;

(c) a list of all investigations by LCH SA in the quarter relating to Ontario Clearing Members;

(d) a list of all Ontario-resident applicants who have been denied Clearing Member status in the quarter by LCH SA;

(e) quantitative information in respect of the Permitted Clearing Services used by Ontario Clearing Members for cleared transactions referred to in subsections 1.9.2 and 1.9.3, including in particular the following:

i) as at the end of the quarter, level, maximum and average daily open interest, number of transactions and notional value of transactions cleared during the quarter for each Ontario Clearing Member;

ii) the percentage of end of quarter level and average daily open interest, number of transactions and the notional value cleared during the quarter for all Clearing Members that represents the end of

August 8, 2019 (2019), 42 OSCB 6721

SROs, Marketplaces, Clearing Agencies and Trade Repositories

quarter and average daily open interest, number of transactions and the notional value of transactions cleared during the quarter for each Ontario Clearing Member;

iii) the aggregate total margin amount required by LCH SA ending on the last trading day during the quarter for each Ontario Clearing Member;

iv) the portion of the total margin required by LCH SA ending on the last trading day of the quarter for all Clearing Members that represents the total margin required during the quarter for each Ontario Clearing Member; and

(f) the default fund contribution, for each Ontario Clearing Member on the last trading day during the quarter, and its proportion of the total default fund contributions;

(g) a summary of risk management analysis related to the adequacy of the default fund requirement, including but not limited to stress testing and backtesting results;

(h) if known to LCH SA, for each Clearing Member (identified by its LEI) offering client clearing to an Ontario resident, the identity of the Ontario resident client (including LEI, if any) receiving such services, and the value and volume cleared by asset class or transaction type during the quarter for and on behalf of each Ontario resident client.

INFORMATION SHARING

11. LCH SA will promptly provide such information as may be requested from time to time by, and otherwise cooperate with, the Commission or its staff, subject to any applicable privacy or other laws that would prevent the sharing of such information and subject to the application of solicitor-client privilege.

12. Unless otherwise prohibited under applicable law, LCH SA will share information relating to regulatory and enforcement matters and otherwise cooperate with other recognized and exempt clearing agencies on such matters, as appropriate.

August 8, 2019 (2019), 42 OSCB 6722

Chapter 25

Other Information

25.1 Consents

25.1.1 Newstrike Brands Ltd. – s. 4(b) of Ont. Reg. 289/00 under the OBCA

Headnote

Consent given to an offering corporation under the Business Corporations Act (Ontario) to continue under the Canada Business Corporations Act.

Statutes Cited

Business Corporations Act, R.S.O. 1990, c. B.16, as am., s. 181. Securities Act, R.S.O. 1990, c. S.5, as am.

Regulations Cited

Regulation made under the Business Corporations Act, Ont. Reg. 289/00, as am., s. 4(b), Securities Act, R.S.O. 1990, c. S.5, as am.

IN THE MATTER OF R.R.O. 1990, REGULATION 289/00, AS AMENDED (the REGULATION) UNDER THE BUSINESS CORPORATIONS ACT (ONTARIO), R.S.O. 1990 c. B.16, AS AMENDED (the OBCA)

AND

IN THE MATTER OF NEWSTRIKE BRANDS LTD.

CONSENT (Subsection 4(b) of the Regulation)

UPON the application (the Application) of Newstrike Brands Ltd. (the Applicant) to the Ontario Securities Commission (the Commission) requesting the Commission’s consent to the Applicant continuing in another jurisdiction pursuant to section 181 of the OBCA (the Continuance);

AND UPON considering the Application and the recommendation of staff of the Commission;

AND UPON the Applicant having represented to the Commission that:

1. The Applicant is an offering corporation under the OBCA.

2. The authorized capital of the Applicant consists of an unlimited number of common shares (the Common Shares), which are not listed or posted for trading on a published market, and of which all of the issued and outstanding Common Shares are owned by HEXO Corp. (HEXO). As at July 23, 2019, the Applicant also has issued and outstanding the following securities:

a. 69,701,500 warrants to purchase 0.06332 of a common share in HEXO at an exercise price of $1.75 with an expiry date of February 16, 2020 issued pursuant to a warrant indenture between Newstrike and TSX Trust Company (TSX Trust) dated February 16, 2018, as supplemented by a Supplemental Warrant Indenture dated as of May 24, 2019 between the Applicant, HEXO and TSX Trust (the February 2020 Warrants);

b. 34,550,000 warrants to purchase 0.06332 of a common share in HEXO at an exercise price of $1.00 with an expiry date of June 19, 2023 issued pursuant to a warrant indenture between Newstrike and TSX Trust dated June 19, 2018, as supplemented by a Supplemental Warrant Indenture dated as of May 24, 2019 between

August 8, 2019 (2019), 42 OSCB 6723

Other Information

the Applicant, HEXO and TSX Trust (the June 2023 Warrants, and together with the February 2020 Warrants, the Listed Warrants); and

c. 9,445,140 unlisted warrants to purchase 0.06332 of a common share in HEXO.

3. The February 2020 Warrants and June 2023 Warrants are listed and posted for trading on the TSX Venture Exchange (TSXV) under the symbols HIP.WT and HIP.WT.A, respectively. The Listed Warrants are the only securities of the Applicant that are listed for trading on a published market.

4. The Applicant intends to apply to the Director pursuant to section 181 of the OBCA (the Application for Continuance) for authorization to continue as a corporation under the Canada Business Corporations Act, R.S.C., 1985, c. C-44 (the CBCA).

5. The Application for Continuance is being made to facilitate the amalgamation of the Applicant with other wholly-owned subsidiaries of HEXO.

6. The material rights, duties and obligations of a corporation governed by the CBCA are substantially similar to those of a corporation governed by the OBCA.

7. The Applicant is a reporting issuer under the Securities Act, R.S.O. 1990, c. S.5, as amended (the Act) and the securities legislation of each of the provinces of Canada, other than Quebec (together with the Act, the Legislation), and will remain a reporting issuer in these jurisdictions following the Continuance.

8. The Applicant is not in default of any of the provisions of the OBCA or the Legislation, including the regulations made thereunder.

9. The Applicant is not in default of any provision of the rules, regulations or policies of the TSXV.

10. The Applicant is not subject to any proceeding under the OBCA or the Legislation.

11. The Commission is the principal regulator of the Applicant and will remain the Applicant’s principal regulator following the Continuance.

12. HEXO, as the sole shareholder, has authorized the Continuance on July 24, 2019.

13. Subsection 4(b) of the Regulation requires the Application for Continuance be accompanied by a consent from the Commission.

AND UPON the Commission being satisfied that to do so would not be prejudicial to the public interest;

THE COMMISSION CONSENTS to the continuance of the Applicant under the CBCA.

DATED at Toronto, Ontario this 31st day of July, 2019.

“Craig Hayman” Part-time Commissioner Ontario Securities Commission

“Tim Moseley” Vice Chair Ontario Securities Commission

August 8, 2019 (2019), 42 OSCB 6724

Other Information

25.2 Application to Extend Temporary Order

25.2.1 Sean Daley et al. – ss. 127(8), 127(1)

IN THE MATTER OF SEAN DALEY; and SEAN DALEY carrying on business as the ASCENSION FOUNDATION, OTO.Money, SilentVault, and CryptoWealth; WEALTH DISTRIBUTED CORP.; CYBERVISION MMX INC.; KEVIN WILKERSON; and AUG ENTERPRISES INC.

APPLICATION OF STAFF OF THE ONTARIO SECURITIES COMMISSION (For Extension of a Temporary Order Subsections 127(8) and 127(1) of the Securities Act, RSO 1990, c S.5)

A. ORDERS SOUGHT

The Applicant, Staff of the Ontario Securities Commission (“Staff”), requests that the Ontario Securities Commission (the “Commission”) make the following orders:

1. An order extending the Temporary Order of the Commission made with respect to Sean Daley (“Daley”), Daley carrying on business as the Ascension Foundation, OTO.Money, SilentVault, and CryptoWealth., and Wealth Distributed Corp. (“Wealth Distributed”), Cybervision MMX Inc. (“CyberVision”), Kevin Wilkerson (“Wilkerson”), and Aug Enterprises Inc. (“Aug Enterprises”), dated August 6, 2019, for such period as it considers necessary if satisfactory information is not provided to the Commission within the fifteen-day period after the Temporary Order was made, pursuant to subsection 127(8) of the Securities Act, RSO 1990, c S.5 (the “Act”);

2. If necessary, an order abridging the time required for service pursuant to Rules 3 and 4(2) of the Ontario Securities Commission Rules of Procedure; and

3. Such other Order as the Commission considers appropriate in the public interest.

B. GROUNDS

The grounds for the request are:

1. In July 2018, Staff commenced an investigation into Daley, Ascension Foundation, OTO.Money, SilentVault, and CryptoWealth;

2. During the course of the investigation, Staff found evidence that Daley; Daley carrying on business as Ascension Foundation, OTO.Money, SilentVault, and CryptoWealth; Wealth Distributed; Cybervision; Wilkerson; and Aug Enterprises appeared to be trading or acting in furtherance of trades without being registered to trade and without a prospectus having been filed and receipted contrary to sections 25 and 53 of the Act, respectively;

3. On August 6, 2019, the Commission issued a temporary order (the “Temporary Order”).

4. The Temporary Order provided that:

a. all trading in any securities by Daley, and Daley carrying on business as Ascension, OTO.Money, SilentVault, and CryptoWealth.com, and Wealth Distributed, Cybervision, Wilkerson, and Aug Enterprises shall cease;

b. all trading in ‘overcome the odds’ vouchers, also known as OTO.Vouchers and Lyra shall cease;

c. any exemptions contained in Ontario securities law do not apply to Daley; Daley carrying on business as Ascension, OTO.Money, SilentVault, and CryptoWealth, and Wealth Distributed, Cybervision, Wilkerson, and Aug Enterprises;

d. the Temporary Order shall take effect on August 6, 2019 and shall expire on the 15th day after its making

August 8, 2019 (2019), 42 OSCB 6725

Other Information

unless extended by order of the Commission;

5. The investigation into the conduct described in the Temporary Order is continuing;

6. The Respondents have obstructed Staff’s investigation;

7. The order sought by Staff is necessary to protect investors from serious and ongoing harm and is in the public interest;

8. Subsections 127(1) and 127(8) of the Act; and

9. Such further and other grounds as counsel may advise and the Commission may permit.

C. EVIDENCE

The Applicant intends to rely on the following evidence at the hearing:

1. The Affidavit of Kevin Dusseldorp to be filed.

Date: August 6, 2019

Matthew Britton Tel: (416) 593-2493 Fax: (416) 593-9345 Email: [email protected]

Kai Olson Tel: (416) 597-7242 Fax: (416) 593-9345 Email: [email protected]

Lawyers for Staff of the Ontario Securities Commission

August 8, 2019 (2019), 42 OSCB 6726

Index

Ascension Foundation Daley, Sean Notice of Hearing – ss. 127(8), 127(1) ...... 6619 Notice of Hearing – ss. 127(8), 127(1) ...... 6619 Notice from the Office of the Secretary ...... 6620 Notice from the Office of the Secretary ...... 6620 Temporary Order – ss. 127(1), 127(5) ...... 6630 Temporary Order – ss. 127(1), 127(5) ...... 6630 Application to Extend Temporary Order – ss. Application to Extend Temporary Order – ss. 127(8), 127(1) ...... 6725 127(8), 127(1) ...... 6725

Aug Enterprises Inc. Delivra Corp. Notice of Hearing – ss. 127(8), 127(1) ...... 6619 Order ...... 6628 Notice from the Office of the Secretary ...... 6620 Temporary Order – ss. 127(1), 127(5) ...... 6630 Driehaus Capital Management LLC Application to Extend Temporary Order – ss. Voluntary Surrender ...... 6707 127(8), 127(1) ...... 6725 Environmental Waste International Inc. Banque Centrale De Compensation Cease Trading Order ...... 6631 Clearing Agencies – Application for Exemption from Recognition as a Clearing Agency – OSC Notice Equium Capital Management Inc. and Request for Comment ...... 6714 Change in Registration Category ...... 6707

Baskin Financial Services Inc. Evolving Gold Corp. Change in Registration ...... 6707 Cease Trading Order ...... 6631

BetterU Education Corp. Foresters Asset Management Inc. Cease Trading Order ...... 6631 Decision ...... 6621

Border Petroleum Limited Freedom International Brokerage Company Cease Trading Order ...... 6631 Decision ...... 6625

Covenant Securities Corp. Highvista Gold Inc. Name Change ...... 6707 Cease Trading Order ...... 6631

CryptoWealth IIROC Notice of Hearing – ss. 127(8), 127(1) ...... 6619 SROs – Amendments Respecting Provision of Notice from the Office of the Secretary ...... 6620 Price Improvement by a Dark Order – Notice of Temporary Order – ss. 127(1), 127(5) ...... 6630 Commission Approval ...... 6709 Application to Extend Temporary Order – ss. 127(8), 127(1) ...... 6725 imaxx Canadian Bond Fund Decision ...... 6621 CSA Staff Notice 51-358 – Reporting of Climate Change-related Risks imaxx Canadian Dividend Plus Fund Notice ...... 6617 Decision ...... 6621

CSE imaxx Canadian Fixed Pay Fund Marketplaces – Amendments to Trading System Decision ...... 6621 Functionality & Features – Notice and Request for Comment ...... 6710 imaxx Equity Growth Fund Marketplaces – Notice of Withdrawal of Proposed Decision ...... 6621 Amendments to Trading Rules ...... 6713 imaxx Global Fixed Pay Fund Cybervision MMX Inc. Decision ...... 6621 Notice of Hearing – ss. 127(8), 127(1) ...... 6619 Notice from the Office of the Secretary ...... 6620 imaxx Short Term Bond Fund Temporary Order – ss. 127(1), 127(5) ...... 6630 Decision ...... 6621 Application to Extend Temporary Order – ss. 127(8), 127(1) ...... 6725

August 8, 2019 (2019), 42 OSCB 6727

Index

Investment Industry Regulatory Organization of Waseco Resources Inc. Canada Cease Trading Order ...... 6631 SROs – Amendments Respecting Provision of Price Improvement by a Dark Order – Notice of Wealth Distributed Corp. Commission Approval ...... 6709 Notice of Hearing – ss. 127(8), 127(1) ...... 6619 Notice from the Office of the Secretary ...... 6620 Jeotex Inc. Temporary Order – ss. 127(1), 127(5) ...... 6630 Cease Trading Order ...... 6631 Application to Extend Temporary Order – ss. 127(8), 127(1) ...... 6725 LCH SA Clearing Agencies – Application for Exemption from Wilkerson, Kevin Recognition as a Clearing Agency – OSC Notice Notice of Hearing – ss. 127(8), 127(1) ...... 6619 and Request for Comment ...... 6714 Notice from the Office of the Secretary ...... 6620 Temporary Order – ss. 127(1), 127(5) ...... 6630 Maclos Capital Inc. Application to Extend Temporary Order – ss. Cease Trading Order ...... 6631 127(8), 127(1) ...... 6725

Newstrike Brands Ltd. – s. 4(b) of Ont. Reg. 289/00 under the OBCA Consent – s. 4(b) of Ont. Reg. 289/00 under the OBCA ...... 6723

OSC Staff Notice 33-750 Compliance and Registrant Regulation – Summary Report for Dealers, Advisers and Investment Fund Managers Notice ...... 6615

OTO.Money Notice of Hearing – ss. 127(8), 127(1) ...... 6619 Notice from the Office of the Secretary ...... 6620 Temporary Order – ss. 127(1), 127(5) ...... 6630 Application to Extend Temporary Order – ss. 127(8), 127(1) ...... 6725

Peeks Social Ltd. Cease Trading Order ...... 6631

Pentecostal Securities Corp. Name Change ...... 6707

Performance Sports Group Ltd. Cease Trading Order ...... 6631

Portage Biotech Inc. Cease Trading Order ...... 6631

RBC Dominion Securities Inc. Decision ...... 6625

SBD Capital Corp. Cease Trading Order ...... 6631

SilentVault Notice of Hearing – ss. 127(8), 127(1) ...... 6619 Notice from the Office of the Secretary ...... 6620 Temporary Order – ss. 127(1), 127(5) ...... 6630 Application to Extend Temporary Order – ss. 127(8), 127(1) ...... 6725

TD Securities Inc. Decision ...... 6625

August 8, 2019 (2019), 42 OSCB 6728