The Securities Commission

OSC Bulletin

August 20, 2020

Volume 43, Issue 34

(2020), 43 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 ...... 6491 Chapter 5 Rules and Policies ...... 6583 1.1 Notices ...... 6491 5.1.1 Start-up Crowdfunding Guide for 1.1.1 CSA Notice of Amendments to National Businesses ...... 6583 Instrument 51-102 Continuous Disclosure 5.1.2 Start-up Crowdfunding Guide for Funding Obligations and Changes to Certain Policies Portals ...... 6593 Related to the Business Acquisition Report 5.1.3 Start-up Crowdfunding Guide for Investors .... 6600 Requirements ...... 6491 1.1.2 Joint CSA/IIROC Staff Notice 23-327 – Update Chapter 6 Request for Comments ...... (nil) on Internalization within the Canadian Equity Market ...... 6504 Chapter 7 Insider Reporting ...... 6607 1.2 Notices of Hearing ...... 6533 1.2.1 ESW Capital, LLC and Optiva Inc. – s. 104 .... 6533 Chapter 9 Legislation ...... (nil) 1.3 Notices of Hearing with Related Statements of Allegations ...... (nil) Chapter 11 IPOs, New Issues and Secondary 1.4 Notices from the Office Financings ...... 6679 of the Secretary ...... 6534 1.4.1 ESW Capital, LLC and Optiva Inc...... 6534 Chapter 12 Registrations ...... 6687 1.4.2 First Global Data Ltd. et al...... 6534 12.1.1 Registrants ...... 6687 1.4.3 Joseph Debus ...... 6535 1.4.4 Canada Cannabis Corporation et al...... 6535 Chapter 13 SROs, Marketplaces, 1.5 Notices from the Office Clearing Agencies and of the Secretary with Related Trade Repositories ...... 6689 Statements of Allegations ...... (nil) 13.1 SROs ...... (nil) 13.2 Marketplaces ...... 6689 Chapter 2 Decisions, Orders and Rulings ...... 6537 13.2.1 Canadian Securities Exchange – Amendments 2.1 Decisions ...... 6537 to Trading System Functionality & Features – 2.1.1 Picton Mahoney Asset Management et al...... 6537 Notice and Request for Comment ...... 6689 2.1.2 Georgeson Shareholder Communications 13.3 Clearing Agencies ...... 6692 Canada Inc...... 6543 13.3.1 Canadian Derivatives Clearing Corporation 2.1.3 Wealthsimple Digital Assets Inc...... 6548 (CDCC) – Proposed Amendments to the 2.1.4 Mercer Global Investments Canada Limited ... 6562 Rules of CDCC with Respect to the CGZ 2.1.5 Ninepoint Partners LP ...... 6565 Futures Contract – OSC Staff Notice of 2.2 Orders...... 6568 Request for Comment ...... 6692 2.2.1 Alchemist Mining Incorporated ...... 6568 13.4 Trade Repositories ...... (nil) 2.2.2 First Global Data Ltd. et al...... 6569 2.2.3 Horizons ETFs Management (Canada) Inc. ... 6570 Chapter 25 Other Information ...... (nil) 2.2.4 Lendified Holdings Inc...... 6572 2.3 Orders with Related Settlement Index ...... 6693 Agreements ...... (nil) 2.4 Rulings ...... (nil)

Chapter 3 Reasons: Decisions, Orders and Rulings ...... 6577 3.1 OSC Decisions ...... 6577 3.1.1 Joseph Debus ...... 6577 3.2 Director’s Decisions ...... (nil)

Chapter 4 Cease Trading Orders ...... 6581 4.1.1 Temporary, Permanent & Rescinding Issuer Cease Trading Orders ...... 6581 4.2.1 Temporary, Permanent & Rescinding Management Cease Trading Orders ...... 6581 4.2.2 Outstanding Management & Insider Cease Trading Orders ...... 6581

August 20, 2020 (2020), 43 OSCB

Chapter 1

Notices

1.1 Notices

1.1.1 CSA Notice of Amendments to National Instrument 51-102 Continuous Disclosure Obligations and Changes to Certain Policies Related to the Business Acquisition Report Requirements

CSA Notice of Amendments to National Instrument 51-102 Continuous Disclosure Obligations and Changes to Certain Policies Related to the Business Acquisition Report Requirements

August 20th, 2020

Introduction

The Canadian Securities Administrators (CSA or we) are making amendments and changes to:

• National Instrument 51-102 Continuous Disclosure Obligations (NI 51-102);

• Companion Policy 51-102CP Continuous Disclosure Obligations (Companion Policy 51-102CP);

• Companion Policy to National Instrument 41-101 General Prospectus Requirements (Companion Policy 41- 101CP);

• Companion Policy to National Instrument 44-101 Short Form Prospectus Distributions (Companion Policy 44-101CP);

(the Amendments).

Provided all necessary ministerial approvals are obtained, the Amendments are effective on November 18, 2020.

Details of the Amendments are outlined in Annexes C through F of this notice and will also be available on websites of CSA jurisdictions, including:

www.bcsc.bc.ca www.albertasecurities.com www.fcaa.gov.sk.ca www.mbsecurities.ca www.osc.gov.on.ca www.lautorite.qc.ca nssc.novascotia.ca

Substance and Purpose

A reporting issuer that is not an investment fund is required to file a business acquisition report (BAR) after completing a significant acquisition. Part 8 of NI 51-102 sets out three significance tests: the asset test, the investment test and the profit or loss test. An acquisition of a business or related businesses is a significant acquisition that requires the filing of a BAR under Part 8 of NI 51-102:

• for a reporting issuer that is not a venture issuer, if the result from any one of the three significance tests exceeds 20%;

• for a venture issuer, if the result of either the asset test or investment test exceeds 100%

(collectively, the BAR requirements).

August 20, 2020 (2020), 43 OSCB 6491

Notices

The Amendments

• alter the determination of significance for reporting issuers that are not venture issuers such that an acquisition of a business or related businesses is a significant acquisition only if at least two of the existing significance tests are triggered (the Two-Trigger Test); and

• increase the threshold of the significance tests for reporting issuers that are not venture issuers from 20% to 30%.

The Amendments are aimed at reducing the regulatory burden imposed by the BAR requirements in certain instances, without compromising investor protection.

Background

The BAR requirements were introduced in 20041 to provide investors with relatively timely access to historical financial information on a significant acquisition. They also require a reporting issuer that is not a venture issuer to include pro forma financial statements in a BAR. Since adoption, however, the CSA has heard that, in some cases, the significance tests may produce anomalous results, that preparation of a BAR entails significant time and cost, and that the information necessary to comply with the BAR requirements may, in some instances, be difficult to obtain. In addition, some reporting issuers have applied for, and in appropriate circumstances were granted, exemptive relief from certain of the BAR requirements.

On September 5, 2019, the CSA published a Notice and Request for Comment (the Publication for Comment Materials) proposing the Amendments. The Amendments were developed over the course of an extensive consultation process, including comment letters and other stakeholder feedback received respecting the BAR requirements in response to CSA Consultation Paper 51-404 Considerations for Reducing Regulatory Burden for Non-Investment Fund Reporting Issuers.2 In addition, the CSA considered data (including analyzing in each jurisdiction the BARs filed and the exemptive relief from the BAR requirements granted over an approximate three-year period) to assess the impact of the Amendments on a look back basis.

Based on the 16 comment letters responding to the Publication for Comment Materials, the CSA is not making any material changes to the Amendments. We have summarized our responses to the feedback received, which reflect the following:

• 13 commenters expressed general support for the Amendments while one commenter opposed.

• 10 commenters specifically expressed support for the Two-Trigger Test while one commenter objected to this amendment.

• Seven commenters specifically supported increasing the significance test threshold to 30% while two commenters objected to this amendment and recommended we maintain the 20% threshold. Three commenters recommended a greater increase in the percentage than what we proposed.

In addition, we considered other options to reduce the regulatory burden associated with the BAR requirements but determined that they either did not align with our policy objectives or that the reduction in burden did not justify a potential significant loss of information to investors. We also considered international developments, including the final amendments published in May 2020 by the U.S. Securities and Exchange Commission3, but think that the Amendments appropriately address concerns raised by stakeholders in the Canadian market.

Summary of Written Comments Received by the CSA

The Publication for Comment Materials were published on September 5, 2019 and the comment period ended on December 4, 2019. We considered all the comments received and thank the commenters for their input. The names of the commenters are contained in Annex A along with a summary of the comments and our responses in Annex B.

The comment letters can be viewed on the website of each of:

• the Alberta Securities Commission at www.albertasecurities.com

• the Autorité des marchés financiers at www.lautorite.qc.ca

• the Ontario Securities Commission at www.osc.gov.on.ca

1 Certain aspects of these requirements were subsequently amended in 2015 as they apply to venture issuers. 2 The comment letters were summarized in CSA Staff Notice 51-353 Update on CSA Consultation Paper 51-404 Considerations for Reducing Regulatory Burden for Non-Investment Fund Reporting Issuers. 3 Amendments to Financial Disclosures about Acquired and Disposed Businesses, Release No. 33-10786; 34-88914; IC-33872; File No. S7-05-19.

August 20, 2020 (2020), 43 OSCB 6492

Notices

Summary of Changes

We have revised the Amendments and changes proposed in the Publication for Comment Materials to remove an outdated cross reference and to reflect current drafting principles. As these changes are not material, we are not publishing the Amendments for a further comment period.

Consequential Amendments

We are making the following consequential changes:

• revised subsection 5.9(5) of Companion Policy 41-101CP and subsection 4.9(3) of Companion Policy 44- 101CP to reflect the application of the Two-Trigger Test;

• added guidance to subsection 8.1(4) of Companion Policy 51-102CP reminding issuers of the differing interpretations of “business” for securities and accounting purposes; and

• removed an outdated reference in paragraph 8.6(4)(b) of Companion Policy 51-102CP.

Local Matters

Annex G to this notice outlines the consequential amendments to local securities legislation and includes additional text, as required, to respond to local matters in a local jurisdiction. Each jurisdiction that is proposing local amendments will publish an Annex G.

Contents of Annexes

This notice includes the following annexes:

• Annex A – List of Commenters

• Annex B – Summary of Comments and CSA Responses

• Annex C – Amendments to NI 51-102

• Annex D – Changes to Companion Policy 51-102CP

• Annex E – Changes to Companion Policy 41-101CP

• Annex F – Changes to Companion Policy 44-101CP

• Annex G – Local Matters

Questions

Please refer your questions to any of the following:

Diana D’Amata Nadine Gamelin Senior Regulatory Advisor, Senior Analyst, Direction de l’information continue Direction de l’information financière Autorité des marchés financiers Autorité des marchés financiers 514 395-0337, ext. 4386 514 395-0337, ext. 4417 [email protected] [email protected] Mike Moretto Elliott Mak Chief of Corporate Disclosure Senior Legal Counsel, Corporate Finance British Columbia Securities Commission British Columbia Securities Commission 604 899-6767 604 899-6501 [email protected] [email protected] Maggie Zhang Gillian Findlay Senior Securities Analyst, Corporate Finance Senior Legal Counsel, Corporate Finance British Columbia Securities Commission Alberta Securities Commission 604 899-6823 403 279-3302 [email protected] [email protected]

August 20, 2020 (2020), 43 OSCB 6493

Notices

Roger Persaud Matthew Young Senior Securities Analyst, Corporate Finance Senior Securities Analyst, Securities Division Alberta Securities Commission Financial and Consumer Affairs Authority of 403 297-4324 Saskatchewan [email protected] 306 787-6067 [email protected] Patrick Weeks Julius Jn-Baptiste Corporate Finance Analyst Legal Counsel, Corporate Finance Manitoba Securities Commission Ontario Securities Commission 204 945-3326 416 595-8939 [email protected] [email protected] Michael Rizzuto Jack Jiang Accountant, Corporate Finance Securities Analyst, Corporate Finance Ontario Securities Commission Nova Scotia Securities Commission 416 263-7663 902 424-7059 [email protected] [email protected]

August 20, 2020 (2020), 43 OSCB 6494

Notices

ANNEX A

LIST OF COMMENTERS

No. Commenter Date 1. The Canadian Advocacy Council of CFA Societies Canada October 18, 2019

2. The Real Property Association of Canada November 26, 2019

3. Canadian Coalition for Good Governance November 27, 2019

4. Investment Industry Association of Canada (IIAC) November 28, 2019

5. Magna International Inc. December 2, 2019

6. Cenovus Energy Inc. December 3, 2019 7. Quebec Bourse December 4, 2019

8. Canadian Investor Relations Institute December 4, 2019

9. Stikeman Elliott LLP December 4, 2019

10. Ernst & Young LLP December 4, 2019

11. McCarthy Tétrault LLP December 4, 2019 12. Chartered Professional Accountants of Canada December 4, 2019

13. Portfolio Management Association of Canada December 4, 2019

14. TSX Inc. and TSX Venture Exchange Inc. December 4, 2019

15. PricewaterhouseCoopers LLP December 19, 2019

16. Veritas Investment Research January 6, 2020

August 20, 2020 (2020), 43 OSCB 6495

Notices

ANNEX B

SUMMARY OF COMMENTS AND CSA RESPONSES

No. Subject Summarized Comment Response

1 General Support 13 commenters supported the proposed We thank the commenters for their views. amendments. We acknowledge the views expressed in the One commenter strongly opposed to the comment letter opposing the proposed proposed amendments. amendments. However, we think the proposed amendments achieve the right balance between investor protection and reducing regulatory burden.

2 Adoption of the Ten commenters explicitly expressed We thank the commenters for their views. two-trigger test to support for the two-trigger test. determine We acknowledge the views expressed in the significance One commenter specifically objected to the comment letter objecting to the two-trigger test. adoption of the two-trigger test. However, our analysis indicates that the two- trigger test is more effective in reducing anomalous results arising from the current tests than most of the other options considered, including those suggested by certain commenters.

3 30% significance Seven commenters explicitly supported We thank the commenters for their views. threshold for the increasing the significance threshold to 30%. two-trigger test We note that increasing the significance test Three commenters recommended CSA threshold is consistent with the consultation provide further information to help them feedback received and with the CSA’s strategic better understand plan to reduce regulatory burden while maintaining investor protection. • the relative importance between the two proposed amendments with Our analysis of the BARs filed and the BAR respect to the anticipated impact on exemptive relief granted on a look-back basis the number of expected filings, and indicates that the two-trigger test is more effective in reducing anomalous results than • the rationale behind the proposed most of the other options considered. This increase of the significance test analysis also helped the CSA conclude that threshold from 20% to 30%. increasing the significance test threshold to 30% would achieve an appropriate balance between investor protection and reduction of burden. 4 Keeping the Two commenters objected to increasing the significance test significance test threshold from 20% to 30%. Additionally, we received feedback that the 30% threshold at 20% threshold more appropriately recognizes the for the two-trigger profile of Canadian issuers when compared with test US issuers and the burden of preparing a BAR for smaller transactions. 5 Increasing the Three commenters recommended increasing Finally, we considered the suggestions to further significance the significance test threshold to 50% or increase the significance threshold but threshold to 50% 75%. determined that the reduction in burden did not or higher for the justify a potentially significant loss of information two-trigger test to investors.

6 Eliminating the Four commenters recommended eliminating We thank the commenters for their views. BAR the BAR, citing only modest relevance or limited value. At this time, we are not proposing to eliminate the BAR entirely as we think that the BAR Among these four commenters, one provides investors with relevant information for

August 20, 2020 (2020), 43 OSCB 6496

Notices

No. Subject Summarized Comment Response

commenter recommended replacing the their decision-making purposes. BAR with a detailed news release and/or a material change report.

Among these four commenters, two commenters recommended eliminating the BAR for all issuers, including venture issuers.

7 Keeping the One commenter strongly opposed the We thank the commenter for its view. current BAR proposed amendments based on the view requirements that historical financial information contained We agree that the BAR contains relevant in the BAR is useful for making investment information that may be helpful for making decisions. investment decisions. We think the proposed amendments achieve the right balance between investor protection and reducing regulatory burden.

8 Alignment with Five commenters recommended some form We thank the commenters for their views. We SEC of consideration or alignment with the SEC have monitored international developments, proposed amendments, such as modifying including the SEC final amendments published in the investment test to reflect the fair value of May 2020. the acquired business, and otherwise monitoring developments. We think that the proposed amendments provide an appropriate solution to address concerns raised by stakeholders in the Canadian market.

9 Pro forma Three commenters recommended We thank the commenters for their views. At this financial eliminating pro forma financial statements, time, we are not proposing to eliminate pro forma statements citing only modest relevance or limited value. financial statements as we think they provide useful information to some investors for making investment decisions.

10 Profit or loss test Four commenters recommended the We thank the commenters for their views. At this following changes to the profit or loss test: time, we are not proposing to make changes to the profit or loss test. • replace the profit or loss test with alternatives such as EBITDA We understand from the consultation feedback that the primary concern with the profit or loss • make substantive amendments to test was that it often produces anomalous the BAR requirements to address results. Our data analysis indicates that the two- the challenges related to the profit trigger test is more effective in reducing or loss test anomalous results than the other suggestions raised during the consultation, such as removing • align with the SEC’s proposal to the profit or loss test or introducing a revenue add a revenue component test etc.

• increase the significance test threshold from 20-30%

11 Other specific One commenter suggested the following: We thank the commenters for their views. recommendations to BAR • clarifying the specific time-frame At this time, we are not proposing to make requirements that applies to consider acquisitions further changes to other areas of the BAR of related businesses on a requirements. We acknowledge the suggestions combined basis; and continue to welcome feedback that may lead to policy projects in the future. • narrowing the definition of

August 20, 2020 (2020), 43 OSCB 6497

Notices

No. Subject Summarized Comment Response

“acquisition of a related business”.

One commenter suggested modifying the BAR requirements to treat the required significance tests as a filtering mechanism for the optional significance tests.

12 51-102CP One commenter indicated that the proposed We thank the commenter for its view. We remind amendments – S. amendments add ambiguity in determining issuers that the evaluation of the term “business” 8.1(4) whether or not an acquisition would be for securities regulatory purposes should be considered a business for regulatory conducted separately from the determination for purposes versus IFRS purposes. accounting purposes.

13 Tailoring the BAR Three commenters recommended changes We thank the commenters for their views. At this requirements to tailored to issuers in specific industries. time, we are not proposing any industry specific specific industry rules or amendments.

14 Other disclosure Three commenters made specific We thank the commenters for their views. requirements recommendations to other continuous Commenters are encouraged to continue disclosure requirements, including for providing their views to the other relevant policy instance, permitting semi-annual reporting. initiatives as a result of the other CSA reducing regulatory burden efforts.

15 Application to No commenter objected to the application of We thank the commenters for their views. non-venture the proposed amendments to non-venture issuers issuers only.

One commenter explicitly agreed that no further changes are required for venture issuers.

August 20, 2020 (2020), 43 OSCB 6498

Notices

ANNEX C

AMENDMENTS TO NATIONAL INSTRUMENT 51-102 CONTINUOUS DISCLOSURE OBLIGATIONS

1. National Instrument 51-102 Continuous Disclosure Obligations is amended by this Instrument.

2. Subsection 8.3(1) is amended by replacing “subsection (3) and subsections 8.10(1) and 8.10(2)” with “subsection (5) and subsections 8.10(1) and (2)”.

3. Paragraph 8.3(1)(a) is amended by replacing “any of the three” with “2 or more of the”.

4. In the following provisions, “20” is replaced with “30”:

(a) paragraph (b) of subsection 8.3(1);

(b) paragraphs (a), (b) and (c) of subsection 8.3(2);

(c) paragraph (b) of subsection 8.3(3);

(d) paragraphs (a), (b) and (c) of subsection 8.3(4).

5. Subsection 8.3(5) is replaced with the following:

(5) Despite subsection (1) and for the purposes of subsection (3), an acquisition of a business or related businesses is not a significant acquisition,

(a) for a reporting issuer that is not a venture issuer, if the acquisition does not satisfy at least two of the optional significance tests under subsection (4); or

(b) for a venture issuer, if the acquisition would not satisfy the optional significance tests set out in paragraphs (4) (a) and (b) if “30 percent” were read as “100 percent”..

6. (1) This Instrument comes into force on November 18, 2020.

(2) In Saskatchewan, despite subsection (1), if these regulations are filed with the Registrar of Regulations after November 18, 2020, these regulations come into force on the day on which they are filed with the Registrar of Regulations.

August 20, 2020 (2020), 43 OSCB 6499

Notices

ANNEX D

CHANGES TO COMPANION POLICY 51-102CP CONTINUOUS DISCLOSURE OBLIGATIONS

1. Companion Policy 51-102CP Continuous Disclosure Obligations is changed by this Document.

2. Subsection 8.1(4) is changed by adding the following at the end of the subsection:

Reporting issuers are reminded that an acquisition may constitute the acquisition of a business for securities legislation purposes, even if the acquired set of activities or assets does not meet the definition of a “business” for accounting purposes..

3. Subsection 8.2(1) is replaced with the following:

8.2 Significance Tests

(1) Application of Significance Tests – Subsection 8.3(2) of the Instrument sets out the required significance tests for determining whether an acquisition of a business by a reporting issuer is a “significant acquisition”. The application of the significance tests depends on the status of the reporting issuer such that:

(a) if the reporting issuer is not a venture issuer, an acquisition is significant if it satisfies two or more of the significance tests at a 30% threshold; or

(b) if the reporting issuer is a venture issuer, an acquisition is significant if it satisfies either of the asset or investment test at a 100% threshold.

The test must be applied as at the acquisition date using the most recent audited annual financial statements of the reporting issuer and the business..

4. Paragraph 8.6(4)(b) is replaced with the following:

(b) When complete financial records of the business acquired do not exist, carve-out financial statements should be prepared..

5. These changes become effective on November 18, 2020.

August 20, 2020 (2020), 43 OSCB 6500

Notices

ANNEX E

CHANGES TO COMPANION POLICY TO NATIONAL INSTRUMENT 41-101 GENERAL PROSPECTUS REQUIREMENTS

1. Companion Policy to National Instrument 41-101 General Prospectus Requirements is changed by this Document.

2. Subsection 5.9(5) is changed by replacing the text of the first bullet with:

if the indirect acquisition would be considered a significant acquisition under subsection 35.1(4) of Form 41-101F1 if the issuer applied those provisions to its proportionate interest in the indirect acquisition of the business;.

3. This change becomes effective on November 18, 2020.

August 20, 2020 (2020), 43 OSCB 6501

Notices

ANNEX F

CHANGES TO COMPANION POLICY TO NATIONAL INSTRUMENT 44-101 SHORT FORM PROSPECTUS DISTRIBUTIONS

1. Companion Policy to National Instrument 44-101 Short Form Prospectus Distributions is changed by this Document.

2. Subsection 4.9(3) is changed by replacing the text of the first bullet with:

if the indirect acquisition would be considered a significant acquisition under Part 8 of NI 51-102 if the issuer applied those provisions to its proportionate interest in the indirect acquisition of the business; and.

3. This change becomes effective on November 18, 2020.

August 20, 2020 (2020), 43 OSCB 6502

Notices

ANNEX G

LOCAL MATTERS

ONTARIO SECURITIES COMMISSION

The Ontario Securities Commission:

• made the amendments to NI 51-102 pursuant to section 143 of the Securities Act (Ontario) (the Act), and

• adopted the changes to Companion Policy 51-102CP, Companion Policy 41-101CP and Companion Policy 44-101CP (the Changes) pursuant to section 143.8 of the Act.

The rule amendments and other required materials were delivered to the Minister of Finance on August 19, 2020.

The Minister may approve or reject the amendments or return them for further consideration. If the Minister approves the amendments or does not take any further action by October 18, 2020, the amendments and the Changes will come into force on November 18, 2020.

August 20, 2020 (2020), 43 OSCB 6503

Notices

1.1.2 Joint CSA/IIROC Staff Notice 23-327 – Update on Internalization within the Canadian Equity Market

Joint CSA/IIROC Staff Notice 23-327

Update on Internalization within the Canadian Equity Market

August 20, 2020

I. INTRODUCTION

This Staff Notice is a follow-up to Joint CSA/IIROC Consultation Paper 23-406 Internalization within the Canadian Equity Market (the Consultation Paper) that was published for a 60-day comment period on March 12, 2019, by staff of the Canadian Securities Administrators (CSA) and the Investment Industry Regulatory Organization of Canada (IIROC) (together, Staff or we).1 The Consultation Paper was published in response to concerns raised about the internalization of equity trades on Canadian marketplaces. 21 comment letters were received.

This Staff Notice summarizes the feedback received, refreshes certain data published as part of the Consultation Paper and provides an update on next steps.

II. BACKGROUND

Beginning in 2017, Staff became aware of growing concerns about a perceived increase in the magnitude of internalization of retail/small orders within the Canadian equity market.

Internalization generally refers to trades that are executed with the same dealer as both the buyer and the seller, with the dealer either acting as an agent for its clients on both sides of the trade, or trading as principal and taking the other side of a client order. Internalized trades occur on Canadian marketplaces as either “intentional” or “unintentional” crosses.2

The Consultation Paper provided background information that described certain relevant aspects of the Canadian rule framework, identified specific issues and concerns, and provided data illustrating recent levels of internalization in Canada.

A. Issues and Concerns

Below, we discuss the primary issues presented and the feedback received in response to the Consultation Paper. A complete summary of comments received and Staff responses is at Appendix B.

i. Broker Preferencing

As described in the Consultation Paper, broker preferencing is an important element of the concerns raised in relation to internalization. Broker preferencing is a common order matching feature of many Canadian equity marketplaces. It allows an incoming order sent to a marketplace to match and trade first with other orders from the same dealer, ahead of orders from other dealers that are at the same price and which have time priority. Broker preferencing is relevant to issues associated with internalization as it can facilitate internalization through the execution of unintentional crosses. It has been a divisive issue for many years in Canada, and the responses that Staff received to specific questions in the Consultation Paper related to broker preferencing reflects the continuing divergence in the views of stakeholders.

Some respondents articulated their belief that broker preferencing is a benefit to clients of dealers and a preferable alternative to equity market structure models in other jurisdictions. Some supporters expressed the view that retail clients were specific beneficiaries of better execution quality as a result of broker preferencing, and that the ability for dealers to efficiently interact with their own orders on a marketplace encourages the transparent display of liquidity on Canadian marketplaces.

Other commenters however, described negative impacts of broker preferencing, notably in the context of fairness through the creation of an unlevel playing field, where not all market participants, including investors, have equal access to interact with orders. Despite the views that broker preferencing benefits the Canadian market by encouraging displayed liquidity, some respondents argued that the impact is less beneficial and felt that the ability to override the time priority of other displayed orders

1 Published at: https://www.osc.gov.on.ca/documents/en/Securities-Category2/csa_20190312_internalization-within-the-canadian-equity-market.pdf 2 An “intentional” cross is considered to mean a trade that results from the simultaneous entry by a dealer of both the buy and the sell sides of a transaction in the same security at the same price. An “unintentional” cross is considered to mean the execution of a trade where the two orders are from the same dealer, but not simultaneously entered.

August 20, 2020 (2020), 43 OSCB 6504

Notices in an order book results in a negative impact on immediacy and a perception of a lack of fairness where a displayed order might not receive an execution despite it having been at the top of the order book queue.

The Consultation Paper specifically requested views on whether broker preferencing conveys greater benefits to larger dealers. Most commenters agreed that larger dealers and their clients may receive greater benefits. The Consultation Paper also specifically requested any data that illustrated either the positive or negative impacts of broker preferencing (and internalization, more generally). Very limited data was received that could quantitatively evidence the impacts. ii. The Individual Versus the Common Good

The Consultation Paper described the issue of the individual good versus the common good. It was noted that, while it may be reasonable to conclude that the internalization of client orders may benefit individual dealers and their respective clients, it may also be true that a market in which participants collectively act to maximize their own benefits may not result in a market which functions in the best interests of all those participating. Staff noted the importance of a balance between a market that adheres to the principles of fairness and integrity and one that operates to the benefit of the individual participants who interact within it.

The comments received regarding the common versus the individual good were mixed. Many characterized internalization as being contrary to the common good, while others suggested that Canadian market structure should seek to find an appropriate balance through the use of internalization. iii. Segmentation of Retail Orders

Segmentation of orders typically means the separation of orders from one class or type of market participant from those of other classes of participants. In describing this issue in the Consultation Paper, Staff noted that, in the Canadian context, this is typically focused on the orders of retail investors. The Consultation Paper discussed the value proposition inherent in interacting with retail orders, and we offered commentary on how Canadian market structure has evolved with various methods that seek to either implicitly or explicitly segment retail orders.

Most commenters believed that the segmentation of orders is a concern for a variety of reasons, including that the removal of access to retail orders (or orders of any participant) is contrary to principles of fairness and may result in a lower quality, less liquid and less competitive market. Some felt that a distinction was warranted between the segmentation resulting from participants choosing between various commercial models that are available to all market participants, and the segmentation schemes that serve to isolate retail orders through restricting access.

It was not evident from responses to the Consultation Paper that the Canadian market has reached a point where the level of segmentation requires an immediate policy response. Most respondents believed that the structure of the Canadian market provides for favourable outcomes for retail investors, although continued caution was recommended to avoid unbalanced results. iv. Automated Matching Against Client Orders on a Marketplace

The Consultation Paper highlighted that, as part of the ongoing technological evolution of the Canadian market, systems may be used by dealers to automate the internalization of orders through broker preferencing. It was noted by Staff, that such systems may appear to exhibit the characteristics of a marketplace as defined within the Canadian rule framework.3

Most commenters were of the view that systems that automate the internalization of orders should be considered a marketplace, and that relevant provisions of the rules should apply. Concerns were raised about the creation of discrete silos of liquidity within dealers that become inaccessible to the broader market. Some, however, suggested that dealers may simply be automating what has historically been a manual process, one that has never been considered a marketplace, and that the application of technology alone should not change the regulatory classification of dealer workflows.

III. Revised Internalization Data

In addition to describing various issues and seeking feedback, the Consultation Paper also included data that explored the magnitude of:

• intentional crosses;

• unintentional crosses;

• crosses where the dealer acted as principal; and

• the use of broker preferencing on certain Canadian marketplaces.

3 The definition of a “marketplace” is included in National Instrument 21-101 Marketplace Operation and, in Ontario, also in the Securities Act (Ontario).

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With respect to intentional and unintentional crosses, the data in the Consultation Paper relied on information received by IIROC through the Market Regulation Feed and submitted by each Canadian marketplace for the period of January 2016 through June 2018.

Data examining the magnitude of broker preferencing was provided directly to Staff by the marketplaces themselves. However, not all Canadian marketplaces were able to accurately distinguish between unintentional crosses resulting from broker preferencing itself (and where time priority was not followed), and unintentional crosses where a resting order was already in a position of time priority and would have been executed despite the availability of broker preferencing. This incomplete broker preferencing data requested from marketplaces covered the period of January 2017 through July 2018.

Some time has passed since the publication of the Consultation Paper and Staff’s review of the feedback received and associated data collected, and we are of the view that it is important to update certain data to more accurately reflect current market statistics. Therefore, we are republishing certain data at Appendix A that updates the period of coverage from January 2016 through October 2019. We have also added charts that represent information that the Consultation Paper included in graphs to make the information easier to read.

The data at Appendix A however, does not update the specific broker preferencing information initially provided by marketplaces for purposes of the Consultation Paper. While this data was informative, it did not include all Canadian marketplaces and as such, is incomplete for the purposes of regulatory policy decisions. IIROC has been working with Canadian marketplaces to receive broker preferencing data as part of the Market Regulation Feed, but IIROC has not received this for a sufficient length of time to provide updated information at Appendix A. Future analysis will consider this information and may also consider other market structure developments such as changes implemented by marketplaces that may impact levels of internalization.

IV. NEXT STEPS

The Consultation Paper purposely did not offer Staff’s views on the issues presented, but rather, focused specifically on seeking feedback in order to help inform future policy decisions. The background information and related narrative in the Consultation Paper recognized the competing interests associated with internalization and attempted to provide a balanced presentation of what Staff considers to be the primary issues.

The feedback received was varied and, consistent with the way the issues were framed in the Consultation Paper, balance was a common theme presented in the responses. Specifically regarding broker preferencing, while the practice is at odds with price/time priority in order execution, broker preferencing is a longstanding part of Canadian market structure. As currently functioning, broker preferencing may allow dealers to benefit from interaction with their own orders, and may also benefit individual clients with improved execution quality. There may be nuanced outcomes of broker preferencing, and some market participants may not be impacted in the same way as others. Based on the feedback received and the data reviewed, we do not believe that the Canadian market is presently functioning in a way that warrants near-term policy work or changes to the current rule framework.

As noted, the Consultation Paper highlighted that systems may be used by dealers to automate the internalization of orders, and that these systems may appear to exhibit characteristics of a marketplace as defined within the Canadian regulatory framework. This is further described in the guidance included in the Companion Policy to National Instrument 21-101 Marketplace Operation (NI 21-101CP) regarding when dealers may be operating a marketplace.4 The CSA will consider whether additional clarification should be provided in relation to when a system is a “marketplace”.

With respect to the updated data published at Appendix A, Staff note that the level of unintentional crosses has increased since the six-month period of January through June 2018, which was the final period of data initially published alongside the Consultation Paper. While the most recent data illustrates an increase, Staff have looked at the underlying non-public data and are comfortable that the increase is not an indication of broad changes in the way in which dealers are managing their orders or of a specific concern that necessitates an immediate regulatory policy response.

We will however, continue to monitor the data on an ongoing basis and if there are any indications that changes to internalization practices, including internalization that is enabled through the use of dealer systems, are possibly impacting Canadian market quality in a negative way, we will consider appropriate responses at that time.

4 Specifically, subsection 2.1(8) of NI 21-101CP clarifies that, if a dealer uses a system to match buy and sell orders or pair orders with contra-side orders outside of a marketplace and routes the matched or paired orders to a marketplace as a cross, it may be considered to be operating a marketplace under subparagraph (a)(iii) of the definition of “marketplace”.

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V. QUESTIONS

Please refer your questions to any of the following:

Kent Bailey Kortney Shapiro Senior Advisor, Trading, Market Regulation Legal Counsel, Market Regulation Ontario Securities Commission Ontario Securities Commission [email protected] [email protected]

Ruxandra Smith Roland Geiling Senior Accountant, Market Regulation Analyste en produits dérivés Ontario Securities Commission Direction de l'encadrement des bourses et des OAR [email protected] Autorité des marchés financiers [email protected]

Serge Boisvert Lucie Prince Analyste en réglementation Analyste Direction de l'encadrement des bourses et des OAR Direction de l'encadrement des bourses et des OAR Autorité des marchés financiers Autorité des marchés financiers [email protected] [email protected] Jesse Ahlan Meg Tassie Regulatory Analyst, Market Structure Senior Advisor Alberta Securities Commission British Columbia Securities Commission [email protected] [email protected]

Kevin McCoy Vice-President, Market Policy & Trading Conduct Compliance IIROC [email protected]

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Appendix A

Quantitative Analysis of Internalization on Canadian Marketplaces

Appendix A looks quantitatively at trading activity and features associated with the internalization of orders and updates the data that was initially published as Part 1 of Appendix A to the Consultation Report.

This appendix provides data with respect to the occurrences of intentional and unintentional crosses on all Canadian marketplaces for the period of January 2016 to October 2019, and relies on data received by IIROC through the Market Regulation Feed submitted by each marketplace.

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Fig. 1 – Percentage of Total Trades Executed as Intentional (IC) or Unintentional Crosses (UIC)

This figure shows overall crosses as a percentage of total number of trades. The upper chart shows unintentional crosses and the lower chart shows intentional crosses. Table 1 provides a summary of the averages and the percentage change over the

Fig 2 - Percentage of Total Volume Executed as Intentional or Unintentional Crosses

This figure shows overall crosses as a percentage of total volume traded. The upper chart shows unintentional crosses and the lower chart shows intentional crosses. Table 1 provides a summary of the averages and the percentage change over the id

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Fig 3 - Percentage of Total Value Executed as Intentional or Unintentional Crosses

This figure shows overall crosses as a percentage of total value traded. The upper chart shows unintentional crosses and the lower chart shows intentional crosses. Table 1 provides a summary of the averages and the percentage change over the period.

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Table 1 – Six-month Averages of Intentional and Unintentional Crosses

Change between Jan 2016 2016 2017 2017 2018 2018 2019 Change between Period 1 2016- Jun 2018 & Jul Period 1 Period 2 Period 3 Period 4 Period 5 Period 6 Period 7 and 7 2018 – Oct 2019 Net % Jan-June July-Dec Jan-June July-Dec Jan-June July-Dec Jan-June Net Change % Change Change Change Unintentional by 12.27% 11.64% 12.07% 13.12% 13.91% 15.38% 16.32% 4.05% 33.04% 3.44% 27.26% Trade Unintentional by 11.85% 11.70% 11.58% 12.62% 12.75% 13.23% 13.90% 2.05% 17.34% 1.49% 12.28% Volume Unintentional by 11.44% 11.39% 11.48% 12.65% 13.40% 14.21% 15.12% 3.68% 32.16% 2.99% 24.74% Value Intentional by 0.06% 0.07% 0.07% 0.10% 0.11% 0.11% 0.10% 0.04% 63.72% 0.02% 18.76% Trade Intentional by 11.53% 10.03% 10.46% 9.41% 8.87% 9.46% 9.09% -2.45% -21.21% -0.82% -8.19% Volume Intentional by 13.18% 12.13% 13.82% 12.09% 11.67% 10.88% 10.43% -2.75% -20.84% -1.94% -15.40% Value

Table 1 shows the average percentages of total trade executions executed as intentional and unintentional crosses by number of trade, total volume and value averaged over six-month periods. Net change between period 1 and 7 is calculated by comparing period 7 (Jan-June 2019) to period 1 (Jan-June 2016). % Change between period 1 and 7 is the net change as a percentage of the period 1 percentage.

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Fig 4 – Average Cross Trades by Account Type – Compared Against Average Non-cross (NC) Trades

Composition by Trades

100% 3% 1% 12% 90% 17% 80% 70% 31% 60% 78% 50% 40% 80% 30% 57% 20% 10% 22% 0% NC Trade UIC Trade IC Trade

CL-CL CL-IN OTHER

Fig 4 shows the percentage of intentional and unintentional crosses by number of trades and client types. Client types of non-cross trades are provided for comparison purposes. “OTHER” refers to any trade involving an account type market that is not CL-CL (Client to Client) or CL-IN (Client to Inventory).

Fig 5 – Average Cross Volume by Account Type – Compared Against Average Non-cross Volume

Composition by Volume 100% 7% 3% 3% 90% 18% 80% 23% 70% 60% 69% 50% 40% 80% 70% 30% 20% 28% 10% 0% NC Volume UIC Volume IC Volume

CL-CL CL-IN OTHER

Fig 5 shows the percentage of intentional and unintentional crosses by volume and client types. Client types of non-cross trades are provided for comparison purposes.

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Fig 6 – Average Cross Value by Account Type – Compared Against Average Non-cross Value

Composition by Value

100% 4% 2% 12% 90% 22% 80% 70% 32% 60% 73% 50% 40% 74% 30% 57% 20% 10% 25% 0% NC Value UIC Value IC Value

CL-CL CL-IN OTHER

Fig 6 shows the percentage of intentional and unintentional crosses by value traded and client types. Client types of non-cross trades are provided for comparison purposes.

Fig 7 – Crosses by Account Type

Fig 7 shows the change over the period by number of trades, total volume traded and total value traded by client type. The percentages are measured against the total trading that occurred on all marketplaces.

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Table 2 – Cross by Account Types – 6-month Averages

2016 2016 2017 2017 2018 2018 2019 Change between Change between Jan Period 1 Period 2 Period 3 Period Period Period 6 Period 7 Period 1 and 7 2016 – Jun 2018 & Jul 4 5 2018 – Oct 2019 Cross Account Jan-June July-Dec Jan-June July- Jan- Jul-Dec Jan-June Net % Net Change % Change Type Dec June Change Change Unintentional CL-CL 10.25% 9.47% 9.89% 10.13% 10.72% 12.35% 13.02% 2.77% 27.00% 2.73% 27.00% by Trade CL-IN 1.73% 1.95% 1.95% 2.74% 2.81% 2.58% 2.79% 1.07% 61.73% 0.50% 22.35% OTHER 0.29% 0.23% 0.24% 0.25% 0.39% 0.45% 0.51% 0.22% 75.44% 0.21% 76.05% Unintentional CL-CL 8.80% 8.46% 8.22% 8.79% 9.95% 10.95% 11.46% 2.66% 30.19% 2.72% 30.73% by Value CL-IN 2.25% 2.53% 2.91% 3.51% 3.00% 2.78% 2.93% 0.68% 30.20% 0.03% 1.20% OTHER 0.39% 0.40% 0.36% 0.35% 0.45% 0.48% 0.73% 0.34% 88.34% 0.23% 60.36% Unintentional CL-CL 9.37% 9.31% 8.97% 9.83% 10.12% 10.69% 11.32% 1.96% 20.92% 1.49% 15.61% by Volume CL-IN 2.18% 2.14% 2.38% 2.58% 2.40% 2.19% 1.97% -0.21% -9.44% -0.26% -11.20% OTHER 0.30% 0.25% 0.23% 0.21% 0.23% 0.35% 0.60% 0.30% 98.79% 0.26% 106.71% Intentional by CL-CL 0.018% 0.020% 0.019% 0.023% 0.019% 0.017% 0.019% 0.0005% 2.52% -0.002% -9.04% Trade CL-IN 0.04% 0.05% 0.05% 0.08% 0.09% 0.09% 0.08% 0.04% 87.98% 0.02% 26.13% OTHER 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% NA * 0.001% NA * Intentional by CL-CL 4.13% 3.75% 3.56% 3.23% 2.56% 2.26% 2.03% -2.10% -50.92% -1.33% -38.50% Value CL-IN 9.04% 8.38% 10.26% 8.65% 8.64% 8.11% 7.92% -1.12% -12.44% -0.96% -10.69% OTHER 0.00% 0.00% 0.00% 0.20% 0.47% 0.51% 0.49% 0.48% NA * 0.35% NA * Intentional by CL-CL 3.54% 3.16% 2.96% 2.94% 2.24% 2.44% 2.09% -1.45% -40.87% -0.69% -23.37% Volume CL-IN 7.99% 6.86% 7.50% 6.24% 6.16% 6.44% 6.46% -1.53% -19.19% -0.53% -7.69% OTHER 0.00% 0.00% 0.00% 0.23% 0.48% 0.58% 0.54% 0.54% NA * 0.40% NA *

Table 2 shows the average percentages of intentional and unintentional crosses by client type and number of trades, total volume and value averaged over six-month periods. Net change is calculated by comparing period 7 (Jan-June 2019) to period 1 (Jan-June 2016). % Change between period 1 and 7 is the net change as a percentage of the period 1 percentage. * Due to the negligible values in the denominator, the % changes are not informative. Thus, they are marked as NA.

Table 2.1 – Marketplace Reference Data

Market Name Market Alias Dark Market Market Full Name

ALF ALF No Alpha

AQD AQD Yes NEO-D

AQL AQL No NEO-L AQN AQN No NEO-N

CDX TSXV No TSX Venture

CHX CHX No Nasdaq CXC

CNQ CSE No Canadian Securities Exchange

CX2 CX2 No Nasdaq CX2 CXD CXD Yes Nasdaq CXD

ICX ICX Yes Instinet ICX

LIQ LIQ Yes Liquidnet

LYX LYX No Lynx

OMG OMG No Omega

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PTX PTX No Pure TCM TCM Yes MATCHNow

TSE TSX No TSX

Fig 8 – Average Cross Percentage by Marketplace – Relative to Own Trading

UIC Percentages per Marketplace 97.3% 100.0% 80.0% 59.8% 60.0% 40.0% 8.3% 16.4% 14.3% 14.8% 13.2% 20.0% 4.2% 7.9% 7.9% 7.5% 3.4% 6.3% 7.9% 7.5% 0.0% LIQ ICX TCM TSE CDX AQN AQL CX2 OMG CHX LYX AQD CXD ALF CNQ

TradeUIC VolumeUIC ValueUIC

IC Percentages Per Marketplace 100.0% 80.0% 60.4% 60.0% 40.0% 26.4% 20.0% 8.0% 4.7% 3.1% 2.1% 2.1% 0.2% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% AQN CHX CNQ OMG TSE CDX CX2 ALF LYX TCM AQL CXD LIQ ICX AQD

TradeIC VolumeIC ValueIC

Fig 8 shows the percentage of intentional and unintentional crosses by total trades, total volume and total value measured against each marketplace’s own trading. Percentages displayed above the bars correspond to volume.

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Fig 9 – Average Contribution by Marketplace

Fig 9 shows the percentage contribution by each marketplace against the total traded by all marketplaces. For comparison purposes, total (including cross and non-cross activity) number of trades, volume and value has been included. This chart is generated based on the exact data in Table 2.2.

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Table 2.2 – Average contribution by each marketplace in terms of intentional / unintentional cross trades and overall trades

Market Trade Volume Value Trade UIC Volume UIC Value UIC Trade IC Volume IC Value IC TSE 48.6% 36.3% 54.8% 55.1% 47.0% 66.4% 29.7% 29.8% 27.5% CDX 2.1% 18.2% 0.8% 2.1% 20.6% 0.9% 1.4% 4.0% 0.3% CHX 16.4% 10.4% 14.8% 12.8% 6.2% 9.2% 24.5% 28.1% 31.6% CNQ 3.2% 8.9% 2.2% 1.7% 9.3% 0.8% 3.3% 4.3% 3.8% TCM 6.2% 6.1% 5.7% 9.1% 4.0% 6.5% 0 0 0 AQN 2.5% 5.1% 5.5% 2.4% 1.7% 1.5% 40.1% 31.8% 33.2% ALF 5.5% 4.5% 5.8% 3.6% 2.6% 4.2% 0.1% 0.1% 0.1% OMG 6.9% 3.7% 4.2% 5.6% 2.3% 3.0% 0.1% 1.2% 2.9% CX2 5.8% 3.5% 3.8% 5.1% 2.2% 3.4% 0.8% 0.8% 0.7% AQL 2.1% 2.3% 1.5% 2.0% 2.6% 1.5% 0 0 0 CXD 0.6% 0.6% 0.5% 0.4% 0.4% 0.4% 0 0 0 LYX 0.2% 0.3% 0.1% 0.1% 0.1% 0.1% 0.001% 0.000% 0.000% LIQ 0.001% 0.1% 0.2% 0.0% 1.0% 1.8% 0 0 0 ICX 0.017% 0.020% 0.045% 0.1% 0.1% 0.2% 0 0 0 AQD 0.004% 0.004% 0.007% 0.003% 0.002% 0.004% 0 0 0 Total 100% 100% 100% 100% 100% 100% 100% 100% 100%

Fig 10 – CL-CL Crosses by Security Price

Fig 10 shows a breakdown of intentional and unintentional client-client crosses as a percentage of total trading activity over the period by security price. 5 buckets are used: =<.10, >.10 - $1, >$1 - $5, >$5 - $10, >$10.

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Fig 11 – CL-IN Crosses by Security Price

Fig 11 shows a breakdown of intentional and unintentional client-inventory crosses as a percentage of total trading activity over the period by security price. 5 buckets are used: =<.10, >.10 - $1, >$1 - $5, >$5 - $10, >$10.

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Fig 12 –Crosses by Liquidity

Fig 12 shows a breakdown of intentional and unintentional crosses as a percentage of total trading activity by client type over the period by liquidity. For the calculation of liquidity, the IIROC highly-liquid security list was used.

Table 3 – Average Contribution by Top 15 Dealers

Total Value 88.04%

Total Volume 81.87%

Total Trades 87.77%

Intentional Crosses - Value 85.97%

Intentional Crosses - Volume 77.11%

Intentional Crosses - Trades 81.16%

Unintentional Crosses - Value 94.75%

Unintentional Crosses - Volume 94.68%

Unintentional Crosses - Trades 98.59%

Table 3 aggregates the activity of the top 15 dealers as measured by trading activity. Percentages reflect the aggregate contribution over the period. For comparison purposes, total (including cross and non-cross trades) number of trades, volume and value have been included.

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Fig 13 – Top 15 Dealers - Crosses - Percentage of Own Trading

Fig 13 shows the percentage of intentional and unintentional crosses by client type of the top 15 dealers as compared against the total trading activity of the same top 15 dealers on all marketplaces.

Fig 14 – Top 15 Dealers - Crosses - Percentage of Total Trading

Fig 14 shows the percentage of intentional and unintentional crosses by client type of the top 15 dealers as compared against the total trading activity of all dealers on all marketplaces.

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APPENDIX B

Summary of comments received and responses

LIST OF COMMENTERS

1. The Canadian Advocacy Council for Canadian CFA Institute Societies

2. Leede Jones Gable Inc. – Jason Jardine

3. Buy Side Investment Management Association – Brent Robertson

4. Select Vantage Canada Inc. – Daniel Schlaepfer, Hugo Kruyne and Mario Josipovic

5. Canadian Foundation for Advancement of Investor Rights

6. NEO Exchange Inc. – Cindy Petlock

7. TD Direct Investing – Paul Clark

8. TD Securities Inc. – David Panko

9. Desjardins Securities

10. Acumen Capital Finance Partners Limited – Myja Miller

11. Ian Bandeen

12. Independent Trading Group

13. TMX Group Limited – Kevin Sampson

14. BMO Capital Markets – Dave Moore

15. Investment Industry Association of Canada – Susan Copland

16. RBC Dominion Securities Inc. Capital Markets and Wealth Management – Thomas Gajer

17. Scotiabank - Alex Perel

18. National Bank Financial Inc. – Nicolas Comtois, Alain Katchouni and Patrick McEntyre

19. Canadian Security Traders Association Inc.

20. Nasdaq Canada

21. CIBC World Markets Inc.

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Topic Summary of Comments CSA/IIROC Response General Comments One commenter suggested that the consultation process The public comment process specifically is biased towards large market participants and solicited views from all interested suggested that regulators hold both formal and informal stakeholders and we received comments roundtables in order to solicit views from all industry from both large and small participants. participants. Conversely, one commenter was supportive of what they believed was a collaborative consultation process.

One respondent expressed the view that regulatory While we agree with the view that concern in Canada stems from related concerns with the notable differences in market structure securities industry in the United States, and noted exist between Canada and the United differences in market structure between both countries, States, we do not agree with the belief particularly with respect to retail that the regulatory concern with respect internalization/wholesaling. to internalization in Canada stems from similar concerns that are present in the United States. We note, as an example, that broker preferencing is an important element of the concerns expressed and is an aspect of market structure that is generally unique to Canada.

Question 1 – How The Consultation Paper defined internalization as being do you define generally “a trade that is executed with the same dealer internalization? as both the buyer and the seller.” Most commenters agreed with the Consultation Paper’s definition of the term.

One respondent believed, however, that for the purposes The definition set out in the Consultation of the Consultation Paper, the definition should focus on Paper was not intended to focus on methods of internalization that are intentional and have a methods of internalization, but rather to high degree of certainty of the outcome, whether provide a broad definition from which we facilitated by technology or performed manually. could solicit feedback on several related issues.

Question 2 – (Key Most commenters agreed that the attributes set out in the We agree that the key market attributes attributes of a Consultation Paper are relevant considerations from a that were described as early as 1997, market) - Are all of regulatory policy perspective. and which have guided the consideration these attributes of market structure policy changes relevant One commenter believed that rather than applying the should be applied broadly to the entire considerations attributes strictly, they should be applied to the entire market. We note that these attributes from a regulatory market ecosystem to recognize the role that dealers play have influenced policy decisions over policy in contributing to market quality. the years that are related not only to perspective? If not, marketplaces, but to issues that impact please identify all stakeholders. those which are not relevant, and why.

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Question 3 – (Key Most respondents articulated that internalization can We highlight the differing views attributes of a impact the stated attributes, either positively or presented by respondents. We believe market) - How does negatively. One commenter stated that internalization that the diversity of comments supports internalization harms all the attributes. Another commenter stated that the position that while some attributes relate to each of internalization increases segmentation, which in turn may be impacted through internalization, these attributes? If affects various attributes. the magnitude of the impact cannot be other attributes easily quantified. should be Specifically, some argued that increased levels of considered in the internalization will impact liquidity through wider spreads context of and more unstable quotes, while others believed that internalization, internalization enhances both liquidity and immediacy of please identify order execution. these attributes and provide Some commenters believed that changes to the rules We note this response as an example rationale. related to internalization, particularly broker preferencing, that recognizes the need to be cautious may cause dealers to seek to replicate the benefits that that regulatory policy changes are they receive in other ways, which may negatively impact balanced and do not result in unintended key market attributes. outcomes.

Question 4 - Please Most commenters characterized internalization as being We highlight the reference to balance as provide your detrimental to the common good, however many also a common theme throughout many of thoughts on the expressed a desire to find a balance between the the responses received. We are of the question of the individual good (e.g. internalization, broker preferencing) view that balance is an important common versus and the common good (e.g. fair access, price discovery). consideration in evaluating any policy the individual good However, a few commenters supported internalization work in relation to the concerns raised. in the context of over the common good. internalization and best execution. Several commenters prioritized the common good over We recognize the underlying concerns the individual good, while others expressed concern with respect to increased levels of about the outcomes of increased internalization, including internalization. While we do not believe its impacts on liquidity and overall market toxicity. that the current data regarding internalization indicates concerns that One respondent believed that market participants who warrant an immediate policy response, benefit from internalization may have little incentive to we intend to monitor data on an ongoing promote the common good. basis, both specific to the magnitude of internalization as well as general market quality measures. Where we see evidence of negative impacts, we will consider appropriate policy responses at that time.

One commenter, however, expressed concern over As previously noted, we recognize the focusing primarily on the common good because in doing need to continue to ensure a competitive so, it may ultimately sacrifice execution quality and pose Canadian market while also being a risk of losing global order flows into the Canadian cautious that regulatory policy changes market. do not result in unintended outcomes.

Question 5 - Please The sole direct respondent to this question asserted that We highlight the lack of available data provide any data it is difficult to measure the impact of internalization on from respondents and reiterate that we regarding market market quality without conducting a formal study. have not seen specific negative impacts quality measures Furthermore, they believe that the U.S. market has a that warrant an immediate policy that have been higher execution quality than in Canada, and believes this response. impacted by may be a result of greater liquidity available through internalization. internalization. Please include if there are quantifiable differences between liquid and illiquid equities.

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Question 6 - The sole respondent to this question asserted their clients See above re: Question 5. Market benefit from internalization through higher fill rates on participants: passive orders, reduced market impact of marketable please provide any orders, lower indirect cost of execution and a reduction in data that illustrates adverse selection. the impacts to you or your clients resulting from your own efforts (or those of dealers that execute your orders) to internalize client orders (e.g. cost savings, improved execution quality) or the impacts to you or your clients resulting from internalization by other market participants (e.g. inferior execution quality/reduced fill rates).

August 20, 2020 (2020), 43 OSCB 6524

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Question 7 – Commenters highlighted many benefits and drawbacks to As referenced above, we believe that the Please provide broker preferencing. Generally, respondents were divided diversity of views expressed in the your views on the in their support or opposition. comments we received is supportive of benefits and/or Specific benefits that were noted included: the position that the magnitude of the drawbacks of • immediacy of trade execution and reduced execution impact of broker preferencing cannot be broker costs; easily quantified, and we again highlight preferencing? • improves the ability of retail and institutional clients to the theme of balance. We are of the capture the spread; view that a policy response at this time, • reduction in the market impact of larger orders; absent clear evidence of a market • broker preferencing is preferable to other alternatives, structure that is negatively impacting the including an expansion in the number of dark pools common good, may affect the balance of and/or dealers setting up their own trading venues; Canadian market structure and result in and other outcomes. As part of our ongoing • as compared to U.S. market structure, it is preferable monitoring, we are committed to because: continuing to evaluate the extent to o it is more fair; which order execution results from o the primary beneficiaries are retail clients; broker preferencing, and any and corresponding impacts. o it encourages the posting of liquidity on public marketplaces and client-to-client order matching. Drawbacks that were noted included: • a negative impact on fairness and/or the principles of We refer to previous responses related a fair and open market by creating an unlevel playing to potential unintended outcomes that field, as not all participants have the chance to may result from immediate policy interact with a given order; and responses that are not supported by • a negative impact on immediacy for displayed orders measurable evidence of an existing and a resulting negative perception of fairness if issue. orders are not executed or if immediacy is reduced.

Several commenters noted that the concerns raised may be especially impactful where broker preferencing is leveraged on a systematic basis.

Many respondents offered comments in relation to potential changes to the application of broker preferencing. Commenters were divided in this regard.

Several commenters supported either a full prohibition of broker preferencing, or a limitation of its application to smaller orders (typically less than 50 standard trading units).

Respondents who were not in favour of changes or restrictions, were of the view that this would result in increased costs and complexity and that alternatives could lead to greater market fragmentation and an increased advantage to market participants who utilize low latency trading strategies.

It was also noted that restrictions are unnecessary as We will continue to monitor our trading Rule 6.3 Order Exposure of the Universal Market Integrity rules and that the policy objectives Rules (UMIR)already facilitates price discovery, continue to be met. We may propose immediacy and liquidity. amendments where appropriate if we identify rules that are not meeting the intended policy objectives. One commenter also believed that restrictions on broker preferencing could impact the competitiveness of the Canadian market by increasing costs.

August 20, 2020 (2020), 43 OSCB 6525

Notices

Question 8 - One commenter observed that, based on its internal We highlight the lack of available data Market statistics, no one client segment benefits illustrating specific negative impacts that participants: where disproportionately from broker preferencing. warrant an immediate policy response. available, please provide any data that illustrates the impact of broker preferencing on order execution for you or your clients (either positive or negative).

Question 9 - Please Most commenters supported the view that larger firms We recognize the concerns that, in provide your gain greater benefits relative to smaller dealers. One relation to broker preferencing, smaller thoughts regarding commenter noted that broker preferencing creates an dealers may be at a disadvantage as the view that incentive for liquidity providers to become clients of larger compared to larger dealers that have broker dealers. significantly higher volume of orders. We preferencing note that benefits of broker preferencing conveys greater Others were less supportive of this view and offered a are not exclusive to larger dealers and benefits to larger number of qualifying comments. Respondents expressed that small dealers can also benefit both dealers. the view that broker preferencing does not only benefit in circumstances where they have larger dealers, but any dealer with two-sided volume of existing orders in an order book, and client orders, with diversified business lines or with a potentially by access to greater liquidity large amount of active (i.e. marketable) order flow. provided through the trading activity of other dealers. Absent clear evidence of One commenter believed that broker preferencing an unbalanced market structure that is benefits smaller dealers as it provides greater liquidity, causing measurable negative impacts, price discovery and access to order flow as compared to we are cautious of proposing changes at alternative market structures that exclude small dealers this time, but will continue to monitor for entirely. impacts going forward.

August 20, 2020 (2020), 43 OSCB 6526

Notices

Question 10 – A couple of commenters noted that they were not aware Does broker of any studies covering the impact of broker preferencing preferencing on either liquid or illiquid securities. impact (either positively or Those that responded to the question had mixed views. A We believe that the divergent views negatively) illiquid couple of commenters noted that there is a higher trading support the position that the magnitude or thinly-traded volume in liquid securities which ultimately leads to a of any impacts of broker preferencing equities differently higher frequency of broker preferencing. between liquid and less-liquid securities than liquid cannot be easily determined. We will equities? Most of those who responded to this question thought continue to monitor market quality that the impact of broker preferencing is more measures and the magnitude of broker pronounced on illiquid securities, for reasons including: preferencing and will consider the • the value of time priority is large for thinly traded liquidity profile of a security. securities or for those where trading is concentrated on one marketplace; • queue-jumping resulting from broker preferencing may have a greater impact on the perception of fairness with respect to illiquid securities; • concerns about the liquidity of these securities are already high; and • broker preferencing may incentivize dealers to make markets, thus contributing to liquidity when it is most needed.

A couple of commenters thought the impact of broker preferencing is higher on liquid securities. One commenter noted that more liquid securities trade in multiple order books with deep queues, especially at lower price points. It is difficult for resting orders to be filled on time priority alone, thus they benefit from broker preferencing.

Another respondent thought that broker preferencing is not a key factor in the liquidity of thinly-traded securities, as liquidity is primarily a function of institutional ownership, retail interest, research coverage and not of market microstructure.

Finally, one commenter noted that the impact is likely the same for liquid and illiquid securities.

August 20, 2020 (2020), 43 OSCB 6527

Notices

Question 11 – Do Two commenters, representing sell-side participants, We are of the view that, if a dealer’s you believe that a were of the view that if dealers are automating what could activities are similar to those undertaken dealer that be done manually, or what was done manually in the by a marketplace, in that the dealer internalizes orders past, they should not be considered a marketplace as systematically matches buy and sell on an automated defined in the Marketplace Rules. The application of orders of securities with limited and systematic technology should not change how an activity is classified discretion by the dealer in the execution basis should be from a regulatory perspective. One of the commenters process, it may meet the definition of a captured under the noted, however, that mechanisms for holding large marketplace. The CSA will consider definition of a numbers of client orders away from the open market whether additional clarification should be marketplace in the while systematically seeking to find matches within those provided in relation to when a system is Marketplace orders would be outside what can be done manually by a “marketplace”. Rules? Why, or dealers and such systems would be a marketplace. why not? Most commenters, however, thought that a dealer or any We share the concerns of respondents system that automates the internalization of orders in relation to silos of liquidity and should be considered a marketplace. These commenters potential negative impacts on the noted that the Canadian market is relatively small and Canadian market, but do not believe that has large intermediaries and significant retail the current available data illustrates participation. Creating silos of liquidity would not only concerns that require an immediate reduce efficiency but so too negatively impact fairness. If policy response. As highlighted in considered marketplaces, the fair access requirements in previous responses, we intend to the Marketplace Rules would therefore apply. continue monitoring for such negative impacts and will consider appropriate policy measures where, and if necessary.

August 20, 2020 (2020), 43 OSCB 6528

Notices

Question 12 – Do The majority of commenters thought segmentation of We note that we share some of the you believe orders is a concern, for reasons including: concerns highlighted, especially as they segmentation of • it runs contrary to the principle of fair access; relate to overall quality of the Canadian orders is a • it siloes liquidity and reduces opportunities for the market. concern? Why, or broadest degree of order interaction; why not? Do your • undermining the diversity of orders in the market As noted in the Consultation Paper, views differ would make it less liquid and less competitive; segmentation of orders may result from between order • segmentation of retail orders in particular, is an different mechanisms including: segmentation that unhealthy trend, particularly in a smaller market like • marketplace fee models (i.e. is achieved by a Canada where there are liquidity challenges; fee and rebate structures); dealer internalizing • removal of one category of orders would negatively • other marketplace functionality its own orders and impact price discovery; it was noted that the removal (e.g. order processing delays, order of retail order flow would negatively impact price market maker programs); and segmentation that discovery as it is a significant contributor to price • dealer trading practices or is facilitated by discovery; processes that seek to marketplaces? • removal of retail order flow would increase toxicity internalize retail, or potentially among the remaining non-retail market, driving the other order flow. non-retail market away from transparent markets; • segmentation is often associated with information leakage; and • it may erode market quality in Canada.

Some commenters noted the proliferation of order types and incentives offered by marketplaces. One also noted that these marketplace offerings drive unnecessary intermediation.

One commenter indicated that there should be a In the review of various marketplace distinction between implicit and explicit segmentation. proposals, we consider issues related to The commenter noted that there is a difference between segmentation, particularly in the context competing commercial models that incentivize of fair access and leakage of participants to seek out the services that best meet their information, and the impacts of objectives, but marketplace features should be accessible marketplace proposals on Canadian to all and users can choose how to use them. However, market quality. We have not currently there should not be features that explicitly segment identified concerns from segmentation of orders and restrict access. orders that we believe necessitates an Some commenters noted that the concerns with respect immediate policy response. to segmentation are the same regardless of whether it occurs at the dealer level, through internalization, or through marketplace features. It was noted that marketplaces and dealers enabling segmentation have been treated differently from a regulatory perspective, which is a concern.

One commenter was of the view that some level of segmentation is necessary in order to improve execution quality for certain classes of orders, however, if it were excessive, it would impact market quality. The commenter noted that the segmentation of retail orders in the U.S., through wholesaling, has been successful in improving immediacy, execution quality and market impact for retail clients. The same commenter was of the view that the erosion of the Canadian market share is directly related to the inability to segment retail order flow in the existing regulatory framework.

August 20, 2020 (2020), 43 OSCB 6529

Notices

Question 13 – Do While not necessarily agreeing in all cases with the term While we are of the view that a “perfect” you believe that “optimal”, commenters were generally supportive of market structure likely does not exist, we Canadian market Canadian market structure relative to other jurisdictions believe that the current Canadian market structure and the and were of the view that the Canadian market structure ecosystem represents a reasonable existing rule and the existing rule framework provide for favourable equilibrium between the needs of framework execution outcomes for retail orders. Some highlighted various market participants, including provides for certain rules and requirements supporting retail order retail investors. optimal execution execution, while another noted that retail orders are the outcomes for retail beneficiaries of low trading fees charged by retail dealers. orders? Why or why not? One commenter noted the inherent challenge in the obligation for dealers to improve retail order execution outcomes, and the potential impact on the wider market. This sentiment was echoed by another commenter who suggested that any additional decisions taken to benefit retail should be undertaken with caution to avoid tradeoffs between the common and individual good.

One commenter disagreed with the notion that retail We agree with the importance of orders receive optimal execution outcomes and ensuring the Canadian market continues suggested that retail orders receive better execution in to be competitive, especially where the U.S. This commenter highlighted the importance of trading in securities listed in Canada can ensuring that Canadian markets are competitive with the easily be effected in Canada and/or in U.S. to protect our market share while attracting other jurisdictions. additional orders.

August 20, 2020 (2020), 43 OSCB 6530

Notices

Question 14 - Many respondents provided views on potential changes Should the CSA to the rule framework to address concerns related to retail and IIROC orders. One commenter highlighted existing rules and consider changes noted that IIROC and the CSA should continue ensuring to the rule that dealers comply, including with respect to order framework to exposure, best execution, and client-principal trading. address considerations Several commenters specifically highlighted UMIR Rule As part of the on-going work associated related to orders 6.3 Order Exposure and expressed the view that the with this project, IIROC will review many from retail order size thresholds associated with its application of the provisions within UMIR to ensure investors? If yes, should be reviewed with the possibility of amending them the intended policy objectives continue please provide in a way that strengthens the rule and the corresponding to be met. IIROC will consider rules your views on the benefits for retail orders. It was noted that this may amendments as appropriate. specific similarly strengthen other UMIR Rules to which the considerations that thresholds are applicable. could be addressed and Several respondents identified the “guaranteed fill” The CSA has considered the various proposed facilities or functionality in place at various Canadian ‘guaranteed fill’ facilities in the context of solutions. marketplaces and which typically apply to the execution balancing the obligations of exchange of retail orders. Some were of the view that these facilities market makers relative to the benefits should be revisited in a way that either limits or afforded. The CSA believes that they are reconsiders their use entirely, although one commenter currently balanced appropriately and noted that such facilities have allowed retail dealers to note that while some may view such find better liquidity for retail order execution. One facilities as a benefit rather than an commenter also suggested that such facilities only be obligation, the programs are typically permitted to be offered by a listing exchange in the designed to supplement liquidity in an context of a formal market making program. exchange’s order book and further note that existing displayed orders receive execution priority.

A number of commenters recommended that the CSA The CSA has proposed such reporting and IIROC introduce order routing and execution requirements in the past, but did not reporting requirements both in the context of retail and move forward with finalizing proposals. If institutional orders. warranted, the CSA would again consider whether reporting would provide meaningful benefits.

Two commenters suggested a dedicated facility for the The CSA and IIROC are supportive of execution of retail orders that would have open access for innovation that might help to improve anyone seeking to provide liquidity to retail orders on a Canadian market structure and would multilateral basis. One of these commenters believed that review any marketplace proposals in this this would provide some of the advantages of the regard in accordance with the normal wholesale model in the U.S., but ensure multilateral processes. interactions.

One commenter recommended that the CSA and IIROC Like many jurisdictions globally, we are require the provision of access to real-time data for retail considering a variety of issues investors and investment advisors to provide a better associated with market data. Any view of available liquidity and how orders are executed, proposals in relation to market data while supporting more informed investment decisions. would be made under a separate policy initiative.

August 20, 2020 (2020), 43 OSCB 6531

Notices

Question 15 – Are Some respondents offered additional areas that they there other believed would be relevant for consideration. relevant areas that should be One commenter highlighted the mandated trading We acknowledge the comment but note considered in the increments defined in UMIR as being at the core of that removing the minimum trading scope of our internalization activities and the practice of spread increment would result in trades quoted review? capture. This commenter suggested that reducing or at sub-penny increments. We are eliminating the minimum trading increment would benefit cautious of any potential unintended investors and the potential for spread reductions could consequences and impacts to the result in greater volume and improved liquidity. industry.

Another respondent suggested that the CSA reconsider fee structures that discriminate between different types of participants with the goal of providing a better balance between the individual and the common good.

Further related to fee structures, one commenter expressed support for the proposed CSA trading fee rebate pilot, noting that trading fees and trading fee models are some of the biggest contributors to segmentation. While not expressing support for the pilot, another respondent suggested capping rebates for liquidity-removal paid by marketplaces with inverted “taker-maker” fee schedules.

One commenter suggested that orders that are created solely to take advantage of existing orders are not appropriate.

August 20, 2020 (2020), 43 OSCB 6532

Notices

1.2 Notices of Hearing

1.2.1 ESW Capital, LLC and Optiva Inc. – s. 104

FILE NO.: 2020-26

IN THE MATTER OF ESW CAPITAL, LLC

AND

IN THE MATTER OF OPTIVA INC.

NOTICE OF HEARING Section 104 of the Securities Act, RSO 1990, c S.5

PROCEEDING TYPE: Application for Transactional Proceeding

HEARING DATE AND TIME: August 21, 2020 at 10:00 a.m.

LOCATION: By Videoconference

PURPOSE

The purpose of this proceeding is to consider the Application filed by ESW Capital, LLC dated August 6, 2020, requesting an order granting exemptive relief from the requirement set forth in section 2.29.1(c) of National Instrument 62-104 - Take-Over Bids and Issuer Bids.

The hearing set for the date and time indicated above is the first attendance in this proceeding, as described in subsection 7(1) of the Commission’s Practice Guideline.

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 12th day of August, 2020

“Grace Knakowski” Secretary to the Commission

For more information

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

August 20, 2020 (2020), 43 OSCB 6533

Notices

1.4 Notices from the Office of the Secretary 1.4.2 First Global Data Ltd. et al.

1.4.1 ESW Capital, LLC and Optiva Inc. FOR IMMEDIATE RELEASE August 14, 2020 FOR IMMEDIATE RELEASE August 12, 2020 FIRST GLOBAL DATA LTD., GLOBAL BIOENERGY RESOURCES INC., ESW CAPITAL, LLC and NAYEEM ALLI, OPTIVA INC., MAURICE AZIZ, File No. 2020-26 HARISH BAJAJ, AND ANDRE ITWARU, TORONTO – On August 12, 2020 the Commission issued File No. 2019-22 a Notice of Hearing pursuant to Section 104 of the Securities Act, RSO 1990, c S.5 to consider the Application TORONTO – The Commission issued an Order in the filed by ESW Capital, LLC dated August 6, 2020, above named matter. requesting an order granting exemptive relief from the requirement set forth in section 2.29.1(c) of National A copy of the Order dated August 13, 2020 is available at Instrument 62-104 - Take-Over Bids and Issuer Bids. www.osc.gov.on.ca.

The hearing will be held on August 21, 2020 at 10:00 a.m. OFFICE OF THE SECRETARY GRACE KNAKOWSKI A copy of the Notice of Hearing dated August 12, 2020 and SECRETARY TO THE COMMISSION the Application dated August 6, 2020 are available at www.osc.gov.on.ca. For Media Inquiries:

OFFICE OF THE SECRETARY [email protected] GRACE KNAKOWSKI SECRETARY TO THE COMMISSION For General Inquiries:

For Media Inquiries: 1-877-785-1555 (Toll Free) [email protected] [email protected]

For General Inquiries:

1-877-785-1555 (Toll Free) [email protected]

August 20, 2020 (2020), 43 OSCB 6534

Notices

1.4.3 Joseph Debus 1.4.4 Canada Cannabis Corporation et al.

FOR IMMEDIATE RELEASE FOR IMMEDIATE RELEASE August 18, 2020 August 18, 2020

JOSEPH DEBUS, CANADA CANNABIS CORPORATION, File No. 2019-16 CANADIAN CANNABIS CORPORATION, BENJAMIN WARD, TORONTO – The Commission issued its Reasons for SILVIO SERRANO, and Decision in the above named matter. PETER STRANG, File Nos. 2019-34 and 2020-13 A copy of the Reasons for Decision dated August 18, 2020 is available at www.osc.gov.on.ca. TORONTO – Take notice that an attendance in the above- named matters is scheduled to be heard on August 26, OFFICE OF THE SECRETARY 2020 at 10:00 a.m. GRACE KNAKOWSKI SECRETARY TO THE COMMISSION OFFICE OF THE SECRETARY GRACE KNAKOWSKI For Media Inquiries: SECRETARY TO THE COMMISSION [email protected] For Media Inquiries:

For General Inquiries: [email protected]

1-877-785-1555 (Toll Free) For General Inquiries: [email protected] 1-877-785-1555 (Toll Free) [email protected]

August 20, 2020 (2020), 43 OSCB 6535

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August 20, 2020 (2020), 43 OSCB 6536

Chapter 2

Decisions, Orders and Rulings

2.1 Decisions PICTON MAHONEY FORTIFIED ARBITRAGE ALTERNATIVE FUND 2.1.1 Picton Mahoney Asset Management et al. PICTON MAHONEY FORTIFIED ARBITRAGE PLUS ALTERNATIVE FUND Headnote (the Existing Funds) and the investment funds, including exchange traded funds, structured as National Policy 11-203 Process for Exemptive Relief “alternative mutual funds” as defined in Applications in Multiple Jurisdictions – Relief granted from National Instrument 81-102 Investment Funds short selling and cash borrowing restrictions in NI 81-102 to (NI 81-102) managed and advised by the Filer in the permit alternative mutual funds to conduct physical short future (the Future Funds and, collectively with the sales and cash borrowing up to a combined aggregate limit Existing Funds, the Funds) of 100% of the fund’s net asset value, subject to conditions. DECISION Relief also granted from custody and collateral restrictions in NI 81-102 to permit excluding, from the 25% of an Background alternative mutual fund’s net asset value that may be deposited with a borrowing agent that is not the fund’s The principal regulator in the Jurisdiction has received an custodian or sub-custodian as security in connection with a application (the Application) from the Filer on behalf of the short sale, the aggregate market value of proceeds from Funds for a decision under the securities legislation of the outstanding short sales of portfolio securities held by the Jurisdiction (the Legislation) exempting each Fund from: borrowing agent, subject to conditions. (i) the following restrictions of NI 81-102 to permit Applicable Legislative Provisions each Fund to sell securities short and/or borrow cash up to a combined aggregate total of 100% of National Instrument 81-102 Investment Funds, ss. 2.6, the net asset value (NAV) of the Fund: 2.6.1, 2.6.2, 6.1, 19.1. (a) Subparagraph 2.6.1(1)(c)(v), which July 7, 2020 restricts a Fund from selling a security short if, at the time, the aggregate market IN THE MATTER OF value of all securities sold short by the THE SECURITIES LEGISLATION OF Fund exceeds 50% of the Fund’s NAV ONTARIO (together with ((i)(c) below, the Short (the Jurisdiction) Selling Limit);

AND (b) Subparagraph 2.6(2)(c), which restricts a Fund from borrowing cash if the value of IN THE MATTER OF cash borrowed, when aggregated with THE PROCESS FOR EXEMPTIVE RELIEF the value of all outstanding borrowing by APPLICATIONS the Fund, exceeds 50% of the Fund’s IN MULTIPLE JURISDICTIONS NAV (together with (i)(c) below, the Cash AND Borrowing Limit);

IN THE MATTER OF (c) Section 2.6.2, which restricts a Fund from PICTON MAHONEY ASSET MANAGEMENT borrowing cash or selling securities short (the Filer) if, immediately after entering into a cash borrowing or short selling transaction, the AND aggregate value of cash borrowed combined with the aggregate market IN THE MATTER OF value of all securities sold short by the PICTON MAHONEY FORTIFIED ACTIVE EXTENSION Fund (the Combined Aggregate Value) ALTERNATIVE FUND would exceed 50% of the Fund’s NAV PICTON MAHONEY FORTIFIED MARKET NEUTRAL and which requires a Fund, if the ALTERNATIVE FUND Combined Aggregate Value exceeds PICTON MAHONEY FORTIFIED MULTI STRATEGY 50% of the Fund’s NAV, as quickly as ALTERNATIVE FUND commercially reasonable, to take all PICTON MAHONEY FORTIFIED INCOME ALTERNATIVE necessary steps to reduce the Combined FUND

August 20, 2020 (2020), 43 OSCB 6537

Decisions, Orders and Rulings

Aggregate Value to 50% or less of the securities, third party borrowers and the Fund’s securities Fund’s NAV; and lending agent;

(ii) the requirement in subsection 6.1(1) of NI 81-102 Representations that, except as provided, all portfolio assets of a Fund be held under the custodianship of one This decision is based on the following facts represented qualified custodian, to permit a Fund to deposit by the Filer: portfolio assets with a borrowing agent that is not the Fund’s custodian or sub-custodian in The Filer connection with a short sale of securities, if the aggregate market value of the portfolio assets held 1. The Filer is a general partnership formed under by the borrowing agent after such deposit, the laws of the Province of Ontario. The head excluding the aggregate market value of the office of the Filer is in Toronto, Ontario. proceeds from outstanding short sales of 2. The Filer is the investment fund manager and securities held by the borrowing agent, does not portfolio manager of each Existing Fund and will exceed 25% of the NAV of the Fund at the time of be the investment fund manager and portfolio deposit (the Short Sale Collateral Relief); manager of each of the Future Funds. As such, ((i) (a) and (c) together, the Short Selling Relief, (i) (b) and the Filer is, or will be, responsible for managing (c) together, the Cash Borrowing Relief, and collectively the assets of the Funds and has, or will have, with the Short Sale Collateral Relief, the Requested complete discretion to invest and reinvest the Relief). Funds’ assets and is, or will be, responsible for executing all portfolio transactions. Under the Process for Exemptive Relief Applications in Multiple Jurisdictions (for a passport application): 3. The Filer is registered as an investment fund manager, portfolio manager and exempt market (i) the Ontario Securities Commission is the dealer in the Province of Ontario and is registered principal regulator for the Application; as an adviser in the category of commodity trading manager under the Commodity Futures Act (ii) the Filer has provided notice that (Ontario). subsection 4.7(1) of Multilateral Instrument 11-202 Passport System (MI 4. The Filer is also registered as an investment fund 11-102) is intended to be relied upon in manager, portfolio manager and exempt market each of British Columbia, Alberta, dealer in the Province of Québec; an investment Saskatchewan, Manitoba, Québec, New fund manager and exempt market dealer in the Brunswick, Nova Scotia, Prince Edward Province of Newfoundland and Labrador; an Island, Newfoundland and Labrador, exempt market dealer in the Province of Alberta; Yukon, Northwest Territories and and as a portfolio manager and exempt market Nunavut (the Other Jurisdictions and, dealer in the provinces of British Columbia, together with the Jurisdiction, the Saskatchewan, Manitoba and Prince Edward Jurisdictions). Island.

Interpretation 5. The Filer is not in default of applicable securities legislation in any of the Jurisdictions. Terms defined in National Instrument 14-101 Definitions have the same meaning if used in this decision, unless The Funds otherwise defined; 6. Each of the Funds is, or will be, organized as a AIF means an annual information from of a Fund prepared trust established under the laws of the Province of in accordance with Form 81-102F2 Contents of Annual Ontario or another Jurisdiction. Information Form, as amended from time to time; 7. Each of the Existing Funds is, and each of the Prime Broker means any entity that acts as a lender or Future Funds will be, an open-ended public borrowing agent, as the case may be, to one or more “alternative mutual fund” as defined in and investment funds; governed by NI 81-102.

Prospectus means a prospectus of a Fund prepared in 8. Units of the Funds are, or will be, offered by accordance with Form 81-101F1 Contents of Simplified Prospectus, AIF, fund facts and, in certain Prospectus or Form 41-101F2 Information Required in an instances, ETF facts, filed in one or more of the Investment Fund Prospectus, as each may be amended Jurisdictions and, accordingly, each Fund is, or from time to time; will be, a reporting issuer in the Jurisdictions where the Requested Relief is relied upon. Securities Lending Agreements means agreements which effect securities lending, repurchase or reverse repurchase transactions between a Fund, as lender of the

August 20, 2020 (2020), 43 OSCB 6538

Decisions, Orders and Rulings

9. Each of the Existing Funds is not in default of (a) Prime Brokers typically have greater applicable securities legislation in any of the flexibility to offer more favourable Jurisdictions. financing terms to a Fund in relation to the aggregate amount of the Fund’s Reasons for the Requested Relief assets held in the prime brokerage margin account. Derivative instruments, Short Selling Relief and Cash Borrowing Relief such as futures contracts and over the counter (OTC) derivatives, are not held in 10. The investment objective of each Fund will differ a prime brokerage account and therefore but, in each case, key investment strategies which reduce the ability of a Fund to obtain the may be utilized by a Fund will include (a) the use most beneficial pricing terms available. of market-neutral, offsetting, inverse or shorting strategies requiring the use of short selling in (b) Margin requirements for derivative excess of the Short Selling Limit and/or (b) the instruments are primarily based on the use of cash borrowing to provide additional underlying investment exposure and, as investment exposure in connection with the a result, can be high. investment strategies of the Fund in excess of the Cash Borrowing Limit. (c) Certain derivative instruments (such as futures contracts) require cash or near 11. Market-neutral strategies are well-recognized for cash securities (such as government limiting market risk, balancing long and short treasuries) to be deposited with the positions within an investment portfolio with the counterparty as collateral. This would objective of providing positive returns regardless require a Fund to use these portfolio of whether the broader market rises, falls or is flat. assets to satisfy collateral requirements Market-neutral strategies are designed to have rather than utilizing them in connection less volatility than the broader market when with the Fund’s investment strategy. measured over medium to long-term periods. Market-neutral strategies also provide 15. The Funds may use cash borrowing as a more diversification to investors as returns are intended flexible and cost-efficient means of providing to be uncorrelated to the performance of the additional leverage for investment strategies such broader market – such strategies are designed to as merger arbitrage strategies where the use of effectively remove any “beta” component from derivative instruments to provide the same level of their returns and investment exposures. exposure may not be not practical. In connection with such strategies, the Filer is typically required 12. As part of an investment strategy, short positions to respond in a timely manner to public disclosure can serve as both a hedge against exposure to a relating to a transaction and market movements in long position or a group of long positions and also the share price of the target and/or acquiror as a source of returns with an offsetting long company. The use of cash borrowing in such position or positions. The Funds will generally circumstances provides an easily accessible tool seek to generate an attractive risk/return profile which enables the Filer to implement the independent of the direction of the broad equity investment decision more quickly compared to the markets. As such, at the portfolio level, these use of derivative instruments which provide the strategies will seek to hedge out a Fund’s same level of exposure on a synthetic basis. exposure to the direction of broad equity markets, and to generate positive performance from the 16. Cash borrowing is more efficient to utilize on a day difference, specifically, the spread between the to day basis compared to derivative instruments performance of the portfolio’s long and short which generally require a higher degree of positions. negotiation and ongoing administration on the part of the Filer. The Cash Borrowing Relief would 13. The ability to engage in additional short selling provide the Filer with access to a more functional and cash borrowing in connection with the source of additional leverage to utilize on behalf of investment strategies of a Fund may provide the Funds at a lower cost which, in turn, would material cost savings to the Fund compared to benefit investors. obtaining the same level of investment exposure through the use of specified derivatives while, at 17. The investment strategies of each Fund permit, or the same time, not increasing the overall level of will permit, it to: risk to the Fund. (a) sell securities short provided that, at the 14. The costs to the Funds of engaging in physical time the Fund sells a security short (i) the short sales and cash borrowing are typically less aggregate market value of securities of when compared to the equivalent derivative any one issuer (other than “government transactions due to a number of factors which may securities” as defined in NI 81-102) sold include: short by the Fund does not exceed 10% of the NAV of the Fund and (ii) the

August 20, 2020 (2020), 43 OSCB 6539

Decisions, Orders and Rulings

aggregate market value of all securities funds may utilize shorting strategies using a sold short by the Fund does not exceed combination of short sale transactions (subject to 100% of its NAV; the Short Selling Limit) and specified derivative positions and obtain additional investment (b) borrow cash provided that, at the time, exposure using a combination of cash borrowing the value of cash borrowed when (subject to the Cash Borrowing Limit) and aggregated with the value of all specified derivative positions subject, in all cases, outstanding borrowing by the Fund does to the Leverage Limit. Alternative mutual funds not exceed 100% of the Fund’s NAV; that were previously known as commodity pools provide 100% or 200% inverse exposure through (c) borrow cash or sell securities short, the use of specified derivatives, which is provided that the aggregate value of consistent with the Leverage Limit and does not cash borrowed combined with the trigger the application of the Short Selling Limit or aggregate market value of the securities Cash Borrowing Limit for which the Filer is sold short by the Fund does not exceed requesting exemptive relief. Accordingly, the Short 100% of the Fund’s NAV (the Total Selling Relief and Cash Borrowing Relief would Borrowing and Short Selling Limit). If simply allow the Funds to do directly what they the Total Borrowing and Short Selling could otherwise do indirectly through the use of Limit is exceeded, the Fund shall, as specified derivatives. quickly as is commercially reasonable, take all necessary steps to reduce the 19. The Funds require the flexibility to enter into aggregate value of cash borrowed physical short positions and borrow cash when combined with the aggregate market doing so is, in the opinion of the Filer, in the best value of securities sold short to be within interests of the applicable Fund and to not be the Total Borrowing and Short Selling obligated to utilize an equivalent short position or Limit; and amount of leverage synthetically through the use of specified derivatives as a result of regulatory (d) borrow cash, sell securities short or enter restrictions in NI 81-102 that the Filer believes do into specified derivatives transactions, not provide any material additional benefit or provided that immediately after entering protection to investors. into a cash borrowing, short selling or specified derivative transaction, the 20. Certain Existing Funds have used derivative aggregate value of cash borrowed instruments to synthetically achieve the exposure combined with the aggregate market for which the Short Selling Relief and the Cash value of securities sold short and Borrowing Relief is requested. The Filer believes aggregate notional amount of the Fund’s that the Short Selling Relief and the Cash specified derivatives positions (other than Borrowing Relief would allow the Filer to more positions held for hedging purposes, as effectively manage each Fund’s investment defined in NI 81-102) would not exceed exposure by providing it with the ability to respond 300% of the NAV of the Fund as set out to market developments in a timely manner and in section 2.9.1 of NI 81-102 (the enabling the Filer to reduce the related expenses Leverage Limit). If the Leverage Limit is incurred by the Funds. In addition, specified exceeded, the Fund shall, as quickly as derivative options may not be readily available for is commercially reasonable, take all certain securities, may be relatively illiquid or may necessary steps to reduce the aggregate require large capital commitments on the part of value of cash borrowed combined with the Fund. the aggregate market value of securities sold short and the aggregate notional 21. While there may be certain situations where using amount of the Fund’s specified a synthetic short position may be preferable, derivatives positions (other than positions physical short positions are typically less costly, held for hedging purposes) to be within because of the ability to execute trades with a the Leverage Limit. larger number of counterparties, compared to a single counterparty for synthetic shorts. This can 18. An alternative mutual fund that is subject to NI 81- result in lower borrowing costs for the Fund and 102 is permitted to take leveraged long and short reduce its exposure to counterparty risk (e.g. positions using specified derivatives up to the counterparty default, counterparty insolvency and Leverage Limit. As such, the Short Selling Relief premature termination of derivatives) compared to and Cash Borrowing Relief would not be required a synthetic short position. if the Funds utilized solely specified derivatives (such as over-the-counter total return swaps) to 22. The Filer, as a registrant and a fiduciary, is in the obtain short exposure to the underlying securities best position to determine, depending on the or to provide additional investment exposure in surrounding circumstances, whether the Funds connection with the Fund’s investment strategies. should enter into a physical short position and/or NI 81-102 contemplates that alternative mutual obtain additional investment exposure via cash

August 20, 2020 (2020), 43 OSCB 6540

Decisions, Orders and Rulings

borrowing versus achieving the same result 28. The Filer has comprehensive risk management through the use of specified derivatives. The Short policies and/or procedures that address the risks Selling Relief and Cash Borrowing Relief would associated with short selling and cash borrowing provide the Filer with the required flexibility to in connection with the implementation of the make timely trading decisions between physical investment strategy of each Fund. and synthetic short sale positions and/or achieving additional investment exposure through cash 29. Each Fund will implement the following controls borrowing or synthetic transactions. Accordingly, when conducting a short sale: the Short Selling Relief and the Cash Borrowing Relief would permit the Filer to implement more (a) The Fund will assume the obligation to effective portfolio management activities on behalf return to the borrowing agent the of a Fund and its investors. Investors would securities borrowed to effect the short benefit by obtaining access to a more diversified sale; set of investment opportunities than are currently available, while remaining within the overall (b) The Fund will receive cash for the investment limits set out in NI 81-102. securities sold short within normal trading settlement periods for the market in 23. Any physical short position or cash borrowing which the short sale is effected; transaction entered into by a Fund will be consistent with the investment objectives and (c) The Filer will monitor the short positions strategies of the applicable Fund. within the constraints of the Requested Relief as least as frequently as daily; 24. The Prospectus, AIF, fund facts and ETF facts, as applicable, will comply with the applicable (d) The security interest provided by the requirements of National Instrument 81-101 Fund over any of its assets that is Mutual Fund Prospectus Disclosure and Form 41- required to enable the Fund to effect a 101F4 Information Required in an ETF Facts short sale transaction is made in Document for alternative mutual funds, including accordance with industry practice for that cover page text box disclosure in the fund facts type of transaction and relates only to and ETF facts to highlight how the Fund differs obligations arising under such short sale from other mutual funds and alternative mutual transactions; funds and emphasize that the short selling and (e) The Filer will maintain appropriate cash borrowing strategies and increased ability to internal controls regarding short sales, engage in short selling and cash borrowing including written policies and procedures permitted for the Fund are outside the scope of for the conduct of short sales, risk the restrictions in NI 81-102 applicable to both management controls and proper books mutual funds and alternative mutual funds. and records; and 25. The investment strategies of each Fund will clearly (f) The Filer will keep proper books and disclose that the short selling and cash borrowing records of short sales and all assets of a strategies and abilities of the Fund are outside the Fund deposited with borrowing agents as scope of NI 81-102, including that the aggregate security. market value of all securities sold short by the Fund and/or the aggregate amount of cash 30. The Filer believes that it is in the best interests of borrowed may exceed 50% of the NAV of the each of the Funds to be permitted to engage in Fund. The Prospectus will also contain physical short selling and to obtain additional appropriate risk disclosure, alerting investors of investment exposure through the use of cash any material risks associated with such investment borrowing in excess of the current limits set out in strategies. NI 81-102.

26. The Filer does not consider that granting the Short Short Sale Collateral Relief Selling and Cash Borrowing Relief would constitute either a fundamental or material change 31. As part of its investment strategies, each Fund for the Existing Funds under NI 81-102 or National that engages in short sales of securities is Instrument 81-106 Investment Fund Continuous permitted to grant a security interest in favour of Disclosure. and to deposit pledged portfolio assets with its Prime Broker. If a Fund engages as its Prime 27. The Filer will determine the risk rating for each Broker an entity that is not its custodian or sub- Fund using the Investment Risk Classification custodian, then a Fund may only deliver to its Methodology as set out in Appendix F of NI 81- Prime Broker portfolio assets having a market 102. The Filer does not anticipate that the current value, in the aggregate, of not more than 25% of risk ratings of the Existing Funds would change if the NAV of the Fund at the time of deposit. the Short Selling and Cash Borrowing Relief were granted.

August 20, 2020 (2020), 43 OSCB 6541

Decisions, Orders and Rulings

32. A Prime Broker may not wish to act as the derivatives does not exceed the borrowing agent for a Fund that has the ability to Leverage Limit. sell securities short that have an aggregate market value of up to 50% of the Fund’s NAV (or 2. In the case of a short sale, the short sale: more if the Short Selling Relief is granted) if the Prime Broker is only permitted to hold, as security (a) otherwise complies with all of the short for such transactions, portfolio assets having an sale requirements applicable to aggregate market value that is not in excess of alternative mutual funds under section 25% of the NAV of the Fund. 2.6.1 and 2.6.2 of NI 81-102; and

33. Prime Brokers that are qualified to act as a (b) is consistent with the Fund’s investment custodian or sub-custodian under NI 81-102 are objectives and strategies. not widely appointed as custodians or sub- custodians under NI 81-102 as it can be both 3. In the case of a cash borrowing transaction, the operationally challenging and costly to appoint transaction: them to act in such capacity. (a) otherwise complies with all of the cash 34. Given the typical collateral requirements that borrowing requirements applicable to Prime Brokers impose on their customers who alternative mutual funds under section engage in the short sale of securities, if the Short 2.6 and 2.6.2 of NI 81-102; and Sale Collateral Limits apply, the Funds would (b) is consistent with the Fund’s investment need to retain multiple Prime Brokers in order to objectives and strategies. sell short securities to the extent permitted under Section 2.6.1 of NI 81-102 and, if granted, the 4. The Prospectus under which securities of a Fund Short Selling Relief described above. Managing are offered: and overseeing relationships with multiple Prime Brokers introduces unnecessary operational and (a) discloses that the Fund can sell administrative complexities and additional costs of securities short or borrow cash up to, and operation for the Funds. subject to, the limits described in condition 1 above; and Decision (b) describes the material terms of this The principal regulator is satisfied that the decision meets decision. the test set out in the Legislation for the principal regulator to make the decision. In respect of the Short Sale Collateral Relief:

The decision of the principal regulator under the Legislation 5. Each Fund otherwise complies with subsections is that the Requested Relief is granted provided that: 6.8.1(2) and (3) of NI 81-102.

In respect of the Short Selling and Cash Borrowing Relief: “Darren McKall” Manager 1. A Fund may sell a security short or borrow cash Investment Funds and Structured Products Branch only if, immediately after the cash borrowing or Ontario Securities Commission short selling transaction:

(a) the aggregate market value of all

securities sold short by the Fund does

not exceed 100% of the Fund’s NAV;

(b) the aggregate value of all cash borrowing by the Fund does not exceed 100% of the Fund’s NAV;

(c) the aggregate market value of securities sold short by the Fund combined with the aggregate value of cash borrowing by the Fund does not exceed 100% of the Fund’s NAV; and

(d) the Fund’s aggregate exposure to short selling, cash borrowing and specified

August 20, 2020 (2020), 43 OSCB 6542

Decisions, Orders and Rulings

2.1.2 Georgeson Shareholder Communications Canada Inc.

Headnote

Company finding lost shareholders for issuers exempt from dealer registration – relief limited to facilitating sales orders for found securityholders of their claimed securities – execution through appropriately registered IIROC investment dealers.

Statute cited

Securities Act, R.S.O. 1990, c. S.5, as am., ss. 1(1), 25, 74.

August 13, 2020

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 GEORGESON SHAREHOLDER COMMUNICATIONS CANADA INC. (the Filer)

DECISION

Background

The principal regulator in the Jurisdiction has received an application from the Filer for a decision under the securities legislation of the Jurisdiction (the Legislation) that the Filer be exempt from the dealer registration requirement in the Legislation in connection with facilitating trades pursuant to the Share Selling Service (as defined below) (the Exemption Sought).

Under National Policy 11-203 Process for Exemptive Relief Applications in Multiple Jurisdictions (for a passport application):

(a) the Ontario Securities Commission is 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 each of British Columbia, Alberta, Saskatchewan, Manitoba, Québec, New Brunswick, Nova Scotia, Prince Edward Island, Newfoundland and Labrador, Northwest Territories, Yukon and Nunavut (together with the Jurisdiction, the Jurisdictions).

Interpretation

Terms defined in National Instrument 14-101 Definitions and MI 11-102 have the same meanings in this decision, unless otherwise defined.

Representations

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

The Filer

1. The Filer is a corporation with its head office located in Toronto, Ontario.

2. The Filer is a wholly-owned, indirect subsidiary of Computershare Limited.

3. The Filer is not registered under applicable securities legislation of any province or territory of Canada. The Filer is not in default of securities legislation in any jurisdiction of Canada.

4. The business of the Filer is to provide asset reunification services to issuers and their securityholders, which operates as follows:

August 20, 2020 (2020), 43 OSCB 6543

Decisions, Orders and Rulings

a. The Filer is engaged by issuers to assist them in locating securityholders who:

i. hold interests of entities (including securities of such entities) acquired by or merged into the issuer (or parties related to the issuer),

ii. hold securities which have by their terms matured or terminated or have been redeemed,

iii. hold interests that have been converted (whether by conversion of the interest by the entity and/or conversion of the entity itself and including, without limitation, the conversion of a mutual company into a shareholder-owned company (e.g., a demutualization of an insurance company)),

iv. by virtue of their ownership of securities of the issuer are entitled to receive securities of an entity that has been spun-out by the issuer, or

v. have an entitlement to a cash payment in lieu of the interests set out in subparagraphs (i) to (iv) above, and

have failed to tender their securities or other interest or to take whatever other action is required to receive any entitlement resulting therefrom.

b. Once a securityholder has been actually or potentially located (Found Securityholders), the Filer offers to assist the securityholder in exchanging the unexchanged securities or the claiming of additional securities or cash entitlements, as the case may be, through the delivery of an explanatory notice to such Found Securityholders detailing the steps that the Found Securityholders will be required to take to claim their entitlements (the Claim Notice). The Claim Notice will include the following information, along with the information referred to paragraphs (c) and (d), and paragraphs 5, 6 and 13 below:

i. Role of the Filer in assisting the specified issuer in locating securityholders,

ii. Name of the specified issuer and the specific entitlements of the Found Securityholder,

iii. Details on how the Found Securityholder can claim an entitlement, which will include an Asset Reunification Form for completion by the Found Securityholder,

iv. Details on the service fee payable by the Found Securityholder for the Asset Reunification Service and an explanation that the fee will be paid to the Filer,

v. Details on the optional Share Selling Service;

vi. Details on the fees payable by the Found Securityholder to the Filer for the Share Selling Service, if applicable,

vii. Toll-free phone numbers, along with hours of operation, of the Filer, which Found Securityholders are encouraged to use,

viii. An explanation of the Filer’s privacy policy, and

ix. An explanation of what will happen if the Found Securityholder fails to respond to the Claims Notice.

c. Found Securityholders are under no obligation to use the Filer to exchange their unexchanged securities or claim their entitlements. The issuer may have the capability to arrange for the exchanges and claims separate and apart from the Filer through a transfer agent or other internal process. As part of the Claim Notice, if applicable, the Filer informs Found Securityholders that they can claim the unexchanged securities or their entitlements through the transfer agent, or such other process, if they wish.

d. If a Found Securityholder elects to engage the Filer to exchange their unexchanged securities or claim their entitlements, the Filer charges a service fee to the Found Securityholder, which is detailed and disclosed in the Claim Notice.

e. The Filer will verify the Found Securityholder’s entitlement to the unexchanged securities or to the additional securities or cash and will work with the issuer and its transfer agent to:

i. have the applicable security certificates or ‘direct registration statements’ issued in the Found Securityholder’s name and sent to the Found Securityholder, or

August 20, 2020 (2020), 43 OSCB 6544

Decisions, Orders and Rulings

ii. have payment of the cash entitlement sent by cheque or other form of payment to the Found Securityholder, or

iii. have a combination of security certificates/DRS and cash entitlement sent to the Found Securityholder.

5. Once a Found Securityholder has exchanged the unexchanged securities it holds for its entitlement, or claimed the additional securities to which it is entitled, the Filer wishes to offer the Found Securityholder the ability to sell those securities by using a third party registered dealer to execute the trade at the prevailing market price (the Share Selling Service). The Share Selling Service will only be available for publicly listed securities. The Share Selling Service will be outlined in the Claim Notice and it will be clear that only Found Securityholders who elect to use the Filer to exchange their unexchanged securities or claim their entitlements to additional securities may use the Share Selling Service.

6. Found Securityholders are not required to sell the securities they receive in respect of any exchange or entitlement and will not be required to sell their shares through the Filer. Found Securityholders who wish to sell their securities or entitlements in another manner (for example, by transferring their holdings to another dealer with whom they have a brokerage relationship) will be able to do so. This ability to do this will be outlined in the Claim Notice and the Filer will not charge a fee in respect of any such transfer.

7. Under the Share Selling Service, Found Securityholders, subject to applicable foreign laws, will be able to sell their securities they acquired through the entitlement by contacting the Filer either through written instructions (sent by mail or delivered in person or provided via an internet web portal) or by telephone.

8. Under the Share Selling Service, Found Securityholders will only be able to instruct the Filer to sell the securities at the market price. The Found Securityholders will not be able to place a “price limit order” with the Filer. The Filer and its directors, officers, employees, contractors and agents will not be providing recommendations or advice regarding the decision to sell or hold the applicable securities to Found Securityholders. The Filer will inform all Found Securityholders with inquiries concerning the decision to sell or hold the applicable securities to contact a professional advisor.

9. The Filer will establish an account with a registered investment dealer and member of the Investment Industry Regulatory Organization of Canada (the Assisting Dealer). The Assisting Dealer may change from time to time.

10. The Filer will transfer the securities to the Assisting Dealer for execution and will arrange with the Assisting Dealer to sell the securities of any Found Securityholder, who wishes to use the Share Selling Service to sell his/her securities. The Assisting Dealer will take instructions from the Filer (as per the Filer’s communication with the Found Securityholders) and will execute the trade at the market price.

11. The Assisting Dealer will provide the Filer with settlement advice and the settlement proceeds. The Filer will remit the proceeds of the trade, less applicable fees, to the Found Securityholders, as soon as possible following the receipt of the settlement proceeds from the Assisting Dealer.

12. The Filer holds any client securities and client cash separate and apart from the Filer’s own property, and, client cash will be held in a designated trust account held at a Canadian financial institution in trust for Found Securityholders, pending distribution out to the Found Securityholders. The Filer maintains records sufficient to show the beneficial ownership of the cash and securities of each Found Securityholder. The Filer maintains sufficient insurance coverage for its business activities.

13. Any Found Securityholder that wishes to use the Share Selling Service will pay the Filer a fee plus, depending on the program, a cents-per-share fee for each sale of securities under the Share Selling Service. The nature of the fee to be paid to the Filer will depend on the specific asset reunification program and will be negotiated with the particular issuer engaging the Filer. The Claim Notice will outline the fees to be paid by the Found Securityholder to the Filer in respect of the Share Selling Service. No other fees are paid by the Found Securityholder in relation to the Share Selling Service. The Filer itself will pay the brokerage commissions to the Assisting Dealer.

14. Any materials distributed to Found Securityholders regarding the Share Selling Service will not contain any recommendations or advice as to whether the Found Securityholder should hold or sell their securities.

15. Found Securityholders who choose to use the Filer to exchange their unexchanged securities or claim their entitlements, but who do not elect to use the Share Selling Service at the time they notify the Filer of their decision to use the asset reunification services of the Filer, will not be able to later use the Share Selling Service, and will not receive further communications regarding the Share Selling Service.

16. In providing the Share Selling Service, the Filer will be facilitating trades pursuant to the Share Selling Service by: (i) receiving orders from Found Securityholders to sell their securities, (ii) instructing the Assisting Dealer to execute the

August 20, 2020 (2020), 43 OSCB 6545

Decisions, Orders and Rulings

order to sell the securities, (iii) remitting the proceeds less applicable fees from the sale of securities to the Found Securityholders, and (iv) receiving a fee from the Found Securityholders for the Share Selling Service.

17. The Filer submits that the Exemption Sought would not be prejudicial to the public interest because:

a. A significant number of the Found Securityholders may not have any prior experience in share ownership or brokerage relationships, and so would have to take additional steps to independently establish an account, and bear any associated costs. Given the relatively small number of securities that they may hold, brokers may not be interested in opening individual accounts for such small security holdings.

b. The Share Selling Service is an efficient and effective way by which Found Securityholders can obtain their unclaimed assets, in a cash form, that they may not otherwise obtain due to their lack of experience in share ownership or brokerage relationships and given the small number of securities that they will likely hold.

c. It is considered good corporate governance for issuers to engage asset reunification firms, such as the Filer, to locate securityholders who have not claimed their entitlements and to allow such Found Securityholders to have options in monetizing their holdings through the Share Selling Service.

18. Upon the granting of the Exemption Sought, the Filer will be a “market participant” as defined in the Legislation. As a market participant, among other requirements, the Filer will be required to comply with the record keeping and provision of information provisions under the Legislation, which include the requirement to keep such books, records and other documents as are necessary for the proper recording of business transactions and financial affairs and the transactions executed on behalf of others and to deliver such records to the principal regulator if required.

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 Exemption Sought is granted, provided that all of the following conditions are met:

a. The Filer facilitates only the sale of securities from Found Securityholders through an Assisting Dealer, which will be an investment dealer and member of the Investment Industry Regulatory Organization of Canada.

b. The Filer deals honestly, fairly and in good faith with the Found Securityholders.

c. The Filer and its directors, officers, employees, contractors and agents will not be providing recommendations or advice regarding the decision to sell or hold the applicable securities to Found Securityholders.

d. The Filer will inform all Found Securityholders with inquiries concerning the decision to sell or hold the applicable securities to contact a professional advisor.

e. The Filer holds any client securities and client cash separate and apart from the Filer’s own property and holds client cash in a designated trust account held at a Canadian financial institution in trust for Found Securityholders, pending distribution out to the Found Securityholders.

f. The Filer maintains records sufficient to show the beneficial ownership of the cash and securities of each Found Securityholder.

g. The Filer remits the proceeds of any trade made under the Share Selling Service, less applicable fees, to the Found Securityholders, as soon as possible following the receipt of the settlement proceeds from the Assisting Dealer.

h. Where a Found Securityholder uses the Share Selling Service, the Filer will provide Found Securityholders with a statement outlining the detail of the trade(s) made under the Share Selling Service, including the number of securities sold, the proceeds of any sale and the fees paid by the Found Securityholder.

i. The Filer will not require, recommend or advise that Found Securityholders sell the securities they receive in respect of any exchange or entitlement and Found Securityholders who wish to sell such securities will not be required to do so through the Filer’s Share Selling Service. These facts will be outlined in the Claim Notice.

j. Within 30 days of the end of the first year (2021) and the third year (2023) after the date of this Decision, the Filer provides to the principal regulator the following information for each issuer for whom the Filer has established a Share Selling Service for the applicable period since the date of this Decision or the date of the last report, as applicable:

August 20, 2020 (2020), 43 OSCB 6546

Decisions, Orders and Rulings

i. The number of Found Securityholders who elect to use the Filer to sell their shares pursuant to the Share Selling Service,

ii. The proportion of Found Securityholders who use the Share Selling Service out of all Found Securityholders who elect to use the Filer to exchange their unexchanged securities or to claim the additional securities or cash entitlements,

iii. The number of shares and value of those shares sold pursuant to the Share Selling Service,

iv. The fees paid to the Filer by the Found Securityholders using the Share Selling Service, and

v. Any complaints received from the Found Securityholders relating to the Share Selling Service and how those complaints were resolved.

k. The Filer will provide, on a timely basis, any report, document or information to the principal regulator that may be requested by the principal regulator from time to time for the purpose of monitoring compliance with securities legislation and the conditions in the Decision, in a format acceptable to the principal regulator.

l. This decision may be amended by the Ontario Securities Commission from time to time upon prior written notice to the Filer in accordance with applicable securities legislation.

“Wendy Berman” Vice Chair Ontario Securities Commission

“Tim Moseley” Vice Chair Ontario Securities Commission

August 20, 2020 (2020), 43 OSCB 6547

Decisions, Orders and Rulings

2.1.3 Wealthsimple Digital Assets Inc.

Headnote

CSA Regulatory Sandbox – Application for time-limited relief from certain registrant obligations, prospectus requirement and trade reporting requirements – suitability relief to allow the Filer to distribute Crypto Contracts Rights and operate a platform that facilitates the buying, selling and holding of crypto assets – relief granted subject to certain conditions set out in the decision, including investment limits, account appropriateness and reporting requirements – relief is time-limited to allow the Filer to operate in a test environment and will expire upon the earlier of twenty-four (24) months or the date the filer transitions the platform to its IIROC affiliate – relief granted based on the particular facts and circumstances of the application with the objective of fostering capital raising by innovative businesses in Canada and liquidity for investors – decision should not be viewed as precedent for other filers in the jurisdictions of Canada.

Applicable Legislative Provisions

Securities Act, R.S.O. 1990, c. S.5, as amended, ss. 1(1), 53 & 74. Multilateral Instrument 11-102 Passport System, ss. 4.7. National Instrument 21-101 Marketplace Operation, ss. 1.1. National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations, ss. 12.1, 13.3. OSC Rule 91-506 Derivatives: Product Determination, ss. 2 & 4. OSC Rule 91-507 Trade Repositories and Derivatives Data Reporting, Part 3.

August 7, 2020

IN THE MATTER OF THE SECURITIES LEGISLATION OF ONTARIO (the Jurisdiction) AND ALBERTA, BRITISH COLUMBIA, MANITOBA, NEW BRUNSWICK, NEWFOUNDLAND AND LABRADOR, NORTHWEST TERRITORIES, NOVA SCOTIA, NUNAVUT, PRINCE EDWARD ISLAND, SASKATCHEWAN, AND YUKON

AND

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

AND

IN THE MATTER OF WEALTHSIMPLE DIGITAL ASSETS INC. (the Filer)

DECISION Background

As set out in CSA Staff Notice 21-327 Guidance on the Application of Securities Legislation to Entities Facilitating the Trading of Crypto Assets (CSA SN 21-327), securities and/or derivatives legislation may apply to platforms that facilitate the buying and selling of crypto assets, including crypto assets that are commodities, because the user’s contractual right to the crypto asset may itself constitute a security and/or a derivative (Crypto Rights Contract).

To foster innovation and respond to novel circumstances, the CSA has considered an interim, time-limited registration framework that would allow crypto asset platforms to operate within a regulated environment, with regulatory requirements tailored to the crypto asset platform’s operations. The overall goal of the regulatory framework is to ensure there is a balance between the need to be flexible and facilitate innovation in the Canadian capital markets, while upholding the regulatory mandate of promoting investor protection and fair and efficient capital markets.

The Filer has made an application to the CSA Regulatory Sandbox, an initiative of the CSA to support fintech businesses seeking to offer innovative products, services and applications in Canada. It allows firms to test their products, services and applications throughout the Canadian market under a flexible process and on a time-limited basis.

The Filer wishes to operate, on an interim basis, a platform that permits clients resident in Canada to enter into Crypto Rights Contracts to purchase, hold and sell Bitcoin and Ether (together, the Crypto Assets) through the Filer. The Filer wishes to

August 20, 2020 (2020), 43 OSCB 6548

Decisions, Orders and Rulings ultimately carry on this activity through its affiliated entity, which is registered as an investment dealer and a member of the Investment Industry Regulatory Organization of Canada (IIROC). While the Filer is engaged in discussions with IIROC on a regulatory approach for its affiliated entity to carry on this activity, the Filer wishes to commence operations and conduct beta testing. In the context of the CSA Regulatory Sandbox, the Filer filed an application to be registered in the category of restricted dealer and an application to be exempted from certain requirements under applicable securities legislation. This Decision has been tailored for the specific facts and circumstances of the Filer, and the securities regulatory authority or regulator in the Applicable Jurisdictions (as defined below) or in any other jurisdiction will not consider this Decision as constituting a precedent for other filers, whether in the Applicable Jurisdictions or in any other jurisdiction.

Relief Requested

The securities regulatory authority or regulator in the Jurisdiction has received an application from the Filer (the Passport Application) for a decision under the securities legislation of the Jurisdiction (the Legislation) exempting the Filer from:

a) the prospectus requirements under the Legislation in respect of the Filer entering into Crypto Rights Contracts with clients to purchase, hold and sell Crypto Assets (the Prospectus Relief); and

b) the requirement in subsection 12.10(2) of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103) to deliver annual audited financial statements to the regulator and the requirement in section 13.3 of NI 31-103 to take reasonable steps to ensure that, before it makes a recommendation to or accepts instructions from a client to buy or sell a security, the purchase or sale is suitable for the client (collectively, the Registrant Obligations Relief).

The securities regulatory authority or regulator in the Jurisdiction and each of the other jurisdictions referred to in Appendix A (the Coordinated Review Decision Makers) have received an application from the Filer (collectively with the Passport Application, the Application) for a decision under the securities legislation of those jurisdictions exempting the Filer from certain reporting requirements under the Local Trade Reporting Rules (as defined in Appendix A) (the Trade Reporting Relief, and together with the Prospectus Relief and Registrant Obligations Relief, the Requested Relief).

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

a) the Ontario Securities Commission is the principal regulator for this Application (the Principal Regulator),

b) in respect of the Prospectus Relief and Registrant Obligations Relief, the Filer has provided notice that, in the jurisdictions where required, subsection 4.7(1) of Multilateral Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon in each of the other provinces and territories of Canada except Québec (the Non-Principal Jurisdictions, and, together with the Jurisdiction, the Applicable Jurisdictions), and

c) the decision in respect of the Trade Reporting Relief is the decision of the Principal Regulator and evidences the decision of each Coordinated Review Decision Maker.

Interpretation

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

Representations

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

The Filer

1. The Filer is a corporation incorporated under the federal laws of Canada with its principal office in Toronto, Ontario.

2. The Filer is a wholly owned subsidiary of Wealthsimple Financial Corp. (WFC), a holding company that owns 100% of the issued and outstanding securities of several operating companies that are registered under applicable securities legislation in each of the provinces and territories of Canada, including Wealthsimple Inc., a registered adviser in the category of portfolio manager, and Canadian ShareOwner Investments Inc. (ShareOwner), a registered dealer in the category of investment dealer and member of IIROC.

3. The Filer does not have any securities listed or quoted on an exchange or marketplace in any jurisdiction inside or outside of Canada. However, a majority of the voting and non-voting securities of WFC are controlled by subsidiaries and entities affiliated with Power Corporation. Power Corporation is a reporting issuer under the legislation of the Applicable Jurisdictions and its securities are listed for trading on the Toronto Stock Exchange.

4. Concurrent with this application, the Filer is seeking registration as a dealer in the category of restricted dealer with the

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Applicable Jurisdictions, except in Québec where it is seeking registration as a derivatives dealer and in a separate decision, exemptions from certain requirements applicable to a derivatives dealer as well as the qualification requirement under the Derivatives Act (Québec).

5. The Filer’s books and records, financial controls and compliance systems (including its policies and procedures) are designed to closely resemble in all material respects, except as necessary to address operational differences, those in place today at ShareOwner. The ultimate designated person (UDP) and chief compliance officer (CCO) of the Filer are the same individuals who are also the UDP and CCO of ShareOwner.

6. The Filer’s personnel consists, and will consist, of software engineers, compliance professionals and finance professionals who each have deep experience operating in a regulated financial services environment and expertise in blockchain technology. All of the Filer’s personnel have passed, and new personnel will have passed, criminal records and credit checks. The Filer will not have any dealing representatives at the time of registration.

7. Neither the Filer nor ShareOwner is in default of securities legislation of any of the Applicable Jurisdictions.

Wealthsimple Crypto

8. The Filer will operate under the business name of “Wealthsimple Crypto”. The Filer has been established to operate, on an interim basis, a proprietary and fully automated internet-based platform (the Platform) that will enable clients to enter into Crypto Rights Contracts with the Filer to buy, sell and hold the Crypto Assets through the Filer.

9. The Filer’s role under Crypto Rights Contracts is to buy or sell Crypto Assets and to manage the custody of all purchased Crypto Assets with third parties.

10. The Filer’s trading of Crypto Rights Contracts is consistent with activities described in CSA SN 21-327 and constitutes the trading of securities and/or derivatives.

11. The Filer and ShareOwner would like the Platform to be operated by ShareOwner. The Filer and ShareOwner have begun discussions with IIROC on a regulatory approach to transition the Platform to ShareOwner in the future. The Filer and ShareOwner will work actively and diligently with IIROC to transition the operation of the Platform from the Filer to ShareOwner.

12. The Filer wishes to commence operations by initially beta testing the Platform. Beta testing will involve inviting individuals, who have signed up to join the Wealthsimple Crypto waitlist, to open accounts and begin using the Platform. The Filer will gradually invite more individuals to use the Platform so long as the Filer continues to achieve internal operational metrics. The Filer will solicit feedback from early users to improve the Platform and transition from beta testing to normal operation.

13. The Filer will not hold any proprietary positions in Crypto Assets for itself; it will not take a long or short position in a Crypto Asset with any party, including clients.

14. The Filer does not have any authority to act on a discretionary basis on behalf of clients and will not manage any discretionary accounts.

15. The Filer will not be a member firm of the Canadian Investor Protection Fund (CIPF) and the Crypto Assets custodied with third parties will not qualify for CIPF coverage. The Risk Statement (defined below) will include disclosure that there will be no CIPF coverage for the Crypto Assets and clients must acknowledge that they have received, read and understood the Risk Statement before opening an account with the Filer.

16. The preparation of audited financial statements for a registered dealer in Canada that trades Crypto Rights Contracts and holds Crypto Assets in trust at a third-party custodian is novel. In consultation with its external auditors and external legal counsel, the Filer has worked diligently, for a sustained period of time, to establish a suitable framework for preparing audited financial statements. The Filer anticipates that it will be able to obtain audited financial statements for the Filer’s 2021 financial year end.

17. During the period of this relief:

a) the Filer will work closely with its auditors to be able to file annual audited financial statements in accordance with subsection 12.10(2) of NI 31-103, and

b) the financial statements of the Filer will be consolidated with the annual audited financial statements of its parent, WFC, and until such time as the Filer can deliver annual audited financial statements, the Filer will file both annual unaudited financial statements and the annual audited financial statements of WFC with the Principal Regulator.

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Account Opening

18. The Platform will be available to any individual who is resident in Canada, who has reached the age of majority, and who has the legal capacity to open a securities brokerage account.

19. Clients of the Filer will open a Wealthsimple Crypto account using the Wealthsimple Trade mobile app (the App), which is owned by Wealthsimple Technologies Inc., a wholly-owned subsidiary of WFC. Clients will use their Wealthsimple Crypto accounts to trade in Crypto Rights Contracts.

20. Clients will also use the App to open accounts with ShareOwner. Clients’ cash will be held in these accounts with ShareOwner. ShareOwner will not take orders from clients to buy or sell Crypto Assets. ShareOwner’s role will be limited to processing debits and credits into and out of a client’s cash brokerage account, based on instructions received from a client or from the Filer acting with the client’s authorization. Clients’ cash will only be sent from their account with ShareOwner to the Filer and from the Filer to their account with ShareOwner, unless the client wishes to withdraw their cash from ShareOwner.

21. The Filer will comply with the applicable “know your client” account opening requirements under applicable legislation and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations.

22. As part of the account opening process, the Filer will provide a prospective client with a separate statement of risks that clearly explains, in plain language, the Crypto Rights Contracts and Crypto Assets and the risks associated with the Crypto Rights Contracts and Crypto Assets, including the disclosure in Appendix B of this decision (the Risk Statement).

23. In accordance with section 14.2 of NI 31-103, the Filer will also deliver to a prospective client relationship disclosure information that includes a description of the Crypto Rights Contracts, the location and manner in which Crypto Assets are held for the client, the risks and benefits to the client of the Crypto Assets being held at that location and in that manner, the manner in which the Crypto Assets are accessible by the Filer, and the risks and benefits to the client arising from the Filer having access to the Crypto Assets in that manner.

24. In order for a prospective client to open and operate a Wealthsimple Crypto account:

a) the Filer will obtain an electronic acknowledgement from the prospective client confirming that the prospective client has received, read and understood the Risk Statement. Such acknowledgement will be prominent and separate from other acknowledgements provided by the prospective client as part of the account opening process; and

b) the Filer will determine, prior to opening the account, whether it would be appropriate for the prospective client to use the Platform to enter into a Crypto Rights Contract in order to buy and sell Crypto Assets.

25. The Filer will have policies and procedures for updating the Risk Statement to reflect any material changes to the disclosure or include any material risks that may develop with respect to the Crypto Rights Contracts and Crypto Assets. In the event the Risk Statement is updated, existing clients of the Filer will be promptly notified and provided with a copy of the updated Risk Statement.

26. The Filer will also prepare and make available to its clients, on an ongoing basis and in response to emerging issues in Crypto Assets, educational materials and other informational updates about trading on the Platform and the ongoing development of Crypto Assets and Crypto Asset trading markets. To do so, the Filer will build upon the existing communication channels and techniques used by affiliates in the WFC group of companies.

Platform Operations

27. All Crypto Rights Contracts entered into by clients to buy and sell Crypto Assets will be placed with the Filer through the App. Clients will be able to submit market buy and sell orders, either in units of the applicable Crypto Asset (i.e., BTC or ETH) or in Canadian dollars, 24 hours a day, 7 days a week.

28. The Platform is similar to those developed for order execution only online brokerages in that the client trades without other communication with, or advice from, the dealer or its personnel. In this regard, the Filer will not provide recommendations or advice to clients or conduct a trade-by-trade suitability determination for clients, but will rather perform account and product assessments, taking into account the investor’s experience in investing in Crypto Assets, the investor’s experience in using order execution only online brokerages, and the investor’s risk tolerance. These factors will be used by the Filer to evaluate whether entering into a Crypto Rights Contract with the Filer is appropriate for a prospective client before the opening of an account. After completion of the assessments, a prospective client will receive appropriate messaging about using the Platform to enter into a Crypto Rights Contract, which could include

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messaging to a prospective client that WDA believes that using the Platform to enter into a Crypto Rights Contract is not appropriate for them.

29. Over time, the Filer intends to continue to develop the Platform, in part based on user feedback from beta testing.

30. The Filer will rely upon multiple crypto asset trading firms (Liquidity Providers) to act as sellers of Crypto Assets that may be purchased by the Filer for its clients. Liquidity Providers will also buy any Crypto Assets from the Filer that a client has purchased using the Platform and wishes to sell.

31. The Filer will evaluate the price obtained from its Liquidity Providers on an ongoing basis against global benchmarks to provide fair and reasonable pricing to its clients.

32. The Filer has verified or will verify that each Liquidity Provider is appropriately registered and/or licensed to trade in the Crypto Assets in their home jurisdiction, or that their activities do not require registration in their home jurisdiction, and that they are not in default of securities legislation in the Applicable Jurisdictions.

33. The Filer has verified that each Liquidity Provider has effective policies and procedures to address concerns relating to fair price, fraud and market manipulation.

34. A Crypto Rights Contract is a bilateral contract between a client and the Filer. Accordingly, the Filer will be the counterparty to each buy or sell transaction initiated by a client. For each client transaction, the Filer will also be a counterparty to a corresponding Crypto Assets buy or sell transaction with a Liquidity Provider. The Filer will trade as a riskless principal, in that the Filer will not take any proprietary positions when trading with clients or with a Liquidity Provider.

35. After the order has been placed by a client, the Platform will obtain a price for the Crypto Asset from a Liquidity Provider, after which the Platform will incorporate a ‘spread’ to compensate the Filer, and will present this adjusted price to the client as the price at which the Filer is willing to transact against the client.

36. If the client finds the price agreeable, the client will accept the price and agree to the trade.

37. In a buy transaction under a Crypto Rights Contract, this will result in the client instructing WDA to request cash from the client’s account with ShareOwner in order to fund the purchase. In a sell transaction under a Crypto Rights Contract, cash proceeds will be transferred by WDA to the client’s account with ShareOwner.

38. The Filer will not extend margin or otherwise offer leverage to clients.

39. The Filer will confirm the transaction with the Liquidity Providers.

40. The Filer will record in its books and records the particulars of each trade.

41. The Filer will promptly, and no later than two days after the trade, settle transactions with the Liquidity Providers on a net basis. Where there are net purchases of Crypto Assets, the Filer will arrange for the cash to be transferred to the Liquidity Provider and Crypto Assets to be sent by the Liquidity Provider to the Filer’s custodian. Where there are net sales of Crypto Assets, the Filer will arrange for Crypto Assets to be sent from the Filer’s custodian to the Liquidity Provider in exchange for cash received by the Filer from the Liquidity Providers.

42. Clients will receive electronic trade confirmations and monthly statements setting out the details of the transaction history in their account with the Filer.

43. The Platform is a “closed loop” system. Clients will not be permitted to transfer into their account with the Filer any Crypto Assets they purchased outside the platform or withdraw from their account with the Filer any Crypto Assets they have purchased pursuant to their Crypto Rights Contracts with the Filer. Any Crypto Assets that may be purchased under a Crypto Rights Contract will be held by the Filer in trust for the client and by default must be sold in a trade with the Filer. Notwithstanding the foregoing, the Filer may, in certain limited circumstances and for a fee, deliver possession and/or control of the Crypto Assets purchased under a Crypto Rights Contract to another Crypto Asset trading platform or a personal crypto asset wallet at the direction of the client, subject to satisfying all applicable legal and regulatory requirements, including anti-money laundering requirements.

44. The Filer believes a closed loop system will significantly reduce the likelihood of fraud, money laundering or client error in sending or receiving Crypto Assets to incorrect wallet addresses. However, a closed loop system may also expose the client to insolvency risk (credit risk), fraud risk or proficiency risk on the part of the Filer.

45. The Filer will be compensated by the spread on trades. It does not currently charge any account opening or maintenance fees, commissions, or other charges of any kind.

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46. In addition to the client risk disclosure and ongoing education initiatives described in paragraphs 22-26 above, and the account and product appropriateness exercise described in paragraph 28 above, the Filer will also monitor client activity, and contact clients to discuss their trading behaviour if it indicates a lack of knowledge or understanding of Crypto Asset trading, in an effort to identify and deter behaviours that may indicate that trading a Crypto Rights Contract is not appropriate for the client, or that additional education is required. The outcome of this engagement with a client may result, in some cases, in a decision by the Filer to close a client’s account.

Custody of Crypto Assets and Cash

47. The Filer will not maintain its own hot or cold wallets to hold Crypto Assets. Instead, Gemini Trust Company, LLC (Gemini), a third-party custodian, will act as custodian of the Crypto Assets purchased by clients through the Filer. Gemini is a licensed digital asset exchange and a New York trust company regulated by the New York State Department of Financial Services. Gemini is a “qualified custodian” for purposes of NI 31-103 and has completed a SOC 2 Type 2 examination. The Filer has conducted due diligence on Gemini, including a review of the SOC 2 Type 2 examination report, and has not identified any material concerns.

48. Gemini will operate a custody account for the Filer to use for the purpose of holding clients’ Crypto Assets. The Filer is not permitted to pledge, re-hypothecate or otherwise use any Crypto Assets owned by its clients in the course of its business.

49. Gemini will hold all Crypto Assets in trust for clients of the Filer in an omnibus account in the name of the Filer and separate and distinct from the assets of the Filer, the Filer’s affiliates, and all of Gemini’s other clients.

50. Gemini has established and applies policies and procedures that manage and mitigate the custodial risks, including, but not limited to, an effective system of controls and supervision to safeguard the Crypto Assets for which it acts as custodian.

51. The Filer has assessed the risks and benefits of using Gemini and, has determined that in comparison to a Canadian custodian (as that term is defined in NI 31-103) it is more beneficial to use Gemini, a U.S. custodian, to hold client assets than using a Canadian custodian.

52. A client can maintain their Crypto Rights Contract with the Filer indefinitely.

53. Neither the Filer nor Gemini will hold client cash. As set out in paragraph 20 above, each client of the Filer will open a non-registered cash brokerage account with ShareOwner for the sole purpose of holding cash that a client may use to engage in transactions on the Platform.

54. Gemini currently maintains $200 million in specie coverage for digital assets, including the Crypto Assets owned by clients of the Filer, held in Gemini’s cold storage system. Gemini also maintains separate commercial crime insurance coverage for any digital assets that may be temporarily custodied in its “hot wallet”, including the Crypto Assets owned by clients of the Filer.

Marketplace and Clearing Agency

55. The Filer will not operate a “marketplace” as that term is defined in National Instrument 21-101 Marketplace Operation and in Ontario, subsection 1(1) of the Securities Act (Ontario) (the Act).

56. The Filer will not operate a “clearing agency” as defined in securities legislation. Any clearing or settlement activity conducted by the Filer is incidental to the Filer engaging in the business of a Crypto Asset dealer. Any activities of the Filer that may be considered the activities of a clearing agency are related to the Filer arranging or providing for settlement of obligations resulting from agreements entered into on a bilateral basis and without a central counterparty.

Decision

The Principal Regulator is satisfied that the Decision satisfies the test set out in the Legislation for the Principal Regulator to make the Decision and each Coordinated Review Decision Maker is satisfied that the Decision in respect of the Trade Reporting Relief satisfies the test set out in the securities legislation of its jurisdiction for the Coordinated Review Decision Maker to make the Decision in respect of the Trade Reporting Relief.

The Decision of the Principal Regulator under the Legislation is that the Requested Relief is granted, and the Decision of each Coordinated Review Decision Maker under the securities legislation in its jurisdiction is that the Trade Reporting Relief is granted, provided that:

I. Unless otherwise exempted by a further decision of the Principal Regulator, the Filer complies with

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a) all of the terms, conditions, restrictions and requirements applicable to a registered dealer under securities legislation, including the Legislation, and any other terms, conditions, restrictions or requirements imposed by a securities regulatory authority or regulator on the Filer;

b) the terms and conditions of the decision granted by the Autorité des marchés financiers dated August 7, 2020 in respect of relief from certain requirements of the Derivatives Act (Québec).

II. WDA is registered as a restricted dealer in the Jurisdiction and the jurisdiction in which the client is resident.

III. The Filer will work actively and diligently with IIROC to transition the operation of the Platform from the Filer to ShareOwner.

IV. The Filer, and any representatives of the Filer, will not provide recommendations or advice to any client or prospective client on the Platform.

V. The Filer will only engage in the business of trading Crypto Rights Contracts in relation to Crypto Assets, and performing its obligations under those contracts. The Filer will undertake no other activity.

VI. The Filer will not operate a "marketplace” as the term is defined in National Instrument 21-101 Marketplace Operation and in Ontario, in subsection 1(1) of the Act or a “clearing agency” as the term is defined in securities legislation.

VII. At all times, the Filer will hold the Crypto Assets with a custodian that meets the definition of a qualified custodian under NI 31-103.

VIII. The Filer will take reasonable steps to verify that:

a) the custodian has appropriate insurance to cover the loss of Crypto Assets held at the custodian; and

b) the custodian, has established and applies written policies and procedures that manage and mitigate the custodial risks, including, but not limited to, an effective system of controls and supervision to safeguard the specified crypto assets for which it acts as custodian.

IX. The Filer will promptly notify the Principal Regulator if the U.S. Securities and Exchange Commission, the U.S. Commodity Futures Trading Commission, the Financial Industry Regulatory Authority, or the National Futures Association, makes a determination that the Filer’s custodian is not permitted by that regulatory authority to hold client Crypto Assets.

X. The Filer will only use a Liquidity Provider that it has verified is registered and/or licensed, to the extent required in its home jurisdiction, to execute trades in the Crypto Assets and is not in default of securities legislation.

XI. The Filer will evaluate the price obtained from its Liquidity Providers on an ongoing basis against global benchmarks and will provide fair and reasonable prices to its clients.

XII. Before each client opens an account, the Filer will deliver to the client a Risk Statement, and will require the client to provide electronic acknowledgement of having received, read and understood the Risk Statement.

XIII. The disclosure in condition XII will be prominent and separate from other disclosures given to the client as part of the account opening process, and the acknowledgement will be separate from other acknowledgements by the client as part of the account opening process.

XIV. A copy of the Risk Statement acknowledged by a client will be made available to the client in same place as the client’s other statements in the App.

XV. The Filer will update the Risk Statement to reflect any material changes to the disclosure or include any material risks that may develop with respect to the Crypto Rights Contracts or Crypto Assets and, in the event of any update to the Risk Statement, will promptly notify each existing client of the update and deliver to them a copy of the updated Risk Statement.

XVI. Prior to the Filer delivering a Risk Statement to a client, the Filer will deliver, or will have previously delivered, a copy of the Risk Statement delivered to the client to the Principal Regulator.

XVII. For each client, prior to opening an account, the Filer will perform an account appropriateness assessment and product-type assessment as described in paragraph 28.

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XVIII. The Filer will monitor client activity, and contact clients to discuss their trading behaviour if it indicates a lack of knowledge or understanding of Crypto Asset trading, in an effort to identify and deter behaviours that may indicate that trading a Crypto Rights Contract is not appropriate for the client, or that additional education is required.

XIX. The Filer will ensure that the maximum amount that a client may fund, in a 12-month period, to trade pursuant to Crypto Rights Contracts, is C$30,000.

XX. In the jurisdictions where the Prospectus Relief is required, the first trade of a Crypto Rights Contract is deemed to be a distribution under securities legislation of that jurisdiction.

XXI. The Filer will provide the Principal Regulator with at least 10 days' prior written notice of any:

a) change of custodian; and

b) material changes to the Filer’s ownership or its business operations, including its systems, or its business model.

XXII. The Filer will notify the Principal Regulator, promptly, of any material breach or failure of its custodian’s system of controls or supervision, and what steps have been taken by the Filer to address each such breach or failure. The loss of any amount of specified crypto asset will be considered a material breach or failure.

Data Reporting

XXIII. The Filer will provide the following information to the Principal Regulator, and to the securities regulatory authority or regulator in each of the Non-Principal Jurisdictions with respect to clients in those jurisdictions individually, within 30 days of the end of each March, June, September and December:

a) aggregate reporting of activity conducted pursuant to Crypto Rights Contracts that will include the following:

1. number of client accounts opened each month in the quarter;

2. number of client accounts closed each month in the quarter;

3. number of trades each month in the quarter;

4. average value of the trades each month in the quarter;

5. number of client accounts that hold over $10,000 of Crypto Assets at the end of each month in the quarter;

6. number of client accounts with no trades during the quarter;

7. number of client accounts that have not been funded at the end of each month in the quarter; and

8. number of client accounts that hold a positive amount of Crypto Assets at end of each month in the quarter;

b) the details of any client complaints received by the Filer during the calendar quarter and how such complaints were addressed; and

c) the details of any fraudulent activity or cybersecurity incidents on the Platform during the calendar quarter, any resulting harms and effects on clients, and the corrective measures taken by the Filer to remediate such activity or incident and prevent similar activities or incidents from occurring in the future.

XXIV. The Filer will deliver to the regulator or the securities regulatory authority in each of the Applicable Jurisdictions, in a form and format acceptable to the regulator or the securities regulatory authority, a report that includes the following anonymized account-level data for activity conducted pursuant to a Crypto Rights Contract for each client within 30 days of the end of each March June, September and December:

a) unique account number and unique client identifier, as applicable;

b) jurisdiction where the client is located;

c) cumulative realized gains/losses since account opening in CAD;

d) unrealized gains/losses as of the report end date in CAD;

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e) quantity traded by Crypto Asset during the quarter in number of units;

f) Crypto Asset traded by the client (BTC or ETH);

g) quantity held of each Crypto Asset by the client as of the report end date in units;

h) CAD equivalent aggregate value for each Crypto Asset traded by the client, calculated as the amount in (g) multiplied by the market price of the asset in (f) as of the report end date;

i) age of account in months.

XXV. Until such time as the Filer can deliver annual audited financial statements in accordance with subsection 12.10(2) of NI 31-103, the Filer will deliver annual unaudited financial statements of the Filer and the annual audited financial statements of WFC for each financial year to the Principal Regulator as soon as they are available.

XXVI. In addition to any other reporting required by Legislation, the Filer will provide, on a timely basis, any report, data, document or information to the Principal Regulator, including any information about the Filer’s custodian and the Crypto Assets held by the Filer’s custodian, that may be requested by the Principal Regulator from time to time as reasonably necessary for the purpose of monitoring compliance with Legislation and the conditions in the Decision, in a format acceptable to the Principal Regulator.

XXVII. Upon request, the Filer will provide the Principal Regulator and the securities regulators or securities regulatory authorities of each of the Non-Principal Jurisdictions with aggregated and/or anonymized data concerning client demographics and activity on the Platform that may be useful to advance the development of the Canadian regulatory framework for trading crypto assets.

XXVIII. This Decision shall expire upon the earlier of:

a) two years from the date of this Decision; or

b) the date of the transition of the Platform to ShareOwner.

XXIX. The Filer will promptly make any changes to its business practices or policies and procedures that may be required to address investor protection concerns that may be identified by the Filer or by the Principal Regulator arising from the operation of the Platform.

XXX. This Decision may be amended by the Principal Regulator upon prior written notice to the Filer.

In respect of the Prospectus Relief:

“Wendy Berman” Vice Chair Ontario Securities Commission

“Tim Moseley” Vice Chair Ontario Securities Commission

In respect of the Requested Relief other than the Prospectus Relief:

“Pat Chaukos” Director, Office of Economic Growth and Innovation Ontario Securities Commission

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Appendix A - Local Trade Reporting Rules

In this Decision the “Local Trade Reporting Rules” collectively means each of the following:

a. Part 3, Data Reporting of Ontario Securities Commission Rule 91-507 Trade Repositories and Derivatives Data Reporting (OSC Rule 91-507);

b. Part 3, Data Reporting of Manitoba Securities Commission Rule 91-507 Trade Repositories and Derivatives Data Reporting (MSC Rule 91-507); and

c. Part 3, Data Reporting of Multilateral Instrument 96-101 Trade Repositories and Derivatives Data Reporting in Alberta, British Columbia, New Brunswick, Newfoundland and Labrador, Northwest Territories, Nova Scotia, Nunavut, Prince Edward Island, Saskatchewan, and Yukon (MI 96-101).

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Appendix B – Disclosure to be Included in Risk Statement

Disclosure Statement for Crypto Assets

This Statement is presented to you at the time of opening your account and is available to you within your documents settings in the Wealthsimple Trade App. You must acknowledge having received, read and understood this Statement in order to open and operate a Wealthsimple Crypto account. Please read this Statement in its entirety.

The Statement does not disclose all of the risks or relevant considerations of entering into a contract with Wealthsimple Digital Assets (WDA) to buy, sell and hold Crypto Assets. In light of the risks, you should undertake such transactions only if you understand the nature of the contractual relationship with WDA into which you are entering, and the extent of your exposure to the risks associated with trading in Crypto Assets. Please refer to WDA’s Client Relationship Disclosure [link] for a more detailed description of this relationship. There are limited circumstances in which you can obtain possession of the Crypto Assets you have purchased (see “Closed Loop System” below). The Crypto Assets that you have purchased will be held in trust for you, in a pooled account that is in the name of WDA, at a third-party custodian independent of WDA. As such, there is a risk you will not be able to successfully obtain possession of the Crypto Assets, and a risk that the assets in this pooled account will not be sufficient to ensure that you receive the value of your interest in the Crypto Assets.

Trading in Crypto Assets may not be suitable for certain members of the public. You should carefully consider whether trading is appropriate for you in light of your knowledge, experience, financial objectives, financial resources and other relevant circumstances.

Introduction

WDA believes that its customers should be aware of the risks involved in the purchase, sale and custody of Crypto Assets. Crypto Asset trading may not be appropriate for you, particularly if you use funds drawn from retirement savings, student loans, mortgages, emergency funds, or funds set aside for other purposes. The volatility and unpredictability of the price of Crypto Assets relative to fiat currency may result in significant loss over a short period of time. The following is a brief non-exhaustive summary of certain more significant factors and special risks you should take into account when deciding whether to trade Crypto Assets.

What are Crypto Assets?

Crypto Assets are digital representations of value that function as a medium of exchange, a unit of account, or a store of value, but do not have legal tender status. Crypto Assets are sometimes exchanged for currencies, but they are not generally backed or supported by any government or central bank. Their value is derived by market forces of supply and demand, and they are traditionally more volatile than fiat currencies. The value of Crypto Assets may be derived from the continued willingness of market participants to exchange fiat currency for Crypto Assets, which may result in the potential for permanent and total loss of value of a particular Crypto Asset should the market for a Crypto Asset disappear entirely. Federal, provincial, territorial or foreign governments may restrict the use and exchange of Crypto Assets, and regulation in North America is still developing.

Crypto Assets differ in their functions, structures, governance and rights. Wealthsimple permits the trading of well established Crypto Assets that function as a form of payment or means of exchange on a decentralized network, such as bitcoin and ether. These Crypto Assets have certain features that are analogous to existing commodities, such as currencies and precious metals, but are also different in many key respects, as described in this disclosure statement.

Risks in Trading Crypto Assets

The following is a brief summary of some of the risks connected with trading Crypto Assets.

(1) Short History Risk

As a relatively new open source technology, it is expected that there will continue to be technical developments in blockchain technology, which could impact the value of a Crypto Asset. Due to this short history, it is not certain whether the economic value, governance or functional elements of Crypto Assets will persist over time. The Crypto Asset community has successfully navigated a considerable number of technical and political challenges since the genesis of the bitcoin blockchain, which WDA believes is a strong indicator that it will continue to engineer its way around future challenges. That said, the continuation of a vibrant Crypto Asset community is not guaranteed, and insufficient software development, contribution rates, community disputes regarding the development of the network and scaling options, or any other unforeseen challenges that the community is not able to navigate could have an adverse impact on the price of a Crypto Asset.

Open source developers of blockchain technology have signalled that they will continue to make efforts to improve the scaleability and security of public blockchains like bitcoin and ethereum. For example, in respect of the ethereum blockchain, developers are planning to replace the current hash-based mining consensus mechanism of proof-of-work with a proof-of-stake mechanism. Changes may also occur to the bitcoin blockchain, for example with the continued development of scaleability

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Decisions, Orders and Rulings protocols like the Lightning Network, which operate on top of the bitcoin blockchain. The expected timing and impacts of this change are uncertain.

(2) Volatility in the Price of Crypto Asset and Loss of Liquidity

The Crypto Asset markets are sensitive to new developments, and since volumes are still maturing, any significant changes in market sentiment (by way of sensationalism in the media or otherwise) can induce large swings in volume and subsequent price changes. Crypto Asset prices on trading platforms have been volatile and subject to influence by many factors, including the levels of liquidity, public speculation on future appreciation in value, swings in investor confidence and the future growth of alternative Crypto Assets that may gain market share. In certain circumstances, it may become difficult or impossible to assess the value of your Crypto Assets.

The trading of Crypto Assets on public trading platforms has a limited history. The prices available on those platforms have, in some cases, been more volatile and subject to influence by additional factors not specific to the value of Crypto Assets, including liquidity levels and operational interruptions. Operational interruptions can limit the liquidity of Crypto Assets on the trading platform, which could result in volatile prices and reduced confidence in the Crypto Assets traded on those platforms.

Wealthsimple Crypto uses multiple brokers, which we refer to as liquidity providers, to buy and sell the Crypto Assets that we trade for you. These liquidity providers connect to multiple trading platforms in order to ensure ongoing liquidity of Crypto Assets. Use of multiple liquidity providers and multiple trading platforms is designed to reduce the liquidity risk and operational risk associated with any one trading platform. However, there is a risk that the liquidity sources accessed directly and indirectly by Wealthsimple Crypto are unable to return the best possible prices or execution quality on your behalf. This risk may be greater during periods of high market volatility or operational outages at a major trading platform.

(3) Potential Decrease in Global Demand for Crypto Assets

Crypto Assets represent a new form of digital value that is still being digested by society. Their underlying value is driven by their utility as a store of value, means of exchange, or unit of account. Just as oil is priced by the supply and demand of global markets, as a function of its utility to, for instance, power machines and create plastics, so too is a Crypto Asset priced by the supply and demand of global markets for its own utility within remittances, B2B payments, time-stamping, etc. Speculators and investors using Crypto Asset as a store of value then layer on top of means of exchange users, creating further demand. If consumers stop using Crypto Assets as a means of exchange, or their adoption slows, then the price may suffer. Investors should be aware that there is no assurance that Crypto Assets will maintain their long-term value in terms of purchasing power in the future or that the acceptance of Crypto Assets for payments by mainstream retail merchants and commercial businesses will continue to grow.

While the value of bitcoin may be derived primarily from its capitalization and position as first mover, the value of ether relies far more on its underlying blockchain technology. The ethereum blockchain is intended to allow people to operate decentralized applications using blockchain technology that do not rely on the actions of a centralized intermediary. Ether, which is the primary currency of the ethereum blockchain, can then be used to compensate for the effort of others to power these decentralized applications and ensure that any transactions that occur on these applications are recorded in the blockchain. Accordingly, the long term value of ether may be tied to the success or failure of the blockchain technology and the decentralized applications built upon the ethereum blockchain.

(4) The Blockchains on which Crypto Assets operate may Temporarily or Permanently Fork

Both the bitcoin and ethereum blockchain networks are powered by open source software. When a modification to that software is released by developers, and a substantial majority of miners consent to the modification, a change is implemented and the blockchain network continues uninterrupted. However, if a change were to be introduced with less than a substantial majority consenting to the proposed modification, and the modification is not compatible with the software in operation prior to its modification, the consequence would be what is known as a “fork” (i.e. a split) of the blockchain. One blockchain would be maintained by the pre-modification software and the other by the post-modification software. The effect is that both blockchains would operate in parallel, but independently. There are examples of such forks occurring in the past on both the bitcoin and ethereum blockchain networks. In the future, such a fork could occur again, and affect the viability or value of a Crypto Asset. Wealthsimple Crypto may choose not to support any future fork of the underlying blockchain of the Crypto Assets available on our platform, in which case you may not have any rights to the new crypto assets that may be created as a result of that fork.

(5) Issues with the Cryptography Underlying the Crypto-networks

In the past, flaws in the source code for digital assets have been exposed and exploited, including flaws that disabled some functionality for users, exposed users’ personal information and/or resulted in the theft of users’ digital assets. Although the bitcoin and ethereum blockchains have demonstrated resiliency and integrity over time, the cryptography underlying either one could, in the future, prove to be flawed or ineffective. For example, developments in mathematics and/or technology, including advances in digital computing, algebraic geometry and quantum computing, could result in the cryptography of the blockchain network being vulnerable to attack. This could negatively affect the value of Crypto Assets traded with Wealthsimple Crypto.

August 20, 2020 (2020), 43 OSCB 6559

Decisions, Orders and Rulings

(6) Uncertainty in Regulation and Future Financial Institution Support

The regulation of Crypto Assets continues to evolve in Canada and in foreign jurisdictions, which may restrict the use of Crypto Assets or otherwise impact the demand for Crypto Assets. There may be limitations on the ability of a securities regulator in Canada to enforce Canadian laws on foreign entities, and foreign rules that apply to Crypto Asset activities which occur in other jurisdictions may not necessarily be enforced in that jurisdiction. Furthermore, banks and other financial institutions may refuse to process funds for Crypto Asset transactions, process wire transfers to or from Crypto Asset trading platforms, Crypto Asset- related companies or service providers, or maintain accounts for persons or entities transacting in Crypto Assets.

(7) Concentration Risks

Certain addresses on the bitcoin and ethereum blockchain networks hold a significant amount of the currently outstanding bitcoin and ether, respectively. If one of these addresses were to exit their bitcoin or ether positions, it could cause volatility that may adversely affect the price.

Further, if anyone gains control over 51% of the computing power (hash rate) used by the blockchain network, they could use their majority share to double spend their Crypto Assets. If such a “51% attack” were to be successful, this would significantly erode trust in public blockchain networks like bitcoin and ethereum to store value and serve as a means of exchange, which may significantly decrease the value of Crypto Assets.

(8) Electronic Trading and Dependence on the Internet

There are risks associated with using an internet-based trade execution software application including, but not limited to, the failure of hardware and software. WDA maintains an independent and secure ledger of all transactions to minimize loss, and maintains contingency plans to minimize the possibility of system failure. However, WDA does not control signal power, reception, routing via the internet, configuration of your equipment or the reliability of your connection to the internet. The result of any failure of the foregoing may be that you are unable to place an order, your order is not executed according to your instructions, or your order is not executed at all. Under certain market conditions, you may find it difficult or impossible to liquidate a position quickly at a reasonable price. This can occur, for example, when the market for a particular Crypto Asset suddenly drops, or if trading is halted due to recent news events, unusual trading activity, or changes in the underlying Crypto Asset system. The greater the volatility of a particular Crypto Asset, the greater the likelihood that problems may be encountered in executing a transaction. In addition to normal market risks, you may experience losses due to one or more of the following: system failures, hardware failures, software failures, network connectivity disruptions, and data corruption.

(9) Cyber Security Risk

The nature of Crypto Assets may lead to an increased risk of fraud or cyber attack. A breach in cyber security refers to both intentional and unintentional events that may cause WDA to lose proprietary information or other information subject to privacy laws, suffer data corruption, or lose operational capacity. This in turn could cause WDA to incur regulatory penalties, reputational damage, additional compliance costs associated with corrective measures and/or financial loss. Cyber security breaches may involve unauthorized access to WDA’s digital information systems (e.g. through “hacking” or malicious software coding), but may also result from outside attacks such as denial-of-service attacks (i.e. efforts to make network services unavailable to intended users). In addition, cyber security breaches of WDA’s third-party service providers (e.g. the liquidity providers and custodian) can also give rise to many of the same risks associated with direct cyber security breaches. As with operational risk in general, WDA has established risk management systems designed to reduce the risks associated with cyber security.

(10) Closed Loop System

When you enter into a contract with WDA to buy and sell Crypto Assets, that contract provides you with certain rights and imposes certain responsibilities; the contract, and your contractual right to the crypto assets that you may buy, hold and sell pursuant to the contract, constitute a security or derivative. In particular, the contract you sign with WDA enables you to buy, sell and hold Crypto Assets without the need for you to receive and hold your Crypto Assets in your own private wallet. We refer to this as a “closed loop” system. We believe that a closed loop system significantly reduces the likelihood of user error in sending or receiving Crypto Assets to incorrect wallet addresses. However, a closed loop system may also expose you to insolvency risk (credit risk), fraud risk or proficiency risk on the part of WDA or the custodian designated to hold your Crypto Assets.

(11) Lack of Investor Protection Insurance

Crypto Assets purchased and held in an account with WDA are not protected by the Canadian Investor Protection Fund, the Canadian Deposit Insurance Corporation or any other investor protection insurance scheme.

August 20, 2020 (2020), 43 OSCB 6560

Decisions, Orders and Rulings

(12) Commission and Other Charges

Although WDA does not charge a commission fee, there are certain costs built into the spread offered on your purchase and sale of Crypto Assets, as disclosed to you within the Wealthsimple Trade app. Fees are based in part on the fees charged to us by our third-party liquidity providers and custodian, which are subject to change.

August 20, 2020 (2020), 43 OSCB 6561

Decisions, Orders and Rulings

2.1.4 Mercer Global Investments Canada Limited (b) the Filer has provided notice that subsection 4.7(1) of Multilateral Headnote Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon in National Policy 11-203 Process for Exemptive Relief British Columbia, Alberta, Saskatchewan, Applications in Multiple Jurisdictions – Relief granted to Manitoba, Québec, New Brunswick, registered adviser from certain provisions of National Nova Scotia, Prince Edward Island, Instrument 31-103 Registration Requirements, Exemptions Newfoundland and Labrador, Yukon, and Ongoing Registrant Obligations amended or introduced Northwest Territories and Nunavut (the under the Client Relationship Model Phase 2, specifically Passport Jurisdictions and, together sections 14.2, 14.2.1, 14.14.1, 14.14.2, 14.17 and 14.18 I – with Ontario, the Jurisdictions); and in respect of certain institutional clients that do not meet the definition of “permitted client” and are not individuals. (c) the decision of the principal regulator automatically results in an equivalent Applicable Legislative Provisions decision in the Passport Jurisdictions.

Multilateral Instrument 11-102 Passport System, s. 4.7. Interpretation National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations, Terms defined in MI 11-102, National Instrument 14-101 ss. 14.2, 14.2.1, 14.14.1, 14.14.2, 14.17, 14.18, Definitions and NI 31-103 have the same meaning if used 15.1. in this decision, unless otherwise defined.

August 14, 2020 Representations

IN THE MATTER OF This decision is based on the following facts represented THE SECURITIES LEGISLATION OF by the Filer: ONTARIO (the Jurisdiction) The Filer

AND 1. The Filer is a corporation existing under the laws of Canada with its head office located in Toronto, IN THE MATTER OF Ontario. THE PROCESS FOR EXEMPTIVE RELIEF APPLICATIONS 2. The Filer is registered: IN MULTIPLE JURISDICTIONS (a) under the securities legislation of all AND provinces and territories of Canada as a portfolio manager and an exempt market IN THE MATTER OF dealer; MERCER GLOBAL INVESTMENTS CANADA LIMITED (the Filer) (b) under the securities legislation of Ontario, Québec, Newfoundland and Labrador DECISION and Manitoba as an investment fund manager; Background (c) under The Commodity Futures Act The principal regulator in the Jurisdiction has received an (Manitoba) as an adviser; application (the Application) from the Filer for a decision under the securities legislation of the Jurisdiction of the (d) under the Commodity Futures Act principal regulator (the Legislation) that pursuant to section (Ontario) as a commodity trading 15.1 of National Instrument 31-103 Registration manager; and Requirements, Exemptions and Ongoing Registrant Obligations (NI 31-103) with regard to the Overflow Accounts (e) under the Derivatives Act (Québec) as a and the Institutional Investor Accounts described below, the derivatives portfolio manager. Filer is exempt from the reporting requirements in sections 14.2, 14.2.1, 14.14.1, 14.14.2, 14.17 and 14.18 of NI 31-103 3. The Filer is not in default of securities legislation in (the CRM2 Reporting) (the Requested Relief). any jurisdiction of Canada.

Under the Process for Exemptive Relief Applications in 4. One of the Filer’s lines of business is called the Multiple Jurisdictions (for a passport application): “Outsourced Chief Investment Officer” (the OCIO), which offers discretionary investment management (a) the Ontario Securities Commission is the services to institutional permitted clients. principal regulator for the Application; 5. The Filer has another line of business called “Private Wealth”, which provides wealth

August 20, 2020 (2020), 43 OSCB 6562

Decisions, Orders and Rulings

management services primarily to high net worth 11. The Filer considers these clients to be individuals. The Filer currently provides CRM2 “institutional” clients because they meet other Reporting to its clients within the “Private Wealth” criteria common to institutional clients. In line of business. The OCIO and “Private Wealth” particular, each client with an Institutional Investor lines of business are distinct business units that Account will be a permitted client at account serve very distinct market segments with different opening but may, over time, technically cease to products and services that are tailored to their be a permitted client due to market or other respective clients’ specific needs. conditions causing the client to fall below the financial tests in the definition of permitted client in 6. The Filer’s clients utilizing the OCIO services are section 1.1 of NI 31-103. exclusively institutional permitted clients (the Existing Permitted Clients). The Existing 12. Without the Requested Relief, the Filer must Permitted Clients are sophisticated institutional provide the Accounts with the CRM2 Reporting. investors. The Filer has worked collaboratively with the Existing Permitted Clients to develop 13. The Accounts in aggregate will not exceed 2% of tailored institutional reporting that provides a level the Filer’s total assets under management. of transparency to best suit their governance needs and reporting obligations to their 14. The Existing Permitted Clients have worked with beneficiaries, auditors, governance committees, the Filer to provide institutional reporting tailored etc. This institutional reporting includes tailored to meet specific client requirements. and detailed requirements with respect to format, frequency and content of account statements and 15. In common with Existing Permitted Clients, the performance reports, and, in some cases, include Accounts are expected to have detailed more disclosure than what is required under the requirements with respect to the format, frequency CRM2 Reporting requirements. or content of the account statements and performance reports they receive because of the CRM2 Reporting reporting they have to provide for their stakeholders including beneficiaries, auditors, 7. Under NI 31-103, registered firms, such as the governance committees, etc. Filer, are required to provide CRM2 Reporting to non-permitted clients and all individual clients. The 16. In common with Existing Permitted Clients, the CRM2 Reporting applies to all categories of Accounts may also engage professional advisors, registered dealers and registered advisers, with such as consultants, auditors or legal counsel, some application to investment fund managers. who may recommend specific reporting (form, frequency, tailored content etc.) which may, in 8. CRM2 Reporting includes performance reporting some cases, differ from CRM2 Reporting. requirements and enhanced cost disclosure and client statement requirements. 17. In common with Existing Permitted Clients, the Accounts are expected to require reporting 9. CRM2 Reporting includes certain exemptions for content that is highly detailed and transparent. permitted clients that are not individuals. The reporting will be robust and comprehensive and may, in some cases, include more disclosure The Accounts than what is required by CRM2 Reporting.

10. Certain of the Filer’s Existing Permitted Clients 18. The Institutional Investor Accounts will want to may from time to time: continue to receive the same tailored institutional reporting even if they no longer strictly meet the a. request that the Filer open new accounts definition of permitted client. It is important for for related entities that do not qualify as consistency of reporting to such a client, including permitted clients only because they fall the reporting that such a client must provide to its short of the financial tests in the definition stakeholders, that they continue to receive the of permitted client in section 1.1 of NI 31- same reporting after failing to meet the definition 103, but otherwise have the of permitted client. characteristics of an institutional investor (an Overflow Account); and/or 19. The Overflow Accounts are often overseen by the same governance bodies as the Existing b. due to market or other conditions after an Permitted Clients. It would be undesirable to account is opened with the Filer, fall short provide the same governance body of the related of the financial tests in the definition of Overflow Account with reporting that complies with permitted client in section 1.1 of NI 31- CRM2 Reporting, but differs from the tailored 103, but otherwise continue to have the institutional reporting already being received by characteristics of an institutional investor the Existing Permitted Client. (an Institutional Investor Account and with an Overflow Account, an Account). 20. The OCIO service operates in a business unit that is distinct from the Filer’s line of business that

August 20, 2020 (2020), 43 OSCB 6563

Decisions, Orders and Rulings

provides CRM2 Reporting to clients. It would be “Felicia Tedesco” costly and burdensome for the Filer to build the Deputy Director CRM2 Reporting capabilities to the OCIO Compliance and Registrant Regulation Branch business unit and economically infeasible for the Ontario Securities Commission very small number of Accounts contemplated under the Requested Relief. It would also be undesirable from the perspective of the Existing Permitted Client if its related Account was transferred to a different business unit and serviced outside of the OCIO business unit.

21. The Filer would incur significant costs and resource-strain to implement CRM2 Reporting for the Accounts.

22. Each Account will be informed by the Filer that it

will not receive the CRM2 Reporting that it would have been entitled to but for the Requested Relief and will receive an explanation of what is provided with CRM2 Reporting as compared to the current reporting it receives.

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 Relief is granted provided that:

(a) the Requested Relief applies to the Accounts serviced by the Filer under the OCIO service (or as the OCIO service evolves over time, provided that such future service substantially meets the representations set out herein);

(b) the Accounts in aggregate do not exceed 2% of the Filer’s total assets under management at the

end of each fiscal year of the Filer;

(c) the Accounts receive comprehensive account reporting from the Filer on an ongoing basis which

is consistent with the reporting provided by the Filer to the Existing Permitted Clients;

(d) each Account is informed that it will not receive the CRM2 Reporting that it would have been entitled to but for the Requested Relief;

(e) each Account receives an explanation of what is provided with CRM2 Reporting as compared to the reporting it will receive; and

(f) if the Filer opens any new accounts for (i) clients that are not permitted clients at the time of account opening, other than the Accounts, or (ii) permitted clients that are individuals, it will provide CRM2 Reporting for those new accounts, unless it obtains other exemptive relief in respect of them.

August 20, 2020 (2020), 43 OSCB 6564

Decisions, Orders and Rulings

2.1.5 Ninepoint Partners LP simplified prospectus of the Existing Alternative Funds was April 21, 2021 (the Headnote Lapse Date Relief); and

National Policy 11-203 Process for Exemptive Relief (b) grants relief to the Funds from the Applications in Multiple Jurisdictions – Relief granted to requirement in subsection 5.1(4) of mutual funds for extensions of lapse dates of their National Instrument 81-101 Mutual Fund prospectuses – Relief granted to mutual funds to allow the Prospectus Disclosure (NI 81-101) which combination of the simplified prospectus of an alternative states that a simplified prospectus for an mutual fund with the simplified prospectus of a alternative mutual fund must not be conventional mutual fund – Filer will incorporate offering of consolidated with a simplified prospectus the funds under the same offering documents when they of another mutual fund if the other mutual are renewed – Extensions of lapse dates will not affect the fund is not an alternative mutual fund currency or accuracy of the information contained in the (the Consolidation Relief and together current prospectuses. with the Lapse Date Relief, the Requested Relief). Applicable Legislative Provisions Under the Process for Exemptive Relief Applications in Securities Act, R.S.O. 1990, c. S.5, as am., s. 62(5). Multiple Jurisdictions (for a passport application): National Instrument 81-101, ss. 6.1, 5.1(4). (a) the Ontario Securities Commission is the July 21, 2020 principal regulator for this application; and IN THE MATTER OF THE SECURITIES LEGISLATION OF (b) the Filer has provided notice that ONTARIO subsection 4.7(1) of Multilateral (the Jurisdiction) Instrument 11-102 Passport System (MI 11-102) is intended to be relied upon in AND each of the other provinces and territories of Canada (together with IN THE MATTER OF Ontario, the Jurisdictions). THE PROCESS FOR EXEMPTIVE RELIEF APPLICATIONS Interpretation IN MULTIPLE JURISDICTIONS Terms defined in National Instrument 14-101 Definitions AND and MI 11-102 have the same meaning if used in this decision, unless otherwise defined. IN THE MATTER OF NINEPOINT PARTNERS LP Representations (the Filer) This decision is based on the following facts represented DECISION by the Filer:

Background 1. The Filer is a limited partnership formed and organized under the laws of the Province of The principal regulator in the Jurisdiction has received an Ontario. The general partner of the Filer is application from the Filer on behalf of certain alternative Ninepoint Partners GP Inc., a corporation mutual funds as listed in Schedule A (collectively, the incorporated under the laws of the Province of Existing Alternative Funds) and Ninepoint Enhanced U.S. Ontario. The head office of the Filer is located in Equity Class (the Proposed Alternative Fund, and Ontario. collectively, with the Existing Alternative Funds, the Existing Funds) and any alternative mutual fund 2. The Filer is registered as (i) an investment fund established or restructured in the future and managed by manager in Ontario, Quebec and Newfoundland the Filer or an affiliate of the Filer (the Future Funds, and and Labrador, (ii) a portfolio manager in Ontario, collectively, with the Existing Funds, the Funds), for a British Columbia, Alberta, Saskatchewan, decision under the securities legislation of the Jurisdiction Manitoba, New Brunswick, Nova Scotia and of the principal regulator (the Legislation) that: Newfoundland and Labrador, and (iii) an exempt market dealer in Ontario, British Columbia, (a) the time limits for the renewal of the Alberta, Saskatchewan, Manitoba, New simplified prospectus of the Existing Brunswick, Nova Scotia, Newfoundland and Alternative Funds dated November 8, Labrador and Quebec. 2019 be extended to the time limits that would apply if the lapse date of the

August 20, 2020 (2020), 43 OSCB 6565

Decisions, Orders and Rulings

3. The Filer is the trustee and manager of each of Other Funds and combining them in the same the Existing Alternative Funds. The Filer is also simplified prospectuses will allow investors to the manager of 18 other mutual funds as listed in more easily compare the features of the Other Schedule B (the Other Funds), including the Funds and the Existing Alternative Funds. Proposed Alternative Fund that are offered in each of the Jurisdictions under a simplified 10. The Filer may make changes to the features of the prospectus with a lapse date of April 21, 2021. Other Funds as part of the process of renewing the Other Funds’ Prospectus Documents. The 4. Neither the Filer nor any of the Existing Funds is in ability to file the Prospectus Documents of the default of securities legislation in any of the Existing Alternative Funds with those of the Other Jurisdictions. Funds will ensure that the Filer can make the operational and administrative features of the 5. Each of the Existing Alternative Funds is an open- Existing Alternative Funds and the Other Funds ended mutual fund trust established under the consistent with each other, if necessary. laws of Ontario. The Proposed Alternative Fund represents one class of shares of Ninepoint 11. If the Lapse Date Relief is not granted, and Corporate Class Inc., a mutual fund corporation assuming that the Consolidation Relief is granted, created under the laws of Ontario. Each of the it will be necessary to renew the Prospectus Existing Funds is a reporting issuer in each of the Documents of the Existing Alternative Funds twice Jurisdictions. within a short period of time in order to consolidate the Prospectus Documents of the Existing 6. Securities of the Existing Alternative Funds are Alternative Funds with the Prospectus Documents currently qualified for distribution in each of the of the Other Funds, and it would be unreasonable Jurisdictions under the current simplified for the Filer to incur the costs and expenses prospectus of the Existing Alternative Funds dated associated therewith, given investors would not be November 8, 2019, as amended by amendment prejudiced by the Lapse Date Relief. no. 1 dated April 9, 2020 and amendment no. 2 dated May 1, 2020 (the Current Prospectus). 12. There have been no material changes in the affairs of the Existing Alternative Funds since the 7. The lapse date for the Current Prospectus is date of the Current Prospectus. Accordingly, the November 8, 2020 (the Current Lapse Date). Current Prospectus and current fund facts Accordingly, under the Legislation, the distribution document(s) of each of the Existing Alternative of securities of each of the Existing Alternative Funds continue to provide accurate information Funds would have to cease on the Current Lapse regarding the Existing Alternative Funds. date unless: (i) the Existing Alternative Funds file a pro forma simplified prospectus at least 30 days 13. Given the disclosure obligations of the Filer and prior to its Current Lapse Date; (ii) the final the Existing Alternative Funds, should any simplified prospectus is filed no later than 10 days material change in the business, operations or after its Current Lapse Date; and (iii) a receipt for affairs of the Existing Alternative Funds occur, the the final simplified prospectus is obtained within Current Prospectus and current fund facts 20 days after its Current Lapse Date. document(s) of the applicable Existing Alternative Fund(s) will be amended as required under the 8. Securities of the Proposed Alternative Fund are Legislation. currently qualified for distribution in each of the Jurisdictions under the current simplified 14. New investors of the Existing Alternative Funds prospectus of the Other Funds dated April 21, will receive delivery of the most recently filed fund 2020, as amended by amendment no. 1 dated facts document(s) of the applicable Fund(s). The May 27, 2020. Current Prospectus of the Existing Alternative Funds will remain available to investors upon 9. The Filer wishes to combine the simplified request. prospectus of the Existing Alternative Funds with the simplified prospectus of the Other Funds in 15. The Lapse Date Relief will not affect the accuracy order to reduce renewal, printing and related of the information contained in the Current costs. Offering the Existing Alternative Funds Prospectus or the respective fund facts under the same renewal simplified prospectus and document(s) of each of the Existing Alternative annual information form (the Prospectus Funds, and will therefore not be prejudicial to the Documents) as the Other Funds would facilitate public interest. the distribution of the Existing Alternative Funds in the Jurisdictions under the same prospectus 16. As noted above, consolidating the simplified disclosure and enable the Filer to streamline prospectuses would reduce renewal, printing and disclosure across the Filer’s fund platform. The related costs. Offering the Existing Funds under Existing Alternative Funds share many common the same renewal simplified prospectus and operational and administrative features with the annual information form as the Other Funds would

August 20, 2020 (2020), 43 OSCB 6566

Decisions, Orders and Rulings

facilitate the distribution of the Existing Funds in Schedule A the Jurisdictions under the same prospectus and enable the Filer to streamline disclosure across Ninepoint FX Strategy Fund the Filer’s fund platform. Even though the Existing Ninepoint Alternative Credit Opportunities Fund Funds are, or will be, alternative mutual funds, they share many common operational and Schedule B administrative features with the Other Funds that are conventional mutual funds and combining Ninepoint Diversified Bond Fund them in the same simplified prospectuses will Ninepoint Energy Fund allow investors to more easily compare the Ninepoint Global Infrastructure Fund features of the Other Funds and the Funds. Ninepoint Global Real Estate Fund Ninepoint Gold and Precious Minerals Fund 17. NI 41-101 does not contain an equivalent Ninepoint High Interest Savings Fund provision to subsection 5.1(4) of NI 81-101. Ninepoint Alternative Health Fund Accordingly, an investment fund manager that Ninepoint International Small Cap Fund manages exchange-traded funds (ETFs) is Ninepoint Concentrated Canadian Equity Fund permitted to consolidate a prospectus under Ninepoint Diversified Bond Class National Instrument 41-101 General Prospectus Ninepoint Resource Class Requirements (NI 41-101) for its ETFs that are Ninepoint Silver Equities Class alternative mutual funds with a prospectus for its Ninepoint Enhanced Balanced Class ETFs that are conventional mutual funds. There is Ninepoint Enhanced Equity Class no reason why mutual funds filing a prospectus Ninepoint Enhanced U.S. Equity Class under NI 81-101 should be treated differently from Ninepoint Focused Global Dividend Class ETFs filing a prospectus under NI 41-101. Ninepoint Gold Bullion Fund Ninepoint Silver Bullion Fund 18. If the Consolidation Relief is not granted, it will be necessary to add the Proposed Alternative Fund into the prospectus documents of the Existing Alternative Funds very quickly after the restructuring of the Proposed Alternative Fund from a conventional mutual fund to an alternative mutual fund is completed, and it would be unreasonable for the Filer to incur the costs and expenses associated therewith, given investors would not be prejudiced by the Consolidation Relief.

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 Relief is granted.

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

August 20, 2020 (2020), 43 OSCB 6567

Decisions, Orders and Rulings

2.2 Orders

2.2.1 Alchemist Mining Incorporated

Headnote

National Policy 11-207 Failure-to-File Cease Trade Orders and Revocations in Multiple Jurisdictions – Application by an issuer for a revocation of cease trade orders issued by the Commission and British Columbia Securities Commission – cease trade order issued because the issuer had failed to file certain continuous disclosure materials required – defaults subsequently remedied by bringing continuous disclosure filings up-to-date – Ontario opt-in to revocation order issued by British Columbia Securities Commission, as principal regulator.

Applicable Legislative Provisions

Securities Act, R.S.O. 1990, c. S.5, as am., ss.127, 144. National Policy 11-207 Failure to File Cease Trade Orders and Revocations in Multiple Jurisdictions.

Citation: 2020 BCSECCOM 294

REVOCATION ORDER

Alchemist Mining Incorporated Under the securities legislation of British Columbia and Ontario (the Legislation)

Background

Alchemist Mining Incorporated (the Issuer) is subject to a failure-to-file cease trade order (the FFCTO) issued by the regulator of the British Columbia Securities Commission (the Principal Regulator) and Ontario (each a Decision Maker) respectively on September 4, 2019.

¶ 1 The Issuer has applied to each of the Decision Makers under National Policy 11-207 Failure-to-File Cease Trade Orders and Revocation in Multiple Jurisdictions (NP 11-207) for an order revoking the FFCTOs.

¶ 2 This order is the order of the Principal Regulator and evidences the decision of the Decision Maker in Ontario.

Interpretation

¶ 3 Terms defined in National Instrument 14-101 Definitions or in NP 11-207 have the same meaning if used in this order, unless otherwise defined.

Order

¶ 4 Each of the Decision Makers is satisfied that the order to revoke the FFCTO meets the test set out in the Legislation for the Decision Maker to make the decision.

¶ 5 The decision of the Decision Makers under the Legislation is that the FFCTO is revoked.

¶ 6 July 29, 2020

“Allan Lim, CPA, CA” Manager Corporate Finance

August 20, 2020 (2020), 43 OSCB 6568

Decisions, Orders and Rulings

2.2.2 First Global Data Ltd. et al.

FILE NO.: 2019-22

IN THE MATTER OF FIRST GLOBAL DATA LTD., GLOBAL BIOENERGY RESOURCES INC., NAYEEM ALLI, MAURICE AZIZ, HARISH BAJAJ, and ANDRE ITWARU

Timothy Moseley, Vice-Chair and Chair of the Panel

August 13, 2020

ORDER

WHEREAS on August 13, 2020, the Ontario Securities Commission held a hearing by video conference, at the request of the parties;

ON HEARING the oral submissions of the representatives for Staff of the Commission, Global Bioenergy Resources Inc., Nayeem Alli, Maurice Aziz, Harish Bajaj and Andre Itwaru, no one appearing for First Global Data Ltd.;

IT IS ORDERED THAT:

1. Any motion regarding the schedule or mode of the merits hearing shall be heard on September 2, 2020, at 10:00 a.m., by video conference, or on such other date or time as may be agreed to by the parties and set by the Office of the Secretary. The motion materials shall be served and filed according to the following deadlines:

a. moving parties’ motion records and written submissions by August 24, 2020; and

b. responding affidavits, if any, and written submissions by August 31, 2020;

2. By August 19, 2020:

a. Staff shall serve the respondents with a hearing brief containing copies of the documents, and identifying the other things, that Staff intends to produce or enter as evidence at the merits hearing; and

b. each respondent shall serve every other party with any documents, and identify any other things, that have not previously been produced to Staff and that the respondent intends to produce or enter as evidence at the merits hearing;

3. By August 26, 2020, each respondent shall serve every other party with:

a. a hearing brief containing copies of the documents, and identifying the other things, that are not already contained in Staff’s hearing brief and that the respondent intends to produce or enter as evidence at the merits hearing; and

b. a list of the documents or things contained in Staff’s hearing brief that the respondent intends to produce or enter as evidence at the merits hearing.

“Timothy Moseley”

August 20, 2020 (2020), 43 OSCB 6569

Decisions, Orders and Rulings

2.2.3 Horizons ETFs Management (Canada) Inc.

Headnote

National Policy 11-206 Process for Cease to be a Reporting Issuer Applications – Application for an order that terminating exchange-traded funds are not reporting issuers under applicable securities laws – relief granted.

Applicable Legislative Provisions

Securities Act, R.S.O. 1990, c. S.5, as am., s. 1(10)(a)(ii).

July 23, 2020

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

AND

IN THE MATTER OF THE PROCESS FOR CEASE TO BE A REPORTING ISSUER APPLICATIONS

AND

IN THE MATTER OF HORIZONS ETFS MANAGEMENT (CANADA) INC. (the Filer)

AND

HORIZONS MORNINGSTAR HEDGE FUND INDEX ETF HORIZONS ABSOLUTE RETURN GLOBAL CURRENCY ETF (each, a Horizons Fund, and collectively, the Horizons Funds)

ORDER

Background

The principal regulator in the Jurisdiction has received an application from the Filer, on behalf of the Horizons Funds, for an order under the securities legislation of the Jurisdiction of the principal regulator (the Legislation) that each Horizons Fund has ceased to be a reporting issuer in all jurisdictions of Canada in which each Horizons Fund 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 each of the other provinces and territories of Canada.

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.

Representations

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

1. none of the Horizons Funds are OTC reporting issuers under Multilateral Instrument 51-105 Issuers Quoted in the U.S. Over-the-Counter Markets;

2. the outstanding securities of each Horizons Fund 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;

August 20, 2020 (2020), 43 OSCB 6570

Decisions, Orders and Rulings

3. no securities of any of the Horizons Funds, 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 each Horizons Fund has ceased to be a reporting issuer in all of the jurisdictions of Canada in which each Horizons Fund is currently a reporting issuer; and

5. none of the Horizons Funds are 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.

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

August 20, 2020 (2020), 43 OSCB 6571

Decisions, Orders and Rulings

2.2.4 Lendified Holdings Inc.

Headnote

Section 144 of the Securities Act (Ontario) – Application for a partial revocation of a failure-to-file cease trade order – Issuer cease traded due to failure to file audited annual financial statements of a wholly-owned subsidiary – Issuer applied for a variation of the cease trade order to permit the Issuer to complete a private placement of securities to accredited investors – Issuer will use proceeds to bring itself into compliance with its continuous disclosure obligations and to fund certain expenses to maintain operations – Partial revocation granted subject to conditions.

Applicable Legislative Provisions

Securities Act, R.S.O. 1990, c. S.5, as am., s. 144. National Policy 11-207 Failure-to-File Cease Trade Orders and Revocations in Multiple Jurisdictions.

IN THE MATTER OF LENDIFIED HOLDINGS INC.

PARTIAL REVOCATION ORDER Under the securities legislation of Ontario (the Legislation)

Background

1. Lendified Holdings Inc. (the Issuer) is subject to a failure-to-file cease trade order (the FFCTO) issued by the Ontario Securities Commission (the Principal Regulator) on July 9, 2020.

2. The Issuer has applied to the Principal Regulator for a partial revocation order of the FFCTO.

Interpretation

Terms defined in the Legislation, National Instrument 14-101 – Definitions or National Policy 11-207 – Failure-to-File Cease Trade Orders and Revocations in Multiple Jurisdictions have the same meaning if used in this order, unless otherwise defined.

Representations

3. This decision is based on the following facts represented by the Issuer:

a) The Issuer was incorporated on August 13, 2018 pursuant to the provisions of the Canada Business Corporations Act under the name “Hampton Bay Capital Inc.”. The Issuer completed a qualifying transaction, announced on December 24, 2019 (the Qualifying Transaction), pursuant to which the Issuer merged with Lendified Holdings Inc. and changed its name to Lendified Holdings Inc.

b) The Issuer's registered office is located at 365 Bay Street, Suite 811, Toronto, Ontario M5H 2V1 and its head office is located at 365 Bay Street, Suite 811, Toronto, Ontario M5H 2V1.

c) The Issuer is a reporting issuer under the securities legislation of the provinces of Ontario, British Columbia and Alberta. The Issuer is not a reporting issuer in any other jurisdiction in Canada.

d) The authorized share capital of the Issuer consists of an unlimited number of common shares and an unlimited number of preferred shares (issuable in series). The Issuer currently has 95,154,575 common shares and no preferred shares issued and outstanding. In addition, the Issuer has issued 19,158,437 warrants to acquire common shares, has granted 841,463 stock options to acquire common shares and has outstanding $6,000,000 principal amount of debt convertible into 17,142,856 common shares.

e) The Issuer's Common Shares are listed on the TSX Venture Exchange under the symbol “LHI”. A trading halt was implemented on July 10, 2020 following the issuance of the FFCTO after the close of trading on July 9, 2020.

f) The FFCTO was issued as a result of the Issuer's failure to file the following continuous disclosure materials as required by Ontario securities law:

August 20, 2020 (2020), 43 OSCB 6572

Decisions, Orders and Rulings

• audited annual financial statements for the year ended December 31, 2019 of Lendified PrivCo Holding Corporation (Subco), a wholly-owned subsidiary of the Issuer acquired in connection with the Qualifying Transaction, pursuant to section 4.10(2)(a)(i) of National Instrument 51-102 Continuous Disclosure Obligations (NI 51-102).

(the Required Annual Filings).

g) The Required Annual Filings were not filed due to several factors including (i) the former Chief Financial Officer of the Issuer resigned, as disclosed in a press release dated June 9, 2020 and the Issuer only recently filled the position; (ii) the Issuer changed auditors from BDO Canada LLP to McGovern, Hurley LLP, which was disclosed on May 19, 2020 (iii) the COVID-19 pandemic had a significant effect on the Issuer; and (iv) the Qualifying Transaction took the time and attention of senior management to complete.

h) No later than July 14, 2020, the Issuer was required to file the following continuous disclosure materials:

i) Subco’s interim financial report for the three months ended March 31, 2020 as required by NI 51-102;

ii) the Issuer’s interim financial report for the three months ended March 31, 2020 as required by NI 51- 102;

iii) the Issuer’s management’s discussion and analysis (the MD&A) for the period covered by the Interim Financial Report as required by NI 51-102; and

iv) certifications of the Interim Financial Report pursuant to National Instrument 52-109 – Certification of Disclosure in Issuers’ Annual and Interim Filings.

(collectively, the Required Interim Filings, and together with the Required Annual Filings, the Required Filings).

i) Although the Issuer did not file the Required Interim Filings by the July 14, 2020 deadline, the Issuer subsequently filed the Issuer’s interim financial report, MD&A and certifications referred to in (h)(ii), (iii) and (iv) above.

j) The Issuer is seeking a partial revocation of the FFCTO to complete a private placement (the Private Placement) for aggregate gross proceeds of up to $1,427,318 in order to raise the funds necessary to complete and file the outstanding Required Filings and fund the expenses as outlined below. The Private Placement securities will consist of units (the Units) at a price of a minimum of $0.015 per Unit, with each Unit comprised of one Common Share and one share purchase warrant (Warrant). Each Warrant is exercisable to acquire one Common Share at a price of $0.05 per share for a period of 36 months following the closing date of the Offering. Assuming the maximum proceeds are raised at a price of $0.015 per Unit, the Issuer will issue 95,154,575 Common Shares and 95,154,575 Warrants pursuant to the Offering.

k) The Private Placement will be conducted on a prospectus exempt basis with subscribers in Ontario, British Columbia and other provinces who are accredited investors (as defined in section 73.3 of the Securities Act (Ontario) (the Act) and National Instrument 45-106 – Prospectus Exemptions.

l) The Issuer intends to prepare and file the Required Filings (other than the Issuer’s interim financial report, MD&A and certifications, which have been filed as of the date hereof) in order to bring itself into compliance with its disclosure obligations and pay all outstanding fees as set out below. The Issuer also intends to apply to the Principal Regulator to have the FFCTO fully revoked within a reasonable time following completion of the Private Placement.

m) The Private Placement is subject to the approval of the TSX Venture Exchange and will be completed in accordance with all applicable laws.

n) The Issuer is not considering, nor is it involved in, any discussions relating to a reverse take-over, merger, amalgamation or other form of combination or transaction similar to any of the foregoing.

o) Other than the failure to file the Required Filings, the Issuer is not in default of any of the requirements of the Act or the rules and regulations made pursuant thereto. The Issuer's SEDAR and SEDI profiles are up to date.

p) The Issuer intends to allocate the proceeds from the Private Placement as follows:

August 20, 2020 (2020), 43 OSCB 6573

Decisions, Orders and Rulings

Description Cost (thousands) Payroll and other employee-related costs (but not including any fees $ 336 payable to senior management);

Accounting, audit and legal fees associated with the preparation and $ 163 filing of the relevant continuous disclosure documents;

$ 98 Costs and fees associated with the Private Placement;

Filing fees associated with obtaining the partial revocation order and $ 5 the full revocation order, including fees payable to the applicable regulators, including the Principal Regulator;

Legacy accounts payable, including accounting and legal fees, $ 675 consulting fees and outstanding transfer agent fees; and

$ 150 Working capital and general and administrative expenses. Total: $ 1,427

q) The Issuer reasonably believes that, while there are no assurances that the Private Placement will be completed in full, if completed in full it will be sufficient to bring its continuous disclosure obligations up to date and pay all related outstanding fees and provide it with sufficient working capital to enable it to continue operations.

r) As the Private Placement would involve a trade of securities and acts in furtherance of trades, the Private Placement cannot be completed without a partial revocation of the FFCTO.

s) Prior to completion of the Private Placement, the Issuer will:

i) provide any subscriber to the Private Placement with a copy of the FFCTO and a copy of the partial revocation order;

ii) obtain from each subscriber or recipient of Common Shares in connection with the Private Placement a signed and dated acknowledgment which clearly states that all of the Issuer's securities, including any common shares and warrants issued in connection with the Private Placement, will remain subject to the FFCTO, and that the issuance of a partial revocation order does not guarantee the issuance of a full revocation order in the future; and

iii) will make available a copy of the written acknowledgements referred to in paragraph 4(t) to staff of the Principal Regulator on request.

t) Additionally, the Issuer will issue a press release announcing the order and the intention to complete the Private Placement. Upon completion of the Private Placement, the Issuer will issue a press release and file a material change report. As other material events transpire, the Issuer will issue appropriate press releases and file a material change report as applicable.

ORDER

4. The Principal Regulator is satisfied that a partial revocation order of the FFCTO meets the test set out in the Legislation for the Principal Regulator to make the decision.

5. The decision of the Principal Regulator under the Legislation is that the FFCTO is partially revoked solely to permit the trades in securities of the Issuer (including for greater certainty, acts in furtherance of trades in securities of the Issuer) that are necessary for and are in connection with the Private Placement, provided that:

a) Prior to completion of the Private Placement, the Issuer will:

i) provide to each subscriber under the Private Placement a copy of the FFCTO;

ii) provide to each subscriber under the Private Placement a copy of this Order; and

August 20, 2020 (2020), 43 OSCB 6574

Decisions, Orders and Rulings

iii) obtain from each subscriber under the Private Placement a signed and dated acknowledgment, which clearly states that all of the Issuer’s securities, including the common shares and warrants issued in connection with the Private Placement will remain subject to the FFCTO, and that the issuance of a partial revocation order does not guarantee the issuance of a full revocation order in the future.

b) the Issuer will make available a copy of the written acknowledgements referred to in paragraph 5(a)(iii) to staff of the Principal Regulator on request;

c) the partial revocation order only varies the FFCTO order and does not provide an exemption from the prospectus requirement; and

d) this Order will terminate on the earlier of (A) the closing of the Private Placement and (B) 60 days from the date hereof.

DATED this 14th day of August, 2020.

“Lina Creta” Manager, Corporate Finance Ontario Securities Commission

August 20, 2020 (2020), 43 OSCB 6575

Decisions, Orders and Rulings

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August 20, 2020 (2020), 43 OSCB 6576

Chapter 3

Reasons: Decisions, Orders and Rulings

3.1 OSC Reasons

3.1.1 Joseph Debus

Citation: Debus (Re), 2020 ONSEC 20 Date: 2020-08-18 File No. 2019-16

IN THE MATTER OF JOSEPH DEBUS

REASONS FOR DECISION

Hearing: In writing Decision: August 18, 2020 Panel: M. Cecilia Williams Commissioner and Chair of the Panel Submissions Dalbir Kelley For Joseph Debus received from: Kathryn Andrews For Staff of the Investment Industry Regulatory Organization of Sally Kwon Canada Katrina Gustafson For Staff of the Ontario Securities Commission

REASONS FOR DECISION

I. OVERVIEW

[1] Joseph Debus has applied for a hearing and review of an Investment Industry Regulatory Organization of Canada (IIROC) decision,1 in which an IIROC panel found that Debus breached IIROC’s rules and imposed sanctions on him. There have been several appearances before the Ontario Securities Commission (the Commission) to determine dates of the hearing and for the exchange of materials by the parties in advance of the hearing.

[2] The hearing was scheduled to begin on July 29, 2020. On July 22, 2020, Debus sought an adjournment of the hearing until October 2020 and an extension of the timeline for filing his reply submissions, citing the continued unavailability of his counsel, Mark M. Persaud, due to health reasons. Debus provided a medical note from Persaud’s physician in support of his request (the Medical Note).

[3] On July 28, 2020, I ordered2 that:

a. the Medical Note be marked as confidential;

b. Debus serve and file written reply submissions, if any, by no later than September 22, 2020; and

c. the hearing be held by videoconference on September 29 and 30, 2020.

[4] I advised that my reasons for that decision would follow. These are my reasons.

II. HISTORY OF THE PROCEEDING

[5] On August 21, 2019, I scheduled the hearing for March 23 and 24, 2020, and ordered Debus to provide his hearing brief, witness summaries, if any, and written submissions (Materials) by January 17, 2020.

1 Debus (Re), 2019 IIROC 5; Debus (Re), 2019 IIROC 18 2 Debus (Re), (2020), 43 OSCB 6097

August 20, 2020 (2020), 43 OSCB 6577

Reasons: Decisions, Orders and Rulings

[6] On January 14, 2020, Debus requested a four-week extension to file his Materials due to his counsel’s unspecified health issues. I granted an extension, on consent of the parties, to February 14, 2020.

[7] At an attendance on February 24, 2020, Debus requested that I issue a summons to a third party for the delivery of certain documents. I asked the parties to provide written submissions with respect to that request.

[8] Because of the need for submissions on the summons issue, I extended the deadline for Debus to deliver his Materials to April 23, 2020, and adjourned the hearing to May 21 and 22, 2020 (the First Adjournment).

[9] Debus failed to serve and file his Materials by April 23, 2020. On April 24, 2020, again citing his counsel’s health issues, Debus requested a 60-day extension of the time to serve and file his Materials, a similar extension of the relevant timelines for service of materials by IIROC and Staff, and an adjournment of the hearing to September 2020.

[10] On May 8, 2020, I:

a. ordered that Debus serve and file his Materials by June 22, 2020 (60 days from the April 23, 2020, deadline);

b. granted extensions to IIROC and Staff for the service and filing of their materials to July 8, 2020 and July 15, 2020, respectively;

c. ordered that Debus serve and file any reply submissions by July 22, 2020; and

d. set July 29 and 30, 2020, as the dates for the hearing (the Second Adjournment).

III. ANALYSIS

A. Confidentiality of the Medical Note

[11] As a preliminary matter I address my decision to mark the Medical Note, which contained intimate personal information, as confidential.

[12] Counsel did not request that the Medical Note be marked as confidential. However, under Rule 22(4) of the Commission’s Rules of Procedure and Forms3 and subsection 2(2) of the Tribunal Adjudicative Records Act, 20194, a Panel may order an adjudicative record to be kept confidential, if it determines that “intimate financial or personal matters or other matters contained in the record are of such a nature that the public interest or the interest of a person served by avoiding disclosure outweighs the desirability of adhering to the principle that the record be available to the public.”5

[13] In my view, the objective of transparency is adequately served by the general description of the contents of the Medical Note in paragraph [22] below. Disclosure of the specifics would infringe on Persaud’s privacy for no good reason. I therefore concluded that Persaud’s interest in avoiding the disclosure of those specifics outweighs the desirability that the Medical Note be made available to the public. Therefore, I ordered the Medical Note to be marked as confidential.

B. Does Debus’s counsel’s continued unavailability warrant a further adjournment of this matter?

[14] The main issue I must decide is whether the fact that Debus’s counsel continues to be unavailable due to health reasons justifies a further adjournment of the hearing.

[15] Rule 29(1) of the Rules provides that every merits hearing shall proceed on the scheduled date unless the party requesting an adjournment “satisfies the Panel that there are exceptional circumstances requiring an adjournment.”

[16] The Commission has ruled that the standard set out in Rule 29(1) is a “high bar” that reflects the important objective set out in Rule 1, that Commission proceedings be conducted in a “just, expeditious and cost-effective manner”.6 This objective must be balanced against parties’ ability to participate meaningfully in the hearing and present their case.7

[17] The balancing of these objectives is necessarily fact-based and must take into account the circumstances of the parties and the manner in which they have conducted themselves in the proceeding.8

3 (2019) 42 OSCB 9714, r 22(4) (the Rules) 4 SO 2019, c 7, Sch 60 5 Tribunal Adjudicative Records Act, 2019, s 2(2)(b) 6 Pro-Financial Asset Management Inc (Re), 2018 ONSEC 18, (2018) 41 OSCB 3512 at para 28; Money Gate Mortgage Investment Corporation (Re), 2019 ONSEC 40, (2020) 43 OSCB 35 (Money Gate) at para 54 7 Money Gate at para 54 8 Money Gate at para 54

August 20, 2020 (2020), 43 OSCB 6578

Reasons: Decisions, Orders and Rulings

[18] Debus has already been granted an extension of the filing timelines in this matter and two adjournments. In my May 21, 2020 reasons for decision granting the Second Adjournment I assessed how the behaviour of the parties factored into my decision to grant that adjournment. I considered the timeline extension due to Debus’s counsel’s health issues to be a negative factor, while the First Adjournment was a neutral factor in my analysis.9

[19] In my May 21, 2020 reasons for decision I weighed the circumstances relating to the request for the Second Adjournment and I consider that request to be neutral with respect to my analysis of this request.

[20] The fact that Persaud was experiencing health issues was one of the circumstances that factored into my decision to grant the Second Adjournment.

[21] For the purposes of this request I have been provided with new evidence, the Medical Note. Up to this point, Persaud’s health issues had been unspecified.

[22] The Medical Note stated that Persaud is under active care for a condition that had recently worsened, and that he was, as a result, unable to participate in any prolonged matter that lasts more than a couple of hours. The Medical Note also indicated that the condition was unlikely to have sufficiently improved by the end of July to permit Persaud to return to his regular work functions.

[23] While both the Statutory Powers Procedure Act10 and the Rules provide that a party appearing before the Commission has the right to be represented by counsel, that right is not absolute.

[24] Limitations have been placed, in an administrative context, on the right of a party to be represented by counsel of choice. The right to be represented by counsel does not include the right of a party to insist on adjournments due to the unavailability of counsel, where such adjournments would unreasonably delay the course of the proceedings.11

[25] While Debus’s counsel’s health has been an issue for some months, the Medical Note provides specificity and makes clear that a hearing in July was not possible. An adjournment into late September should provide time for Persaud’s care to continue and for Debus to assess whether or not alternate arrangements may be necessary for the hearing to proceed as scheduled. I find that the circumstances meet the level of “exceptional” for the purposes of a further adjournment of this matter.

IV. CONCLUSION

[26] On July 28, 2020, I ordered that the Medical Note be marked as confidential, pursuant to subsection 2(2) of the Tribunal Adjudicative Records Act, 2019 and Rule 22(4) of the Rules.

[27] I also granted an extension of time for Debus to deliver reply submissions, if any, to September 22, 2020.

[28] The hearing is now scheduled to take place by videoconference on September 29 and 30, 2020, commencing at 10:00 a.m. on each scheduled day, or on such other dates or times as may be agreed to by the parties and set by the Office of the Secretary.

Dated at Toronto this 18th day of August, 2020.

“M. Cecilia Williams”

9 Debus (Re), 2020 ONSEC 13 at paras 24 to 26 10 RSO 1990, c S.22 11 Aseervatham v Canada (Minister of Citizenship and Immigration), [2000] FCJ No. 804 at para 16 cited in Re Hollinger Inc., 2006 ONSEC 2 at para 22

August 20, 2020 (2020), 43 OSCB 6579

Reasons: Decisions, Orders and Rulings

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August 20, 2020 (2020), 43 OSCB 6580

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 Permanent Date of Order Order Lapse/Revoke

THERE IS NOTHING TO REPORT THIS WEEK.

Failure to File Cease Trade Orders

Company Name Date of Order Date of Revocation King Global Ventures Inc. June 22, 2020 August 13, 2020

iAnthus Capital Holdings, Inc. June 22, 2020 August 14, 2020

4.2.1 Temporary, Permanent & Rescinding Management Cease Trading Orders

Company Name Date of Order Date of Lapse

THERE IS NOTHING TO REPORT THIS WEEK.

4.2.2 Outstanding Management & Insider Cease Trading Orders

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

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

Company Name Date of Order Date of Lapse

RYU Apparel Inc. 17 June 2020

August 20, 2020 (2020), 43 OSCB 6581

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August 20, 2020 (2020), 43 OSCB 6582

Chapter 5

Rules and Policies

5.1.1 Start-up Crowdfunding Guide for Businesses

Start-up Crowdfunding Guide for Businesses

Crowdfunding is a process through which an individual or a business can raise small amounts of money from a large number of people, typically through the Internet. The objective is to raise sufficient funds in order to carry out a specific project. There are different types of crowdfunding, such as by donation, pre-selling of products or securities crowdfunding. This guide discusses securities crowdfunding.

Securities crowdfunding

With securities crowdfunding, a business raises funds through the Internet by issuing securities (such as bonds or shares) to many people. This type of crowdfunding is overseen by the regulator of the province or territory where the business and potential purchasers are located.

Valérie has a brilliant idea. She has developed a soft drink flavoured with maple syrup and other local products. She has prepared a detailed business plan and hopes to turn a profit from her business venture. She thinks there is a market for maple soft drinks in gourmet grocery stores, bars and restaurants. She wants to begin production. She needs $75,000 in order to bottle and market her soft drinks. She applied to a financial institution for a loan, but was refused. She is thinking about raising the funds she needs by issuing shares through a securities crowdfunding campaign.

Legal Obligations

In Canada, all trading of securities is subject to legal obligations. For example, a business seeking to raise capital by issuing securities must file a prospectus with the securities regulator of their province or territory or have an exemption from the prospectus requirement under securities law.

These obligations, however, can be costly for start-ups and early stage businesses. The securities regulators in British Columbia, Alberta, Saskatchewan, Manitoba, Ontario, Québec, New Brunswick and Nova Scotia (the participating jurisdictions) allow start-ups and small businesses (issuers) to raise funds using securities crowdfunding without filing a prospectus or preparing financial statements. In this guide, we refer to this as the “start-up crowdfunding exemptions” or “start-up crowdfunding.”

Start-up crowdfunding allows a start-up or early stage issuer to raise relatively small amounts of capital by distributing securities to investors without filing a prospectus (start-up prospectus exemption).

A funding portal is permitted to facilitate trades of those securities without having to register as a dealer (start-up registration exemption). In all participating jurisdictions, a funding portal can also be operated by a registered dealer.

The purpose of this guide is to assist issuers intending to raise funds by relying on the start-up prospectus exemption. In this guide, “regulator” means the securities regulator or regulatory authority in a participating jurisdiction.

August 20, 2020 (2020), 43 OSCB 6583

Rules and Policies

How Start-up Crowdfunding Works

In order to raise funds using the start-up prospectus exemption, issuers must prepare and post an offering document on a funding portal’s crowdfunding website. Investors will then be able to read about the offering and decide whether to invest. Before investing, investors will have to confirm that they have read the offering document and understood that the investment is risky.

When should an issuer consider start-up crowdfunding?

Before launching a start-up crowdfunding campaign, the management of the issuer should:

• Evaluate other sources of funding, such as a loan from a financial institution

• Assess whether they are willing to invest the time and efforts needed to prepare and run a start-up crowdfunding campaign

• Determine the type and characteristics of securities that will be sold

• Determine the number of securities to be sold and at what price

• Assess if they have the capabilities to manage a great number of security holders

If a start-up crowdfunding campaign is successful, the founders of the issuer may have to give up part of the ownership of the issuer to investors. The issuer will also need to be accountable to investors. Investors will expect to be informed about successes and failures of the issuer’s business. Management of the issuer should assess whether they are willing to spend the time and effort to maintain contact with investors.

The start-up prospectus exemption is not available to reporting issuers. Reporting issuers are companies that are required to make continuous disclosure to the public of their business activities by filing financial statements and other documents as required by securities legislation. These types of issuers are considered to be more established than the start-up or early stage issuers that are permitted to use start-up crowdfunding.

Where is start-up crowdfunding available?

The start-up prospectus exemption is only available to issuers that have a head office located in one of the participating jurisdictions (British Columbia, Alberta, Saskatchewan, Manitoba, Ontario, Québec, New Brunswick or Nova Scotia). In addition, the investor must be a resident in one of the participating jurisdictions.

If an issuer wants to raise funds in a participating jurisdiction, the issuer will want to make sure that the funding portal they choose is also operating in that participating jurisdiction.

August 20, 2020 (2020), 43 OSCB 6584

Rules and Policies

What is the maximum amount that can be raised? Are there any time limitations for raising that amount?

$250,000 per start-up crowdfunding distribution.

The offering document must indicate a minimum amount that has to be raised before the offering can close. The issuer has a maximum of 90 days to raise the minimum amount, starting on the day the issuer’s offering document is first made available to investors through a funding portal’s website.

The money will be held in trust by the funding portal until the minimum amount of the offering is reached. The issuer may then complete the offering by issuing the securities.

If the minimum amount is not reached, or the start-up crowdfunding campaign is withdrawn, the funding portal must return the money to the investors.

How often can an issuer raise money using start-up crowdfunding?

An issuer group may complete a maximum of two start-up crowdfunding distributions per calendar year. The issuer group cannot have more than one start-up crowdfunding campaign running at the same time or on different funding portals for the same purpose. The issuer group must wait until the first campaign has ended before launching a second one.

The “issuer group” means the issuer, any affiliates of the issuer and any other issuer that is engaged in a common enterprise with the issuer or an affiliate, or whose business is founded or organized by the same person or company who founded or organized the issuer.

What is the maximum amount an issuer can raise from each investor?

$1,500 per start-up crowdfunding distribution. However, this amount can be increased to $5,000 if:

• the investor resides in British Columbia, Alberta, Saskatchewan or Ontario;

• the issuer has a head office in British Columbia, Alberta, Saskatchewan or Ontario;

• the start-up crowdfunding distribution is made through a registered dealer; and

• the dealer has determined that the investment is suitable for the investor.

The issuer may require a minimum amount per investor (e.g. $500).

Compliance with the start-up prospectus exemption

Although each of the participating jurisdictions has their own Start-up Crowdfunding order, the start-up crowdfunding prospectus exemption in each order is substantially harmonized with the other participating jurisdictions.

Nevertheless, the issuer must ensure that they are in compliance with the order in each participating jurisdiction where they are raising funds. Please check the applicable order which can be found on the regulator’s website.

If an issuer does not meet the conditions of the start-up prospectus exemption, then it can no longer rely on that exemption to raise money from investors.

Launching a Start-up Crowdfunding Campaign

Once an issuer has determined that it will launch a start-up crowdfunding campaign, it will need to prepare an offering document and choose a funding portal to post its offering document. Issuers are required to prepare the offering document using Form 1 Start-up Crowdfunding – Offering Document.

What is a funding portal?

A funding portal lists start-up crowdfunding campaigns on its website and facilitates the payment of the purchase price from the investor to the issuer. Funding portals will generally charge issuers for hosting a start-up crowdfunding campaign.

The funding portal is responsible for:

• Providing a risk warning form to potential investors

• Holding all investor funds in trust until the issuer raises the minimum funding target

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• Returning funds to investors, without deduction, if the issuer does not reach its minimum funding target or if the issuer withdraws the start-up crowdfunding campaign

Please refer to the Start-up Crowdfunding Guide for Funding Portals for more information on funding portal requirements for the different types of funding portals.

What types of funding portals are available?

There are two types of funding portals that may facilitate start-up crowdfunding in Ontario:

• funding portals that are operated by registered investment dealers or exempt market dealers that must provide advice on suitability of the investment to investors, and

• funding portals that are operated by persons relying on the start-up registration exemption and that cannot provide suitability advice.

The issuer has the choice of which type of funding portal to use for its start-up crowdfunding campaign.

A funding portal operated by an investment dealer or exempt market dealer must confirm in writing to the issuer that it can provide certain services necessary for start-up crowdfunding, including that it will make the offering document and risk warnings available to the purchaser through its website. The issuer may also check with a regulator to determine whether the funding portal is authorized to operate in jurisdictions that it proposes to conduct start-up crowdfunding. The contact information for the participating jurisdictions can be found at the end of this guide. In addition, the issuer may want to evaluate other aspects of the funding portal’s business, such as finding out about the individuals operating the funding portal, how it handles the funds collected from investors, what participating jurisdiction the funding portal is operating in, and what fees it will charge the issuer for posting its start-up crowdfunding offering document.

What information needs to be in the offering document?

The offering document must include basic information about the business and the offering, how it will use the money and any risk to the project. The offering document must also include the minimum amount needed to be raised to accomplish the issuer’s business goals.

The information contained in the offering document must be kept up to date throughout the duration of the start-up crowdfunding campaign. If information contained in the offering document is no longer true, the issuer must amend the offering document as soon as practicable and send the new version to the funding portal. The funding portal will post the new version of the offering document on its website and will notify investors about the amendment.

The offering document does not need to be updated after the start-up crowdfunding campaign is over.

If the issuer raises funds in Québec, the offering document and the risk acknowledgement form must be made available to investors in Québec in French or in French and English.

For additional details on the offering document, including instructions on how to prepare this document, please refer to “Preparing an Offering Document” below.

What if an investor changes their mind?

Investors have the right to withdraw their investment within 48 hours following the investor’s subscription. Investors also have the right to withdraw their investment within 48 hours of the funding portal notifying the investor of an amendment to an offering document.

To exercise this right of withdrawal, investors must notify the funding portal. The funding portal must give investors the opportunity to exercise this right. The funding portal must return the funds to an investor who exercises this right, without any deduction, within five business days after the notice.

Completing a Start-up Crowdfunding Campaign

Once the minimum amount has been raised, the issuer has the discretion to close the start-up crowdfunding campaign by issuing the securities to investors. However, the issuer must wait until each investor’s 48-hour withdrawal period has expired.

If the issuer has disclosed in the offering document what it will do with any extra funds raised above the minimum amount, then the issuer can continue raising funds provided the issuer closes the offering within the 90-day maximum offering period and up to the maximum amount indicated in the offering document. This maximum amount cannot be more than $250,000.

At the closing of the distribution, the funding portal releases the funds raised to the issuer.

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Can an issuer use another prospectus exemption to meet the minimum amount?

Although an issuer cannot have two start-up crowdfunding campaigns running at the same time or on more than one funding portal, the issuer can raise funds using other prospectus exemptions during a start-up crowdfunding campaign. For example, the issuer may issue securities to an accredited investor. Other prospectus exemptions, such as the accredited investor exemption, are found in the instruments and rules of the local regulator, including National Instrument 45-106 Prospectus Exemptions. The funds raised under other prospectus exemptions can be used to reach the minimum amount stated in the offering document if they are unconditionally available to the issuer. This would not trigger the requirement to amend the offering document by the issuer.

Valérie’s objective is to raise a minimum of $75,000. Through the funding portal, she raised $45,000 from investors under the start-up crowdfunding exemption. At the same time, Paul, who is considered to be an “accredited investor” because of his income and assets, unconditionally undertakes to invest $30,000 in Valérie’s enterprise. The minimum amount has been reached because Valérie can include Paul’s $30,000 investment as part of the start-up crowdfunding offering minimum amount. By including this amount, Valérie would not have to amend her start-up offering document. Valérie can now close her start-up crowdfunding distribution and ask the funding portal to release the $45,000 raised on its crowdfunding website as soon as the 48-hour withdrawal period has expired for all investors.

If an issuer raises funds under other prospectus exemptions, it must comply with the start-up crowdfunding exemptions and the legal requirements of the other exemptions. An issuer should seek professional advice if it has any questions regarding compliance. After the closing

Filing of the offering document and report of exempt distribution

The offering document and a report of exempt distribution must be filed with the regulator of each participating jurisdiction where investors are located no later than 30 days after the closing of the distribution. For example, if the issuer has raised money in Ontario and Québec, the offering document and report of exempt distribution must be filed with the Ontario Securities Commission and the Autorité des marchés financiers.

When filing the offering document, the issuer must include all copies of the offering document, including any amended versions.

In addition, the offering document and report of exempt distribution must be filed with the regulator of the participating jurisdiction where the issuer’s head office is located, even if no investors were located in this jurisdiction.

The issuer must follow the filing requirements of the applicable participating jurisdiction(s) as indicated in the table below:

Participating Jurisdiction Filing requirements

British Columbia What to file: • Form 1 Start-up Crowdfunding - Offering Document • Form 45-106F1 Report of Exempt Distribution How to file: • Electronically via BC’s eServices website (https://eservices.bcsc.bc.ca/). When submitting a report of exempt distribution for a start-up crowdfunding distribution, there will be an option to attach the offering document.

Manitoba What to file: New Brunswick • Form 1 Start-up Crowdfunding - Offering Document Nova Scotia • Form 5 Start-up Crowdfunding - Report of Exempt Distribution Québec o Schedule 1 to Form 5 Start-up Crowdfunding – Purchaser Information Saskatchewan How to file: • Electronically through SEDAR, in accordance with National Instrument 13-101 System for Electronic Document Analysis and Retrieval (SEDAR) The Canadian Securities Administrators (CSA) has information regarding the SEDAR filing requirements. Please see: • CSA Staff Notice 13-323 – Frequently Asked Questions About Making Exempt Market Offering and Disclosure Filings on SEDAR • CSA website on Reports of Exempt Distribution contains links to the reports for start-up crowdfunding prospectus exemption for SEDAR filing

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Alberta What to file: • Form 1 Startup Crowdfunding – Offering Document • Form 45-106F1 Report of Exempt Distribution How to file: • See instructions for Manitoba, New Brunswick, Nova Scotia, Québec and Saskatchewan, above.

Ontario What to file: • Form 1 Start-up Crowdfunding - Offering Document • Form 45-106F1 Report of Exempt Distribution How to file: • Electronically through the OSC Electronic Filing Portal at https://www.osc.gov.on.ca/filings

Different filing requirements

An issuer may be subject to different filing requirements if they are required to file documents in Ontario and in any of the other participating jurisdiction(s).

Valérie’s brilliant idea raised $55,000 through start-up crowdfunding. She raised the following funds from investors: $10,000 in Ontario, $10,000 in Québec, $12,000 in New Brunswick, and $23,000 in British Columbia.

To meet her filing requirements, Valérie will need to file:

• the Form 1 and Form 45-106F1 electronically through the OSC Electronic Filing Portal at https://www.osc.gov.on.ca/filings;

• the Form 1 and Form 5 electronically through SEDAR (she indicates on SEDAR that she is filing for both Québec and New Brunswick); and

• the Form 1 and Form 45-106F1 electronically via BC’s eServices website (https://eservices.bcsc.bc.ca/).

Confirmation notice to investors

Within 30 days after the closing of the distribution, the issuer must send a confirmation notice to each investor who purchases securities with the following information:

• The date of subscription and the closing date of the distribution

• The quantity and description of securities purchased

• The price paid per security

• The total commission, fee and any other amounts paid by the issuer to the funding portal in respect of the start-up crowdfunding distribution

Preparing an Offering Document

Issuers are responsible for preparing an offering document that investors will read to determine if they want to invest in that issuer. The offering document must be prepared using Form 45-506 F1 Start-up Crowdfunding – Offering Document. The issuer must provide information for each of the items in the form.

The following will help issuers complete certain items of the offering document and should be read together with the form.

Item 2: The issuer

2.1 (a) The organizing documents are the issuer’s articles of incorporation, limited partnership agreement or other similar documents.

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(b) The head office is generally where the people managing the issuer, including the CEO, maintain their offices. This may be the same address, or different from the registered office address, depending on the legal structure of the corporation. The address of the head office should be a physical address and not be a P.O. Box.

Item 4: Management

4.1 The people named here are important for investors to assess if they want to invest in the issuer. These people should preferably have experience in managing a business, or in the same industry as the issuer.

Director: An individual occupying the position of director with the issuer. If the issuer is a limited partnership, information should also be provided for the directors of the general partner.

Officer: Includes the chief executive officer, president, vice-president, corporate secretary, general manager or any other individual who performs functions of officer for the issuer. If the issuer is a limited partnership, information should also be provided for the officers of the general partner.

Promoter: A person who takes the initiative in founding or organizing the issuer is generally considered a promoter of the issuer.

Control person: A person that holds more than 20% of the voting rights, alone or with other persons acting in concert, is generally considered a control person of the issuer.

4.2 If any of the persons listed in item 4.1 is or has been subject to any of the proceedings described in item 4.2, state this fact. Provide the name of the person involved and enough details on the time, nature and the outcome of the proceedings.

A quasi-criminal offence may include offences under the Income Tax Act (R.S.C. 1985, c. 1 (5th Suppl.)), the Immigration and Refugee Protection Act (R.S.C., 2001, c. 27) or the tax, immigration, drugs, firearms, money laundering or securities legislation of any province or territory of Canada or foreign jurisdiction.

Item 5: Start-up crowdfunding distribution

5.1 The issuer must provide the offering document to a funding portal. The funding portal must make the offering document available on its website before the issuer can begin to raise money. If the issuer is using a funding portal that is operated by a registered dealer, it must provide the name of the registered dealer in addition to the name of the funding portal. The offering document can only be posted on one funding portal.

5.3 (a) A start-up crowdfunding distribution is not allowed to close if the minimum offering amount has not been reached within 90 days. The offering document will be posted on the funding portal’s website on the date agreed to by the issuer and the funding portal.

(b) During the offering period, the issuer must immediately amend the offering document if the information that it contains is no longer true. Provide the date the amended offering document is posted on the funding portal’s website and a description of the information that was amended. If the offering document is amended, the issuer must not modify the date in (a). Investors will have the right to withdraw their subscription within 48 hours of the funding portal notifying the investor that the offering document has been amended.

If the offering document has not been amended, (b) is not applicable.

5.5 The issuer must tell investors what rights are attached to the securities described in item 5.4, if any. This information is usually found in the organizing documents referred to in item 6.3.

5.6 The restrictions and conditions to be described here are generally found in shareholder’s agreements or limited partnership agreements.

A tag-along right is a contractual obligation used to protect minority shareholders. The right assures that if the majority shareholder sells his stake, minority shareholders have the right to join and sell their securities on the same terms and conditions as would apply to the majority shareholder.

A drag-along right is designed to protect a majority shareholder. A drag-along right enables a majority shareholder to force minority shareholders to join in the sale of a company, by giving the minority shareholders the same price, terms, and conditions as any other seller.

A pre-emptive right is the right of existing shareholders to acquire new shares issued by the issuer. It can allow existing shareholders to maintain their proportional ownership of the issuer, preventing stock dilution.

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5.7 The issuer must set a minimum amount to be raised before it can close a start-up crowdfunding distribution. The maximum amount cannot exceed $250,000.

The amount raised needs to be equal to the total number of securities the issuer wishes to issue multiplied by the price per security.

5.8 The issuer has the option to set a minimum investment amount per investor. This amount cannot be over $1,500. If the issuer does not wish to set a minimum investment amount, item 5.8 should be left blank. The minimum investment amount per investor cannot be below the price per security.

Item 6: Issuer’s business

6.1 The description of the issuer’s business is a very important part of the offering document. Enough details should be provided for an investor to clearly understand what the issuer does, or intends to do. Consideration should be given to the following:

• What makes the issuer’s business special and different from other competitors in the industry?

• What milestones has the issuer already reached?

• Where does the issuer see its business in three, five and ten years?

• What are the issuer’s future plans and hopes for its business and how does it plan to get there?

• What is the issuer’s management experience in running a business or in the same industry?

6.2 Indicate whether the issuer is a corporation, a limited partnership, a general partnership or other. Also, indicate the province, territory or state where the issuer is incorporated or organized.

6.3 Specify where investors can review the issuer’s organizing documents. Online access to these documents is convenient for investors.

6.5 The issuer is not required to provide financial statements to investors in connection with a start-up crowdfunding distribution. However, many investors use financial statements to assess and compare investment opportunities and may be reluctant to invest in a business that does not provide this type of information.

The issuer can choose to make financial statements available to investors. If so, it must include the statement provided in item 6.5 in the offering document. The issuer may want to post the financial statements on the issuer’s website for the convenience of its investors.

The issuer should not, however, include the financial statements with or provide a link to the financial statements in the offering document. If the issuer chooses to include the financial statements or a link in the offering document, there may be an obligation under securities laws to prepare the financial statements using certain accounting principles and to audit the financial statements using certain auditing standards.

Item 7: Use of funds

7.1 If the issuer has previously raised funds, specify for which purpose they were used. Include enough details so an investor can clearly understand:

• How much money the issuer has already raised

• How the issuer raised it

• What prospectus exemption was used

• How has that money been used

If the issuer has not previously raised funds, state this fact.

7.2 The issuer must tell investors what it will do with the money raised from this start-up crowdfunding distribution by providing enough details to allow investors to make a reasoned investment decision. Incomplete or unrealistic information will not help the issuer raise more money. Therefore, the issuer should make sure its plans are realistic and achievable.

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Item 8: Previous start-up crowdfunding distributions

8.1 Provide the information listed under item 8.1 if any of the persons listed in item 4.1 have been involved in a start-up crowdfunding distribution in any of the participating jurisdictions in the past five years, whether with the issuer, or with another issuer.

Item 9: Compensation paid to funding portal

9.1 Describe the fees (e.g., commission, arranging fee or other fee) that the funding portal is charging for its services. Describe each type of fee and the estimated amount to be paid for each type. If a commission is being paid, indicate the percentage that the commission will represent of the gross proceeds of the offering (assuming both the minimum and maximum offering).

Item 10: Risk factors

10.1 Explain the risks of investing in the issuer for the investor in a meaningful way, avoiding overly general or “boilerplate” disclosure. Disclose both the risk and the factual basis for it. Risks can relate to the issuer’s business, its industry, its clients, etc.

Issuers should be truthful, reasonable and clear. Investors deserve to be able to make a reasoned decision based on all the information, even the downside. Issuers may indicate how they plan to mitigate these risks, but should not de- emphasize the risks by including excessive caveats or conditions.

Item 11: Reporting obligations

11.1 Tell investors how the issuer will keep them informed about the business and their investment.

The regulator does not require that the issuer report to investors, but investors will want to be kept informed. If the issuer fails to do this, it may create disgruntled investors that can make it difficult for the issuer to raise money in the future.

Setting out a reasonable reporting plan is important. Issuers should make sure the plan is realistic. Reporting doesn’t have to be complex or costly. Reporting can be through newsletters, social media sites, e-mail, financial statements or similar documents. Issuers should go over the milestones that have been met, confirm how investors’ money was used, and discuss future plans.

Where can I get further information?

For more information about the start-up crowdfunding exemptions in the participating jurisdictions, please refer to the following contact information:

British Columbia British Columbia Securities Commission Telephone: 604-899-6854 or 1-800-373-6393 E-mail: [email protected] www.bcsc.bc.ca

Alberta Alberta Securities Commission Telephone: 403-355-4151 E-mail: [email protected] www.albertasecurities.com

Saskatchewan Financial and Consumer Affairs Authority of Saskatchewan Securities Division Telephone: 306-787-5645 E-mail: [email protected] www.fcaa.gov.sk.ca

Manitoba The Manitoba Securities Commission Toll free in Manitoba: 1-800-655-2548 E-mail: [email protected] www.msc.gov.mb.ca

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Ontario Ontario Securities Commission Toll free: 1-877-785-1555 E-mail: [email protected] www.osc.ca

Québec Autorité des marchés financiers Direction du financement des sociétés Toll free in Québec: 1-877-525-0337 E-mail: [email protected] www.lautorite.qc.ca

New Brunswick Financial and Consumer Services Commission Toll free: 1-866-933-2222 E-mail: [email protected] www.fcnb.ca

Nova Scotia Nova Scotia Securities Commission Toll free in Nova Scotia: 1-855-424-2499 E-mail: [email protected] www.nssc.novascotia.ca

The information in this Guide is for educational purposes only and does not constitute legal advice.

If any information in this Guide is inconsistent with Ontario Instrument 45–506 Start-Up Crowdfunding Registration and Prospectus Exemptions (Interim Class Order), please follow the instrument and the related forms.

Published August 20, 2020.

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5.1.2 Start-up Crowdfunding Guide for Funding Portals

Start-up Crowdfunding Guide for Funding Portals

Crowdfunding is a process through which an individual or a business can raise small amounts of money from a large number of people, typically through the Internet. The objective is to raise sufficient funds in order to carry out a specific project. There are different types of crowdfunding, such as by donation, or pre-selling of products, and securities crowdfunding. This guide discusses securities crowdfunding.

Securities crowdfunding

In Canada, all trading of securities is subject to legal obligations. For example, a person cannot be in the business of trading securities unless the person is registered in the province or territory where it is carrying on this business or has an exemption from the registration requirement under securities laws. Similarly, a business seeking to raise capital by issuing securities must file a prospectus with the securities regulator of their province or territory or have an exemption from the prospectus requirements under securities laws.

These obligations, however, can be costly for start-ups and early stage issuers. The securities regulators in British Columbia, Alberta, Saskatchewan, Manitoba, Ontario, Québec, New Brunswick and Nova Scotia (the participating jurisdictions) have made available exemptions to facilitate securities crowdfunding (the start-up crowdfunding exemptions) to help make it easier for start-ups and early-stage businesses to raise money by issuing securities.

The start-up crowdfunding exemptions allow:

• a start-up or early stage issuer to raise relatively small amounts of capital by distributing securities to investors without filing a prospectus (the start-up prospectus exemption); and

• a funding portal to facilitate trades of those securities without having to register as a dealer (the start-up registration exemption), although a funding portal can be operated by a registered dealer.

Start-ups and early stage issuers intending to conduct a start-up crowdfunding offering must use a funding portal. A funding portal posts information about investment opportunities and facilitates the payment of the purchase price from the investor to the issuer.

The purpose of this guide is to assist funding portals. In this guide, “regulator” means the securities regulator or regulatory authority in a participating jurisdiction.

There are two types of funding portals that may facilitate start-up crowdfunding:

• funding portals operated by persons relying on the start-up registration exemption

• funding portals operated by registered investment dealers or exempt market dealers

Funding portals operating under the start-up registration exemption

A person operating a funding portal does not have to register as a dealer if they meet all conditions of the start-up registration exemption. These conditions include, among other things, that the funding portal must:

• have its head office in Canada

• have a majority of its directors be Canadian residents

• not be registered under Canadian securities legislation

• not tell investors an investment is suitable for them or otherwise discuss the merits of an investment

o This means the funding portal cannot tell an investor that the securities offered are a good investment or that the investor should make an investment for whatever reason. The funding portal must refrain from saying or doing anything that might lead an investor to think that they should buy the securities because the securities somehow meet their investment needs or objectives.

o However, the funding portal can give factual information about the securities. For example, it may tell investors about the features of the securities, the risks of the investment, how start-up crowdfunding works, and other items of a general, factual nature.

• must make available the issuers’ offering documents and risk warnings on its website

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o A funding portal can carry out reviews of issuers before making their offering documents available on its website to protect the funding portal’s own interests or reputation.

o Funding portals may want to be mindful that their website could be used in ways not intended by the funding portal. For example, peer-to-peer messaging systems on a funding portal’s website might be used by the funding portal’s visitors to solicit the purchase and sale of other securities without the portal’s knowledge. This may result in the funding portal indirectly facilitating illegal securities distributions.

• ensure that investors confirm online, by ticking a box, that they have read and understood the offering document and risk warning available on the funding portal

• take reasonable measures to ensure that the head office of each issuer using the funding portal is in a participating jurisdiction and that each investor is a resident of a participating jurisdiction

• not allow entry to its website by any person until that person acknowledges that they are entering a website of a funding portal:

o that is not operated by a registered dealer under Canadian securities legislation, and

o that will not provide advice about the suitability or the merits of any investment

the regulators call this the “pop-up acknowledgement”. For further information on the mechanics of the pop- up acknowledgement, please see the section in this guide entitled Pop-up Acknowledgement

• not receive a commission or fee from an investor

• discloses on its website:

o the full legal name, municipality and jurisdiction of residence, business mailing and e-mail address, and business telephone number of each promoter,1 director, officer and control person2 (principals) of the funding portal, and

o the names of the participating jurisdictions where the funding portal is operating and relying on the start-up registration exemption

. Each of the participating jurisdictions has their own Start-up Crowdfunding Exemptions order (blanket order). With some exceptions, each blanket order is substantially harmonized with the other participating jurisdictions. However, the funding portal must ensure that they are in compliance with the blanket order in each participating jurisdiction where they are operating. Please check the applicable blanket orders which can be found on the regulators’ website.

The regulators expect that these disclosures will be prominently displayed on the funding portal’s website

• hold investors’ assets separate from the funding portal’s property, in trust for the investor and, in the case of cash, at a Canadian financial institution

o This requirement is a fundamental obligation of the start-up registration exemption. Funding portals should expect that regulators will assess how the funding portal is handling client assets at both the initial stage and during future compliance reviews. The regulators intend to ensure that these conditions are followed closely.

• keep its books and records, including its compliance procedures, at its head office for eight years from the date a record is created

• not facilitate the distribution of securities to purchasers under prospectus exemptions other than the start-up prospectus exemption.

1 A person who founded, organized or significantly reorganized the funding portal is generally considered to be a promoter. 2 A person who holds a sufficient number of voting rights to control the funding portal or who holds 20% or more of the voting rights of the funding portal is generally considered a control person of the funding portal.

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In Ontario, an unregistered funding portal must also disclose on its website the process the funding portal will use to notify purchasers if it becomes insolvent or discontinues operations, and how the funding portal will return the purchasers’ assets it is holding to those purchasers.

Before starting operations

Step one

A funding portal intending to rely on the start-up registration exemption must deliver the following forms to regulators:

• a completed Form 3 – Start-up Crowdfunding - Funding Portal Information Form (Form 3)

• a completed Form 4 – Start-up Crowdfunding - Funding Portal - Individual Information Form (Form 4) for each principal of the funding portal

• any other completed documents and any additional information that may be requested by the regulators

Submitting the following documents to the regulators with the Form 3 may help expedite the process:

• business plans and financial statements, if the funding portal intends to facilitate start-up crowdfunding distributions in Québec

• organizing documents such as articles and certificate of incorporation or partnership agreement if the funding portal intends to facilitate start-up crowdfunding distributions in Saskatchewan, Manitoba, Ontario, Québec, or Nova Scotia

• business registration numbers and proof of extra-provincial registration if the funding portal intends to facilitate start-up crowdfunding distributions in Saskatchewan, Manitoba, Ontario, Québec, or Nova Scotia

• documents describing the funding portal’s process and procedure for handling investors’ funds, including the following details:

o the name of the Canadian financial institution where the trust account for investors’ cash is located

o the name of the signatories on that trust account and their role with the funding portal

o how the investors’ assets will be kept separate and apart from the funding portal’s assets

o how the cash will flow from: (i) the investors to the funding portal’s trust account; (ii) from the funding portal’s trust account back to the investors’ bank accounts in the event that the offering does not close; and (iii) from the funding portal’s trust account to the issuer in the event that the offering does close

• a copy of the trust agreement for the funding portal’s trust account with a Canadian financial institution or details surrounding the establishment of this account

The regulators may also request access to the funding portal’s website in a test environment when the website is complete and ready for viewing.

The funding portal must deliver the forms and documents by e-mail to the regulator in each participating jurisdiction where the funding portal intends to facilitate start-up crowdfunding distributions. For example, a funding portal with a head office in Saskatchewan that intends to seek funds from investors in all participating jurisdictions must deliver the forms and documents described in this guide to the Financial and Consumer Affairs Authority of Saskatchewan and the regulators in each of the other participating jurisdictions.

Delivery of the forms, and documents by the funding portal is only the first step and does not mean that the funding portal can start operations. The regulators may have questions for the funding portal regarding these forms and documents.

Step two

Before starting operations, the funding portal must receive written confirmation from the regulator that the forms and documents delivered to the regulator in step one are complete.

Please note that the regulator may notify the funding portal that it cannot use the start-up registration exemption because its principals, or their past conduct, demonstrate a lack of integrity, financial responsibility or relevant knowledge or expertise. (In

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Ontario, the regulator will make this assessment based on the criteria set out in the registration exemption in the Ontario Blanket Order, Ontario Instrument 45-506 Start-Up Crowdfunding Registration and Prospectus Exemptions (Interim Class Order)).

If a change occurs and the information in the forms and documents delivered to a regulator are no longer up-to-date, the funding portal must update the information by delivering a new form or document setting out the change. For example, if management at a funding portal changes, an updated funding portal information form as well as a funding portal individual information form for each new officer must be delivered to the regulators.

In Ontario, an unregistered funding portal must file the Form 3, Forms 4 and supporting documents and then wait 30 days before soliciting investors. During the 30-day waiting period the regulator may notify the funding portal that it has not satisfied the start-up registration exemption and cannot operate as an exempt funding portal until such time as the funding portal is able to demonstrate it meets the conditions of the start-up registration exemption. Some of the reasons this notification may be given include:

• the documents the funding portal delivered are incomplete,

• the funding portal or any of its principals, or any entity it or its principals has been the principal of has had a judgment, sanction or similar order imposed against it based on fraud, theft, breach of trust, insider trading, or allegations of similar conduct, or

• the policies and procedures for handling funds in relation to a start-up crowdfunding distribution described in the funding portal information form and supporting documents does not satisfy the conditions of the start-up registration exemption.

Compliance with laws and regulations

The funding portal’s activities are subject to the securities laws of the jurisdictions where its head office or other places of business are located, as well as the jurisdictions where the issuers and purchasers are resident.

If a funding portal intending to rely on the start-up registration exemption has its head office located in a jurisdiction where that exemption is not available then the funding portal may be required to be registered as a dealer. Once registered as a dealer in any jurisdiction then the start-up registration exemption is no longer available (see later section on Funding portals operated by registered dealers).

Failing to comply with local securities laws is a serious offence that could prevent the funding portal from being able to rely on the start-up registration exemption. The funding portal must also ensure that it complies with all other applicable laws and regulations of a participating jurisdiction. We encourage funding portals to consult a lawyer for advice.

Regulators in the participating jurisdictions plan to conduct compliance reviews of funding portals relying on the start-up registration exemption soon after the commencement of operations. If a funding portal does not meet the conditions of the start- up registration exemption, then it cannot rely on that registration exemption.

In Ontario, an unregistered funding portal must certify, within ten days of a calendar year-end, that it has sufficient working capital to continue its operations for at least the next 12 months. This is done by filing the necessary Form 5 with the Ontario Securities Commission. A funding portal’s working capital is calculated based on current assets less current liabilities. The terms “current assets” and “current liabilities” are defined under Canadian GAAP. Current assets generally include assets such as cash, accounts receivable, inventory and other assets that can be realised, sold or consumed within a year. Current liabilities generally include accounts payable, wages, taxes, and the portion of debt to come due within a year. Good practices for compliance with this condition include:

• Keeping documentation that is regularly maintained to ensure effective monitoring; and

• Establishing, maintaining and applying a system of controls and supervision sufficient to ensure the accuracy of the documents, including financial statements, used to support the funding portal’s assessment of working capital.

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“Pop-up" Acknowledgement The start-up crowdfunding exemptions require investors to acknowledge certain information before entering the platform of a funding portal, which may be the funding portal’s website or app. This requirement does not distinguish between where or how the investor enters the funding portal’s platform. As a result, funding portals must design their platform so that investors acknowledge the required information regardless of whether those investors enter the platform through the funding portal’s home page or through another page on the funding portal’s website.

The funding portal should also manage the risk that potential investors are visiting the funding portal’s platform using a shared computer, tablet, or other mobile device. In other words, multiple people in a household may be entering the funding portal’s platform at different times using the same device. As a result, in order to comply with the pop-up acknowledgment requirements, the funding portal should consider designing their website so that the required pop-up acknowledgements reappear each time the investor’s internet browser is closed and re-opened.

We expect the pop-up acknowledgement to appear in the following circumstances:

The pop-up acknowledgement should appear upon the first and every subsequent time a person enters a funding portal’s website. This means that after opening their internet browser: (a) If a person lands on any page of a funding portal’s platform (home page or other page) the pop-up acknowledgment should appear. (b) If the person clicks "I acknowledge" and then immediately closes out of their browser, when the person goes back to any page on a funding portal’s platform, the pop-up acknowledgment should appear. The result is that the same person will have to click on "I acknowledge" to go back into the funding portal’s platform regardless of the fact that they had just been to that platform.

The pop-up acknowledgement should appear regardless of a person’s entry point to the platform (home page or other page). For example: (c) If a person were to search the name of the funding portal and finds a link to the funding portal’s platform, the link would take the person to the funding portal’s home page and a pop-up acknowledgement would appear. (d) If a person were to search the name of the funding portal and finds a link to the funding portal’s issuer-offering page, the link would take the person to that page of the funding portal’s platform and a pop-up acknowledgement would appear.

Once a person clicks “I acknowledge” and enters the funding portal’s platform, they can navigate from page to page within the platform without the re-appearance of the pop-up acknowledgement.

Funding portals operated by registered dealers Registered exempt market dealers and investment dealers are allowed to operate start-up funding portals. Exempt market dealers and investment dealers that operate funding portals must:

• meet their existing registration obligations under securities legislation (including the know-your-client, know- your-product and suitability obligations owed to investors)

• confirm to issuers that the funding portal meets certain of the conditions in the start-up prospectus exemption, such as making an offering document and risk warning available to investors on the funding portal’s website

• prompt any person entering the funding portal’s website to acknowledge that the funding portal is operated by a registered dealer that will provide suitability advice

• file a Form 33-109F5 Change of Registration Information that describes the change in its business to include operating a funding portal

• must disclose all fees charged to investors in accordance with relationship disclosure requirements under National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations

A funding portal operated by a registered dealer is permitted to facilitate a larger investment. Typically, an investor may invest up to $1,500 under the start-up prospectus exemption. However, in British Columbia, Alberta, Saskatchewan and Ontario, investors can purchase up to $5,000 if the registered dealer has determined that the investment is suitable for the investor.

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How does start-up crowdfunding work? Issuers are responsible for preparing an offering document that complies with the prescribed form in the province they are based, and the province the investor resides in. In particular, issuers must indicate the minimum amount necessary to close a start-up crowdfunding distribution. Issuers will provide the offering document to the funding portal to post online. The funding portal must take reasonable measures to ensure that the issuer is a resident of a participating jurisdiction where the offering document is made available. Investors will read the offering document and decide whether or not to invest.

Before accepting an investment, a funding portal must obtain confirmation from the investor that he or she has read and understood the offering document and the risks described in the risk acknowledgement form. A funding portal must obtain the investor’s personal information and take reasonable measures to ensure the investor resides in a participating jurisdiction.

An issuer cannot close a distribution if it has not raised the minimum amount set out in its offering document and before each purchaser’s right to withdraw has expired. At the closing:

• the issuer distributes shares or other eligible securities to investors

• the funding portal releases funds to the issuer

No later than 15 days following the closing of the distribution, the funding portal must notify investors that the funds have been released to the issuer, and it must provide the issuer with the following information on each investor:

• Full name

• Address

• Telephone number

• E-mail address

• Number of securities purchased

• Total purchase price

The issuer requires this investor information in order to complete a report of exempt distribution. When providing investor information to the issuer, we encourage the funding portal to use the same spreadsheet that the issuer is required to use for filing. Please refer to the Start-up Crowdfunding Guide for Businesses for more information on the issuer’s filing requirements.

If the issuer withdraws its start-up crowdfunding offering or does not raise the minimum amount within 90 days after the funding portal posts the offering document online, all the funds must be returned in full to investors within five business days. No deductions are permitted. The funding portal must also send a notice to the issuer and each investor confirming that the funds have been returned to investors.

The funding portal may send notices to investors and issuers by e-mail.

Related-party restriction A funding portal cannot act in a start-up crowdfunding distribution if one of its principals is also a principal of the issuer group. The issuer group means the issuer, an affiliate of the issuer, and any other issuer that is engaged in a common enterprise with the issuer or an affiliate, or whose business is founded or organized by the same person or company who founded or organized the issuer.

Investor’s right to withdraw Investors have the right to withdraw their investment within 48 hours following the investor’s subscription. Investors also have the right to withdraw their investment within 48 hours of the funding portal notifying the investor of an amendment to the offering document.

To exercise this right of withdrawal, an investor must notify the funding portal. The funding portal must give investors the opportunity to exercise this right. The funding portal must return the funds to an investor who exercises this right, without any deduction, within five business days after the notice.

Amendments to the offering document An issuer must amend its offering document after it has been posted online if the information it contains is no longer true. This could be the case if, for example, an issuer wants to change the price of the securities or the minimum or maximum offering amount. The issuer must send the amended version to the funding portal for posting on the funding portal’s website. The funding portal must notify investors about the amendment.

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Issuer’s financial statements Under the start-up prospectus exemption, issuers are not required to provide financial statements to investors with the offering document.

If an issuer wants to make its financial statements available to investors, it can place a hyperlink on the funding portal leading to the financial statements. However, the hyperlink must not appear in the offering document because the financial statements do not form part of it.

Where can I get further information? For more information about the start-up crowdfunding exemptions in the participating jurisdictions, please refer to the following contact information:

British Columbia British Columbia Securities Commission Telephone: 604-899-6854 or 1-800-373-6393 E-mail: [email protected] www.bcsc.bc.ca Alberta Alberta Securities Commission Telephone: 403-355-4151 E-mail: [email protected] Website: www.albertasecurities.com

Saskatchewan Financial and Consumer Affairs Authority of Saskatchewan Securities Division Telephone: 306-787-5645 E-mail: [email protected] Website: www.fcaa.gov.sk.ca

Manitoba The Manitoba Securities Commission Toll free in Manitoba: 1-800-655-2548 E-mail: [email protected] Website: http://www.mbsecurities.ca/

Ontario Ontario Securities Commission Toll free: 1-877-785-1555 E-mail: [email protected] Website: www.osc.ca

Québec Autorité des marchés financiers Direction du financement des sociétés Toll free in Québec: 1-877-525-0337 E-mail: [email protected] Website: www.lautorite.qc.ca

New Brunswick Financial and Consumer Services Commission Toll free: 1-866-933-2222 E-mail: [email protected] Website: www.fcnb.ca

Nova Scotia Nova Scotia Securities Commission Toll free in Nova Scotia: 1-855-424-2499 E-mail: [email protected] Website: nssc.novascotia.ca

The information in this Guide is for educational purposes only and does not constitute legal advice. If any information in this Guide is inconsistent with Ontario Instrument 45–506 Start-Up Crowdfunding Registration and Prospectus Exemptions (Interim Class Order), please follow the instrument and the related forms.

Published August 20, 2020.

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5.1.3 Start-up Crowdfunding Guide for Investors

Start-up Crowdfunding Guide for Investors

Crowdfunding is a process through which an individual or a business can raise small amounts of money from a large number of people, typically through the Internet. The objective is to raise sufficient funds in order to carry out a specific project. There are different types of crowdfunding, such as by donation, pre-selling of products, or securities crowdfunding. This guide discusses securities crowdfunding.

Securities crowdfunding

With securities crowdfunding, a business raises funds through the Internet by issuing securities (such as bonds or shares) to many people.

In Canada, all trading of securities is subject to legal obligations. For example, a business seeking to raise capital by issuing securities must file a prospectus with the securities regulator of their province or territory or have an exemption from the prospectus requirement under securities laws.

These obligations, however, can be costly for start-ups, small businesses and other issuers. The securities regulators in British Columbia, Alberta, Saskatchewan, Manitoba, Ontario, Québec, New Brunswick and Nova Scotia (the participating jurisdictions) allow start-ups and small businesses to raise funds using securities crowdfunding without filing a prospectus or preparing financial statements. In this guide, we refer to this as the “start-up crowdfunding exemptions” or “start-up crowdfunding”.

Top 3 things to do before investing in a start-up crowdfunding project:

#1 Know the process

#2 Do your homework

#3 Understand the risks

#1 – Know the Process

How Start-up Crowdfunding Works

Start-ups and small businesses (issuers)

The business has an idea but needs to raise funds to make it happen. It must prepare an offering document that includes basic information about the business and the offering, how it will use the money and the risks in investing in the business. The business must state the minimum amount it needs to raise to accomplish its goal. The business must use a crowdfunding website called a funding portal to raise funds this way.

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Investor (you)

You, the investor, spot an interesting business on a funding portal website. After reading the business’ offering document and doing your homework, you may decide to invest up to the amount described in the “How Much Can I Invest?” section of this guide. Before you complete your investment, the funding portal will ask you to confirm that you understand the risks and have read and understood the business’ offering document. You have 48 hours after your investment to change your mind and get your money back.

Crowdfunding website (funding portal)

The funding portal posts start-up crowdfunding projects on its website. The funding portal is responsible for:

• providing a risk warning form to potential investors;

• holding all investor funds in trust until the business raises the minimum funding target; and

• returning funds to investors, without deduction, if the business does not reach its minimum funding target or if the business withdraws the start-up crowdfunding campaign.

When you enter a funding portal website, you will see a pop-up notice telling you whether the funding portal is:

• operated by a registered dealer under Canadian securities legislation. Before you invest, these portals must determine if the investment is suitable for you; or

• not registered under Canadian securities legislation. These portals cannot give you advice. You must decide for yourself if the investment is right for you.

You will be asked to acknowledge that you have read this pop-up notice before entering the funding portal website.

You can check to see if the funding portal can do business in Ontario. You can do this by contacting the Ontario Securities Commission at (toll free) 1-877-785-1555 or by e-mail at [email protected].

#2 Do your homework

Before investing, you should:

• Read the start-up crowdfunding offering document posted on the funding portal. It contains basic information about the business’ activities, its management, its financial condition, the amount it wants to raise, how the money raised will be used and the risks. The securities regulators have not reviewed or approved the offering document. It is your responsibility to understand the information in the offering document.

• Search the Internet for information on the business, its industry and the people operating its business. Check their background to see if they were ever disciplined for bad business practices. You can contact the business and the funding portal for further information.

• The business may also raise funds at the same time other than through start-up crowdfunding. Those investors may receive more or less information than what you are provided in the start-up crowdfunding offering document.

• You can ask the business about any previous successes or failures it may have had trying to raise funds in the past. The start-up offering document must disclose whether that business had any previous start-up crowdfunding distributions and whether they were successful or not. However, businesses are not required to report any failed or withdrawn offerings if they raised funds in another way.

• If the business gives you financial statements, you should know that those financial statements have not been provided to or reviewed by securities regulators and they are not part of the offering document. You should ask the business whether the financial statements have been audited and which accounting standards were used to prepare the financial statements. Do the financial statements include a balance sheet, income statement, statement of changes in financial position and detailed supporting notes?

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• Consider their business plan. How is the business going to grow? How will it make money and within what period? Watch for unsupportable claims about the business’ future success.

• Consider how you will receive a return on your investment. What type of securities is the business going to give you in exchange for your investment? The securities must be described in the offering document. If the business is offering debt securities, consider when the business intends to pay you back. If the business is offering equity securities, such as common shares, read the rights attached to these securities described in the offering document.

• Review all documents relating to your investment. There may be other rights and restrictions about the investment detailed in the business shareholder’s agreement or other agreements.

• Think carefully about your risk tolerance and what you can afford to lose if the investment doesn’t turn out as expected. Consider the cons as well as the pros.

• Ask the business any other questions you may have. The offering document will provide contact information for someone at the business who is able to answer your questions.

#3 Understand the risks

To make an informed decision, you must have a good understanding of the risks related to the start-up crowdfunding offering. These include:

• Securities of start-ups or small businesses are risky. Statistics show that a high percentage of start-ups and small businesses fail. You could lose the entire amount you paid for your investment.

• What is your risk tolerance? If your risk tolerance is low, an investment in a start-up or small business may not be suitable for you.

• What do you know about the individuals operating the business? Do they have the knowledge and experience required to manage it? Businesses are sometimes managed by inexperienced individuals. Find out more about the individuals operating the business before investing.

• Do you have the resources to be patient? If you think you will have to resell your securities in the short term, this type of investment may not be suitable for you. Securities purchased through start-up crowdfunding offerings are not publicly traded. You may have to wait indefinitely before reselling the securities or you may not be able to resell them at all.

• A great deal of information and analysis is available about public corporations. This is not the case for start- ups and small businesses. Unlike reporting issuers (such as companies listed on an exchange), start-ups and small businesses are not required to file audited financial statements or other periodic disclosure. You may receive much less information about the business before or after you invest.

• Once you have made the investment, the start-up or small business will not generally have any obligation to provide you with updates (such as an annual report). You will have to track your investment on your own.

If you are willing to take risks and invest in a start-up, you may want to consider investing in a business that operates in a sector you know well. You may be in a better position to assess its likelihood of success.

The start-up crowdfunding process – an example

Oliver has heard about start-up crowdfunding. He goes to ABC Funding Portal’s website and sees a pop-up notice that says ABC Funding Portal is not registered. He checks the names of their management and does some research to see if they have ever been disciplined for bad business practices.

After satisfying himself about ABC Funding Portal, Oliver browses through the start-up crowdfunding projects listed on its website. He comes across Valerie’s Maple Cola Company. Valerie wants to raise $75,000 to market and bottle soft drinks flavoured with

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Rules and Policies

maple syrup and other local products. Oliver thinks the investment looks interesting.

Oliver reads Valerie’s Maple Cola Company’s start-up crowdfunding offering document carefully, particularly the section that warns of the risks of this investment. Oliver does some additional research on Valerie’s Maple Cola Company, Valerie herself as well as the rest of her management team, and the beverage manufacturing business.

Oliver decides he wants to invest $750 in Valerie’s Maple Cola Company. He reviews the risk warning on ABC Funding Portal website. He confirms, by ticking a box, that he has read the offering document and understands the risks he is taking. He pays for the investment.

ABC Funding Portal holds Oliver’s money in trust until Valerie raises at least $75,000. If Valerie doesn’t raise her $75,000 target, ABC Funding Portal must return Oliver’s money to him, without any deductions.

If Valerie successfully raises $75,000, she can proceed to complete the start-up crowdfunding offering. Oliver is now a shareholder of Valerie’s Maple Cola Company. Upon completion of the offering, Oliver receives a confirmation setting out the number of the common shares he purchased and how much he paid.

There is no guarantee as to the future value of Oliver’s investment. Oliver will have to hold onto these securities for an indefinite period or even be unable to resell them at all.

Frequently asked questions about start-up crowdfunding

Where can I find start-up crowdfunding offerings?

You will find start-up crowdfunding offerings posted on the websites of funding portals. Before a funding portal can operate in any Canadian jurisdiction, it must meet certain conditions such as delivering mandatory documents to the securities regulatory authority in that jurisdiction. You can check with the OSC to see whether any particular funding portal is allowed to do business in Ontario by calling the phone number listed below under “Where can I get further information?”

Should I get investment advice?

You should use a registered portal if you want or need investment advice because they must determine whether an investment is suitable for you.

If you are viewing offerings on an unregistered funding portal, you will not receive investment advice; they are prohibited from telling you whether the securities you are subscribing for are a good investment. You must be prepared to make your own investment decision when investing through an unregistered funding portal. Unregistered portals are also prohibited from charging you a fee or commission for investing through their website.

When you enter a funding portal website, a pop-up notice will inform you whether or not the funding portal is operated by a registered dealer. To check if the funding portal is operated by a registered dealer, go to www.aretheyregistered.ca.

How much can I invest?

You can invest up to $1,500 in a start-up crowdfunding offering. However, this amount can be increased to $5,000 if all of the following apply:

• you live in British Columbia, Alberta, Saskatchewan or Ontario;

• you are interested in investing in a business with a head office in British Columbia, Alberta, Saskatchewan or Ontario;

• the start-up crowdfunding distribution is made through a registered dealer; and

• the dealer has determined that the investment is suitable for you.

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What will I get in return for investing in a start-up crowdfunding project?

With securities crowdfunding, investors receive securities in exchange for their investment. This is different than other types of crowdfunding, where you may get a product. Start-up crowdfunding is restricted to particular types of securities: debt securities, such as bonds; equity securities, such as common shares or preference shares; limited partnership units; and convertible securities, such as warrants, that are convertible into either common shares or preference shares.

The offering document must describe the type of security you will receive in exchange for your investment.

What if I change my mind?

Once you have committed to purchasing securities:

• You may withdraw your investment within 48 hours of subscription if you no longer wish to invest; or

• If the business amends the offering document, you will also have the right to withdraw your investment within 48 hours of the funding portal notifying you that the offering document has been amended.

In either case, you must notify the funding portal that you wish to withdraw before the end of this 48-hour period. After receiving your notification, the funding portal will return your funds to you within 5 business days.

Where can I get further information?

For more information about the start-up crowdfunding exemptions in the participating jurisdictions, please refer to the following contact information:

British Columbia British Columbia Securities Commission Telephone: 604-899-6854 or 1-800-373-6393 E-mail: [email protected] www.bcsc.bc.ca

Alberta Alberta Securities Commission Telephone: 403-355-4151 E-mail: [email protected] Website: www.albertasecurities.com

Saskatchewan Financial and Consumer Affairs Authority of Saskatchewan Securities Division Telephone: 306-787-5645 E-mail: [email protected] www.fcaa.gov.sk.ca

Manitoba The Manitoba Securities Commission Toll free in Manitoba: 1-800-655-2548 E-mail: [email protected] www.msc.gov.mb.ca

Ontario Ontario Securities Commission Toll free: 1-877-785-1555 E-mail: [email protected] www.osc.ca

Québec Autorité des marchés financiers Direction du financement des sociétés Toll free in Québec: 1-877-525-0337 E-mail: [email protected] www.lautorite.qc.ca

New Brunswick Financial and Consumer Services Commission Toll free: 1-866-933-2222 E-mail: [email protected] www.fcnb.ca

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Nova Scotia Nova Scotia Securities Commission Toll free in Nova Scotia: 1-855-424-2499 E-mail: [email protected] www.nssc.novascotia.ca

The information in this Guide is for educational purposes only and does not constitute legal advice.

If any information in this Guide is inconsistent with Ontario Instrument 45–506 Start-Up Crowdfunding Registration and Prospectus Exemptions (Interim Class Order), please follow the instrument and the related forms.

Published August 20, 2020.

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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 20, 2020 (2020), 43 OSCB 6607

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed 1933 Industries Inc Options Kaelin, Patricia 5 2020-07-03 00 1933 Industries Inc Options Kaelin, Patricia 5 2020-08-07 50 0.075 500,000 500,000 1933 Industries Inc Common Shares Ruiz, Eugene 5 2020-06-15 00 80,000 1933 Industries Inc Options Ruiz, Eugene 5 2020-06-15 00 1933 Industries Inc Options Ruiz, Eugene 5 2020-08-07 50 0.075 7,000,000 7,000,000 37 Capital Inc. Common Shares Kalpakian, Jacob H 4 2020-08-11 10 0.05 70,000 -249,000 37 Capital Inc. Common Shares Kalpakian, Jacob H 4 2020-08-12 10 0.05 65,000 -5,000 5N Plus Inc. Common Shares 5N Plus Inc. 1 2020-08-07 38 12,417 -6,800 5N Plus Inc. Common Shares 5N Plus Inc. 1 2020-08-10 38 1.8715 18,517 6,100 5N Plus Inc. Common Shares 5N Plus Inc. 1 2020-08-10 38 11,600 -6,917 5N Plus Inc. Common Shares 5N Plus Inc. 1 2020-08-11 38 1.9146 18,517 6,917 5N Plus Inc. Common Shares 5N Plus Inc. 1 2020-08-11 38 13,017 -5,500 5N Plus Inc. Common Shares 5N Plus Inc. 1 2020-08-12 38 1.9933 18,817 5,800 5N Plus Inc. Common Shares 5N Plus Inc. 1 2020-08-12 38 12,717 -6,100 5N Plus Inc. Common Shares 5N Plus Inc. 1 2020-08-13 38 1.9819 14,317 1,600 5N Plus Inc. Common Shares 5N Plus Inc. 1 2020-08-13 38 7,400 -6,917 5N Plus Inc. Common Shares 5N Plus Inc. 1 2020-08-14 38 2.011 11,300 3,900 5N Plus Inc. Common Shares 5N Plus Inc. 1 2020-08-14 38 5,500 -5,800 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-02 38 21.97 700 300 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-03 38 21 500 200 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-06 38 21.963 1,300 800 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-07 38 21.76 1,500 200 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-08 38 21.634 2,600 1,100 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-09 38 21.5 3,100 500 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-10 38 21.302 3,600 500 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-13 38 21.3 4,500 900 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-16 38 21.74 4,600 100 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-20 38 22.534 5,300 700 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-21 38 22.465 5,700 400 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-22 38 22.695 6,300 600 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-23 38 22.83 7,500 1,200 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-28 38 21.54 7,700 200 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-29 38 20.984 8,600 900 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-30 38 20.488 9,500 900 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-07-31 38 900 -8,600 Abitibi Royalties Inc. Common Shares Abitibi Royalties Inc. 1 2020-08-07 38 0 -900 Absolute Software Rights Performance Booker, Robert Carlton 5 2020-07-17 00 Corporation Share Unit Absolute Software Rights Performance Booker, Robert Carlton 5 2020-08-13 56 14,668 14,668 Corporation Share Unit Absolute Software Rights Restricted Share Booker, Robert Carlton 5 2020-07-17 00 Corporation Unit Absolute Software Rights Restricted Share Booker, Robert Carlton 5 2020-08-13 56 14,668 14,668 Corporation Unit Absolute Software Rights Performance Karim, Ameer 5 2020-08-13 56 57,113 5,873 Corporation Share Unit Absolute Software Rights Restricted Share Karim, Ameer 5 2020-08-13 56 67,520 5,873 Corporation Unit Absolute Software Rights Performance Laforce, Marcel Armand 5 2020-08-13 56 9,123 4,190 Corporation Share Unit Absolute Software Rights Restricted Share Laforce, Marcel Armand 5 2020-08-13 56 47,858 4,190 Corporation Unit Absolute Software Rights Performance Lapierre, Dianne Elizabeth 5 2020-08-13 56 30,627 2,849 Corporation Share Unit Absolute Software Rights Restricted Share Lapierre, Dianne Elizabeth 5 2020-08-13 56 30,627 2,849 Corporation Unit Absolute Software Rights Performance Malli, Maninder 5 2020-08-13 56 6,822 3,097 Corporation Share Unit Absolute Software Rights Restricted Share Malli, Maninder 5 2020-08-13 56 36,175 3,097 Corporation Unit Absolute Software Rights Performance maxwell, sean 5 2020-08-13 56 78,234 10,957 Corporation Share Unit

August 20, 2020 (2020), 43 OSCB 6608

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Absolute Software Rights Restricted Share maxwell, sean 5 2020-08-13 56 115,532 10,957 Corporation Unit Absolute Software Rights Performance Meanchoff, Matthew 5 2020-08-13 56 24,533 5,812 Corporation Share Unit Absolute Software Rights Restricted Share Meanchoff, Matthew 5 2020-08-13 56 36,438 5,812 Corporation Unit Absolute Software Rights Performance Morris, William 5 2020-08-13 56 59,077 6,237 Corporation Share Unit Absolute Software Rights Restricted Share Morris, William 5 2020-08-13 56 59,077 6,237 Corporation Unit Absolute Software Rights Performance Ramsden, Leigh Palmer 5 2020-08-13 56 9,114 5,389 Corporation Share Unit Absolute Software Rights Restricted Share Ramsden, Leigh Palmer 5 2020-08-13 56 35,772 5,389 Corporation Unit Absolute Software Rights Performance Reynolds, Karen 5 2020-08-13 56 23,094 7,533 Corporation Share Unit Absolute Software Rights Restricted Share Reynolds, Karen 5 2020-08-13 56 43,767 7,533 Corporation Unit Absolute Software Rights Performance Toms, Sandra 5 2020-08-13 56 25,193 8,218 Corporation Share Unit Absolute Software Rights Restricted Share Toms, Sandra 5 2020-08-13 56 61,026 8,218 Corporation Unit Absolute Software Rights Performance van Someren, Nicholas 5 2020-08-13 56 74,226 9,040 Corporation Share Unit Benedict Absolute Software Rights Restricted Share van Someren, Nicholas 5 2020-08-13 56 74,226 9,040 Corporation Unit Benedict Absolute Software Rights Performance Wyatt, Christy May 4, 5 2020-08-13 56 203,616 44,253 Corporation Share Unit Absolute Software Rights Restricted Share Wyatt, Christy May 4, 5 2020-08-13 56 194,842 44,253 Corporation Unit Aequus Pharmaceuticals Common Shares Fehr, Ann 5 2020-08-06 15 0.08 159,000 125,000 Inc. Aequus Pharmaceuticals Warrants Fehr, Ann 5 2016-07-22 00 Inc. Aequus Pharmaceuticals Warrants Fehr, Ann 5 2020-08-06 15 62,500 62,500 Inc. Aequus Pharmaceuticals Common Shares Fowler, Stuart William 4 2020-02-01 00 Inc. Aequus Pharmaceuticals Common Shares Fowler, Stuart William 4 2020-08-06 15 0.08 625,000 625,000 Inc. Aequus Pharmaceuticals Options Fowler, Stuart William 4 2020-02-01 00 Inc. Aequus Pharmaceuticals Options Fowler, Stuart William 4 2020-02-14 50 350,000 350,000 Inc. Aequus Pharmaceuticals Warrants Fowler, Stuart William 4 2020-02-01 00 Inc. Aequus Pharmaceuticals Warrants Fowler, Stuart William 4 2020-08-06 15 312,500 312,500 Inc. Aequus Pharmaceuticals Common Shares JANZEN, DOUG 4, 5 2020-08-06 15 0.08 8,474,800 3,125,000 Inc. Aequus Pharmaceuticals Warrants JANZEN, DOUG 4, 5 2020-08-06 15 0.12 1,652,500 1,562,500 Inc. AEterna Zentaris Inc. Common Shares Paulini, Klaus 4, 7, 5 2019-08-15 00 AEterna Zentaris Inc. Common Shares Paulini, Klaus 4, 7, 5 2020-08-11 10 0.55 20,000 20,000 Aether Catalyst Solutions, Common Shares Kerr, Glenn Bradley 5 2020-08-12 10 0.25 962,578 -8,500 Inc. Aether Catalyst Solutions, Common Shares Woodward, Paul John 3, 4, 6, 5 2020-08-11 10 0.2 2,921,200 8,000 Inc. Courtney African Gold Group, Inc. Common Shares Baizak, Daniyal 5 2019-08-14 00 African Gold Group, Inc. Common Shares Baizak, Daniyal 5 2020-08-10 16 0.25 280,000 280,000 African Gold Group, Inc. Options Baizak, Daniyal 5 2020-08-10 50 0.28 400,000 300,000 African Gold Group, Inc. Warrants Baizak, Daniyal 5 2019-08-14 00 African Gold Group, Inc. Warrants Baizak, Daniyal 5 2020-08-10 16 0.25 140,000 140,000 African Gold Group, Inc. Common Shares Begeman, John A. 4 2020-08-10 16 0.25 163,492 100,000 African Gold Group, Inc. Options Begeman, John A. 4 2020-08-10 50 0.28 603,333 400,000 African Gold Group, Inc. Warrants Begeman, John A. 4 2017-04-24 00

August 20, 2020 (2020), 43 OSCB 6609

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed African Gold Group, Inc. Warrants Begeman, John A. 4 2020-08-10 16 0.25 50,000 50,000 African Gold Group, Inc. Common Shares Callow, Daniel John 5 2019-08-13 00 African Gold Group, Inc. Common Shares Callow, Daniel John 5 2020-08-10 16 0.25 900,000 900,000 African Gold Group, Inc. Options Callow, Daniel John 5 2020-08-10 50 0.28 5,000,000 3,000,000 African Gold Group, Inc. Warrants Callow, Daniel John 5 2019-08-13 00 African Gold Group, Inc. Warrants Callow, Daniel John 5 2020-08-10 16 0.25 450,000 450,000 African Gold Group, Inc. Common Shares Choi, Kenny 5 2019-06-03 00 African Gold Group, Inc. Common Shares Choi, Kenny 5 2020-08-10 16 0.25 100,000 100,000 African Gold Group, Inc. Options Choi, Kenny 5 2020-08-10 50 0.28 400,000 200,000 African Gold Group, Inc. Warrants Choi, Kenny 5 2019-06-03 00 African Gold Group, Inc. Warrants Choi, Kenny 5 2020-08-10 16 0.25 50,000 50,000 African Gold Group, Inc. Common Shares Eldridge, Scott Richard 4, 5 2020-08-10 11 0.25 600,000 500,000 African Gold Group, Inc. Options Eldridge, Scott Richard 4, 5 2020-06-15 00 African Gold Group, Inc. Options Eldridge, Scott Richard 4, 5 2020-08-10 50 0.28 703,333 703,333 African Gold Group, Inc. Warrants Eldridge, Scott Richard 4, 5 2020-08-10 11 0.4 300,000 250,000 African Gold Group, Inc. Options Pettigrew, Pierre Stewart 4 2020-08-10 50 0.28 603,333 400,000 African Gold Group, Inc. Common Shares Ptolemy, Ryan Jeffery 5 2017-08-01 00 African Gold Group, Inc. Common Shares Ptolemy, Ryan Jeffery 5 2020-08-10 16 0.25 90,000 90,000 African Gold Group, Inc. Options Ptolemy, Ryan Jeffery 5 2020-08-10 50 0.28 400,000 293,333 African Gold Group, Inc. Warrants Ptolemy, Ryan Jeffery 5 2017-08-01 00 African Gold Group, Inc. Warrants Ptolemy, Ryan Jeffery 5 2020-08-10 16 0.25 45,000 45,000 African Gold Group, Inc. Common Shares Rompel, Andreas 5 2019-06-03 00 African Gold Group, Inc. Common Shares Rompel, Andreas 5 2020-08-10 16 0.25 40,000 40,000 African Gold Group, Inc. Options Rompel, Andreas 5 2020-08-10 50 0.28 400,000 200,000 African Gold Group, Inc. Warrants Rompel, Andreas 5 2019-06-03 00 African Gold Group, Inc. Warrants Rompel, Andreas 5 2020-08-10 16 0.25 20,000 20,000 Ag Growth International Inc. Common Shares Sommerfeld, Steven 5 2020-08-13 10 37.05 26,167 -50,000 Robert AGF Management Limited Common Shares Class B AGF Management Limited, 1 2020-08-06 38 5.25 600 600 La Societe de Gestion AGF Limitee AGF Management Limited Common Shares Class B AGF Management Limited, 1 2020-08-06 38 5.25 0 -600 La Societe de Gestion AGF Limitee AGF Management Limited Common Shares Class B AGF Management Limited, 1 2020-08-10 38 5.25 196,900 196,900 La Societe de Gestion AGF Limitee AGF Management Limited Common Shares Class B AGF Management Limited, 1 2020-08-10 38 5.25 0 -196,900 La Societe de Gestion AGF Limitee Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-08 51 28.92 5,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-08 51 28.92 5,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-08 10 77.9 -5,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-08 10 77.9 -5,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-12 51 28.92 5,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-12 51 28.92 5,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-12 10 80 -5,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-12 10 80 -5,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-26 51 28.92 4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-26 51 28.92 4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-26 10 83 -4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-26 10 83 -4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-27 51 28.92 4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-27 51 28.92 4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-27 10 85 -4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-27 10 85 -4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-09-30 30 76.12 143 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-09-30 30 76.12 143 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-11-07 99 54,335 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-11-07 99 585 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-11-07 99 585

August 20, 2020 (2020), 43 OSCB 6610

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-12-31 57 10,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-12-31 57 10,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-12-31 10 81.58 -5,496 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-12-31 10 79.95 -5,496 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-12-31 10 79.95 -5,496 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-12-31 30 79.08 162 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-12-31 30 79.08 162 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-01-07 51 80.5 24,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-01-07 51 36.37 24,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-01-07 51 36.37 24,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-01-07 10 80.5 -24,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-01-07 10 80.5 -24,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-03-31 30 57.43 241 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-03-31 30 57.43 241 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-07 10 90.01 -841 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-07 10 90.01 -841 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-14 51 56.45 4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-14 51 56.45 4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-14 10 94 -4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-14 10 94 -4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-15 51 56.45 4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-15 51 56.45 4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-15 10 97 -4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-15 10 97 -4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-06-30 30 84.04 150 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-06-30 30 84.04 150 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-08 51 28.92 -5,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-08 51 28.92 -5,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-12 51 28.92 -5,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-12 51 28.92 -5,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-26 51 28.92 -4,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-26 51 28.92 -4,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-27 51 28.92 -4,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-27 51 28.92 -4,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-11-01 99 -120,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-11-01 99 -120,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-01-02 50 79.98 22,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-01-02 50 79.98 22,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-01-07 51 36.37 -24,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-01-07 51 36.37 -24,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-05-14 51 56.45 -4,500 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-05-14 51 56.45 -4,500 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-05-15 51 56.45 -4,500 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-05-15 51 56.45 -4,500 Agnico Eagle Mines Limited Performance Share Units Gosselin, Guy 5 2019-08-02 56 6,000 Agnico Eagle Mines Limited Performance Share Units Gosselin, Guy 5 2019-08-02 56 6,000 Agnico Eagle Mines Limited Performance Share Units Gosselin, Guy 5 2020-01-02 56 7,000 Agnico Eagle Mines Limited Performance Share Units Gosselin, Guy 5 2020-01-02 56 7,000 Agnico Eagle Mines Limited Restricted Share Units Gosselin, Guy 5 2019-11-01 99 25,160 Agnico Eagle Mines Limited Restricted Share Units Gosselin, Guy 5 2019-11-01 99 25,160 Agnico Eagle Mines Limited Restricted Share Units Gosselin, Guy 5 2019-12-31 57 -10,000 Agnico Eagle Mines Limited Restricted Share Units Gosselin, Guy 5 2019-12-31 57 -10,000 Agnico Eagle Mines Limited Restricted Share Units Gosselin, Guy 5 2020-01-02 56 7,000 Agnico Eagle Mines Limited Restricted Share Units Gosselin, Guy 5 2020-01-02 56 7,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-01 00 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-01 00 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-01 00 10,036 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-08 51 28.92 15,036 5,000

August 20, 2020 (2020), 43 OSCB 6611

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-08 10 77.9 10,036 -5,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-12 51 28.92 15,036 5,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-12 10 80 10,036 -5,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-26 51 28.92 14,036 4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-26 10 83 10,036 -4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-27 51 28.92 14,036 4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-08-27 10 85 10,036 -4,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-09-30 30 76.12 10,179 143 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-11-07 99 585 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-11-07 99 585 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-12-31 57 20,179 10,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-12-31 10 79.95 14,683 -5,496 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2019-12-31 30 79.08 14,845 162 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-01-07 51 36.37 38,845 24,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-01-07 10 80.5 14,845 -24,000 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-03-31 30 57.43 15,086 241 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-07 10 90.01 14,245 -841 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-14 51 56.45 18,745 4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-14 10 94 14,245 -4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-15 51 56.45 18,745 4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-05-15 10 97 14,245 -4,500 Agnico Eagle Mines Limited Common Shares Gosselin, Guy 5 2020-06-30 30 84.04 14,395 150 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-08 51 28.92 100,000 -5,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-12 51 28.92 95,000 -5,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-26 51 28.92 91,000 -4,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-08-27 51 28.92 87,000 -4,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-11-01 99 -120,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2019-11-01 99 -120,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-01-02 50 79.98 109,000 22,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-01-07 51 36.37 85,000 -24,000 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-05-14 51 56.45 80,500 -4,500 Agnico Eagle Mines Limited Options Gosselin, Guy 5 2020-05-15 51 56.45 76,000 -4,500 Agnico Eagle Mines Limited Performance Share Units Gosselin, Guy 5 2019-08-01 00 Agnico Eagle Mines Limited Performance Share Units Gosselin, Guy 5 2019-08-02 56 6,000 6,000 Agnico Eagle Mines Limited Performance Share Units Gosselin, Guy 5 2020-01-02 56 13,000 7,000 Agnico Eagle Mines Limited Restricted Share Units Gosselin, Guy 5 2019-11-01 99 25,160 Agnico Eagle Mines Limited Restricted Share Units Gosselin, Guy 5 2019-11-01 99 25,160 Agnico Eagle Mines Limited Restricted Share Units Gosselin, Guy 5 2019-12-31 57 23,000 -10,000 Agnico Eagle Mines Limited Restricted Share Units Gosselin, Guy 5 2020-01-02 56 30,000 7,000 Agnico Eagle Mines Limited Common Shares Grondin, Louise 5 2020-08-12 10 101.64 61,086 -903 Agnico Eagle Mines Limited Common Shares Grondin, Louise 5 2020-08-13 10 103.54 49,086 -12,000 Aimia Inc. Common Shares Mittleman Investment 3 2020-07-28 97 -53,200 Management, LLC Aimia Inc. Common Shares Mittleman Investment 3 2020-07-28 97 15,177,033 -11,200 Management, LLC Aimia Inc. Common Shares Mittleman Investment 3 2020-08-11 97 15,170,433 -6,600 Management, LLC Aimia Inc. Common Shares Mittleman Investment 3 2020-08-13 97 15,144,933 -25,500 Management, LLC Air Canada Options (Long-Term Abbott, Michael 5 2020-08-05 00 30,012 Incentive Plan) Air Canada Share Units (Long-Term Abbott, Michael 5 2020-08-05 00 9,452 Incentive Plan) Air Canada Class B Voting Shares Romanelli, Gilda 5 2020-08-05 00 1,287 Air Canada Options (Long-Term Romanelli, Gilda 5 2020-08-05 00 17,023 Incentive Plan) Air Canada Share Units (Long-Term Romanelli, Gilda 5 2020-08-05 00 8,346 Incentive Plan) AIRBOSS OF AMERICA Common Shares Carrier, Sindy 5 2020-08-13 51 1,161 583 CORP.

August 20, 2020 (2020), 43 OSCB 6612

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed AIRBOSS OF AMERICA Common Shares Carrier, Sindy 5 2020-08-13 51 2,748 1,587 CORP. AIRBOSS OF AMERICA Options Carrier, Sindy 5 2020-08-13 51 11.56 62,451 -1,606 CORP. AIRBOSS OF AMERICA Options Carrier, Sindy 5 2020-08-13 51 9.49 58,779 -3,672 CORP. AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-10-25 00 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-10-25 00 5,582,000 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-11-08 10 0.17 53,000 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-11-08 10 0.17 53,000 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-11-10 10 0.17 8,500 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-11-10 10 0.17 8,500 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-11-14 10 0.17 500 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-11-14 10 0.17 500 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-12-04 10 0.17 33,500 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-12-04 10 0.17 33,500 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-12-06 10 0.17 95,500 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-12-06 10 0.17 95,500 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-12-08 10 0.17 125,000 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-12-08 10 0.17 125,000 AirIQ Inc. Common Shares Vecima Networks Inc. 3 2017-12-08 10 0.17 6,451,500 95,500 Akita Drilling Ltd. Non-Voting Shares Dease, Colin 5 2020-08-12 30 0.37 106,564 1,697 Akita Drilling Ltd. Non-Voting Shares Reynolds, Darcy 5 2020-08-12 30 0.37 39,130 2,121 Alamos Gold Inc. Common Shares Class A Barwell, Christine 5 2020-08-10 30 13.95 29,921 265 Alamos Gold Inc. Common Shares Class A Bostwick, Christopher John 5 2020-08-10 30 13.95 54,492 344 Alamos Gold Inc. Common Shares Class A Chavez - Martinez, Mario 5 2020-08-10 30 10.49 72,832 370 Luis Alamos Gold Inc. Common Shares Class A Engelstad, Nils Frederik 8 2020-08-10 30 13.95 19,578 335 Jonas Alamos Gold Inc. Common Shares Class A Fisher, Gregory S. 5 2020-08-10 30 13.95 24,729 180 Alamos Gold Inc. Common Shares Class A MacPhail, Peter 5 2020-08-10 30 13.95 128,348 484 Alamos Gold Inc. Common Shares Class A McCluskey, John 4, 5 2020-08-10 30 13.95 666,633 784 Alamos Gold Inc. Common Shares Class A Parsons, Scott Kyle 5 2020-08-10 30 13.95 41,303 259 Alamos Gold Inc. Common Shares Class A PAULSE, ADRIAN 5 2020-08-10 30 13.95 14,871 196 Alamos Gold Inc. Common Shares Class A Porter, James 5 2020-08-10 30 13.95 107,537 483 Alamos Gold Inc. Common Shares Class A Webster, Colin 5 2020-08-10 30 13.95 15,380 197 Alamos Gold Inc. Common Shares Class A Webster, Colin 5 2020-08-11 51 9.62 27,357 11,977 Alamos Gold Inc. Common Shares Class A Webster, Colin 5 2020-08-11 10 12.88 15,380 -11,977 Alamos Gold Inc. Common Shares Class A Webster, Colin 5 2020-08-11 51 6.56 35,380 20,000 Alamos Gold Inc. Common Shares Class A Webster, Colin 5 2020-08-11 10 12.93 15,380 -20,000 Alamos Gold Inc. Common Shares Class A Webster, Colin 5 2020-08-11 51 6.58 33,436 18,056 Alamos Gold Inc. Common Shares Class A Webster, Colin 5 2020-08-11 10 12.95 15,380 -18,056 Alamos Gold Inc. Options Webster, Colin 5 2020-08-11 51 9.62 185,876 -11,977 Alamos Gold Inc. Options Webster, Colin 5 2020-08-11 51 6.56 165,876 -20,000 Alamos Gold Inc. Options Webster, Colin 5 2020-08-11 51 6.58 147,820 -18,056 Alianza Minerals Ltd. Common Shares Duncan, Robert Andrew 5 2020-08-10 00 100,000 (formerly Tarsis Resources Ltd.) Alianza Minerals Ltd. Warrants Duncan, Robert Andrew 5 2020-08-10 00 400,000 (formerly Tarsis Resources Ltd.) Allegiant Gold Ltd. Common Shares Gianulis, Peter Lawrence 4, 6 2020-08-12 10 0.33 6,171,800 70,000 Altina Capital Corp. Common Shares Sanidas, Theofilos 4 2020-07-31 00 500,000 Altina Capital Corp. Options Sanidas, Theofilos 4 2020-07-31 00 135,000 Altius Minerals Corporation Common Shares Altius Minerals Corporation 1 2020-07-02 38 9.8 5,000 5,000 Altius Minerals Corporation Common Shares Altius Minerals Corporation 1 2020-07-03 38 9.9 10,000 5,000 Altius Minerals Corporation Common Shares Altius Minerals Corporation 1 2020-07-06 38 10.04 15,000 5,000 Altius Minerals Corporation Common Shares Altius Minerals Corporation 1 2020-07-07 38 10.1 20,000 5,000 Altius Minerals Corporation Common Shares Altius Minerals Corporation 1 2020-07-08 38 10.11 21,900 1,900 Altius Minerals Corporation Common Shares Altius Minerals Corporation 1 2020-07-23 38 10.1 26,900 5,000 Altius Minerals Corporation Common Shares Altius Minerals Corporation 1 2020-07-31 38 0 -26,900

August 20, 2020 (2020), 43 OSCB 6613

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Amarillo Gold Corporation Common Shares 2176423 Ontario Ltd. 3 2020-08-13 16 0.3 68,300,000 43,300,000 Amarillo Gold Corporation Common Shares Baccarat Trade 3 2020-08-13 00 432,500 Investments Ltd. Amarillo Gold Corporation Common Shares Baccarat Trade 3 2020-08-13 00 75,667,000 Investments Ltd. Amarillo Gold Corporation Common Shares Birkett, Alexander David 4 2020-08-13 11 0.3 1,278,142 200,000 Amarillo Gold Corporation Common Shares Lepard, Lawrence 4 2020-08-13 11 0.3 3,750,000 900,000 Amarillo Gold Corporation Common Shares Mutchler, Mike 4, 5 2020-08-13 11 0.3 2,887,858 300,000 Amarillo Gold Corporation Common Shares Raykov, Rostislav Christov 4 2020-08-13 11 0.3 3,471,214 240,000 Amarillo Gold Corporation Common Shares Sprott, Eric S. 3 2020-08-13 16 0.3 68,300,000 43,300,000 Amarillo Gold Corporation Common Shares STOW, STEPHEN 4 2017-09-28 00 WILLIAM CANNING Amarillo Gold Corporation Common Shares STOW, STEPHEN 4 2020-08-13 15 0.3 300,000 300,000 WILLIAM CANNING American Manganese Inc. Common Shares Ali, Shaheem 5 2020-08-06 10 0.22 303,500 -26,000 American Manganese Inc. Common Shares Ali, Shaheem 5 2020-08-07 10 0.22 279,500 -24,000 AMPD Ventures Inc. Common Shares HURSTHOUSE, JAMES 5 2020-08-12 10 0.165 1,594,418 3,000 ROGER AMPD Ventures Inc. Options Kang, Ravinder 4 2020-08-06 52 300,000 -200,000 Anaconda Mining Inc. Common Shares Bullock, Kevin 4, 5 2020-08-06 57 110000 1,125,000 110,000 Anaconda Mining Inc. Rights Restricted Share Bullock, Kevin 4, 5 2020-08-06 57 200,000 -110,000 Units Anaconda Mining Inc. Rights Restricted Share Lawrick, Victor Lewis 4 2020-07-31 56 301,329 7,250 Units Antler Gold Inc. Options Megann, Harold James 4 2020-08-05 50 0.4 400,000 325,000 (Jim) Antler Gold Inc. Options Sparkes, Paul David 4 2020-08-05 50 0.4 337,500 150,000 Aphria Inc. (formerly, Black Rights Restricted Share Faltischek, Denise 5 2020-08-12 56 138,720 63,720 Sparrow Capital Corp.) Units Menikheim Aphria Inc. (formerly, Black Rights Restricted Share Gedeon, Christelle 5 2020-08-12 56 137,116 116,420 Sparrow Capital Corp.) Units Aphria Inc. (formerly, Black Rights Restricted Share Macgregor, Tamara 5 2019-09-01 00 Sparrow Capital Corp.) Units Aphria Inc. (formerly, Black Rights Restricted Share Macgregor, Tamara 5 2020-08-12 56 58,860 58,860 Sparrow Capital Corp.) Units Aphria Inc. (formerly, Black Rights Restricted Share Meiers, James 5 2020-08-12 56 153,430 78,430 Sparrow Capital Corp.) Units Aphria Inc. (formerly, Black Rights Restricted Share MERTON, Carl 5 2020-08-12 56 169,239 116,420 Sparrow Capital Corp.) Units Aphria Inc. (formerly, Black Rights Restricted Share Simon, Irwin 4, 5 2020-08-12 56 1,761,078 434,340 Sparrow Capital Corp.) Units Apteryx Imaging Inc. Common Shares Gane, David 5 2020-08-12 22 0 -37,105 Apteryx Imaging Inc. Common Shares Gane, David 5 2020-08-12 22 0 -82,728 Apteryx Imaging Inc. Common Shares Gane, David 5 2020-08-12 22 0 -25,833 Apteryx Imaging Inc. Common Shares Gane, David 5 2020-08-12 22 0 -227,007 Apteryx Imaging Inc. Common Shares Gane, David 5 2020-08-12 22 0 -4,000 Apteryx Imaging Inc. Common Shares Gane, David 5 2020-08-12 22 0 -57,820 Apteryx Imaging Inc. Common Shares Gane, David 5 2020-08-12 22 0 -29,000 Apteryx Imaging Inc. Convertible Preferred Gane, David 5 2020-08-12 22 0 -170,000 Shares Apteryx Imaging Inc. Options Gane, David 5 2020-08-12 22 0 -825,000 Apteryx Imaging Inc. Common Shares PDDS Buyer, LLC 3 2020-08-12 00 Apteryx Imaging Inc. Common Shares PDDS Buyer, LLC 3 2020-08-12 22 0.65 43,459,671 43,459,671 Apteryx Imaging Inc. Convertible Preferred PDDS Buyer, LLC 3 2020-08-12 00 Shares Apteryx Imaging Inc. Convertible Preferred PDDS Buyer, LLC 3 2020-08-12 22 16,637,624 16,637,624 Shares Apteryx Imaging Inc. Common Shares Roberts, Clayto Lamar 5 2020-08-12 22 0 -356,892 Apteryx Imaging Inc. Options Roberts, Clayto Lamar 5 2020-08-12 22 0 -825,000 Arctic Hunter Energy Inc. Common Shares Coupland, Timothy Andrew 4, 5 2006-02-21 00 400,000 Arctic Hunter Energy Inc. Common Shares Coupland, Timothy Andrew 4, 5 2006-02-21 00 487,500 Arctic Hunter Energy Inc. Common Shares Scholefield, Daniel 3 2020-08-07 16 0.05 710,000 200,000 Arctic Hunter Energy Inc. Warrants Scholefield, Daniel 3 2020-08-07 16 550,000 200,000

August 20, 2020 (2020), 43 OSCB 6614

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed AREV NanoTec Brands Inc. Common Shares Withrow, MIke Withrow 4 2020-08-05 10 0.1 22,890,000 13,500 (Formerly, AREV Brands International Ltd.) AREV NanoTec Brands Inc. Common Shares Withrow, MIke Withrow 4 2020-08-11 10 0.1 22,940,000 50,000 (Formerly, AREV Brands International Ltd.) Artis Real Estate Investment Restricted Units Green, James 5 2020-08-14 56 8.57 97,402 509 Trust Artis Real Estate Investment Deferred Units Jack, Bruce William James 4 2020-08-14 56 8.57 61,145 319 Trust Artis Real Estate Investment Deferred Units Martens, Armin 4, 5 2020-08-14 56 8.57 365,826 1,911 Trust Artis Real Estate Investment Restricted Units Martens, Armin 4, 5 2020-08-14 56 8.57 335,931 1,755 Trust Artis Real Estate Investment Restricted Units Martens, Philip 5 2020-08-14 56 8.57 13,453 70 Trust Artis Real Estate Investment Restricted Units Riley, Kimberly 4 2020-08-14 56 8.57 11,031 58 Trust Artis Real Estate Investment Restricted Units Sherlock, Stephen Francis 5 2020-08-14 56 8.57 13,098 68 Trust Patrick Artis Real Estate Investment Deferred Units Thielmann, Victor 4 2020-08-14 56 8.57 11,963 62 Trust Artis Real Estate Investment Deferred Units Townsend, Kenneth 4 2020-08-14 56 8.57 11,963 62 Trust Artis Real Estate Investment Deferred Units Warkentin, Edward 4 2020-08-14 56 8.57 11,963 62 Trust Artis Real Estate Investment Deferred Units Zucker, Lauren 4 2020-08-14 56 8.57 30,043 157 Trust Asbestos Corporation Common Shares MONETTE, SERGE 3, 4 2020-08-10 10 0.99 156,500 1,500 Limited Asbestos Corporation Common Shares MONETTE, SERGE 3, 4 2020-08-10 10 0.8 158,500 2,000 Limited Ascot Resources Ltd. Common Shares Kiernan, John Gerard 5 2020-02-27 97 60,000 Ascot Resources Ltd. Common Shares Kiernan, John Gerard 5 2020-02-27 56 60,000 Ascot Resources Ltd. Common Shares Kiernan, John Gerard 5 2020-02-27 56 60,000 Ascot Resources Ltd. Rights RSU Kiernan, John Gerard 5 2017-10-07 00 Ascot Resources Ltd. Rights RSU Kiernan, John Gerard 5 2020-02-27 56 60,000 60,000 Aurion Resources Ltd. Common Shares Lotan Holdings Inc. 4 2020-08-10 10 1.32 7,583,000 10,000 Aurion Resources Ltd. Common Shares Lotan Holdings Inc. 4 2020-08-11 10 1.27 7,608,000 25,000 Aurora Cannabis Inc. Common Shares Szweras, Adam Kelley 4 2020-08-07 51 3.6 8,063 4,861 Aurora Cannabis Inc. Options Szweras, Adam Kelley 4 2020-08-07 51 51,424 -4,861 Auryn Resources Inc. Common Shares Arribas, Antonio 4 2015-08-17 00 Auryn Resources Inc. Common Shares Arribas, Antonio 4 2020-08-10 51 1.3 130,000 130,000 Auryn Resources Inc. Common Shares Arribas, Antonio 4 2020-08-10 51 1.42 180,000 50,000 Auryn Resources Inc. Options Arribas, Antonio 4 2020-08-10 51 1.3 200,000 -130,000 Auryn Resources Inc. Options Arribas, Antonio 4 2020-08-10 51 1.42 150,000 -50,000 Auryn Resources Inc. Common Shares Bebek, Ivan 4 2020-08-12 51 1.3 5,063,000 130,000 Auryn Resources Inc. Options Bebek, Ivan 4 2020-08-12 51 1.3 525,000 -130,000 Auryn Resources Inc. Common Shares Wallace, Shawn 3, 4, 5 2020-08-07 51 1.3 3,042,633 130,000 Auryn Resources Inc. Common Shares Wallace, Shawn 3, 4, 5 2020-08-07 10 3.16 2,912,633 -130,000 Auryn Resources Inc. Options Wallace, Shawn 3, 4, 5 2020-08-07 51 1.3 525,000 -130,000 Avalon Advanced Materials Options Wiseman, Mark Edward 5 2020-08-06 52 900,000 -80,000 Inc. Avicanna Inc. Common Shares Ali, Muhamad Amza 5 2020-07-29 57 3,752 3,126 Avicanna Inc. Rights Restricted Share Ali, Muhamad Amza 5 2020-07-29 57 6,254 -3,126 Units Avicanna Inc. Common Shares Giesselman, Janet 4 2020-07-29 57 34,027 1,927 Avicanna Inc. Rights Restricted Share Giesselman, Janet 4 2019-07-29 00 5,781 Units Avicanna Inc. Rights Restricted Share Giesselman, Janet 4 2020-07-29 57 3,854 -1,927 Units Avicanna Inc. Common Shares Nosiglia, Lucas Pablo 7, 5 2020-07-29 57 325,113 5,113 Avicanna Inc. Rights Restricted Share Nosiglia, Lucas Pablo 7, 5 2020-07-29 57 10,227 -5,113 Units

August 20, 2020 (2020), 43 OSCB 6615

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Avicanna Inc. Common Shares Panchal, Chandra 4 2020-07-29 57 156,641 2,083 Avicanna Inc. Rights Restricted Share Panchal, Chandra 4 2020-07-29 57 4,167 -2,083 Units Avicanna Inc. Common Shares Purohit, Setu Nimish 4, 5 2020-07-29 57 2,576,322 5,370 Avicanna Inc. Rights Restricted Share Purohit, Setu Nimish 4, 5 2020-07-29 57 10,740 -5,370 Units Avicanna Inc. Common Shares White, David 4 2020-06-10 10 1.23 36,345 1,032 Avicanna Inc. Common Shares White, David 4 2020-07-29 57 38,324 1,979 Avicanna Inc. Options White, David 4 2020-01-24 50 2.75 35,000 5,000 Avicanna Inc. Rights Restricted Share White, David 4 2020-04-27 56 1.7 15,716 9,779 Units Avicanna Inc. Rights Restricted Share White, David 4 2020-04-27 56 1.46 43,657 27,941 Units Avicanna Inc. Rights Restricted Share White, David 4 2020-07-29 57 41,678 -1,979 Units Axis Auto Finance Inc. Common Shares Hudson, Todd Charles 5 2020-08-07 10 0.418 6,133,876 11,900 Axis Auto Finance Inc. Common Shares Hudson, Todd Charles 5 2020-08-12 10 0.49 6,134,876 1,000 Axis Auto Finance Inc. Common Shares Hudson, Todd Charles 5 2020-08-13 10 0.4722 6,144,876 10,000 Axis Auto Finance Inc. Common Shares Hudson, Todd Charles 5 2020-08-14 10 0.4722 10,000 Axis Auto Finance Inc. Common Shares Hudson, Todd Charles 5 2020-08-14 10 0.5 6,149,876 5,000 Axis Auto Finance Inc. Common Shares Hudson, Todd Charles 5 2020-08-14 10 0.507 6,154,876 5,000 Aztec Minerals Corp. Common Shares Cooke, Bradford 4 2020-08-07 10 0.41 3,288,083 -37,000 Aztec Minerals Corp. Common Shares Cooke, Bradford 4 2020-08-10 10 0.48 3,188,083 -100,000 Aztec Minerals Corp. Options Cooke, Bradford 4 2020-08-07 50 1,000,000 300,000 Aztec Minerals Corp. Options Dyakowski, Simon 5 2020-08-01 00 Christopher Aztec Minerals Corp. Options Dyakowski, Simon 5 2020-08-07 50 0.4 300,000 300,000 Christopher Aztec Minerals Corp. Options Wilkins, Joseph 5 2020-08-07 50 0.4 2,000,000 300,000 B2Gold Corp. Common Shares Bartz, Eduard 5 2019-04-03 10 3.65 0 -25,000 B2Gold Corp. Common Shares Bartz, Eduard 5 2020-08-10 57 9.36 13,251 13,251 B2Gold Corp. Common Shares Bartz, Eduard 5 2020-08-10 10 9.49 0 -13,251 B2Gold Corp. Units Restricted Share Bartz, Eduard 5 2020-08-10 57 9.36 111,456 -13,251 Units (Common Shares) B2Gold Corp. Common Shares Cinnamond, Michael 5 2020-08-10 57 9.36 67,230 46,382 Andrew B2Gold Corp. Common Shares Cinnamond, Michael 5 2020-08-10 10 9.49 40,767 -26,463 Andrew B2Gold Corp. Restricted Share Units Cinnamond, Michael 5 2020-08-10 57 9.36 392,124 -46,382 Andrew B2Gold Corp. Common Shares Craig, Dale Alton 5 2020-08-10 57 9.36 56,241 13,251 B2Gold Corp. Common Shares Craig, Dale Alton 5 2020-08-10 10 9.49 42,990 -13,251 B2Gold Corp. Rights Restricted Share Craig, Dale Alton 5 2020-08-10 57 9.36 129,474 -13,251 Units B2Gold Corp. Common Shares Garagan, Thomas 5 2020-08-10 57 9.36 1,633,306 46,382 B2Gold Corp. Common Shares Garagan, Thomas 5 2020-08-10 10 9.49 1,586,924 -46,382 B2Gold Corp. Restricted Share Units Garagan, Thomas 5 2020-08-10 57 9.36 392,124 -46,382 B2Gold Corp. Common Shares Gayton, Robert 4 2020-08-10 10 9.4 187,500 -12,500 B2Gold Corp. Common Shares Gayton, Robert 4 2020-08-12 10 8.65 182,500 -5,000 B2Gold Corp. Common Shares Gayton, Robert 4 2020-08-13 10 8.8 175,000 -7,500 B2Gold Corp. Common Shares Johnson, Clive Thomas 4 2020-08-10 57 9.36 3,538,951 165,648 B2Gold Corp. Common Shares Johnson, Clive Thomas 4 2020-08-10 10 9.4914 3,373,303 -165,648 B2Gold Corp. Restricted Share Units Johnson, Clive Thomas 4 2020-08-10 57 9.36 1,204,010 -165,648 B2Gold Corp. Restricted Share Units Johnson, Clive Thomas 4 2020-08-10 57 9.4914 165,648 B2Gold Corp. Restricted Share Units Johnson, Clive Thomas 4 2020-08-10 57 9.36 165,648 B2Gold Corp. Restricted Share Units Johnson, Clive Thomas 4 2020-08-10 57 9.36 165,648 B2Gold Corp. Restricted Share Units Johnson, Clive Thomas 4 2020-08-10 10 9.4914 -165,648 B2Gold Corp. Restricted Share Units Johnson, Clive Thomas 4 2020-08-10 10 9.4914 -165,648 B2Gold Corp. Common Shares Lytle, William 5 2020-08-10 57 9.36 126,795 46,382 B2Gold Corp. Common Shares Lytle, William 5 2020-08-10 10 9.49 80,413 -46,382 B2Gold Corp. Restricted Share Units Lytle, William 5 2020-08-10 57 9.36 392,124 -46,382

August 20, 2020 (2020), 43 OSCB 6616

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed B2Gold Corp. Common Shares MacLean, Ian 5 2020-08-10 57 9.36 8,283 B2Gold Corp. Common Shares MacLean, Ian 5 2020-08-10 57 9.36 8,283 B2Gold Corp. Common Shares MacLean, Ian 5 2020-08-10 10 9.4914 -8,283 B2Gold Corp. Common Shares MacLean, Ian 5 2020-08-10 10 9.4914 -8,283 B2Gold Corp. Common Shares MacLean, Ian 5 2020-08-10 57 9.36 504,852 8,283 B2Gold Corp. Common Shares MacLean, Ian 5 2020-08-10 10 9.4914 496,569 -8,283 B2Gold Corp. Restricted Share Units MacLean, Ian 5 2020-08-10 57 9.36 -8,283 B2Gold Corp. Restricted Share Units MacLean, Ian 5 2020-08-10 57 9.36 -8,283 B2Gold Corp. Restricted Share Units MacLean, Ian 5 2020-08-10 57 9.36 8,283 B2Gold Corp. Restricted Share Units MacLean, Ian 5 2020-08-10 57 9.36 8,283 B2Gold Corp. Restricted Share Units MacLean, Ian 5 2020-08-10 10 9.4914 -8,283 B2Gold Corp. Restricted Share Units MacLean, Ian 5 2020-08-10 10 9.4914 -8,283 B2Gold Corp. Restricted Share Units MacLean, Ian 5 2020-08-10 57 9.36 86,440 -8,283 B2Gold Corp. Common Shares Rajala, John Alex 5 2020-08-10 57 9.36 23,190 B2Gold Corp. Common Shares Rajala, John Alex 5 2020-08-10 57 9.36 195,359 23,190 B2Gold Corp. Common Shares Rajala, John Alex 5 2020-08-10 10 9.49 -23,190 B2Gold Corp. Common Shares Rajala, John Alex 5 2020-08-10 10 9.49 185,847 -9,512 B2Gold Corp. Rights Rajala, John Alex 5 2020-08-10 57 9.36 -23,190 B2Gold Corp. Rights Rajala, John Alex 5 2020-08-10 57 9.36 139,413 -23,190 B2Gold Corp. Common Shares Reeder, Neil 5 2020-08-10 57 9.36 9,939 9,939 B2Gold Corp. Common Shares Reeder, Neil 5 2020-08-10 10 9.4914 0 -9,939 B2Gold Corp. Rights Restricted Share Reeder, Neil 5 2020-08-10 57 9.36 88,097 -9,939 Units B2Gold Corp. Common Shares Richer, Roger 5 2020-08-10 58 - 9.36 396,382 46,382 Expirat ion of rights B2Gold Corp. Common Shares Richer, Roger 5 2020-08-10 10 9.49 350,000 -46,382 B2Gold Corp. Restricted Share Units Richer, Roger 5 2020-08-10 57 9.36 392,124 -46,382 B2Gold Corp. Common Shares Scott, Brian 5 2020-08-10 57 9.36 162,758 13,251 B2Gold Corp. Common Shares Scott, Brian 5 2020-08-10 10 9.49 149,507 -13,251 B2Gold Corp. Units Restricted Share Scott, Brian 5 2020-08-10 57 9.36 129,474 -13,251 Units B2Gold Corp. Common Shares Stansbury, Dennis 5 2020-08-10 57 9.36 3,035,315 39,756 B2Gold Corp. Common Shares Stansbury, Dennis 5 2020-08-10 10 9.49 2,995,559 -39,756 B2Gold Corp. Restricted Share Units Stansbury, Dennis 5 2020-08-10 57 9.36 385,498 -39,756 Badger Daylighting Ltd. Common Shares Wallace, Tracey Lynn 5 2020-08-11 10 36.6 4,005 -930 Barrick Gold Corporation Common Shares Hill, Mark Francis 5 2020-08-12 10 35.19 34,697 25,244 Barrick Gold Corporation Rights Restricted Share Hill, Mark Francis 5 2020-03-16 30 21.69 50,468 225 Units (cash settled) Barrick Gold Corporation Rights Restricted Share Hill, Mark Francis 5 2020-06-15 30 32.74 50,615 147 Units (cash settled) Barrick Gold Corporation Rights Restricted Share Hill, Mark Francis 5 2020-08-10 59 37.766 0 -50,615 Units (cash settled) Barsele Minerals Corp. Common Shares Cope, Gary Gordon 4 2020-08-07 10 0.5 15,644,300 11,000 Barsele Minerals Corp. Common Shares Cope, Gary Gordon 4 2020-08-10 10 0.55 15,689,300 45,000 Bayhorse Silver Inc. Common Shares O'Neill, Graeme 5 2020-07-02 11 0.08 1,750,000 Bayhorse Silver Inc. Common Shares O'Neill, Graeme 5 2020-07-02 16 0.08 12,219,862 1,750,000 Bayhorse Silver Inc. Common Shares O'Neill, Graeme 5 2020-07-10 11 0.08 687,500 Bayhorse Silver Inc. Common Shares O'Neill, Graeme 5 2020-07-10 16 0.08 12,907,362 687,500 Bayhorse Silver Inc. Common Shares O'Neill, Graeme 5 2020-08-04 11 0.125 610,000 Bayhorse Silver Inc. Common Shares O'Neill, Graeme 5 2020-08-04 16 0.125 13,517,362 610,000 Bayhorse Silver Inc. Warrants O'Neill, Graeme 5 2020-07-02 11 1,750,000 Bayhorse Silver Inc. Warrants O'Neill, Graeme 5 2020-07-02 16 22,511,934 1,750,000 Bayhorse Silver Inc. Warrants O'Neill, Graeme 5 2020-07-10 11 687,500 Bayhorse Silver Inc. Warrants O'Neill, Graeme 5 2020-07-10 16 23,199,434 687,500 Bayhorse Silver Inc. Warrants O'Neill, Graeme 5 2020-08-04 11 610,000 Bayhorse Silver Inc. Warrants O'Neill, Graeme 5 2020-08-04 16 23,809,434 610,000 Belo Sun Mining Corp. Common Shares Tagliamonte, Peter Wilson 4 2020-08-07 11 3,242,335 Belo Sun Mining Corp. Common Shares Tagliamonte, Peter Wilson 4 2020-08-07 11 3,242,335

August 20, 2020 (2020), 43 OSCB 6617

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Benchmark Botanics Inc. Common Shares Stowell, Claude Clifford 4 2020-08-06 10 0.22 847,600 -2,000 Benchmark Botanics Inc. Common Shares Stowell, Claude Clifford 4 2020-08-10 10 0.2 822,600 -25,000 Benchmark Botanics Inc. Common Shares Stowell, Claude Clifford 4 2020-08-11 10 0.2 772,600 -50,000 Big Rock Brewery Inc. Common Shares Noone, Patrick Donnell 4 2020-07-31 10 3.07 1,854,600 10,000 Big Rock Brewery Inc. Common Shares Noone, Patrick Donnell 4 2020-08-07 10 3.53 1,864,600 10,000 Big Rock Brewery Inc. Common Shares Noone, Patrick Donnell 4 2020-08-12 10 3.62 1,869,600 5,000 Biomark Diagnostics Inc. Common Shares HUANG, GUOYU 5 2020-08-12 10 0.22 2,348,404 2,000 Black Iron Inc. Options Kwasik, Les 5 2020-06-15 50 0.095 1,900,000 1,000,000 Black Iron Inc. Options Kwasik, Les 5 2020-07-28 52 0.05 1,400,000 -500,000 Black Iron Inc. Options Simpson, Matthew James 5 2020-07-28 52 0.05 4,550,000 -1,000,000 Black Mammoth Metals Common Shares Henderson, Dustin 4, 5 2020-08-10 10 0.12 2,042,253 2,500 Corporation Christopher Blackhawk Growth Corp. Options Antony, David Michael 4, 5 2020-08-11 50 0.05 2,200,000 1,000,000 Blackhawk Growth Corp. Options Antony, David Michael 4, 5 2020-08-12 52 1,500,000 -700,000 Blackhawk Growth Corp. Options Lowenstein, Marc Adam 4 2019-07-29 50 0.1 300,000 300,000 Blackhawk Growth Corp. Options Lowenstein, Marc Adam 4 2019-12-20 00 Blackhawk Growth Corp. Options Lowenstein, Marc Adam 4 2020-08-11 50 0.05 1,300,000 1,000,000 Blackhawk Growth Corp. Options OWEN, DALE 4 2020-08-11 50 700,000 500,000 Blackhawk Growth Corp. Options Pels, Frederick 5 2020-08-11 50 0.05 3,300,000 3,000,000 BlockchainK2 Corp. Common Shares Stytsenko, Andri 4 2020-08-06 10 0.58 241,000 -37,500 (formerly Africa Hydrocarbons Inc.) BlockchainK2 Corp. Common Shares Stytsenko, Andri 4 2020-08-07 10 0.58 220,000 -21,000 (formerly Africa Hydrocarbons Inc.) Blue Star Gold Corp. Common Shares Kuhn, Peter Martin 5 2020-08-10 51 0.1 2,648,500 250,000 Blue Star Gold Corp. Options Kuhn, Peter Martin 5 2020-08-10 51 0.1 1,050,000 -250,000 Blue Star Gold Corp. Options Metcalfe, Robert 4 2020-08-07 50 0.125 2,100,000 300,000 Blue Star Gold Corp. Options Yurichuk, Kenneth R. 4 2020-08-07 50 0.125 2,100,000 300,000 BMTC Group Inc. Common Shares Castiglio, Gabriel 4 2020-08-06 10 9.5995 24,010 2,116 BMTC Group Inc. Common Shares Castiglio, Gabriel 4 2020-08-10 10 9.9418 25,970 1,960 BMTC Group Inc. Common Shares Castiglio, Gabriel 4 2020-08-10 10 9.6499 27,028 1,058 BMTC Group Inc. Common Shares Fionda, Tony 4 2020-08-04 10 9.3394 26,904 4,892 BMTC Group Inc. Common Shares Fionda, Tony 4 2020-08-06 10 9.65 27,351 447 BMTC Group Inc. Common Shares Leclair, Anne-Marie 4 2020-08-10 10 9.9418 7,627 444 BMTC Group Inc. Common Shares Leclair, Anne-Marie 4 2020-08-12 10 9.95 8,827 1,200 Bold Ventures Inc. Common Shares Brunelle, Steven Samuel 4 2020-08-11 16 0.05 200,000 200,000 Bold Ventures Inc. Warrants Brunelle, Steven Samuel 4 2020-08-11 16 200,000 200,000 Bold Ventures Inc. Common Shares Graham, David Bruce 4 2020-08-07 16 0.05 802,105 500,567 Bold Ventures Inc. Common Shares Johnstone, William Roy 4, 5 2020-08-07 46 0.05 1,200,000 Bold Ventures Inc. Common Shares Johnstone, William Roy 4, 5 2020-08-07 16 0.05 1,429,849 1,200,000 Bombardier Inc. Performance Share Beaudoin, Pierre 4, 5 2020-08-12 57 -586,598 Units/Unites d'actions liees au rendement Bombardier Inc. Performance Share Beaudoin, Pierre 4, 5 2020-08-12 57 -586,598 Units/Unites d'actions liees au rendement Bombardier Inc. Performance Share Beaudoin, Pierre 4, 5 2020-08-12 57 0 -586,598 Units/Unites d'actions liees au rendement Bombardier Inc. Subordinate Voting Beaudoin, Pierre 4, 5 2020-08-12 57 0.42 1,492,432 539,671 Shares Classe B/ Class B Shares ( Subordinate Voting) Bombardier Inc. Subordinate Voting Beaudoin, Pierre 4, 5 2020-08-14 97 0.42 952,761 -539,671 Shares Classe B/ Class B Shares ( Subordinate Voting) Bombardier Inc. Performance Share Coleal, David 5 2020-08-12 57 -761,422 Units/Unites d'actions liees au rendement Bombardier Inc. Performance Share Coleal, David 5 2020-08-12 57 -761,422 Units/Unites d'actions liees au rendement

August 20, 2020 (2020), 43 OSCB 6618

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Bombardier Inc. Performance Share Coleal, David 5 2020-08-12 57 1,763,266 -761,422 Units/Unites d'actions liees au rendement Bombardier Inc. Subordinate Voting Coleal, David 5 2020-08-12 57 0.42 625,810 322,685 Shares Classe B/ Class B Shares ( Subordinate Voting) Bombardier Inc. Performance Share Di Bert, John 5 2020-08-12 57 -761,422 Units/Unites d'actions liees au rendement Bombardier Inc. Performance Share Di Bert, John 5 2020-08-12 57 -761,422 Units/Unites d'actions liees au rendement Bombardier Inc. Performance Share Di Bert, John 5 2020-08-12 57 1,763,266 -761,422 Units/Unites d'actions liees au rendement Bombardier Inc. Subordinate Voting Di Bert, John 5 2020-08-12 57 0.42 854,653 312,490 Shares Classe B/ Class B Shares ( Subordinate Voting) Bonavista Energy Performance Incentive Estep, Rochelle Lee 5 2020-08-11 59 0.05 0 -248,600 Corporation Awards (PIA) Bonavista Energy Restricted Share Awards Estep, Rochelle Lee 5 2020-08-11 59 0.05 0 -45,000 Corporation (RSA) Bonavista Energy Performance Incentive Jensen, Bruce Wayne 5 2020-08-11 59 0.05 0 -600,000 Corporation Awards (PIA) Bonavista Energy Restricted Share Awards Jensen, Bruce Wayne 5 2020-08-11 59 0.05 0 -93,334 Corporation (RSA) Bonavista Energy Performance Incentive Kobelka, Dean Mark 5 2020-08-11 59 0.05 0 -600,000 Corporation Awards (PIA) Bonavista Energy Restricted Share Awards Kobelka, Dean Mark 5 2020-08-11 59 0.05 0 -93,336 Corporation (RSA) Bonavista Energy Performance Incentive Ranger, Colin 5 2020-08-11 59 0.05 0 -372,000 Corporation Awards (PIA) Bonavista Energy Restricted Share Awards Ranger, Colin 5 2020-08-11 59 0.05 0 -53,333 Corporation (RSA) Bonavista Energy Performance Incentive Robinson, Lynda Julie 5 2020-08-11 59 0.05 0 -342,000 Corporation Awards (PIA) Bonavista Energy Restricted Share Awards Robinson, Lynda Julie 5 2020-08-11 59 0.05 0 -53,334 Corporation (RSA) Bonavista Energy Performance Incentive Shimek, Scott 5 2020-08-11 59 0.05 0 -372,000 Corporation Awards (PIA) Bonavista Energy Restricted Share Awards Shimek, Scott 5 2020-08-11 59 0.05 0 -53,334 Corporation (RSA) Bonavista Energy Performance Incentive Skehar, Jason Edward 4, 5 2020-08-11 59 0.05 0 -898,200 Corporation Awards (PIA) Bonavista Energy Restricted Share Awards Skehar, Jason Edward 4, 5 2020-08-11 59 0.05 0 -146,666 Corporation (RSA) BQE Water Inc. Common Shares Stein, Robert 3 2020-08-11 10 15.85 127,086 600 Brand X Lifestyle Corp. Common Shares Little, Lisa 2 2020-03-30 00 (formerly Block X Capital Corp.) Brand X Lifestyle Corp. Common Shares Little, Lisa 2 2020-08-05 11 305,000 305,000 (formerly Block X Capital Corp.) Brand X Lifestyle Corp. Common Shares Little, Lisa 2 2020-08-05 11 2,187,500 -112,500 (formerly Block X Capital Corp.) Brand X Lifestyle Corp. Common Shares Little, Lisa 2 2020-08-05 11 1,882,500 -305,000 (formerly Block X Capital Corp.) Brigadier Gold Limited Common Shares Clark, James Garnet 4 2020-08-11 00 (Garry) Brigadier Gold Limited Options Clark, James Garnet 4 2020-08-11 00 (Garry) Brigadier Gold Limited Warrants Clark, James Garnet 4 2020-08-11 00 (Garry) Brixton Metals Corporation Warrants Thompson, Randall 4 2018-07-31 00 Brixton Metals Corporation Warrants Thompson, Randall 4 2018-07-31 00

August 20, 2020 (2020), 43 OSCB 6619

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Brixton Metals Corporation Warrants Thompson, Randall 4 2018-07-31 00 Brixton Metals Corporation Warrants Thompson, Randall 4 2018-07-31 00 Brixton Metals Corporation Warrants Thompson, Randall 4 2018-07-31 00 Brixton Metals Corporation Warrants Thompson, Randall 4 2018-07-31 00 Brixton Metals Corporation Warrants Thompson, Randall 4 2018-07-31 00 Brixton Metals Corporation Warrants Thompson, Randall 4 2018-07-31 00 Brixton Metals Corporation Warrants Thompson, Randall 4 2018-07-31 00 Brixton Metals Corporation Warrants Thompson, Randall 4 2018-07-31 00 Brixton Metals Corporation Warrants Thompson, Randall 4 2018-07-31 00 Brixton Metals Corporation Warrants Thompson, Randall 4 2019-12-10 53 0.25 25,000 25,000 Brookfield Renewable Subordinate Voting Flatt, J. Bruce 7 2020-07-30 00 Corporation Shares Class A Exchangeable Brookfield Renewable Subordinate Voting Flatt, J. Bruce 7 2020-07-30 35 2,500 2,500 Corporation Shares Class A Exchangeable Brookfield Renewable Subordinate Voting Lawson, Brian 7 2020-07-30 00 Corporation Shares Class A Exchangeable Brookfield Renewable Subordinate Voting Lawson, Brian 7 2020-07-30 35 525 525 Corporation Shares Class A Exchangeable Brookfield Renewable Subordinate Voting Lawson, Brian 7 2020-07-30 00 Corporation Shares Class A Exchangeable Brookfield Renewable Subordinate Voting Lawson, Brian 7 2020-07-30 35 400 400 Corporation Shares Class A Exchangeable Brookfield Renewable Subordinate Voting McKenna, Frank 7 2020-07-30 00 Corporation Shares Class A Exchangeable Brookfield Renewable Subordinate Voting McKenna, Frank 7 2020-07-30 35 2,224 2,224 Corporation Shares Class A Exchangeable Builders Capital Mortgage Non-Voting Shares Class Loutitt, Sandy Luke 3, 4 2020-08-07 10 8.19 20,133 200 Corp. A Cache Exploration Inc. Common Shares Bal, Jatinder Singh 4 2020-08-11 37 59,786 -358,714 Cache Exploration Inc. Common Shares Bal, Jatinder Singh 4 2020-08-11 16 0.07 20,059,786 20,000,000 Calian Group Ltd. Common Shares Gauthier, Jacqueline 5 2020-08-12 30 60.06 16,846 25 Calian Group Ltd. Common Shares Gauthier, Jacqueline 5 2020-08-13 10 61.01 10,735 -6,111 Calian Group Ltd. Options Johnston, Jerry Patrick 5 2020-08-11 50 60.3 10,775 4,775 Canaccord Genuity Group Common Shares Barlow, Jeffrey Griffin 7 2020-08-11 10 7.6747 335,850 -50,000 Inc. Canaccord Genuity Group Common Shares Daviau, Daniel Joseph 7 2020-08-10 90 865,794 830,934 Inc. Canaccord Genuity Group Common Shares Daviau, Daniel Joseph 7 2020-08-10 10 7.8184 -200,000 Inc. Canaccord Genuity Group Common Shares Daviau, Daniel Joseph 7 2020-08-10 10 7.8184 -200,000 Inc. Canaccord Genuity Group Common Shares Daviau, Daniel Joseph 7 2020-08-10 10 7.8184 665,794 -200,000 Inc. Canaccord Genuity Group Common Shares Daviau, Daniel Joseph 7 2020-08-11 10 7.6074 -328,000 Inc. Canaccord Genuity Group Common Shares Daviau, Daniel Joseph 7 2020-08-11 10 7.6074 -328,000 Inc. Canaccord Genuity Group Common Shares Daviau, Daniel Joseph 7 2020-08-11 10 7.6074 337,794 -328,000 Inc. Canaccord Genuity Group Common Shares Daviau, Daniel Joseph 7 2020-08-11 10 7.6074 142,860 -72,000 Inc. Canaccord Genuity Group Common Shares Daviau, Daniel Joseph 7 2020-08-10 90 0 -830,934 Inc. Canaccord Genuity Group Common Shares Russell, Nicholas Brian 7 2020-08-06 10 7.77 5,279 -5,000 Inc. CanadaBis Capital Inc. Options Cowie, Donald 4 2020-08-10 97 0.32 -650,000 CanadaBis Capital Inc. Options Cowie, Donald 4 2020-08-10 97 0.32 650,000 -650,000 CanadaBis Capital Inc. Options McIntyre, Kimberley Jane 3 2020-08-10 97 0.5 1,800,000 -200,000

August 20, 2020 (2020), 43 OSCB 6620

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed CanadaBis Capital Inc. Options McIntyre, Kimberley Jane 3 2020-08-10 97 0.5 1,000,000 -800,000 CanadaBis Capital Inc. Options McIntyre, Travis Gerald 3, 4, 5 2020-08-10 97 0.5 2,500,000 -500,000 CanadaBis Capital Inc. Options McIntyre, Travis Gerald 3, 4, 5 2020-08-10 97 0.5 1,500,000 -1,000,000 CanadaBis Capital Inc. Options Michaud, Alex Joseph 4 2020-08-10 97 0.5 900,000 -300,000 CanadaBis Capital Inc. Options Michaud, Alex Joseph 4 2020-08-10 97 0.5 600,000 -300,000 CanadaBis Capital Inc. Options O'Neill, Barbara Michele 4, 5 2020-08-10 97 0.5 750,000 -225,000 CanadaBis Capital Inc. Options O'Neill, Barbara Michele 4, 5 2020-08-10 97 0.5 575,000 -175,000 CanadaBis Capital Inc. Options Smith, Gregory Harold 4 2020-08-10 97 0.5 800,000 -250,000 CanadaBis Capital Inc. Options Smith, Gregory Harold 4 2020-08-10 97 0.5 650,000 -150,000 Canadian General Common Shares Brown, Marcia Lewis 4 2020-08-11 10 27.52 1,200 100 Investments, Limited Canadian National Railway Common Shares Reardon, Donald K 5 2020-08-10 51 34.71 20,720 10,480 Company Canadian National Railway Common Shares Reardon, Donald K 5 2020-08-10 10 100.65 10,240 -10,480 Company Canadian National Railway Options Reardon, Donald K 5 2020-08-10 51 34.71 89,052 -10,480 Company Canadian Silver Hunter Inc. Common Shares Hunter, Jeffrey 4, 5 2020-07-30 97 0.07 7,288,700 3,092,700 CanAlaska Uranium Ltd. Options Schimann, Karl 4, 5 2020-05-08 52 595,000 -5,000 Canarc Resource Corp. Common Shares Biles, Garry 5 2020-08-10 10 0.11 1,570,783 -100,000 Canarc Resource Corp. Common Shares Biles, Garry 5 2020-08-10 10 0.11 1,470,783 -100,000 Canarc Resource Corp. Common Shares Cooke, Bradford 4, 5 2020-08-10 10 0.11 8,560,580 -150,000 Candelaria Mining Corp. Options Alexandri, Armando 5 2020-07-27 50 999,999 450,000 Candelaria Mining Corp. Units Restricted Share Alexandri, Armando 5 2020-07-27 30 0.3 770,000 770,000 Units Candelaria Mining Corp. Common Shares gomez, sergio manuel 4 2020-08-11 10 0.4 7,635,675 8,500 Candelaria Mining Corp. Options gomez, sergio manuel 4 2020-07-20 50 549,999 300,000 Candelaria Mining Corp. Units Restricted Share gomez, sergio manuel 4 2020-07-27 30 0.3 300,000 250,000 Units Candelaria Mining Corp. Options Montano, Javier 4 2020-07-27 50 580,000 80,000 Candelaria Mining Corp. Units Restricted Share Montano, Javier 4 2020-07-27 30 0.3 85,000 80,000 Units Candelaria Mining Corp. Options Perez, Ramon 5 2020-07-27 50 2,016,667 700,000 Candelaria Mining Corp. Units Restricted Share Perez, Ramon 5 2020-07-27 30 0.3 650,000 650,000 Units Candelaria Mining Corp. Options Roma, Matthew Frederick 4 2020-07-27 50 80,000 80,000 Candelaria Mining Corp. Units Restricted Share Roma, Matthew Frederick 4 2020-07-27 30 0.3 80,000 80,000 Units Candelaria Mining Corp. Options WONG, SAM K. 5 2020-07-27 50 550,000 450,000 Candelaria Mining Corp. Units Restricted Share WONG, SAM K. 5 2020-07-27 30 0.3 420,000 420,000 Units Canfor Corporation Common Shares Johansson, Mans 5 2020-08-07 10 16.036 60,100 10,100 Cannabis One Holdings Inc. Subordinate Voting Nathoo, Alnoor 4 2020-08-05 00 4,169,000 (formerly, Metropolitan Shares Class "A" Energy Corp.) subordinate voting shares Cannabis One Holdings Inc. Subordinate Voting Nathoo, Alnoor 4 2020-08-11 10 0.085 4,219,000 50,000 (formerly, Metropolitan Shares Class "A" Energy Corp.) subordinate voting shares Cannabis One Holdings Inc. Subordinate Voting Nathoo, Alnoor 4 2020-08-11 10 0.09 4,259,000 40,000 (formerly, Metropolitan Shares Class "A" Energy Corp.) subordinate voting shares Canoe Mining Ventures Common Shares Parnham, Duane 4, 5 2020-08-06 10 0.22 1,429,500 -75,000 Corp. Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2018-07-30 00 Share Unit Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2018-07-30 00 Share Unit Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2020-08-05 56 0.98 200,000 Share Unit Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2020-08-05 56 0.98 200,000 Share Unit Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2020-08-05 56 200,000 Share Unit

August 20, 2020 (2020), 43 OSCB 6621

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2020-08-05 56 200,000 Share Unit Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2018-07-30 00 Share Units Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2018-07-30 00 Share Units Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2018-07-30 00 Share Units Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2018-07-30 00 Share Units Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2018-07-30 00 Share Units Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2020-08-05 56 200,000 Share Units Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2020-08-05 56 200,000 Share Units Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2020-08-05 10 200,000 Share Units Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2020-08-05 10 200,000 Share Units Canopy Rivers Inc. Rights Performance Alexandrian, Narbe 4, 5 2020-08-05 56 200,000 200,000 Share Units Canopy Rivers Inc. Rights Performance Dufourmantelle, Olivier 5 2018-09-17 00 Share Unit Canopy Rivers Inc. Rights Performance Dufourmantelle, Olivier 5 2018-09-17 00 Share Unit Canopy Rivers Inc. Rights Performance Dufourmantelle, Olivier 5 2020-08-05 56 0.98 150,000 Share Unit Canopy Rivers Inc. Rights Performance Dufourmantelle, Olivier 5 2020-08-05 56 0.98 150,000 Share Unit Canopy Rivers Inc. Rights Performance Dufourmantelle, Olivier 5 2020-08-05 56 150,000 Share Unit Canopy Rivers Inc. Rights Performance Dufourmantelle, Olivier 5 2020-08-05 56 150,000 Share Unit Canopy Rivers Inc. Rights Performance Dufourmantelle, Olivier 5 2018-09-17 00 Share Units Canopy Rivers Inc. Rights Performance Dufourmantelle, Olivier 5 2020-08-05 56 150,000 150,000 Share Units Canopy Rivers Inc. Rights Performance Lucarelli, Edward James 5 2018-09-17 00 Share Unit Cirillo Canopy Rivers Inc. Rights Performance Lucarelli, Edward James 5 2018-09-17 00 Share Unit Cirillo Canopy Rivers Inc. Rights Performance Lucarelli, Edward James 5 2020-08-05 56 0.98 150,000 Share Unit Cirillo Canopy Rivers Inc. Rights Performance Lucarelli, Edward James 5 2020-08-05 56 0.98 150,000 Share Unit Cirillo Canopy Rivers Inc. Rights Performance Lucarelli, Edward James 5 2020-08-05 56 150,000 Share Unit Cirillo Canopy Rivers Inc. Rights Performance Lucarelli, Edward James 5 2020-08-05 56 150,000 Share Unit Cirillo Canopy Rivers Inc. Rights Performance Lucarelli, Edward James 5 2018-09-17 00 Share Units Cirillo Canopy Rivers Inc. Rights Performance Lucarelli, Edward James 5 2020-08-05 56 150,000 150,000 Share Units Cirillo Canopy Rivers Inc. Rights Performance Mundy, Matthew Jonathon 5 2018-09-17 00 Share Unit Canopy Rivers Inc. Rights Performance Mundy, Matthew Jonathon 5 2018-09-17 00 Share Unit Canopy Rivers Inc. Rights Performance Mundy, Matthew Jonathon 5 2020-08-05 56 0.98 150,000 Share Unit Canopy Rivers Inc. Rights Performance Mundy, Matthew Jonathon 5 2020-08-05 56 0.98 150,000 Share Unit Canopy Rivers Inc. Rights Performance Mundy, Matthew Jonathon 5 2020-08-05 56 150,000 Share Unit Canopy Rivers Inc. Rights Performance Mundy, Matthew Jonathon 5 2020-08-05 56 150,000 Share Unit

August 20, 2020 (2020), 43 OSCB 6622

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Canopy Rivers Inc. Rights Performance Mundy, Matthew Jonathon 5 2018-09-17 00 Share Units Canopy Rivers Inc. Rights Performance Mundy, Matthew Jonathon 5 2020-08-05 56 150,000 150,000 Share Units Canuc Resources Common Shares Berlet, Christopher James 4 2020-08-06 10 0.12 4,345,000 -1,220,000 Corporation Canuc Resources Common Shares Berlet, Christopher James 4 2020-08-06 10 0.13 4,310,600 -34,400 Corporation Canuc Resources Common Shares Berlet, Christopher James 4 2020-08-06 10 0.125 4,265,000 -45,600 Corporation Canuc Resources Common Shares Berlet, Christopher James 4 2020-08-10 16 0.1 6,515,000 2,250,000 Corporation Canuc Resources Warrants Berlet, Christopher James 4 2020-08-10 16 0.15 935,000 525,000 Corporation Canuc Resources Common Shares Li, Hao 5 2020-08-11 10 115,500 -5,000 Corporation Capital Power Corporation Common Shares Haskins, Sandra Anne 5 2020-07-30 00 2,587 Capital Power Corporation Options Haskins, Sandra Anne 5 2020-07-30 00 30,414 Capital Power Corporation Performance Share Units Haskins, Sandra Anne 5 2020-07-30 00 2,710 Capital Power Corporation Restricted Share Units Haskins, Sandra Anne 5 2020-07-30 00 5,116 Capital Power Corporation Options Kopecky, Christopher L. 5 2020-07-30 00 37,708 Capital Power Corporation Performance Share Units Kopecky, Christopher L. 5 2020-07-30 00 4,025 Capital Power Corporation Restricted Share Units Kopecky, Christopher L. 5 2020-07-30 00 7,567 Cardero Resource Corp. Common Shares Kopple, Robert Charles 3 2020-08-14 10 0.0378 45,000 Cardero Resource Corp. Common Shares Kopple, Robert Charles 3 2020-08-14 10 0.0378 24,160,823 45,000 Cardinal Energy Ltd. Common Shares Brussa, John Albert 4 2020-08-07 10 0.51 1,367,435 60,000 Cardinal Energy Ltd. Common Shares Brussa, John Albert 4 2013-12-10 00 Cardinal Energy Ltd. Common Shares Brussa, John Albert 4 2020-08-07 10 0.515 59,000 59,000 Cardinal Energy Ltd. Common Shares Ratushny, M. Scott 4, 5 2020-08-07 10 0.52 285,000 60,000 Cardinal Energy Ltd. Common Shares Ratushny, M. Scott 4, 5 2020-08-10 10 0.55 325,000 40,000 Cardinal Energy Ltd. Common Shares Ratushny, M. Scott 4, 5 2020-08-10 10 0.54 28,500 3,000 CareRx Corporation Common Shares Grewal, Alpinder 7 2020-06-22 37 3,609 -68,572 (formerly Centric Health Corporation) CareRx Corporation Common Shares Grewal, Alpinder 7 2020-07-30 10 4.46 0 -3,609 (formerly Centric Health Corporation) CareRx Corporation Restricted Stock Units Grewal, Alpinder 7 2020-06-22 37 19,900 -378,121 (formerly Centric Health Corporation) Carlyle Commodities Corp. Common Shares Good, Morgan 4, 5 2020-02-18 37 65,285 -391,716 Carlyle Commodities Corp. Common Shares Good, Morgan 4, 5 2020-02-18 37 203,357 -1,220,143 Carlyle Commodities Corp. Options Good, Morgan 4, 5 2020-02-18 37 28,571 -171,429 Cascades Inc. Common Shares Lemaire, Laurent 3 2020-08-12 10 14.91 7,793,602 300 Cascades Inc. Common Shares Lemaire, Laurent 3 2020-08-13 10 14.98 7,806,029 12,427 CBLT Inc. Common Shares Clausi, Peter Michael 4, 5 2020-08-12 36 0.025 1,859,867 900,000 CBLT Inc. Common Shares Crawford, Brian Lorne 4, 5 2020-08-12 36 0.025 1,521,800 1,020,000 Centerra Gold Inc. Rights Restricted Share Connor, Richard Webster 4 2020-08-14 59 16.96 0 -1,950 Units Centerra Gold Inc. Common Shares Millman, Darren 5 2020-08-07 51 5.99 23,645 9,285 Centerra Gold Inc. Common Shares Millman, Darren 5 2020-08-07 10 18.16 14,360 -9,285 Centerra Gold Inc. Common Shares Millman, Darren 5 2020-08-10 51 6.77 22,460 8,100 Centerra Gold Inc. Common Shares Millman, Darren 5 2020-08-10 10 18.35 19,060 -3,400 Centerra Gold Inc. Common Shares Millman, Darren 5 2020-08-10 10 18.25 14,360 -4,700 Centerra Gold Inc. Common Shares Millman, Darren 5 2020-08-10 51 5.99 27,438 13,078 Centerra Gold Inc. Common Shares Millman, Darren 5 2020-08-10 10 18.29 24,038 -3,400 Centerra Gold Inc. Common Shares Millman, Darren 5 2020-08-10 10 18.35 21,838 -2,200 Centerra Gold Inc. Common Shares Millman, Darren 5 2020-08-10 10 18.27 17,838 -4,000 Centerra Gold Inc. Common Shares Millman, Darren 5 2020-08-10 10 18.34 14,360 -3,478 Centerra Gold Inc. Options Millman, Darren 5 2020-08-07 51 5.99 346,211 -9,285 Centerra Gold Inc. Options Millman, Darren 5 2020-08-10 51 6.77 338,111 -8,100 Centerra Gold Inc. Options Millman, Darren 5 2020-08-10 51 5.99 325,033 -13,078

August 20, 2020 (2020), 43 OSCB 6623

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Centerra Gold Inc. Rights Restricted Share Oskombaev, Askar 4 2020-08-12 59 17.98 15,940 -5,000 Units Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-07 57 18.04 135,399 23,197 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-07 57 18.16 302,157 166,758 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 51 7.33 344,557 42,400 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 10 18.23 334,557 -10,000 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 10 18.19 317,157 -17,400 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 10 17.3 307,157 -10,000 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 10 18.16 302,157 -5,000 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 51 6.71 395,805 93,648 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 10 17.33 352,157 -43,648 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 10 17.33 302,157 -50,000 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 51 7.32 561,219 259,062 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 10 18.1 302,157 -259,062 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 51 6.77 513,801 211,644 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-10 10 17.63 302,157 -211,644 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-13 10 16.34 277,157 -25,000 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-13 10 16.84 227,157 -50,000 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-13 10 16.62 202,157 -25,000 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-13 10 16.5 177,157 -25,000 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-13 10 16.52 152,157 -25,000 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-13 10 16.48 132,157 -20,000 Centerra Gold Inc. Common Shares Perry, Scott Graeme 5 2020-08-13 10 16.37 112,202 -19,955 Centerra Gold Inc. Options Perry, Scott Graeme 5 2020-08-10 51 7.33 1,012,790 -42,400 Centerra Gold Inc. Options Perry, Scott Graeme 5 2020-08-10 51 6.71 919,142 -93,648 Centerra Gold Inc. Options Perry, Scott Graeme 5 2020-08-10 51 7.32 660,080 -259,062 Centerra Gold Inc. Options Perry, Scott Graeme 5 2020-08-10 51 6.77 448,436 -211,644 Centerra Gold Inc. Rights Restricted Share Perry, Scott Graeme 5 2020-08-07 57 18.04 634,452 -23,197 Units Centerra Gold Inc. Rights Restricted Share Perry, Scott Graeme 5 2020-08-07 59 18.04 607,649 -26,803 Units Centerra Gold Inc. Rights Restricted Share Perry, Scott Graeme 5 2020-08-07 57 18.16 440,891 -166,758 Units Centerra Gold Inc. Rights Restricted Share Perry, Scott Graeme 5 2020-08-07 59 18.16 248,210 -192,681 Units Centerra Gold Inc. Common Shares Pressler, Sheryl 4 2020-08-14 57 16.96 46,358 390 Centerra Gold Inc. Rights Restricted Share Pressler, Sheryl 4 2020-08-14 57 16.96 1,560 -390 Units Centerra Gold Inc. Rights Restricted Share Pressler, Sheryl 4 2020-08-14 59 16.96 0 -1,560 Units Central Timmins Exploration Common Shares McNaughton, Kenneth C. 3 2020-04-15 00 Corp. Central Timmins Exploration Common Shares McNaughton, Kenneth C. 3 2020-04-15 16 0.05 2,000,000 2,000,000 Corp. Central Timmins Exploration Common Shares McNaughton, Kenneth C. 3 2020-07-27 16 0.5 2,270,000 270,000 Corp. Central Timmins Exploration Warrants McNaughton, Kenneth C. 3 2020-04-15 00 Corp. Central Timmins Exploration Warrants McNaughton, Kenneth C. 3 2020-07-27 16 270,000 270,000 Corp. Central Timmins Exploration Common Shares Ovsenek, Joseph J. 3, 4 2020-07-27 16 0.6 2,448,748 448,748 Corp. CGI Inc. Options Evans, Richard B. 4 2020-08-05 51 15.49 44,901 -1,500 CGI Inc. Options Evans, Richard B. 4 2020-08-12 51 15.49 43,901 -1,000 CGI Inc. Subordinate Voting Evans, Richard B. 4 2020-08-05 51 15.49 1,500 1,500 Shares Classe A CGI Inc. Subordinate Voting Evans, Richard B. 4 2020-08-05 10 94.481 0 -1,500 Shares Classe A CGI Inc. Subordinate Voting Evans, Richard B. 4 2020-08-12 51 15.49 1,000 1,000 Shares Classe A CGI Inc. Subordinate Voting Evans, Richard B. 4 2020-08-12 10 93.74 0 -1,000 Shares Classe A

August 20, 2020 (2020), 43 OSCB 6624

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed CGI Inc. Subordinate Voting Godin, Serge 3, 4 2003-01-16 00 Shares Classe A CGI Inc. Subordinate Voting Godin, Serge 3, 4 2020-08-10 90 10,560 10,560 Shares Classe A CGI Inc. Subordinate Voting Godin, Serge 3, 4 2020-08-10 90 0 -10,560 Shares Classe A Chesswood Group Limited Common Shares Sonshine, Edward 3, 4 2020-08-12 10 5.01 17,000 10,000 Chesswood Group Limited Common Shares Steiner, Frederick William 7 2020-08-12 10 5.1 91,700 1,700 Chesswood Group Limited Common Shares Steiner, Frederick William 7 2020-08-12 10 5.26 92,000 300 Choom Holdings Inc. Common Shares Chris, Bogart 4 2020-08-05 10 0.09 4,296,750 90,000 CIBT Education Group Inc. Common Shares Chu, Toby 4, 5 2020-08-12 10 0.47 7,441,247 1,000 CIBT Education Group Inc. Common Shares Chu, Toby 4, 5 2020-08-12 10 0.47 7,445,247 4,000 CIBT Education Group Inc. Common Shares CIBT Education Group Inc 1 2020-08-07 10 0.47 4,035,700 50,500 CIBT Education Group Inc. Common Shares CIBT Education Group Inc 1 2020-08-11 10 0.46 4,055,700 20,000 CIBT Education Group Inc. Common Shares CIBT Education Group Inc 1 2020-08-13 10 0.47 4,058,000 2,300 Circa Enterprises Inc. Options Bourgeois, Peter Charles 4 2020-08-12 50 33,333 15,000 Circa Enterprises Inc. Options Epp, Darren 5 2020-08-12 50 65,000 40,000 Circa Enterprises Inc. Options Hulshof, Angela 5 2020-08-12 50 35,000 25,000 Circa Enterprises Inc. Options Johnston, Robert Bruce 4 2020-08-12 50 33,333 15,000 Circa Enterprises Inc. Options Lowry, Michael 4 2019-10-21 00 Circa Enterprises Inc. Options Lowry, Michael 4 2020-08-12 50 15,000 15,000 Circa Enterprises Inc. Options Reeves, Grant 4 2020-08-12 50 15,000 Circa Enterprises Inc. Options Reeves, Grant 4 2020-08-12 50 15,000 Circa Enterprises Inc. Options Reeves, Grant 4 2020-08-12 50 65,000 15,000 Circa Enterprises Inc. Options Tamagi, Cory 5 2020-08-12 50 100,000 50,000 Circa Enterprises Inc. Options White, Warren Joseph 4 2020-08-12 50 55,000 15,000 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-05-04 10 70 $100 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-05-04 10 70 $10,000 $10,000 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-05-06 10 70 $1,000 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-05-06 10 70 $110,000 $100,000 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-05-08 10 70 $2,000 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-05-08 10 70 $310,000 $200,000 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-05-20 10 72.5 $130 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-05-20 10 72.5 $323,000 $13,000 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-07-29 10 80 $230 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-07-29 10 80 $23,000 $23,000 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-07-30 10 80 $60 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-07-30 10 80 $29,000 $6,000 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-07-31 10 80 $710 6.00% échéance le 13 octobre 2021

August 20, 2020 (2020), 43 OSCB 6625

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-07-31 10 80 $100,000 $71,000 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-08-04 10 80 $20 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-08-04 10 80 $102,000 $2,000 6.00% échéance le 13 octobre 2021 Colabor Group Inc. Convertible Debentures Briscoe, Robert John 3, 4, 5 2020-08-11 10 81.25 $140,000 $38,000 6.00% échéance le 13 octobre 2021 COLLIERS Options Friedrichsen, John 5 2020-08-10 51 31.62 200,000 -50,000 INTERNATIONAL GROUP INC. COLLIERS Subordinate Voting Friedrichsen, John 5 2020-08-10 51 31.62 50,000 INTERNATIONAL GROUP Shares INC. COLLIERS Subordinate Voting Friedrichsen, John 5 2020-08-10 51 31.62 509,000 50,000 INTERNATIONAL GROUP Shares INC. Columbia Care Inc. (formerly Common Shares Boesgaard, Lars Robert 5 2020-08-07 57 51,977 12,449 known as Canaccord Genuity Growth Corp.) Columbia Care Inc. (formerly Proportionate Voting Boesgaard, Lars Robert 5 2020-08-07 57 374 -124 known as Canaccord Shares Genuity Growth Corp.) Columbia Care Inc. (formerly Common Shares Hussussian, Guy Jacques 5 2020-08-07 57 25,648 3,112 known as Canaccord Genuity Growth Corp.) Columbia Care Inc. (formerly Proportionate Voting Hussussian, Guy Jacques 5 2020-08-07 57 93 -31 known as Canaccord Shares Genuity Growth Corp.) Columbia Care Inc. (formerly Common Shares Mazanet, Rosemary 5 2020-08-07 57 745,003 699,029 known as Canaccord Genuity Growth Corp.) Columbia Care Inc. (formerly Proportionate Voting Mazanet, Rosemary 5 2020-08-07 57 1,558 -6,990 known as Canaccord Shares Genuity Growth Corp.) Columbia Care Inc. (formerly Common Shares Olson, Bryan Lamont 5 2020-08-07 57 142,775 103,101 known as Canaccord Genuity Growth Corp.) Columbia Care Inc. (formerly Proportionate Voting Olson, Bryan Lamont 5 2020-08-07 57 1,031 -1,031 known as Canaccord Shares Genuity Growth Corp.) Cominar Real Estate Trust Units Bachand, Luc 4 2020-08-12 10 7 30,936 10,000 Investment Trust Cominar Real Estate Trust Units Tremblay, René 4 2020-08-12 10 7.04 80,000 35,000 Investment Trust Condor Petroleum Inc. Common Shares Disbrow, Robert 3 2020-08-10 10 0.54 2,306,000 -29,500 Condor Petroleum Inc. Common Shares Disbrow, Robert 3 2020-08-11 10 0.54 2,300,000 -6,000 Condor Petroleum Inc. Common Shares Disbrow, Robert 3 2020-08-12 10 0.5304 2,249,000 -51,000 Condor Petroleum Inc. Common Shares Disbrow, Robert 3 2020-08-07 10 0.52 2,350,500 -50,000 Condor Petroleum Inc. Common Shares Disbrow, Robert 3 2020-08-12 10 0.53 2,300,500 -50,000 Consolidated HCI Holdings Common Shares Class B Dai, Meng Mike 4, 5 2020-08-07 00 Corporation Consolidated HCI Holdings Common Shares Class B Morris, Bradley Sanderson 4, 5 2020-08-07 00 Corporation Consolidated HCI Holdings Promissory Notes Simeon, Peter Emmanouil 4 2020-08-07 00 $25,000 Corporation Constantine Metal Common Shares Livingstone, Kent Wayne 4 2020-08-07 16 0.15 884,938 200,000 Resources Ltd. Constantine Metal Warrants Livingstone, Kent Wayne 4 2020-08-07 16 159,000 100,000 Resources Ltd. Constantine Metal Common Shares MacVeigh, James Garfield 4, 5 2020-08-07 16 0.15 1,106,765 290,000 Resources Ltd. Constantine Metal Warrants MacVeigh, James Garfield 4, 5 2020-08-07 16 181,765 145,000 Resources Ltd.

August 20, 2020 (2020), 43 OSCB 6626

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Constantine Metal Common Shares Morfopoulos, Aris 5 2020-08-07 16 0.15 100,000 100,000 Resources Ltd. Constantine Metal Warrants Morfopoulos, Aris 5 2006-04-05 00 Resources Ltd. Constantine Metal Warrants Morfopoulos, Aris 5 2020-08-07 16 50,000 50,000 Resources Ltd. Constantine Metal Common Shares Tognetti, John 3 2020-08-07 11 0.15 6,656,421 653,333 Resources Ltd. Constantine Metal Warrants Tognetti, John 3 2020-08-07 11 326,626 Resources Ltd. Constantine Metal Warrants Tognetti, John 3 2020-08-07 11 1,797,255 326,667 Resources Ltd. Constantine Metal Common Shares Vande Guchte, Michael 5 2020-08-07 00 105,000 Resources Ltd. John Constantine Metal Options Vande Guchte, Michael 5 2020-08-07 00 250,000 Resources Ltd. John Constantine Metal Warrants Vande Guchte, Michael 5 2020-08-07 00 50,000 Resources Ltd. John Corby Spirit and Wine Common Shares Class A Cote, Stephane 5 2020-07-28 30 16.095 13,997 177 Limited (formerly Corby Distilleries Limited) Corby Spirit and Wine Common Shares Class A Mayle, Edward 4, 5 2020-07-28 30 16.095 2,440 113 Limited (formerly Corby Distilleries Limited) Corby Spirit and Wine Common Shares Class A Thorne, Mark 5 2020-07-28 30 16.095 2,255 172 Limited (formerly Corby Distilleries Limited) Corby Spirit and Wine Common Shares Class A Valencia, Marc Andrew 5 2020-07-28 30 16.095 36,001 205 Limited (formerly Corby Distilleries Limited) Corsurex Resource Corp. Common Shares Barnett, Richard 4 2020-07-20 00 50,000 Corsurex Resource Corp. Warrants Barnett, Richard 4 2020-07-20 00 50,000 CounterPath Corporation Common Shares Carothers, Todd 5 2020-08-07 30 3.9297 49 CounterPath Corporation Common Shares Carothers, Todd 5 2020-08-07 30 3.9297 49 CounterPath Corporation Common Shares Carothers, Todd 5 2020-08-07 30 3.9297 17,827 49 CounterPath Corporation Common Shares Carothers, Todd 5 2020-08-07 30 4.5911 17,847 20 CounterPath Corporation Common Shares Karp, David Lawrence 5 2020-08-07 30 5.2751 32,518 38 CounterPath Corporation Common Shares Karp, David Lawrence 5 2020-08-07 30 6.1446 32,534 16 Cresco Labs Inc. Subordinate Voting Amann, Kenneth Edward 5 2018-11-30 00 Shares Cresco Labs Inc. Subordinate Voting Amann, Kenneth Edward 5 2020-01-01 11 2.25 62,500 62,500 Shares Cresco Labs Inc. Subordinate Voting Ellis, David William 5 2019-08-04 11 7.47 100,000 100,000 Shares Cresco Labs Inc. Subordinate Voting Erkes, Jason Bennett 5 2018-11-30 00 Shares Cresco Labs Inc. Subordinate Voting Erkes, Jason Bennett 5 2020-02-25 11 1 100,000 100,000 Shares Cresco Labs Inc. Subordinate Voting Erkes, Jason Bennett 5 2020-07-21 11 1 200,000 100,000 Shares Crombie Real Estate Trust Units Special Voting Empire Company Limited 3 2020-08-14 30 13.161 64,701,810 6,140 Investment Trust Cronos Group Inc. Common Shares Abraham, Todd Kevin 5 2019-08-07 00 Cronos Group Inc. Common Shares Abraham, Todd Kevin 5 2020-08-07 10 5.7837 15,000 15,000 Cronos Group Inc. Units Deferred Share Adler, Jason Marc 4 2020-08-07 56 27,764 19,280 Units [cash settled] Cronos Group Inc. Units Deferred Share EVANS, BRONWEN 4 2020-08-07 56 27,764 19,280 Units [cash settled] CHRISTINE Cronos Group Inc. Units Deferred Share Rudyk, James Daniel 4 2020-08-07 56 27,764 19,280 Units [cash settled] Crown Mining Corp. Options Cole, George 4 2020-08-11 50 0.1 600,000 200,000 Crown Mining Corp. Options Dunn, Stephen Ronald 4, 5 2020-08-11 50 0.1 700,000 200,000 Crown Mining Corp. Options Dunn, Stephen Ronald 4, 5 2020-08-11 52 0.1 600,000 -100,000 Crown Mining Corp. Options Fairbairn, James Neville 4 2020-08-11 50 0.1 500,000 200,000 Crown Mining Corp. Options Hughes, Stephen G. 4 2020-08-11 50 400,000 200,000

August 20, 2020 (2020), 43 OSCB 6627

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Crown Mining Corp. Options McRae, Peter Croft 4 2020-08-11 50 0.1 600,000 200,000 CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-07 10 0.12 747,000 1,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-07 10 0.13 787,000 40,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-07 10 0.13 789,000 2,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-07 10 0.13 790,000 1,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-07 10 0.13 791,000 1,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-07 10 0.13 827,000 36,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-07 10 0.12 846,500 19,500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-10 10 0.13 882,000 35,500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-10 10 0.13 884,500 2,500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-10 10 0.13 887,000 2,500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-10 10 0.13 889,500 2,500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-10 10 0.13 922,000 32,500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-11 10 0.135 923,500 1,500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-11 10 0.135 924,500 1,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-11 10 0.135 944,500 20,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-11 10 0.135 984,500 40,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-11 10 0.135 1,024,500 40,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-12 10 0.135 1,064,500 40,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-12 10 0.135 1,104,500 40,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-12 10 0.135 1,164,500 60,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-12 10 0.135 1,204,500 40,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-12 10 0.135 1,222,000 17,500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-12 10 0.135 1,223,500 1,500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-12 10 0.135 1,224,000 500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-12 10 0.135 1,262,000 38,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-13 10 0.135 1,295,500 33,500 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-13 10 0.135 1,335,500 40,000 Corp. CWC Energy Services Corp. Common Shares CWC Energy Services 1 2020-08-13 10 0.135 1,375,500 40,000 Corp. Cypherpunk Holdings Inc. Common Shares Guoga, Antanas (Tony) 4, 5 2020-08-10 10 0.075 7,276,000 202,000 Cypherpunk Holdings Inc. Common Shares Guoga, Antanas (Tony) 4, 5 2020-08-11 10 0.085 7,376,000 100,000 Cypherpunk Holdings Inc. Common Shares Guoga, Antanas (Tony) 4, 5 2020-08-12 10 0.0864 7,426,000 50,000 Desert Mountain Energy Common Shares Rohlfing, Robert 4 2019-01-17 00 1,964,000 Corp. Desert Mountain Energy Options Rohlfing, Robert 4 2020-03-09 50 0.22 900,000 100,000 Corp. DGTL Holdings Inc. Common Shares Belfontaine, John David 3, 4, 5 2020-08-04 10 1,860,000 25,000 (formerly Conscience Alexander Capital Inc.)

August 20, 2020 (2020), 43 OSCB 6628

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed DGTL Holdings Inc. Common Shares Belfontaine, John David 3, 4, 5 2020-08-04 10 1,880,000 20,000 (formerly Conscience Alexander Capital Inc.) DGTL Holdings Inc. Common Shares Belfontaine, John David 3, 4, 5 2020-08-06 10 1,890,000 10,000 (formerly Conscience Alexander Capital Inc.) DGTL Holdings Inc. Common Shares Belfontaine, John David 3, 4, 5 2020-08-07 10 1,891,000 1,000 (formerly Conscience Alexander Capital Inc.) Diagnos Inc. Common Shares Coffin, Tristram 3 2020-08-11 10 0.14 2,286,934 78,000 Diamond Fields Resources Common Shares Gourley, Albert Carlisle 4 2020-08-07 10 0.125 2,550,000 50,000 Inc. Digital Consumer Dividend Trust Units Digital Consumer Dividend 1 2020-08-07 38 12.272 614,400 2,300 Fund Fund Digital Consumer Dividend Trust Units Digital Consumer Dividend 1 2020-08-10 38 12.132 615,900 1,500 Fund Fund Digital Consumer Dividend Trust Units Digital Consumer Dividend 1 2020-08-11 38 11.892 617,700 1,800 Fund Fund Digital Consumer Dividend Trust Units Digital Consumer Dividend 1 2020-08-12 38 11.844 618,400 700 Fund Fund Digital Consumer Dividend Trust Units Digital Consumer Dividend 1 2020-08-13 38 11.888 619,000 600 Fund Fund Discovery Metals Corp. Common Shares 2176423 Ontario Ltd. 3 2020-08-07 16 1.35 77,136,611 11,111,000 Discovery Metals Corp. Warrants 2176423 Ontario Ltd. 3 2020-08-07 16 1.75 14,646,409 5,555,500 Discovery Metals Corp. Common Shares Smith, Moira Tracey 4 2020-08-11 10 2.7963 50,000 Discovery Metals Corp. Common Shares Smith, Moira Tracey 4 2020-08-11 10 2.7963 50,000 Discovery Metals Corp. Common Shares Smith, Moira Tracey 4 2020-08-11 10 2.7963 920,000 -50,000 Discovery Metals Corp. Common Shares Sprott, Eric S. 6 2020-08-07 16 1.35 77,136,611 11,111,000 Discovery Metals Corp. Warrants Sprott, Eric S. 6 2020-08-07 16 1.75 14,646,409 5,555,500 Diversified Royalty Corp. Restricted Share Units Morrison, Sean 5 2020-08-12 56 1.86 698,393 48,729 (Common Shares) Dollarama Inc. Deferred Share Units Bekenstein, Joshua 4 2020-08-07 35 49.108 21,976 19 (DSU) Dollarama Inc. Deferred Share Units David, Gregory 4 2020-08-07 35 49.108 15,837 14 (DSU) Dollarama Inc. Deferred Share Units Garcia C., Elisa D. 4 2020-08-07 35 49.108 20,044 18 (DSU) Dollarama Inc. Deferred Share Units Gunn, Stephen 4 2020-08-07 35 49.108 10,361 10 (DSU) Dollarama Inc. Deferred Share Units Mugford, Kristin Williams 4 2020-08-07 35 49.108 9,077 8 (DSU) Dollarama Inc. Deferred Share Units Nomicos, Nicholas George 4 2020-08-07 35 49.108 22,245 20 (DSU) Dollarama Inc. Deferred Share Units Roy, Richard G 4 2020-08-07 35 49.108 21,775 19 (DSU) Dollarama Inc. Deferred Share Units Thomas, John Huw 4 2020-08-07 35 49.108 21,225 19 (DSU) Dundee Corporation Preferred Shares 5-Year Dundee Corporation 1 2020-07-31 38 16 300 300 Rate Reset First Pref. Shares, Series 2 Dundee Corporation Preferred Shares 5-Year Dundee Corporation 1 2020-07-31 38 16 0 -300 Rate Reset First Pref. Shares, Series 2 Dundee Corporation Preferred Shares Dundee Corporation 1 2020-06-30 38 15.75 1,000 1,000 Cumulative Floating Rate First Preference Shares, Series 3 Dundee Corporation Preferred Shares Dundee Corporation 1 2020-06-30 38 15.75 0 -1,000 Cumulative Floating Rate First Preference Shares, Series 3 Dundee Corporation Preferred Shares Dundee Corporation 1 2020-07-31 38 15.994 1,000 1,000 Cumulative Floating Rate First Preference Shares, Series 3

August 20, 2020 (2020), 43 OSCB 6629

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Dundee Corporation Preferred Shares Dundee Corporation 1 2020-07-31 38 15.994 0 -1,000 Cumulative Floating Rate First Preference Shares, Series 3 Dundee Precious Metals Inc. Common Shares GMT Capital Corp 3 2020-08-10 10 7.28 4,337,090 -17,700 Dundee Precious Metals Inc. Common Shares GMT Capital Corp 3 2020-08-12 10 6.77 4,266,090 -71,000 Dundee Precious Metals Inc. Common Shares GMT Capital Corp 3 2020-08-10 10 7.28 5,733,370 -23,500 Dundee Precious Metals Inc. Common Shares GMT Capital Corp 3 2020-08-12 10 6.77 5,639,370 -94,000 Dundee Precious Metals Inc. Common Shares GMT Capital Corp 3 2020-08-10 10 7.28 8,246,100 -33,800 Dundee Precious Metals Inc. Common Shares GMT Capital Corp 3 2020-08-12 10 6.77 8,111,100 -135,000 Dundee Precious Metals Inc. Common Shares GMT Capital Corp 3 2020-08-10 10 7.28 874,600 -3,600 Dundee Precious Metals Inc. Common Shares GMT Capital Corp 3 2020-08-12 10 6.77 860,200 -14,400 Earth Alive Clean Common Shares Beausoleil, Frederic 5 2020-08-14 10 0.115 745,000 100,000 Technologies Inc. Eastern Zinc Corp. Warrants Teniere, Paul John 5 2020-05-26 11 100,000 Eastern Zinc Corp. Warrants Teniere, Paul John 5 2020-05-26 11 100,000 100,000 Eguana Technologies Inc. Common Shares DHCT II Luxembourg 3 2020-08-10 16 0.13 59,025,912 461,538 S.a.r.l. Elixxer Ltd. Common Shares Zalt, Ferras 4 2020-08-11 10 0.015 12,767,697 2,422,000 Eloro Resources Ltd. Common Shares LARSEN, THOMAS 4, 5 2020-08-05 10 1.05 2,508,250 5,000 Eloro Resources Ltd. Common Shares LARSEN, THOMAS 4, 5 2020-08-05 10 1.1 2,523,250 15,000 Eloro Resources Ltd. Common Shares LARSEN, THOMAS 4, 5 2020-08-11 10 0.99 2,523,650 400 Eloro Resources Ltd. Common Shares LARSEN, THOMAS 4, 5 2020-08-11 10 1 2,528,250 4,600 Emergia Inc. (formerly The Common Shares Castonguay, Francois 4, 5 2018-03-23 00 Delma Group Inc.) Emergia Inc. (formerly The Common Shares Castonguay, Francois 4, 5 2020-08-05 10 0.75 108,843 108,843 Delma Group Inc.) Emergia Inc. (formerly The Common Shares Castonguay, Francois 4, 5 2020-08-06 10 0.75 339,776 Delma Group Inc.) Emergia Inc. (formerly The Common Shares Castonguay, Francois 4, 5 2020-08-06 10 0.75 108,843 Delma Group Inc.) Emergia Inc. (formerly The Warrants Castonguay, Francois 4, 5 2018-03-23 00 Delma Group Inc.) Emergia Inc. (formerly The Warrants Castonguay, Francois 4, 5 2020-08-05 10 108,843 108,843 Delma Group Inc.) Emerita Resources Corp. Common Shares Guy, Michael Lawrence 4 2018-10-10 00 (formerly Emerita Gold Corp.) Emerita Resources Corp. Common Shares Guy, Michael Lawrence 4 2020-07-10 16 0.05 400,000 400,000 (formerly Emerita Gold Corp.) Emerita Resources Corp. Common Shares Guy, Michael Lawrence 4 2018-10-10 00 (formerly Emerita Gold Corp.) Emerita Resources Corp. Common Shares Guy, Michael Lawrence 4 2020-07-10 16 0.05 300,000 300,000 (formerly Emerita Gold Corp.) Emerita Resources Corp. Options Guy, Michael Lawrence 4 2016-08-29 50 0.5 50,000 50,000 (formerly Emerita Gold Corp.) Emerita Resources Corp. Warrants Guy, Michael Lawrence 4 2018-10-10 00 (formerly Emerita Gold Corp.) Emerita Resources Corp. Warrants Guy, Michael Lawrence 4 2020-07-10 16 0.15 200,000 200,000 (formerly Emerita Gold Corp.) Emerita Resources Corp. Warrants Guy, Michael Lawrence 4 2018-10-10 00 (formerly Emerita Gold Corp.) Emerita Resources Corp. Warrants Guy, Michael Lawrence 4 2020-07-10 16 0.15 150,000 150,000 (formerly Emerita Gold Corp.) Enbridge Inc. Common Shares Shamla, Bradley Francis 5 2020-08-11 51 28.77 56,071 10,000 Enbridge Inc. Common Shares Shamla, Bradley Francis 5 2020-08-11 38 45.25 49,711 -6,360 Enbridge Inc. Common Shares Shamla, Bradley Francis 5 2020-08-11 10 45.25 46,071 -3,640

August 20, 2020 (2020), 43 OSCB 6630

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Enbridge Inc. Options $28.775 ($57.55) Shamla, Bradley Francis 5 2020-08-11 51 28.77 45,400 -10,000 - February 14, 2021 Expiry Endeavour Silver Corp. Common Shares Castro, Luis Renato 5 2020-08-10 51 3.23 94,600 69,600 Endeavour Silver Corp. Common Shares Castro, Luis Renato 5 2020-08-10 10 5.4332 25,000 -69,600 Endeavour Silver Corp. Common Shares Castro, Luis Renato 5 2020-08-10 51 2.14 61,600 36,600 Endeavour Silver Corp. Common Shares Castro, Luis Renato 5 2020-08-10 10 5.4332 25,000 -36,600 Endeavour Silver Corp. Options Castro, Luis Renato 5 2020-08-10 51 3.23 229,400 -69,600 Endeavour Silver Corp. Options Castro, Luis Renato 5 2020-08-10 51 2.14 192,800 -36,600 Endeavour Silver Corp. Common Shares Walton, Godfrey John 4 2020-08-10 51 4.3 428,147 300,000 Endeavour Silver Corp. Common Shares Walton, Godfrey John 4 2020-08-10 10 5.62 128,147 -300,000 Endeavour Silver Corp. Options Walton, Godfrey John 4 2020-08-10 51 4.3 964,000 -300,000 Enerflex Ltd. Rights Performance Martinez, Patricia 5 2020-08-09 59 55,297 -25,159 Share Units Enerflex Ltd. Rights Cash Performance Paravi, Anna 7 2020-08-09 59 0 -1,012 Target Plan 2017 Enerflex Ltd. Rights Cash Performance Paravi, Anna 7 2020-08-09 59 1,050 -1,051 Target Plan 2018 Enerflex Ltd. Rights Performance Pyle, Phillip 5 2020-08-09 59 19,502 -8,954 Share Units Enerflex Ltd. Options Rossiter, Marc Edward 5 2020-08-09 52 14.33 688,531 -32,013 Enerflex Ltd. Rights Performance Rossiter, Marc Edward 5 2020-08-09 59 210,958 -28,305 Share Units Enerflex Ltd. Options Stewart, Gregory Dean 5 2020-08-09 52 14.33 432,187 -35,146 Enerflex Ltd. Rights Performance Stewart, Gregory Dean 5 2020-08-09 59 54,760 -14,242 Share Units Enerplus Corporation Common Shares Culbert, Michael Robert 4 2020-01-01 56 8.8041 14,198 (Deferred Share Plan ("DSU")) Enerplus Corporation Common Shares Culbert, Michael Robert 4 2020-01-01 46 8.8041 14,198 (Deferred Share Plan ("DSU")) Enerplus Corporation Common Shares Culbert, Michael Robert 4 2020-01-01 46 8.8041 64,396 8,496 (Deferred Share Plan ("DSU")) Enerplus Corporation Common Shares Culbert, Michael Robert 4 2020-08-14 30 4.17 118 (Deferred Share Plan ("DSU")) Enerplus Corporation Common Shares Culbert, Michael Robert 4 2020-08-14 30 4.62 64,514 118 (Deferred Share Plan ("DSU")) Engine Media Holdings, Inc. Common Shares Lorincz, Darcy 5 2020-08-13 37 5,000 -70,000 (formerly Torque Esports Corp.) Engine Media Holdings, Inc. Options Lorincz, Darcy 5 2020-08-13 37 13,333 -186,667 (formerly Torque Esports Corp.) Engine Media Holdings, Inc. Common Shares Reyhani, Bryan 4 2020-08-13 37 5,000 -70,000 (formerly Torque Esports Corp.) Engine Media Holdings, Inc. Options Reyhani, Bryan 4 2020-08-13 37 20,833 -291,667 (formerly Torque Esports Corp.) Entree Resources Ltd. Common Shares SANDSTORM GOLD LTD. 3 2020-08-13 10 0.405 37,390,880 54,000 Equinox Gold Corp. Deferred Share Units Beaty, Ross J. 4 2017-10-25 00 Equinox Gold Corp. Deferred Share Units Beaty, Ross J. 4 2020-08-10 56 1,710 1,710 Equinox Gold Corp. Rights Restricted Share Belanger, Maryse 4 2020-05-15 00 Units - Time Based Equinox Gold Corp. Rights Restricted Share Belanger, Maryse 4 2020-08-10 56 5,097 5,097 Units - Time Based Equinox Gold Corp. Deferred Share Units Boggio, Lenard 4 2017-12-22 00 Equinox Gold Corp. Deferred Share Units Boggio, Lenard 4 2020-08-10 97 884 884 Equinox Gold Corp. Deferred Share Units Campbell, Gordon 4 2020-08-10 97 60,610 1,539 Equinox Gold Corp. Deferred Share Units Clark, Wesley Kanne 4 2020-08-10 97 60,579 827 Equinox Gold Corp. Deferred Share Units Koval, Marshall 4 2017-12-22 00 Equinox Gold Corp. Deferred Share Units Koval, Marshall 4 2020-08-10 97 1,653 1,653

August 20, 2020 (2020), 43 OSCB 6631

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Equinox Gold Corp. Deferred Share Units Marrone, Peter 4 2020-08-10 56 28,343 1,653 Equinox Gold Corp. Common Shares Milau, Christian 4, 5 2020-08-12 10 16.13 222,279 -55,000 Equinox Gold Corp. Common Shares Milau, Christian 4, 5 2020-08-13 54 12.5 277,529 55,250 Equitable Group Inc. Common Shares Farella, Isabelle 5 2020-08-11 51 53.15 1,479 486 Equitable Group Inc. Common Shares Farella, Isabelle 5 2020-08-11 10 83.3 993 -486 Equitable Group Inc. Options Options granted Farella, Isabelle 5 2020-08-11 51 53.15 5,333 -486 Equitable Group Inc. Common Shares Moor, Andrew 5 2020-08-14 10 85.3 39,752 -2,500 Equitable Group Inc. Common Shares Wilson, Timothy James 5 2020-08-07 51 52.9 17,969 2,500 Equitable Group Inc. Common Shares Wilson, Timothy James 5 2020-08-07 10 81 15,469 -2,500 Equitable Group Inc. Common Shares Wilson, Timothy James 5 2020-08-10 51 52.9 17,878 2,409 Equitable Group Inc. Common Shares Wilson, Timothy James 5 2020-08-10 10 83.1 15,469 -2,409 Equitable Group Inc. Common Shares Wilson, Timothy James 5 2020-08-11 51 59.98 15,472 3 Equitable Group Inc. Common Shares Wilson, Timothy James 5 2020-08-11 51 52.9 17,969 2,497 Equitable Group Inc. Common Shares Wilson, Timothy James 5 2020-08-11 10 85 15,469 -2,500 Equitable Group Inc. Options Options granted Wilson, Timothy James 5 2020-08-07 51 52.9 50,382 -2,500 Equitable Group Inc. Options Options granted Wilson, Timothy James 5 2020-08-10 51 52.9 47,973 -2,409 Equitable Group Inc. Options Options granted Wilson, Timothy James 5 2020-08-11 51 59.98 47,970 -3 Equitable Group Inc. Options Options granted Wilson, Timothy James 5 2020-08-11 51 52.9 45,473 -2,497 Equitorial Exploration Corp. Options Jassal, Brijender (Binny) 4, 5 2020-08-13 52 1,300,000 -25,000 Jassal Erdene Resource Common Shares 2176423 Ontario Ltd. 3 2020-08-11 00 Development Corporation Erdene Resource Common Shares 2176423 Ontario Ltd. 3 2020-08-11 16 0.45 33,333,333 33,333,333 Development Corporation Erdene Resource Warrants August 2020 2176423 Ontario Ltd. 3 2020-08-11 00 Development Corporation Warrants Erdene Resource Warrants August 2020 2176423 Ontario Ltd. 3 2020-08-11 16 0.6 33,333,333 33,333,333 Development Corporation Warrants Erdene Resource Common Shares Biolik, Anna 4 2020-08-12 11 0.45 103,962 22,222 Development Corporation Erdene Resource Warrants August 2020 Biolik, Anna 4 2016-06-15 00 Development Corporation Warrants Erdene Resource Warrants August 2020 Biolik, Anna 4 2020-08-12 53 0.6 22,222 22,222 Development Corporation Warrants Erdene Resource Common Shares Byrne, John Philip 4 2020-08-12 11 0.45 6,187,040 111,111 Development Corporation Erdene Resource Warrants August 2020 Byrne, John Philip 4 2004-08-26 00 Development Corporation Warrants Erdene Resource Warrants August 2020 Byrne, John Philip 4 2020-08-12 53 0.6 111,111 111,111 Development Corporation Warrants Erdene Resource Common Shares Jenkins, Robert 5 2020-08-12 11 0.45 554,611 111,111 Development Corporation Erdene Resource Warrants August 2020 Jenkins, Robert 5 2019-05-01 00 Development Corporation Warrants Erdene Resource Warrants August 2020 Jenkins, Robert 5 2020-08-12 53 0.6 111,111 111,111 Development Corporation Warrants Erdene Resource Common Shares MacDonald, Kenneth 4 2020-08-12 11 0.45 1,026,131 111,111 Development Corporation Erdene Resource Warrants August 2020 MacDonald, Kenneth 4 2019-06-20 00 Development Corporation Warrants Erdene Resource Warrants August 2020 MacDonald, Kenneth 4 2020-08-12 53 0.6 111,111 111,111 Development Corporation Warrants Erdene Resource Common Shares McRae, Cameron 4 2020-08-12 11 0.45 361,111 111,111 Development Corporation Erdene Resource Warrants August 2020 McRae, Cameron 4 2018-03-14 00 Development Corporation Warrants Erdene Resource Warrants August 2020 McRae, Cameron 4 2020-08-12 53 0.6 111,111 111,111 Development Corporation Warrants Erdene Resource Common Shares Mosher, David Vaughn 4 2020-08-12 11 0.45 662,067 111,111 Development Corporation Erdene Resource Warrants August 2020 Mosher, David Vaughn 4 2016-06-15 00 Development Corporation Warrants Erdene Resource Warrants August 2020 Mosher, David Vaughn 4 2020-08-12 53 0.6 111,111 111,111 Development Corporation Warrants

August 20, 2020 (2020), 43 OSCB 6632

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Erdene Resource Common Shares Sprott, Eric S. 3 2020-08-11 00 Development Corporation Erdene Resource Common Shares Sprott, Eric S. 3 2020-08-11 16 0.45 33,333,333 33,333,333 Development Corporation Erdene Resource Warrants August 2020 Sprott, Eric S. 3 2020-08-11 00 Development Corporation Warrants Erdene Resource Warrants August 2020 Sprott, Eric S. 3 2020-08-11 16 0.6 33,333,333 33,333,333 Development Corporation Warrants Ero Copper Corp. Common Shares richard, michel 5 2020-08-11 10 2,028,900 -21,100 Ero Copper Corp. Common Shares richard, michel 5 2020-08-13 10 2,019,200 -9,700 Ero Copper Corp. Common Shares richard, michel 5 2020-08-14 54 1.2 2,119,200 100,000 Ero Copper Corp. Warrants richard, michel 5 2020-08-14 54 1.2 166,666 -100,000 Eskay Mining Corp Common Shares Hennigh, Quinton Todd 4 2020-08-11 00 900,000 Eskay Mining Corp Options Hennigh, Quinton Todd 4 2020-08-11 00 500,000 Ether Capital Corporation Common Shares Wertz, Boris Oliver 4 2020-08-14 10 0.62 185,000 10,000 (formerly named Movit Media Corp.) Ether Capital Corporation Common Shares Wertz, Boris Oliver 4 2020-08-14 10 0.6833 205,000 20,000 (formerly named Movit Media Corp.) Eurolife Brands Inc. Common Shares Hamelin, Lindsay 4 2020-08-10 16 0.18 130,867 41,667 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-10 10 6.45 6,565,900 2,400 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-10 10 6.47 6,573,600 7,700 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-10 10 6.48 6,573,900 300 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-10 10 6.49 6,574,100 200 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-10 10 6.5 6,713,800 139,700 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-10 10 6.51 6,714,200 400 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-10 10 6.53 6,714,400 200 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-10 10 6.54 6,715,300 900 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-11 10 6.55 6,726,900 11,600 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-11 10 6.545 6,732,500 5,600 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-11 10 6.535 6,786,600 54,100 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-11 10 6.52 6,787,400 800 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-11 10 6.51 6,790,100 2,700 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-11 10 6.5 6,790,300 200 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-12 10 6.6 6,805,300 15,000 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-12 10 6.595 6,810,900 5,600 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-12 10 6.59 6,839,300 28,400 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-12 10 6.58 6,840,300 1,000 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-12 10 6.55 6,890,300 50,000 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-13 10 6.54 6,890,800 500 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-13 10 6.55 7,015,300 124,500 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-14 10 6.5 7,039,900 24,600 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-14 10 6.49 7,040,300 400 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-14 10 6.45 7,089,600 49,300 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-14 10 6.44 7,089,900 300 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-14 10 6.43 7,090,300 400 Exco Technologies Limited Common Shares Kernaghan, Edward Hume 3, 4 2020-08-14 10 6.4 7,100,300 10,000 EXMceuticals Inc. Common Shares Summers, Jonathan 5 2020-08-07 36 0.4 14,005,532 660,677 EXMceuticals Inc. Options Summers, Jonathan 5 2020-08-07 50 0.4 5,700,000 700,000 FansUnite Entertainment Common Shares Burton, Scott Anthony 4, 5 2020-08-11 00 4,293,584 Inc. (formerly, HIC Horizon Investments Capital Ltd.) FansUnite Entertainment Options Burton, Scott Anthony 4, 5 2020-08-11 00 479,825 Inc. (formerly, HIC Horizon Investments Capital Ltd.) FansUnite Entertainment Common Shares Hutchings, Jeremy 5 2020-08-11 00 4,082,461 Inc. (formerly, HIC Horizon Investments Capital Ltd.) FansUnite Entertainment Options Hutchings, Jeremy 5 2020-08-11 00 335,878 Inc. (formerly, HIC Horizon Investments Capital Ltd.)

August 20, 2020 (2020), 43 OSCB 6633

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed FansUnite Entertainment Common Shares Keane, James Edward 4 2020-08-11 00 239,912 Inc. (formerly, HIC Horizon Cyril Investments Capital Ltd.) FansUnite Entertainment Options Keane, James Edward 4 2020-08-11 00 335,878 Inc. (formerly, HIC Horizon Cyril Investments Capital Ltd.) FansUnite Entertainment Options Winter, Ian Thomas 5 2020-08-11 00 575,790 Inc. (formerly, HIC Horizon Macaulay Investments Capital Ltd.) Fennec Pharmaceuticals Options Andrade, Robert 5 2020-08-13 51 2.36 379,990 -323,961 Inc. Christopher Fennec Pharmaceuticals Options Brughera, Marco 4 2020-08-13 50 6.17 115,545 20,000 Inc. Fennec Pharmaceuticals Options Haigh, Adrian J. 4 2020-08-13 50 6.17 233,579 20,000 Inc. Fennec Pharmaceuticals Options Islam, Khalid 4 2020-08-13 50 6.17 313,825 25,000 Inc. Fennec Pharmaceuticals Options Jodi, Cook 4 2020-08-13 50 6.17 40,000 20,000 Inc. Fennec Pharmaceuticals Options Rallis, Chris Anigeron 4 2020-08-13 50 6.17 191,857 20,000 Inc. Fennec Pharmaceuticals Options Raykov, Rostislav Christov 4, 5 2020-08-13 51 2.36 20,498,662 -323,961 Inc. Fidelity Minerals Corp. Common Shares Balic, Anthony Bob 4, 5 2020-08-10 11 0.06 1,814,779 458,779 Fidelity Minerals Corp. Options Balic, Anthony Bob 4, 5 2020-08-12 50 0.105 950,000 200,000 Fidelity Minerals Corp. Warrants Balic, Anthony Bob 4, 5 2020-08-10 11 0.07 1,671,979 458,779 Fidelity Minerals Corp. Common Shares Graham, Ian 4, 5 2020-08-10 11 0.06 1,678,913 372,213 Fidelity Minerals Corp. Options Graham, Ian 4, 5 2020-08-12 50 0.105 950,000 200,000 Fidelity Minerals Corp. Warrants Graham, Ian 4, 5 2020-08-10 11 0.07 1,572,213 372,213 Fidelity Minerals Corp. Common Shares Lions Bay Capital Inc. 3 2020-08-10 11 0.06 17,989,811 5,015,583 Fidelity Minerals Corp. Warrants Lions Bay Capital Inc. 3 2020-08-10 11 0.07 11,245,583 5,015,583 Fidelity Minerals Corp. Common Shares Ozcakmak, Bahay 4 2020-08-10 11 0.06 2,927,746 455,546 Fidelity Minerals Corp. Options Ozcakmak, Bahay 4 2020-08-12 50 0.105 950,000 200,000 Fidelity Minerals Corp. Warrants Ozcakmak, Bahay 4 2020-08-10 11 0.07 1,935,546 455,546 Finning International Inc. Common Shares Palaschuk, Gregory 5 2020-08-11 10 20.77 23,412 2,750 Fireweed Zinc Ltd. Common Shares Hemstead, Peter Timothy 4 2020-04-16 00 Fireweed Zinc Ltd. Common Shares Hemstead, Peter Timothy 4 2020-08-06 11 0.65 38,461 Fireweed Zinc Ltd. Common Shares Hemstead, Peter Timothy 4 2020-08-06 11 0.65 38,461 Fireweed Zinc Ltd. Common Shares Hemstead, Peter Timothy 4 2020-08-06 16 0.65 38,461 38,461 Firm Capital Property Trust Units Smuschkowitz, Howard 5 2020-08-11 10 5.16 208,992 15,000 First Majestic Silver Corp. Common Shares Anthony, Todd Olson 5 2020-08-11 10 15.73 5,000 5,000 First Majestic Silver Corp. Common Shares Anthony, Todd Olson 5 2020-08-11 10 15.95 10,000 5,000 First Majestic Silver Corp. Common Shares Anthony, Todd Olson 5 2020-08-11 10 16.13 15,000 5,000 First Majestic Silver Corp. Common Shares Anthony, Todd Olson 5 2020-08-12 10 15.35 20,000 5,000 First Majestic Silver Corp. Common Shares Anthony, Todd Olson 5 2020-08-12 10 15.17 25,000 5,000 First Majestic Silver Corp. Common Shares Anthony, Todd Olson 5 2020-08-13 10 15.49 30,000 5,000 First Majestic Silver Corp. Common Shares Anthony, Todd Olson 5 2020-08-13 10 15.64 35,000 5,000 First Majestic Silver Corp. Common Shares Anthony, Todd Olson 5 2020-08-14 10 15.15 40,000 5,000 First Majestic Silver Corp. Common Shares Poon, Andrew Winston 5 2020-08-10 10 18.03 675 -20,000 First Majestic Silver Corp. Common Shares Poon, Andrew Winston 5 2020-08-11 51 4.8 20,675 20,000 First Majestic Silver Corp. Options Poon, Andrew Winston 5 2020-08-11 51 4.8 280,000 -20,000 First Vanadium Corp. Options ANDERSON, JOHN 4 2020-08-10 50 0.32 650,000 250,000 Fortis Inc. Common Shares Smith, Gary Joseph 7 2020-08-11 51 34.27 21,997 11,600 Fortis Inc. Common Shares Smith, Gary Joseph 7 2020-08-11 10 54.3 10,397 -11,600 Fortis Inc. Common Shares Smith, Gary Joseph 7 2020-08-12 51 33.58 16,097 5,700 Fortis Inc. Common Shares Smith, Gary Joseph 7 2020-08-12 10 54.5 10,397 -5,700 Fortis Inc. Options Smith, Gary Joseph 7 2020-08-11 51 226,568 -11,600 Fortis Inc. Options Smith, Gary Joseph 7 2020-08-12 51 220,868 -5,700 Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2018-08-16 00 (formerly, Fortress Blockchain Corp.)

August 20, 2020 (2020), 43 OSCB 6634

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-30 38 0.11 52,500 52,500 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.12 53,000 500 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.12 53,500 500 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.12 83,500 30,000 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.12 141,000 57,500 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.12 141,500 500 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.12 241,500 100,000 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.12 266,500 25,000 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.12 278,500 12,000 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.12 298,500 20,000 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.12 302,500 4,000 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.125 310,000 7,500 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.125 317,500 7,500 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-07-31 38 0.125 325,000 7,500 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-08-04 38 0.125 340,000 15,000 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-08-04 38 0.125 390,000 50,000 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-08-04 38 0.125 425,000 35,000 (formerly, Fortress Blockchain Corp.) Fortress Technologies Inc. Common Shares Fortress Technologies Inc. 1 2020-08-04 38 0.125 440,000 15,000 (formerly, Fortress Blockchain Corp.) Franco-Nevada Corporation Common Shares Gray, Eaun Harrison 5 2020-08-10 51 100.1 8,803 8,000 Franco-Nevada Corporation Common Shares Gray, Eaun Harrison 5 2020-08-10 10 210.81 803 -8,000 Franco-Nevada Corporation Options Gray, Eaun Harrison 5 2020-08-10 51 100.1 34,401 -8,000 Franco-Nevada Corporation Common Shares Rana, Sandip 5 2020-08-10 51 55.58 50,639 10,000 Franco-Nevada Corporation Common Shares Rana, Sandip 5 2020-08-10 10 208.46 40,639 -10,000 Franco-Nevada Corporation Options Rana, Sandip 5 2020-08-10 51 55.58 116,781 -10,000 Freegold Ventures Limited Common Shares Dickson, Glen Dale 4 2017-06-30 00 60,000 Freegold Ventures Limited Common Shares Glazier, Reagan 4 2020-05-05 10 0.18 55,000 Freegold Ventures Limited Common Shares Glazier, Reagan 4 2020-05-05 10 0.18 30,000 Freegold Ventures Limited Common Shares Glazier, Reagan 4 2020-05-06 10 0.18 1,091,500 30,000 Freegold Ventures Limited Common Shares Glazier, Reagan 4 2020-08-03 51 0.15 987,500 -104,000 Freegold Ventures Limited Warrants Glazier, Reagan 4 2018-06-29 00 250,000 FRONTIER LITHIUM INC. Common Shares Didone, John Ralph 4 2020-07-06 10 0.2 350,000 125,000 FRONTIER LITHIUM INC. Warrants Didone, John Ralph 4 2020-07-06 53 0.27 137,500 62,500

August 20, 2020 (2020), 43 OSCB 6635

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Fura Gems Inc. (formerly Common Shares Gupta, Gaurav 4 2020-08-11 11 0.15 0 -4,933,626 known as Fura Emeralds Inc.) Fura Gems Inc. (formerly Common Shares Lord of Seven Hills 3 2020-08-11 11 0.15 140,048,752 4,933,626 known as Fura Emeralds Holdings FZE Inc.) Fura Gems Inc. (formerly Unsecured Loan Lord of Seven Hills 3 2020-08-14 11 $37,350,000 $8,750,000 known as Fura Emeralds Holdings FZE Inc.) G2 Goldfields Inc. Options Noone, Daniel Joseph 4, 5 2020-08-13 50 0.75 1,000,000 500,000 G2 Goldfields Inc. Rights Restricted Share Noone, Daniel Joseph 4, 5 2010-11-08 00 Units G2 Goldfields Inc. Rights Restricted Share Noone, Daniel Joseph 4, 5 2020-08-13 56 500,000 500,000 Units G2 Goldfields Inc. Options Sheridan, Patrick John 3, 4, 5 2020-08-13 50 0.75 750,000 500,000 G2 Goldfields Inc. Rights Restricted Share Sheridan, Patrick John 3, 4, 5 2016-09-16 00 Units G2 Goldfields Inc. Rights Restricted Share Sheridan, Patrick John 3, 4, 5 2020-08-13 56 500,000 500,000 Units GDI Integrated Facility Subordinate Voting Trottier, Jocelyn 5 2020-08-11 10 37.65 35,922 -500 Services Inc. Shares GDI Integrated Facility Subordinate Voting Trottier, Jocelyn 5 2020-08-11 10 37.75 35,622 -300 Services Inc. Shares GDI Integrated Facility Subordinate Voting Trottier, Jocelyn 5 2020-08-13 10 37.5 34,872 -750 Services Inc. Shares GDI Integrated Facility Subordinate Voting Trottier, Jocelyn 5 2020-08-13 10 37.75 34,672 -200 Services Inc. Shares GDI Integrated Facility Subordinate Voting Trottier, Jocelyn 5 2020-08-13 10 37.85 34,272 -400 Services Inc. Shares GDI Integrated Facility Subordinate Voting Trottier, Jocelyn 5 2020-08-13 10 37.75 33,272 -1,000 Services Inc. Shares GDI Integrated Facility Subordinate Voting Trottier, Jocelyn 5 2020-08-14 10 37.75 32,522 -750 Services Inc. Shares GDI Integrated Facility Subordinate Voting Trottier, Jocelyn 5 2020-08-14 10 37.85 31,922 -600 Services Inc. Shares Gear Energy Ltd. Common Shares Wang, Wilson 4 2020-08-10 10 0.215 691,493 7,985 Generation Mining Limited Common Shares Knoll, Kerry 4 2020-08-11 10 0.44 2,999,502 50,000 Generation Mining Limited Common Shares levy, Jamie 4 2020-08-10 10 0.455 2,821,600 31,000 Generation Mining Limited Common Shares levy, Jamie 4 2020-08-10 10 0.4598 2,921,600 100,000 Generation Mining Limited Common Shares levy, Jamie 4 2020-08-10 10 0.45 3,021,600 100,000 Genesis Land Development Common Shares Genesis Land 1 2020-07-06 38 1.13 166 166 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-08 38 1.25 3,932 3,766 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-09 38 1.25 7,698 3,766 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-10 38 1.22 11,464 3,766 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-16 38 1.0377 15,230 3,766 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-17 38 1 15,396 166 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-20 38 1.1182 15,962 566 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-21 38 1.13 16,528 566 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-22 38 1.1596 18,794 2,266 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-23 38 1.16 19,260 466 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-27 38 1.1414 20,426 1,166 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-31 38 0 -20,426 Corp. Development Corp. Genesis Land Development Common Shares Genesis Land 1 2020-07-31 38 1.17 3,766 3,766 Corp. Development Corp.

August 20, 2020 (2020), 43 OSCB 6636

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed GENIUS METALS INC. Common Shares Goulet, Guy 5 2020-08-07 10 0.26 1,678,686 2,000 GENIUS METALS INC. Common Shares Goulet, Guy 5 2020-08-11 10 0.265 1,682,686 4,000 GENIUS METALS INC. Common Shares Goulet, Guy 5 2020-08-12 10 0.259 1,689,686 7,000 GENIUS METALS INC. Common Shares Goulet, Guy 5 2020-08-13 10 0.246 1,697,686 8,000 GHP Noetic Science- Options Franks, Michael 4, 5 2020-07-30 00 Psychedelic Pharma Inc. GHP Noetic Science- Options Franks, Michael 4, 5 2020-07-30 00 Psychedelic Pharma Inc. GHP Noetic Science- Options Franks, Michael 4, 5 2020-08-11 50 0.2 166,666 166,666 Psychedelic Pharma Inc. GHP Noetic Science- Options Jolley, Andrew 4 2020-07-30 00 Psychedelic Pharma Inc. GHP Noetic Science- Options Jolley, Andrew 4 2020-08-11 15 0.2 166,667 166,667 Psychedelic Pharma Inc. GHP Noetic Science- Common Shares Main, George Iain Prentice 4 2020-07-30 00 300,000 Psychedelic Pharma Inc. GHP Noetic Science- Options Main, George Iain Prentice 4 2020-07-30 00 Psychedelic Pharma Inc. GHP Noetic Science- Options Main, George Iain Prentice 4 2020-08-11 15 0.2 166,667 166,667 Psychedelic Pharma Inc. GHP Noetic Science- Common Shares Noetic Psychedelic Fund 3 2020-07-30 00 1,962,799 Psychedelic Pharma Inc. LP GHP Noetic Science- Common Shares Shah, Sa'ad 4, 5 2020-07-30 00 1,962,799 Psychedelic Pharma Inc. GHP Noetic Science- Options Shah, Sa'ad 4, 5 2020-07-30 00 Psychedelic Pharma Inc. GHP Noetic Science- Options Shah, Sa'ad 4, 5 2020-08-11 15 0.2 166,667 166,667 Psychedelic Pharma Inc. GHP Noetic Science- Common Shares Wright, Warren 4, 5 2020-07-30 00 300,000 Psychedelic Pharma Inc. GHP Noetic Science- Options Wright, Warren 4, 5 2020-07-30 00 Psychedelic Pharma Inc. GHP Noetic Science- Options Wright, Warren 4, 5 2020-08-11 15 0.2 166,667 166,667 Psychedelic Pharma Inc. GIGA Metals Corporation Common Shares Milewski, Anthony 4 2020-08-11 54 0.08 3,450,000 1,500,000 GIGA Metals Corporation Warrants Milewski, Anthony 4 2020-08-11 54 0.08 0 -1,500,000 Gildan Activewear Inc. Common Shares Chamandy, Glenn J. 4, 5 2020-08-14 10 25.588 200,000 200,000 Gildan Activewear Inc. Common Shares Harries, Rhodri 5 2020-08-11 10 19.422 59,457 25,000 Global Dividend Growers Trust Units Global Dividend Growers 1 2020-08-10 38 12.428 5,389,205 500 Income Fund Income Fund Global Dividend Growers Trust Units Global Dividend Growers 1 2020-08-11 38 12.373 5,389,905 700 Income Fund Income Fund Global Innovation Dividend Trust Units Global Innovation Dividend 1 2020-08-07 38 12.879 1,172,600 900 Fund Fund Global Innovation Dividend Trust Units Global Innovation Dividend 1 2020-08-10 38 12.711 1,175,700 3,100 Fund Fund Global Innovation Dividend Trust Units Global Innovation Dividend 1 2020-08-11 38 12.596 1,176,700 1,000 Fund Fund Global Real Estate & E- Trust Units Global Real Estate & E- 1 2020-08-07 38 13.597 623,700 3,100 Commerce Dividend Fund Commerce Dividend Fund Global Real Estate & E- Trust Units Global Real Estate & E- 1 2020-08-10 38 13.622 624,200 500 Commerce Dividend Fund Commerce Dividend Fund Global Real Estate & E- Trust Units Global Real Estate & E- 1 2020-08-11 38 13.585 626,300 2,100 Commerce Dividend Fund Commerce Dividend Fund Global Real Estate & E- Trust Units Global Real Estate & E- 1 2020-08-12 38 13.502 626,800 500 Commerce Dividend Fund Commerce Dividend Fund Global Real Estate & E- Trust Units Global Real Estate & E- 1 2020-08-13 38 13.462 627,300 500 Commerce Dividend Fund Commerce Dividend Fund GlobeX Data Ltd. Options Davis, Scott 5 2020-06-12 50 0.14 800,000 200,000 GMP Capital Inc. Rights Deferred Share Brown, David G. 4 2020-08-07 56 247,487 21,827 Units (DSU) GMP Capital Inc. Rights Deferred Share Ferguson, David Cadwell 4 2020-08-07 56 131,754 23,907 Units (DSU) GMP Capital Inc. Rights Deferred Share Wright, Donald Arthur 4 2020-08-07 56 266,896 64,368 Units (DSU)

August 20, 2020 (2020), 43 OSCB 6637

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed goeasy Ltd. (formerly, Common Shares Mullins, Jason 5 2020-08-13 35 66,316 -559 easyhome Ltd.) goeasy Ltd. (formerly, Common Shares Mullins, Jason 5 2020-08-13 35 9,924 -84 easyhome Ltd.) goeasy Ltd. (formerly, Common Shares Mullins, Jason 5 2020-08-13 35 1,284 -11 easyhome Ltd.) Gold Springs Resource Options with tandem van Doorn, Robert 4 2020-08-12 52 2,950,000 -300,000 Corp. (formerly, TriMetals share appreciation right Mining Inc.) Gold Terra Resource Corp. Options Siwanowicz, Hellen Linda 4 2020-08-11 00 Gold Terra Resource Corp. Options Siwanowicz, Hellen Linda 4 2020-08-11 50 0.435 200,000 200,000 Gold X Mining Corp. Common Shares Beharry, Suresh Edward 4 2020-08-10 51 1.6 57,000 50,000 Gold X Mining Corp. Common Shares Beharry, Suresh Edward 4 2020-08-10 51 1.92 119,500 62,500 Gold X Mining Corp. Common Shares Beharry, Suresh Edward 4 2020-08-10 10 4.2898 7,000 -112,500 Gold X Mining Corp. Options Beharry, Suresh Edward 4 2020-08-10 51 1.6 106,250 -50,000 Gold X Mining Corp. Options Beharry, Suresh Edward 4 2020-08-10 51 1.92 43,750 -62,500 Golden Share Resources Options Graham, David Bruce 4 2020-08-10 50 0.2 520,000 50,000 Corporation Golden Share Resources Options Huang, Demin 5 2020-08-10 50 0.2 270,000 25,000 Corporation Golden Share Resources Options Huang, Zhen 4 2020-08-10 50 0.2 400,000 50,000 Corporation Golden Share Resources Options Roberts, George Wesley 4 2020-08-10 50 0.2 520,000 50,000 Corporation Golden Share Resources Common Shares Zeng, Nick Nianqing 4, 5 2020-08-12 10 0.195 569,000 4,000 Corporation GoldMining Inc. (formerly Common Shares Dhaliwal, Herb 4 2020-08-05 10 2.45 26,641 -5,000 Brazil Resources Inc.) GoldMining Inc. (formerly Common Shares Dhaliwal, Herb 4 2020-08-05 10 2.47 21,641 -5,000 Brazil Resources Inc.) Goldmoney Inc. (formerly Common Shares Fray, steve 5 2020-08-10 57 79,218 13,900 BitGold Inc.) Goldmoney Inc. (formerly Rights Restricted Share Fray, steve 5 2020-08-10 57 172,102 -13,900 BitGold Inc.) Units GOLO Mobile Inc. (formerly, Common Shares Picard, Nicolas Laurent 5 2020-08-06 00 1,734,149 HAW Capital Corp.) GOLO Mobile Inc. (formerly, Options Picard, Nicolas Laurent 5 2020-08-06 00 350,000 HAW Capital Corp.) Goodfood Market Corp. Common Shares Hill, Hamnett 3, 4, 6 2017-06-01 00 (formerly Mira VII Acquisition Corp.) Goodfood Market Corp. Common Shares Hill, Hamnett 3, 4, 6 2017-06-01 00 (formerly Mira VII Acquisition Corp.) Goodfood Market Corp. Common Shares Hill, Hamnett 3, 4, 6 2017-06-01 22 2 8,033,571 (formerly Mira VII Acquisition Corp.) Goodfood Market Corp. Common Shares Hill, Hamnett 3, 4, 6 2017-06-01 22 2 8,033,571 (formerly Mira VII Acquisition Corp.) Goodfood Market Corp. Common Shares Hill, Hamnett 3, 4, 6 2017-06-01 00 (formerly Mira VII Acquisition Corp.) Goodfood Market Corp. Common Shares Hill, Hamnett 3, 4, 6 2017-06-01 22 2 8,033,571 8,033,571 (formerly Mira VII Acquisition Corp.) Goodfood Market Corp. Common Shares Hill, Hamnett 3, 4, 6 2020-08-05 15 6.05 7,463,286 -570,285 (formerly Mira VII Acquisition Corp.) GoviEx Uranium Inc. Common Shares Class A Friedland, Govind 4, 5 2020-08-06 16 0.14 24,235,191 30,715 GoviEx Uranium Inc. Warrants Friedland, Govind 4, 5 2020-08-06 16 148,363 30,715 GoviEx Uranium Inc. Common Shares Class A Wallace, Christopher 4 2020-08-06 16 0.14 631,667 100,000 GoviEx Uranium Inc. Warrants Wallace, Christopher 4 2020-08-06 16 250,000 100,000 Gran Colombia Gold Corp. Common Shares 2176423 Ontario Ltd. 3 2020-08-05 10 7.9 4,435,999 -1,146,300 Gran Colombia Gold Corp. Common Shares Sprott, Eric S. 3 2020-08-05 10 7.9 4,435,999 -1,146,300 Grand Peak Capital Corp. Common Shares Janda, Lucky Lakhwinder 3 2020-08-13 10 14,934,940 2,500

August 20, 2020 (2020), 43 OSCB 6638

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Granite REIT Inc. Deferred Share Units Murray, Sheila A. 4 2020-08-14 35 76.8 2,765 9 Great Bear Resources Ltd. Common Shares Kenyon, John Michael 4 2020-06-24 00 Great Bear Resources Ltd. Options Kenyon, John Michael 4 2020-06-24 00 150,000 Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 25.72 1,000 1,000 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 25.82 1,400 400 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 25.84 1,800 400 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 25.94 2,100 300 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 25.95 2,600 500 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 25.97 3,700 1,100 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 25.98 4,700 1,000 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 25.99 5,900 1,200 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.01 7,400 1,500 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.02 8,500 1,100 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.03 8,900 400 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.04 9,300 400 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.05 9,600 300 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.06 11,100 1,500 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.14 11,400 300 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.16 11,700 300 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.18 13,100 1,400 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.19 15,000 1,900 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.22 16,700 1,700 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.24 17,500 800 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.25 17,557 57 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.27 17,757 200 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.31 18,257 500 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.32 18,657 400 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.35 19,857 1,200 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.36 22,057 2,200 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.37 22,557 500 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.39 22,657 100 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.41 23,257 600 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.42 26,257 3,000 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.44 26,757 500 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.45 30,357 3,600 Corporation Corporation

August 20, 2020 (2020), 43 OSCB 6639

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.46 32,457 2,100 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.47 33,857 1,400 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.48 39,857 6,000 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.49 45,957 6,100 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-09 38 26.5 53,757 7,800 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-10 38 26.25 55,957 2,200 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-10 38 26.26 56,757 800 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-10 38 26.45 57,757 1,000 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-10 38 26.6 300,471 242,714 Corporation Corporation Great Canadian Gaming Common Shares Great Canadian Gaming 1 2020-07-31 38 0 -300,471 Corporation Corporation Great Thunder Gold Corp. Common Shares 2176423 Ontario Ltd. 3 2020-08-13 16 0.65 4,735,000 735,000 Great Thunder Gold Corp. Warrants 2176423 Ontario Ltd. 3 2020-02-28 00 Great Thunder Gold Corp. Warrants 2176423 Ontario Ltd. 3 2020-08-13 16 0.85 367,500 367,500 Great Thunder Gold Corp. Common Shares Naughty, Blair Lawrence 3 2020-08-13 10 0.83 3,028,480 20,000 Great Thunder Gold Corp. Common Shares Naughty, Blair Lawrence 3 2020-08-13 10 0.83 20,000 Great Thunder Gold Corp. Common Shares Sprott, Eric S. 3 2020-08-13 16 0.65 4,735,000 735,000 Great Thunder Gold Corp. Warrants Sprott, Eric S. 3 2020-02-28 00 Great Thunder Gold Corp. Warrants Sprott, Eric S. 3 2020-08-13 16 0.85 367,500 367,500 GreenBank Capital Inc. Options Wettreich, Mark David 4, 5 2020-02-04 50 0.3 800,000 600,000 Greenfields Petroleum Common Shares - New Harkins, John Wilfrid Hugh 4, 5 2020-06-23 37 363,515 -6,906,775 Corporation Greenfields Petroleum Common Shares - New Harkins, John Wilfrid Hugh 4, 5 2020-08-11 10 0.34 339,714 -23,801 Corporation Greenstone Capital Corp. Common Shares Fazil, Mohammad (Mo) 3, 4, 5 2020-08-11 10 0.1 1,025,000 5,000 Shahid Greenstone Capital Corp. Common Shares Fazil, Mohammad (Mo) 3, 4, 5 2020-08-12 10 0.1 10,000 Shahid Greenstone Capital Corp. Common Shares Fazil, Mohammad (Mo) 3, 4, 5 2020-08-12 10 0.1 1,040,000 15,000 Shahid Greenstone Capital Corp. Common Shares Fazil, Mohammad (Mo) 3, 4, 5 2020-08-14 10 0.1 1,045,000 5,000 Shahid Greenstone Capital Corp. Common Shares Fazil, Mohammad (Mo) 3, 4, 5 2020-08-14 10 0.075 1,050,000 5,000 Shahid H&R Real Estate Investment Units Avery, Alexander Danial 4, 5 2020-08-14 10 10.298 150,000 50,000 Trust Happy Creek Minerals Ltd. Common Shares GRAY, RODGER 4 2020-08-13 10 0.1053 784,702 50,000 Harrys Manufacturing Inc. Common Shares Young, Michael Louis 5 2020-08-11 10 0.27 0 -25,000 (formerly, Westridge Resources Inc.) Heatherdale Resources Ltd. Common Shares Thome, Edie 4 2020-08-12 00 1,523,473 Hemlo Explorers Inc. Common Shares Cudney, Robert Douglas 3 2020-05-20 37 5,248,915 -10,497,835 (Formerly, Canadian Orebodies Inc.) Hemlo Explorers Inc. Common Shares Cudney, Robert Douglas 3 2020-08-05 10 0.935 5,258,915 10,000 (Formerly, Canadian Orebodies Inc.) Hemlo Explorers Inc. Common Shares Cudney, Robert Douglas 3 2020-05-20 37 5,299 -10,601 (Formerly, Canadian Orebodies Inc.) Hillcrest Petroleum Ltd. Common Shares Currie, Donald James 4, 5 2020-08-07 16 0.05 10,369,813 1,000,000 Hillcrest Petroleum Ltd. Warrants Currie, Donald James 4, 5 2020-08-07 16 0.07 1,700,000 500,000 Hillcrest Petroleum Ltd. Common Shares Krzus, Michael 4 2020-08-10 11 0.05 4,570,000 1,000,000 Hillcrest Petroleum Ltd. Options Krzus, Michael 4 2020-07-28 51 0.05 450,000 Hillcrest Petroleum Ltd. Options Krzus, Michael 4 2020-07-28 51 0.05 1,300,000 -450,000 Hillcrest Petroleum Ltd. Warrants Krzus, Michael 4 2017-01-20 55 0.08 500,000

August 20, 2020 (2020), 43 OSCB 6640

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Hillcrest Petroleum Ltd. Warrants Krzus, Michael 4 2017-01-20 55 0.08 587,500 -500,000 Hillcrest Petroleum Ltd. Warrants Krzus, Michael 4 2017-07-21 55 0.1 100,000 Hillcrest Petroleum Ltd. Warrants Krzus, Michael 4 2017-07-21 55 0.1 587,500 -100,000 Hillcrest Petroleum Ltd. Warrants Krzus, Michael 4 2020-08-10 53 0.07 1,000,000 1,000,000 Hillcrest Petroleum Ltd. Common Shares Miller, Dale 5 2020-08-13 10 0.08 350,000 -1,600,000 Home Capital Group Inc. Common Shares Lamoureux, Claude 4 2020-08-12 10 24 33,000 3,000 Hudbay Minerals Inc. Common Shares GMT Capital Corp 3 2020-08-12 10 3.74 9,765,590 116,700 (formerly HudBay Minerals Inc.) Hudbay Minerals Inc. Common Shares GMT Capital Corp 3 2020-08-12 10 3.74 14,021,521 269,301 (formerly HudBay Minerals Inc.) Hudbay Minerals Inc. Common Shares GMT Capital Corp 3 2020-08-12 10 3.74 17,406,637 261,000 (formerly HudBay Minerals Inc.) Hudbay Minerals Inc. Common Shares GMT Capital Corp 3 2020-08-12 10 3.74 1,655,900 26,900 (formerly HudBay Minerals Inc.) Hudson Resources Inc. Options Cambon, James Kenneth 5 2020-08-10 50 0.15 6,100,000 1,500,000 Hudson Resources Inc. Options Knudsen, Peter Flemming 4 2020-08-10 50 0.15 630,000 100,000 Hudson Resources Inc. Options McConnell, John Charles 4 2020-08-10 50 0.15 480,000 50,000 Hudson Resources Inc. Options Shields, Robert Lewis 3, 4 2020-08-10 50 0.15 300,000 50,000 Hudson Resources Inc. Options Yik, Samuel Ka Chun 5 2020-08-10 50 0.15 1,750,000 1,250,000 Hut 8 Mining Corp. Rights Restricted Share Vaiopoulos, Demetrios 5 2020-08-10 56 316,667 75,000 (formerly, Oriana Resources Units Corporation) Hydro One Limited Common Shares Millitz-Lee, Saylor 5 2020-08-12 59 27.69 -2,211 Hydro One Limited Common Shares Millitz-Lee, Saylor 5 2020-08-12 30 27 441 Hydro One Limited Common Shares Millitz-Lee, Saylor 5 2020-08-12 30 27 2,170 400 Hydro One Limited Common Shares Millitz-Lee, Saylor 5 2020-08-12 59 27.69 -41 -2,211 Hydro One Limited Common Shares Millitz-Lee, Saylor 5 2020-08-12 30 27 0 41 iA Financial Corporation Inc. Common Shares Jobin, Éric 5 2020-08-12 10 49.74 3,525 500 iA Financial Corporation Inc. Common Shares Stickney, Michael Lee 5 2020-08-10 51 38.48 32,100 1,000 iA Financial Corporation Inc. Common Shares Stickney, Michael Lee 5 2020-08-10 10 48.5 31,100 -1,000 iA Financial Corporation Inc. Common Shares Stickney, Michael Lee 5 2020-08-11 51 38.48 32,100 1,000 iA Financial Corporation Inc. Common Shares Stickney, Michael Lee 5 2020-08-11 10 49.1 31,100 -1,000 iA Financial Corporation Inc. Common Shares Stickney, Michael Lee 5 2020-08-11 51 38.48 32,100 1,000 iA Financial Corporation Inc. Common Shares Stickney, Michael Lee 5 2020-08-11 10 49.25 31,100 -1,000 iA Financial Corporation Inc. Common Shares Stickney, Michael Lee 5 2020-08-11 51 38.48 32,100 1,000 iA Financial Corporation Inc. Common Shares Stickney, Michael Lee 5 2020-08-11 10 49.65 31,100 -1,000 iA Financial Corporation Inc. Options Stickney, Michael Lee 5 2020-08-10 51 38.48 238,000 -1,000 iA Financial Corporation Inc. Options Stickney, Michael Lee 5 2020-08-11 51 38.48 237,000 -1,000 iA Financial Corporation Inc. Options Stickney, Michael Lee 5 2020-08-11 51 38.48 236,000 -1,000 iA Financial Corporation Inc. Options Stickney, Michael Lee 5 2020-08-11 51 38.48 235,000 -1,000 IBI Group Inc. Common Shares Richmond, Dale Elson 4 2020-08-10 10 6.25 46,400 400 IBI Group Inc. Common Shares Richmond, Dale Elson 4 2020-08-11 10 6.3 56,000 9,600 ImagineAR Inc. Common Shares Inwentash, Sheldon 4, 6 2020-08-05 51 0.09 500,000 500,000 ImagineAR Inc. Common Shares Inwentash, Sheldon 4, 6 2020-08-05 10 0.19 0 -500,000 ImagineAR Inc. Options Inwentash, Sheldon 4, 6 2020-08-05 51 0.09 500,000 -500,000 IMC International Mining Options Francis, Janet 5 2020-06-18 00 Corp. IMC International Mining Options Francis, Janet 5 2020-07-03 50 400,000 400,000 Corp. IMC International Mining Options Hawkins, Thomas Gregory 4 2020-03-31 00 Corp. IMC International Mining Options Hawkins, Thomas Gregory 4 2020-07-03 50 700,000 700,000 Corp. Imperial Metals Corporation Common Shares Fairholme Capital 3 2020-08-11 10 3.35 14,534,792 -30,000 Management, L.L.C. Inca One Gold Corp. Common Shares Equinox Gold Corp 3 2020-07-31 11 0.65 6,739,372 1,187,333 Inca One Gold Corp. Common Shares Stevens, Rodney 4 2020-07-17 46 0.1 25,000 Inca One Gold Corp. Common Shares Stevens, Rodney 4 2020-07-17 46 0.18 213,771 25,000

August 20, 2020 (2020), 43 OSCB 6641

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Indigo Books & Music Inc. Common Shares Reisman, Heather M. 4, 6, 5 2020-08-10 10 1.6155 489,143 392,700 Indigo Books & Music Inc. Common Shares Reisman, Heather M. 4, 6, 5 2020-08-11 10 2.5022 631,443 142,300 Indiva Limited Common Shares Wilson, W. Brett 3 2020-08-10 00 3,634,444 Indiva Limited Common Shares Wilson, W. Brett 3 2020-08-10 00 40,833 Indiva Limited Common Shares Wilson, W. Brett 3 2020-08-10 00 79,000 Indiva Limited Common Shares Wilson, W. Brett 3 2020-08-10 00 475,500 Indiva Limited Convertible Debentures Wilson, W. Brett 3 2020-08-10 00 $250,000 Indiva Limited Convertible Debentures Wilson, W. Brett 3 2020-08-10 00 $1,750,000 Indiva Limited Warrants Wilson, W. Brett 3 2020-08-10 00 3,333,333 Infinite Ore Corp. Options Gagne, Jonathan 4 2020-01-29 50 0.08 200,000 200,000 Infinite Ore Corp. Options Gagne, Jonathan 4 2020-06-08 50 0.08 500,000 300,000 Infinite Ore Corp. Options Gagne, Jonathan 4 2020-07-05 00 Inner Spirit Holdings Ltd. Common Shares Bondar, Darren Hartley 3, 4, 5 2020-08-14 10 0.14 10,041,000 -2,145,000 Inovalis Real Estate Units Inovalis Real Estate 1 2020-06-18 38 7.945 1,000 Investment Trust Investment Trust Inovalis Real Estate Units Inovalis Real Estate 1 2020-06-18 38 7.945 216,600 10,000 Investment Trust Investment Trust Inovalis Real Estate Units Inovalis Real Estate 1 2020-07-27 38 7.8673 4,000 Investment Trust Investment Trust Inovalis Real Estate Units Inovalis Real Estate 1 2020-07-27 38 7.8673 92,400 4,400 Investment Trust Investment Trust Inovalis Real Estate Units Inovalis Real Estate 1 2020-08-05 38 14,500 -107,400 Investment Trust Investment Trust Inovalis Real Estate Units Inovalis Real Estate 1 2020-08-10 38 7.9287 32,000 9,700 Investment Trust Investment Trust Inovalis Real Estate Units Inovalis Real Estate 1 2020-08-11 38 7.9938 34,900 2,900 Investment Trust Investment Trust Inovalis Real Estate Units Inovalis Real Estate 1 2020-08-12 38 7.9959 38,300 3,400 Investment Trust Investment Trust Inovalis Real Estate Units Inovalis Real Estate 1 2020-08-14 38 7.9838 48,800 10,500 Investment Trust Investment Trust Integra Resources Corp. Common Shares St-Germain, Andree 5 2020-08-11 10 4.8457 321,111 1,045 (formerly, Mag Copper Limited) Integra Resources Corp. Common Shares St-Germain, Andree 5 2020-08-11 10 4.6731 322,171 1,060 (formerly, Mag Copper Limited) Interfor Corporation Common Shares POZZEBON, RICHARD 5 2020-08-06 00 1,074 Interfor Corporation Common Shares POZZEBON, RICHARD 5 2020-08-06 00 6,440 Interfor Corporation Rights Performance POZZEBON, RICHARD 5 2020-08-06 00 31,020 Share Units Interfor Corporation Rights SARs POZZEBON, RICHARD 5 2020-08-06 00 6,569 Interlapse Technologies Common Shares Guidi, Alex P. 3 2020-08-07 10 0.175 3,563,352 1,000 Corp. (formerly Coronado Resources Ltd.) Intermap Technologies Common Shares Class A Blott, Patrick 5 2020-08-06 11 0.56 6,164,514 267,857 Corporation International Petroleum Performance Share Plan Adair, Ryan 5 2020-08-11 56 163,101 67,000 Corporation International Petroleum Performance Share Plan Fitzgerald, Daniel 5 2020-08-11 56 207,527 92,000 Corporation International Petroleum Performance Share Plan Fountain, Jeffrey 5 2020-08-11 56 273,251 113,000 Corporation International Petroleum Performance Share Plan Gordon, Rebecca 5 2020-08-11 56 166,101 70,000 Corporation International Petroleum Performance Share Plan Hogue, Chris W. 5 2020-08-11 56 96,369 67,000 Corporation International Petroleum Performance Share Plan NERGUARARIAN, 5 2020-08-11 56 321,630 139,000 Corporation CHRISTOPHE International Petroleum Performance Share Plan Nicholson, Mike 4, 5 2020-08-11 56 639,557 271,000 Corporation International Petroleum Performance Share Plan SOBEL, EDWARD 5 2020-08-11 56 96,369 67,000 Corporation Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2016-08-09 00 6,666,667 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 6,715,667 49,000

August 20, 2020 (2020), 43 OSCB 6642

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 6,959,667 244,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 7,083,667 124,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 7,161,667 78,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 7,291,667 130,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 7,451,667 160,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.035 7,458,667 7,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.03 7,658,667 200,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 7,685,667 27,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 7,555,667 -130,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 7,395,667 -160,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.035 7,388,667 -7,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.03 7,188,667 -200,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 6,788,667 -400,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 6,763,667 -25,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 10 0.04 6,685,667 -78,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 99 0.04 6,821,667 136,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 99 0.035 6,828,667 7,000 Internet of Things Inc. Common Shares Gali, Bar-Ziv 4 2020-08-06 99 0.03 7,028,667 200,000 Ivanhoe Mines Ltd. Common Shares Class A Janse van Rensburg, 4 2020-08-10 00 Martie Ivanhoe Mines Ltd. Rights Deferred Share Janse van Rensburg, 4 2020-08-10 00 Units Martie Ivanhoe Mines Ltd. Rights Deferred Share Janse van Rensburg, 4 2020-08-10 56 4,841 4,841 Units Martie Ivanhoe Mines Ltd. Rights Deferred Share Janse van Rensburg, 4 2020-08-10 00 Units Martie Ivanhoe Mines Ltd. Rights Deferred Share Janse van Rensburg, 4 2020-08-10 56 4,841 4,841 Units Martie Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 4.9 51,051 -15,000 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 4.91 43,551 -7,500 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 4.92 41,051 -2,500 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 4.94 38,551 -2,500 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 4.95 36,051 -2,500 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 4.97 33,551 -2,500 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 4.99 28,551 -5,000 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 5 26,051 -2,500 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 5.01 19,451 -6,600 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 5.02 17,151 -2,300 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 5.03 14,651 -2,500 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 5.05 12,151 -2,500 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 5.06 11,100 -1,051 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 5.07 7,700 -3,400 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 5.08 2,700 -5,000 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 5.09 200 -2,500 Ivanhoe Mines Ltd. Common Shares Class A Mahler, Livia 4 2020-08-11 10 5.1 0 -200 Ivanhoe Mines Ltd. Common Shares Class A Meredith, Peter 4 2020-08-11 10 4.9 965,000 -35,000 Ivanhoe Mines Ltd. Common Shares Class A Meredith, Peter 4 2020-08-11 10 4.91 950,000 -15,000 Ivanhoe Mines Ltd. Common Shares Class A Meredith, Peter 4 2020-08-11 10 4.95 940,000 -10,000 Ivanhoe Mines Ltd. Common Shares Class A Meredith, Peter 4 2020-08-11 10 4.9668 925,000 -15,000 Ivanhoe Mines Ltd. Common Shares Class A Meredith, Peter 4 2020-08-11 10 4.97 915,000 -10,000 Ivanhoe Mines Ltd. Common Shares Class A Meredith, Peter 4 2020-08-11 10 5 900,000 -15,000 Ivanhoe Mines Ltd. Common Shares Class A Ntshingila, Nunu 4 2020-08-10 00 Ivanhoe Mines Ltd. Rights Deferred Share Ntshingila, Nunu 4 2020-08-10 00 Units Ivanhoe Mines Ltd. Rights Deferred Share Ntshingila, Nunu 4 2020-08-10 00 Units Ivanhoe Mines Ltd. Rights Deferred Share Ntshingila, Nunu 4 2020-08-10 56 9,682 9,682 Units Izotropic Corporation Common Shares Sodagar, Ali Reza 4 2020-08-14 10 0.59 419,000 11,000 James Bay Resources Common Shares Shefsky, Stephen Mitchell 3, 4, 5 2020-08-11 10 0.05 266,002 244,000 Limited

August 20, 2020 (2020), 43 OSCB 6643

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Jamieson Wellness Inc. Common Shares Potechin, Catherine 4 2020-08-14 10 36.275 5,000 1,200 K2 Gold Corporation Common Shares Robins, John Edward 3, 4, 5 2020-08-11 54 0.4 2,964,250 140,000 K2 Gold Corporation Warrants Robins, John Edward 3, 4, 5 2020-08-11 16 0.4 -140,000 K2 Gold Corporation Warrants Robins, John Edward 3, 4, 5 2020-08-11 54 0.4 255,000 -140,000 Keyera Corp. Common Shares Beztilny, Jarrod 5 2020-08-12 57 22.74 51,555 6,378 Keyera Corp. Rights Share Awards Beztilny, Jarrod 5 2020-08-12 57 40,775 -7,268 Keyera Corp. Common Shares Hill, Kelly 5 2020-08-12 57 22.74 5,238 1,974 Keyera Corp. Rights Share Awards Hill, Kelly 5 2020-08-12 57 24,909 -2,320 Keyera Corp. Rights Share Awards Hunszinger, John 5 2020-08-12 57 24,195 -2,104 Keyera Corp. Common Shares Kostiuk, Dion Otto 5 2020-08-12 57 22.74 25,729 6,412 Keyera Corp. Rights Share Awards Kostiuk, Dion Otto 5 2020-08-12 57 55,226 -7,268 Keyera Corp. Common Shares Lock, Bradley Wayne 5 2020-08-12 57 22.74 212,263 16,810 Keyera Corp. Rights Share Awards Lock, Bradley Wayne 5 2020-08-12 57 95,859 -19,187 Keyera Corp. Common Shares Marikar, Eileen 5 2020-08-12 57 22.74 12,261 3,340 Keyera Corp. Rights Share Awards Marikar, Eileen 5 2020-08-12 57 58,357 -6,250 Keyera Corp. Rights Share Awards Martin, Brian 5 2020-08-12 57 47,849 -8,334 Keyera Corp. Common Shares Setoguchi, Curtis Dean 5 2020-08-12 57 22.74 219,688 16,810 Keyera Corp. Rights Share Awards Setoguchi, Curtis Dean 5 2020-08-12 57 121,131 -19,187 Keyera Corp. Rights Share Awards Slessor, Bradley John 5 2020-08-12 57 22,102 -2,890 Keyera Corp. Common Shares Smith, David G. 5 2020-08-12 57 22.74 586,511 22,262 Keyera Corp. Rights Share Awards Smith, David G. 5 2020-08-12 57 275,334 -50,873 Keyera Corp. Common Shares Urquhart, Kenneth James 5 2020-08-12 57 22.74 12,640 3,249 Keyera Corp. Rights Share Awards Urquhart, Kenneth James 5 2020-08-12 57 52,410 -7,268 Kinaxis Inc. Options Liu, Kerry 5 2020-08-10 50 209.2 65,000 65,000 Kinaxis Inc. Options Mauger, Michael David 5 2020-08-10 50 209.2 66,906 25,000 Kinaxis Inc. Common Shares Paterson, Megan 5 2020-08-12 51 94.66 4,851 3,750 Kinaxis Inc. Common Shares Paterson, Megan 5 2020-08-12 10 191.71 1,101 -3,750 Kinaxis Inc. Common Shares Paterson, Megan 5 2020-08-12 51 86.27 10,301 9,200 Kinaxis Inc. Common Shares Paterson, Megan 5 2020-08-12 10 191.92 1,101 -9,200 Kinaxis Inc. Common Shares Paterson, Megan 5 2020-08-12 51 86.27 1,901 800 Kinaxis Inc. Common Shares Paterson, Megan 5 2020-08-12 10 191.92 1,101 -800 Kinaxis Inc. Options Paterson, Megan 5 2020-08-12 51 94.66 49,917 -3,750 Kinaxis Inc. Options Paterson, Megan 5 2020-08-12 51 86.27 40,717 -9,200 Kinaxis Inc. Options Paterson, Megan 5 2020-08-12 51 86.27 39,917 -800 Kinross Gold Corporation Options Longenecker, Nathan M. 5 2020-08-07 59 4.59 39,792 -13,183 Kirkland Lake Gold Ltd. Common Shares Kirkland Lake Gold Ltd. 1 2020-08-04 38 73.2 500,000 500,000 Kirkland Lake Gold Ltd. Common Shares Kirkland Lake Gold Ltd. 1 2020-08-07 38 0 -500,000 Kirkland Lake Gold Ltd. Common Shares Wagner, Jennifer Laura 5 2020-08-06 51 4.95 10,002 10,002 Kirkland Lake Gold Ltd. Common Shares Wagner, Jennifer Laura 5 2020-08-06 10 75.6 0 -10,002 Kirkland Lake Gold Ltd. Options Wagner, Jennifer Laura 5 2020-08-06 51 4.95 0 -10,002 KP Tissue Inc. Common Shares BIANCO, DINO JOE 4, 5 2020-08-10 10 11.954 8,737 1,500 KP Tissue Inc. Common Shares BIANCO, DINO JOE 4, 5 2020-08-11 10 12.188 9,737 1,000 Leucrotta Exploration Inc. Common Shares Disbrow, Robert 3 2020-08-12 10 0.6 12,728,000 100,256 Leucrotta Exploration Inc. Common Shares Disbrow, Robert 3 2020-08-07 10 0.5405 9,508,275 12,375 Leucrotta Exploration Inc. Common Shares Disbrow, Robert 3 2020-08-07 10 0.5597 9,516,150 7,875 Leucrotta Exploration Inc. Common Shares Disbrow, Robert 3 2020-08-12 10 0.58 9,625,775 109,625 Leucrotta Exploration Inc. Common Shares Disbrow, Robert 3 2020-08-12 10 0.5798 9,642,900 17,125 Lido Minerals Ltd. Options Teniere, Paul John 5 2020-06-30 00 Lido Minerals Ltd. Options Teniere, Paul John 5 2020-08-10 50 0.27 100,000 100,000 Lightspeed POS Inc. Options Lacelle, Patrick 5 2020-08-11 51 0.612 85,327 -6,026 Lightspeed POS Inc. Subordinate Voting Lacelle, Patrick 5 2020-08-11 51 0.612 6,026 6,026 Shares Lightspeed POS Inc. Subordinate Voting Lacelle, Patrick 5 2020-08-11 10 40.48 0 -6,026 Shares Lightspeed POS Inc. Rights Restricted stock Leblanc, Jean-Philippe 5 2020-08-11 57 30.28 10,600 -1,313 units Lightspeed POS Inc. Rights Restricted stock Leblanc, Jean-Philippe 5 2020-08-11 57 33.39 9,013 -1,587 units Lightspeed POS Inc. Subordinate Voting Leblanc, Jean-Philippe 5 2020-08-11 57 30.28 1,313 1,313 Shares

August 20, 2020 (2020), 43 OSCB 6644

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Lightspeed POS Inc. Subordinate Voting Leblanc, Jean-Philippe 5 2020-08-11 10 39.62 0 -1,313 Shares Lightspeed POS Inc. Subordinate Voting Leblanc, Jean-Philippe 5 2020-08-11 57 33.39 1,587 1,587 Shares Lightspeed POS Inc. Subordinate Voting Leblanc, Jean-Philippe 5 2020-08-11 10 39.62 0 -1,587 Shares Lithium Americas Corp. Rights Deferred Share Chubbs, Fabiana Elizabeth 4 2020-08-13 56 21,237 3,816 Units Lithium Americas Corp. Rights Deferred Share Gao, Yuan 4 2020-08-13 56 12,762 3,621 Units Lithium Americas Corp. Rights Deferred Share Ireland, George R. 4, 6 2020-08-13 56 80,279 5,968 Units Lithium Americas Corp. Rights Deferred Share Wang, Xiaoshen 4 2020-08-13 56 45,052 3,591 Units Loblaw Companies Limited Common Shares George Weston Limited 3 2020-08-13 38 70.73 2,492,034 -136,801 Loblaw Companies Limited Common Shares George Weston Limited 3 2020-08-14 38 70.79 2,348,047 -143,987 Lorne Park Capital Partners Debentures 8% Pannella, Carlo 5 2020-08-07 90 $0 -$36,000 Inc. Unsecured Non- convertible (Maturing August 15, 2024) Lorne Park Capital Partners Warrants Pannella, Carlo 5 2020-08-07 90 0 -9,000 Inc. Lorne Park Capital Partners Common Shares Patchet, Peter Bruce 4 2019-04-30 00 Inc. Lorne Park Capital Partners Common Shares Patchet, Peter Bruce 4 2020-08-14 54 12,500 12,500 Inc. Lorne Park Capital Partners Warrants Patchet, Peter Bruce 4 2020-08-14 54 0 -12,500 Inc. Lorne Park Capital Partners Common Shares Schulze, Susan Lynn 7 2019-08-15 00 Inc. Lorne Park Capital Partners Common Shares Schulze, Susan Lynn 7 2020-08-06 54 0.5 5,000 5,000 Inc. Lorne Park Capital Partners Common Shares Schulze, Susan Lynn 7 2019-08-15 00 Inc. Lorne Park Capital Partners Common Shares Schulze, Susan Lynn 7 2020-08-07 54 0.5 7,500 7,500 Inc. Lorne Park Capital Partners Warrants Schulze, Susan Lynn 7 2020-08-06 54 0.5 0 -5,000 Inc. Lorne Park Capital Partners Warrants Schulze, Susan Lynn 7 2020-08-07 54 0.5 0 -7,500 Inc. Lorne Park Capital Partners Common Shares Sewell, Robert Darrell 4, 5 2020-08-14 54 14,040,500 37,500 Inc. Lorne Park Capital Partners Warrants Sewell, Robert Darrell 4, 5 2018-12-31 55 0 -25,000 Inc. Lorne Park Capital Partners Warrants Sewell, Robert Darrell 4, 5 2020-08-14 54 0 -37,500 Inc. Lundin Gold Inc. Common Shares Gosselin, Chantal 4 2020-08-13 10 11.807 13,300 1,300 Lundin Gold Inc. Common Shares Gosselin, Chantal 4 2020-08-14 10 11.66 14,150 850 Lundin Mining Corporation Common Shares Gatley, Stephen Trelawney 5 2020-08-05 51 7.99 142,000 44,000 Lundin Mining Corporation Common Shares Gatley, Stephen Trelawney 5 2020-08-05 10 7.99 98,000 -44,000 Lundin Mining Corporation Common Shares Gatley, Stephen Trelawney 5 2020-08-05 51 4.32 142,000 44,000 Lundin Mining Corporation Options Gatley, Stephen Trelawney 5 2020-08-05 51 4.32 484,990 -44,000 Lundin Mining Corporation Common Shares Laurenson, Annie 5 2018-04-11 00 Lundin Mining Corporation Common Shares Laurenson, Annie 5 2020-08-06 51 6.65 10,000 10,000 Lundin Mining Corporation Common Shares Laurenson, Annie 5 2020-08-06 10 8.1 0 -10,000 Lundin Mining Corporation Options Laurenson, Annie 5 2020-08-06 51 6.65 69,000 -10,000 Lundin Mining Corporation Options Laurenson, Annie 5 2020-08-06 51 6.65 59,000 -10,000 Lundin Mining Corporation Common Shares Richardson, Jonas Peter 5 2020-08-05 51 3.86 45,818 26,000 Haddock Lundin Mining Corporation Common Shares Richardson, Jonas Peter 5 2020-08-05 10 8 19,818 -26,000 Haddock Lundin Mining Corporation Common Shares Richardson, Jonas Peter 5 2020-08-05 51 4.32 39,218 19,400 Haddock Lundin Mining Corporation Common Shares Richardson, Jonas Peter 5 2020-08-05 10 8 19,818 -19,400 Haddock

August 20, 2020 (2020), 43 OSCB 6645

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Lundin Mining Corporation Common Shares Richardson, Jonas Peter 5 2020-08-06 51 4.32 33,418 13,600 Haddock Lundin Mining Corporation Common Shares Richardson, Jonas Peter 5 2020-08-06 10 8.14 19,818 -13,600 Haddock Lundin Mining Corporation Options Richardson, Jonas Peter 5 2020-08-05 51 3.86 708,000 -26,000 Haddock Lundin Mining Corporation Options Richardson, Jonas Peter 5 2020-08-05 51 4.32 688,600 -19,400 Haddock Lundin Mining Corporation Options Richardson, Jonas Peter 5 2020-08-06 51 4.32 675,000 -13,600 Haddock MacDonald Mines Common Shares Class A Boiridy, Mia Ingrid 5 2020-07-08 00 330,000 Exploration Ltd. MacDonald Mines Common Shares Class A Boiridy, Mia Ingrid 5 2020-08-05 16 0.1 530,000 200,000 Exploration Ltd. MacDonald Mines Options Boiridy, Mia Ingrid 5 2020-07-08 00 550,000 Exploration Ltd. MacDonald Mines Warrants Boiridy, Mia Ingrid 5 2020-07-08 00 200,000 Exploration Ltd. MacDonald Mines Warrants Boiridy, Mia Ingrid 5 2020-08-05 16 300,000 100,000 Exploration Ltd. MacDonald Mines Common Shares Class A Dubreuil, Patrice Simon 4 2020-08-05 16 0.1 150,000 50,000 Exploration Ltd. MacDonald Mines Warrants Dubreuil, Patrice Simon 4 2020-08-05 16 75,000 25,000 Exploration Ltd. Madison Pacific Properties Non-Voting Shares Class Heung, Raymond 3 2020-08-11 10 2.9 6,462,217 -3,000 Inc. C Madison Pacific Properties Non-Voting Shares Class Heung, Raymond 3 2020-08-11 10 2.91 6,461,417 -800 Inc. C Madison Pacific Properties Non-Voting Shares Class Heung, Raymond 3 2020-08-11 10 2.7 6,386,417 -75,000 Inc. C Madison Pacific Properties Common Shares Class B Madison Venture 3 2020-08-14 11 3.928 2,062,299 70,500 Inc. Voting Corporation MagIndustries Corp. Options Morrow, Richey 5 2020-08-11 50 0.1 800,000 200,000 Magna Gold Corp. Options Sutherland, Colin 4 2020-08-13 50 1.53 300,000 150,000 Magna International Inc. Common Shares Skudutis, Tommy Joseph 7, 5 2020-08-11 10 69.77 0 -69,606 Magna International Inc. Common Shares Walker, Donald James 4, 5 2020-08-10 10 67.53 1,216,605 -100,000 Magna International Inc. Common Shares Walker, Donald James 4, 5 2020-08-11 51 53.355 1,480,605 264,000 Magna International Inc. Common Shares Walker, Donald James 4, 5 2020-08-11 10 69.7 1,368,505 -112,100 Magna International Inc. Common Shares Walker, Donald James 4, 5 2020-08-11 10 70.31 1,216,605 -151,900 Magna International Inc. Options Walker, Donald James 4, 5 2020-08-11 51 53.355 2,728,970 -264,000 Mainstream Minerals Common Shares Kim, Cejay 3 2020-08-14 00 1,800,000 Corporation Major Drilling Group Deferred Share Units Gignac, Louis-Pierre 4 2020-08-04 30 13,147 977 International Inc. Mangazeya Mining Ltd. Common Shares Yanchukov, Sergey 3 2020-07-27 10 0.105 1,463,000 168,000 Mangazeya Mining Ltd. Common Shares Yanchukov, Sergey 3 2020-08-11 10 0.085 1,798,000 36,000 Manulife Financial Common Shares Pariath, Sebastian 7 2020-06-30 30 22 22 Corporation Manulife Financial Common Shares Pariath, Sebastian 7 2020-08-13 30 904 882 Corporation Maple Leaf Green World Inc. Common Shares Lam, Terence Keung 4, 5 2020-06-23 10 0.095 2,153,000 162,000 Cheung Marathon Gold Corporation DSU Bache, Douglas 4 2020-08-12 56 105,000 55,000 Marathon Gold Corporation DSU Faught, George D. 4 2020-08-12 11 2.11 105,000 55,000 Marathon Gold Corporation DSU Gowans, James Kitchener 4 2020-06-01 00 Marathon Gold Corporation DSU Gowans, James Kitchener 4 2020-08-12 56 55,000 55,000 Marathon Gold Corporation DSU Kemp, Julian 4 2012-11-03 00 50,000 Marathon Gold Corporation DSU Kemp, Julian 4 2020-08-12 56 105,000 55,000 Marathon Gold Corporation DSU Spiteri, Joseph George 4 2020-08-12 56 105,000 55,000 Marathon Gold Corporation DSU Stairs, Janice Alayne 4 2020-08-12 56 105,000 55,000 Martinrea International Inc. Performance Share Units D'Eramo, Frank Patrick 4 2020-08-10 56 10.35 128,149 11,490 Martinrea International Inc. Restricted Share Units D'Eramo, Frank Patrick 4 2020-08-10 56 10.35 128,149 11,490 Martinrea International Inc. Performance Share Units Di Tosto, Alfred 5 2020-08-10 56 10.35 9,658 Martinrea International Inc. Performance Share Units Di Tosto, Alfred 5 2020-08-10 56 10.35 9,658

August 20, 2020 (2020), 43 OSCB 6646

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Martinrea International Inc. Performance Share Units Di Tosto, Alfred 5 2020-08-10 56 19,289 282 Martinrea International Inc. Performance Share Units Di Tosto, Alfred 5 2020-08-10 56 10.35 28,947 9,658 Martinrea International Inc. Restricted Share Units Di Tosto, Alfred 5 2020-08-10 56 19,289 282 Martinrea International Inc. Restricted Share Units Di Tosto, Alfred 5 2020-08-10 56 10.35 28,947 9,658 Martinrea International Inc. Performance Share Units Hunter Lulgjuraj, Megan 5 2020-08-10 56 8,321 151 Rae Martinrea International Inc. Performance Share Units Hunter Lulgjuraj, Megan 5 2020-08-10 56 10.35 13,150 4,829 Rae Martinrea International Inc. Restricted Share Units Hunter Lulgjuraj, Megan 5 2020-08-10 56 8,321 151 Rae Martinrea International Inc. Restricted Share Units Hunter Lulgjuraj, Megan 5 2020-08-10 56 10.35 13,150 4,829 Rae Martinrea International Inc. Performance Share Units Pagliari, Armando 5 2020-08-10 56 7,101 101 Martinrea International Inc. Performance Share Units Pagliari, Armando 5 2020-08-10 56 10.35 11,930 4,829 Martinrea International Inc. Restricted Share Units Pagliari, Armando 5 2020-08-10 56 7,101 101 Martinrea International Inc. Restricted Share Units Pagliari, Armando 5 2020-08-10 56 10.35 11,930 4,829 Martinrea International Inc. Performance Share Units Pope, Kerri Lynn 5 2020-08-10 56 11,296 164 Martinrea International Inc. Performance Share Units Pope, Kerri Lynn 5 2020-08-10 56 10.35 16,125 4,829 Martinrea International Inc. Restricted Share Units Pope, Kerri Lynn 5 2020-08-10 56 11,296 164 Martinrea International Inc. Restricted Share Units Pope, Kerri Lynn 5 2020-08-10 56 10.35 16,125 4,829 Martinrea International Inc. Common Shares Wildeboer, Robert Peter 4, 5 2020-08-13 51 7.33 13,300 Edward Martinrea International Inc. Common Shares Wildeboer, Robert Peter 4, 5 2020-08-13 51 7.33 13,300 Edward Martinrea International Inc. Common Shares Wildeboer, Robert Peter 4, 5 2020-08-13 51 7.33 513,300 13,300 Edward Martinrea International Inc. Options Options to Wildeboer, Robert Peter 4, 5 2020-08-13 51 7.33 13,300 purchase common shares Edward Martinrea International Inc. Options Options to Wildeboer, Robert Peter 4, 5 2020-08-13 51 7.33 13,300 purchase common shares Edward Martinrea International Inc. Options Options to Wildeboer, Robert Peter 4, 5 2020-08-13 51 7.33 255,000 -13,300 purchase common shares Edward Martinrea International Inc. Options Options to Wildeboer, Robert Peter 4, 5 2020-08-13 59 10.538 251,100 -3,900 purchase common shares Edward Martinrea International Inc. Options Options to Wildeboer, Robert Peter 4, 5 2020-08-14 59 10.538 100,000 -151,100 purchase common shares Edward Martinrea International Inc. Performance Share Units Wildeboer, Robert Peter 4, 5 2020-08-10 56 10.35 128,149 11,490 Edward Martinrea International Inc. Restricted Share Units Wildeboer, Robert Peter 4, 5 2020-08-10 56 10.35 128,149 11,490 Edward Mazarin Inc. Common Shares MONETTE, SERGE 7 2020-08-10 10 0.14 1,063,000 2,000 MBN Corporation Common Shares Equity MBN Corporation 1 2020-08-10 38 6 600 600 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2020-08-10 38 0 -600 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2020-08-11 38 6 100 100 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2020-08-11 38 0 -100 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2020-08-13 38 6.0269 1,300 1,300 Shares MBN Corporation Common Shares Equity MBN Corporation 1 2020-08-13 38 0 -1,300 Shares mCloud Technologies Corp. Common Shares Rollison, Rebecca Lee 4 2019-08-09 00 43,487 (formerly Universal mCloud Corp.) Melcor Real Estate Trust Units Young, Ralph Barclay 6 2020-08-14 10 3.98 24,800 1,000 Investment Trust Metalla Royalty & Streaming Rights Restricted Share Clark, Drew 5 2018-01-02 00 Ltd. Units Metalla Royalty & Streaming Rights Restricted Share Clark, Drew 5 2020-08-07 56 18,000 18,000 Ltd. Units Metalla Royalty & Streaming Rights Restricted Share Krepiakevich, Terry 4 2020-01-15 00 Ltd. Units

August 20, 2020 (2020), 43 OSCB 6647

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Metalla Royalty & Streaming Rights Restricted Share Krepiakevich, Terry 4 2020-08-07 56 25,000 25,000 Ltd. Units Metalla Royalty & Streaming Rights Restricted Share Tsang, William To Ping 5 2020-08-07 56 4,500 3,000 Ltd. Units Metallic Minerals Corp. Common Shares 2176423 Ontario Ltd. 3 2020-08-13 16 0.4 16,000,000 3,500,000 Metallic Minerals Corp. Warrants 2176423 Ontario Ltd. 3 2020-08-13 16 0.6 8,000,000 1,750,000 Metallic Minerals Corp. Common Shares Sprott, Eric S. 3 2020-08-13 16 0.4 16,000,000 3,500,000 Metallic Minerals Corp. Warrants Sprott, Eric S. 3 2020-08-13 16 0.6 8,000,000 1,750,000 Methanex Corporation Common Shares M&G Investment 3 2020-08-07 10 19.043 4,466,008 -1,907 Management Limited Methanex Corporation Common Shares M&G Investment 3 2020-08-12 10 21.388 4,465,626 -382 Management Limited Methanex Corporation Common Shares M&G Investment 3 2020-08-13 10 21.386 4,458,593 -7,033 Management Limited Midas Gold Corp. Common Shares Monger, Liz 5 2020-07-27 51 0.59 15,000 15,000 Midas Gold Corp. Common Shares Monger, Liz 5 2020-07-27 10 0 -15,000 Midas Gold Corp. Common Shares Monger, Liz 5 2020-07-30 51 0.59 20,000 20,000 Midas Gold Corp. Common Shares Monger, Liz 5 2020-07-30 10 0 -20,000 Midas Gold Corp. Common Shares Monger, Liz 5 2020-08-04 51 0.59 30,000 30,000 Midas Gold Corp. Common Shares Monger, Liz 5 2020-08-04 10 0 -30,000 Midas Gold Corp. Options Monger, Liz 5 2020-07-27 51 0.59 555,000 -15,000 Midas Gold Corp. Options Monger, Liz 5 2020-07-30 51 0.59 535,000 -20,000 Midas Gold Corp. Options Monger, Liz 5 2020-08-04 51 0.59 505,000 -30,000 Midas Gold Corp. Common Shares Nixon, Peter 4 2020-07-21 11 0.39 99,400 30,000 Midas Gold Corp. Common Shares Nixon, Peter 4 2020-07-21 10 1.33 69,400 -30,000 Midas Gold Corp. Common Shares Nixon, Peter 4 2020-08-04 11 0.66 84,400 15,000 Midas Gold Corp. Common Shares Nixon, Peter 4 2020-08-04 11 1.87 69,400 -15,000 Midas Gold Corp. Options Nixon, Peter 4 2020-07-21 51 0.39 30,000 Midas Gold Corp. Options Nixon, Peter 4 2020-07-21 51 0.39 30,000 Midas Gold Corp. Options Nixon, Peter 4 2020-07-21 11 0.39 30,000 Midas Gold Corp. Options Nixon, Peter 4 2020-07-21 11 0.39 30,000 Midas Gold Corp. Options Nixon, Peter 4 2020-07-21 51 0.39 385,000 -30,000 Midas Gold Corp. Options Nixon, Peter 4 2020-08-04 51 0.66 370,000 -15,000 Middlefield Can-Global REIT Trust Units Middlefield Can-Global 1 2020-08-10 38 10.05 5,329,341 500 Income Fund REIT Income Fund Middlefield Can-Global REIT Trust Units Middlefield Can-Global 1 2020-08-11 38 9.9942 5,330,541 1,200 Income Fund REIT Income Fund Middlefield Can-Global REIT Trust Units Middlefield Can-Global 1 2020-08-12 38 9.9425 5,330,941 400 Income Fund REIT Income Fund Middlefield Global Real Trust Units Middlefield Global Real 1 2020-08-07 38 9.1864 773,300 1,400 Asset Fund Asset Fund Middlefield Global Real Trust Units Middlefield Global Real 1 2020-08-10 38 9.105 776,500 3,200 Asset Fund Asset Fund Middlefield Global Real Trust Units Middlefield Global Real 1 2020-08-11 38 9.1185 777,800 1,300 Asset Fund Asset Fund Middlefield Global Real Trust Units Middlefield Global Real 1 2020-08-12 38 9.1 778,100 300 Asset Fund Asset Fund Middlefield Global Real Trust Units Middlefield Global Real 1 2020-08-13 38 9.0833 779,000 900 Asset Fund Asset Fund Minaurum Gold Inc. Common Shares Jones, David McKinlay 4 2020-07-31 51 600000 600,000 Minaurum Gold Inc. Common Shares Jones, David McKinlay 4 2020-07-31 51 2,114,750 600,000 Minaurum Gold Inc. Common Shares Maynard, Stephen 5 2020-08-12 10 0.63 750,333 -2,000 Minaurum Gold Inc. Common Shares Maynard, Stephen 5 2020-08-13 10 0.5801 662,333 -88,000 MINT Income Fund Trust Units Lauzon, Robert 7 2020-08-07 10 5.29 2,050 -900 MINT Income Fund Trust Units MINT Income Fund 1 2020-08-07 38 5.15 71,771,751 500 MINT Income Fund Trust Units MINT Income Fund 1 2020-08-11 38 5.2 71,772,051 300 MINT Income Fund Trust Units MINT Income Fund 1 2020-08-12 38 5.2119 71,773,651 1,600 Monarch Gold Corporation Common Shares Lavergne, Marc-André 5 2020-08-12 10 0.47 21,000 1,000 Monarch Gold Corporation Common Shares Lévesque, Alain 5 2020-08-13 51 0.1 75,000 75,000 Monarch Gold Corporation Options Lévesque, Alain 5 2020-08-13 51 0.1 975,000 -75,000 Mondias Natural Products Common Shares Chamberland, Guy 3 2020-08-06 97 10,091,667 -1,575,000 Inc.

August 20, 2020 (2020), 43 OSCB 6648

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Mondias Natural Products Common Shares Rancourt, André 3, 4, 5 2020-08-06 97 11,053,167 -1,575,000 Inc. MONETA PORCUPINE Options Ashcroft, Mark Nicholas 4 2020-06-18 00 MINES INC. James MONETA PORCUPINE Options Ashcroft, Mark Nicholas 4 2020-08-10 50 400,000 400,000 MINES INC. James MONETA PORCUPINE Options Heather, Kevin Bruce 4 2020-05-15 52 0.16 500,000 -400,000 MINES INC. MONETA PORCUPINE Options Heather, Kevin Bruce 4 2020-08-10 50 0.18 900,000 400,000 MINES INC. MONETA PORCUPINE Options O'Connor, Gary Vincent 4, 5 2020-08-10 50 0.18 6,200,000 2,000,000 MINES INC. MONETA PORCUPINE Options Vejvoda, Josef 4 2020-08-10 50 0.18 500,000 200,000 MINES INC. Monterey Minerals Inc. Options DiGirolamo, Julio 4, 5 2020-08-10 50 0.1 800,000 200,000 Monterey Minerals Inc. Options Le Page, Guy Touzeau 4 2020-08-10 50 0.1 650,000 200,000 Monterey Minerals Inc. Options Lees, David 4 2019-12-11 00 Monterey Minerals Inc. Options Lees, David 4 2020-02-19 50 0.1 300,000 300,000 Monterey Minerals Inc. Options Lees, David 4 2020-08-10 50 0.1 400,000 100,000 Monterey Minerals Inc. Options Macintosh, James Maitland 4, 5 2020-08-10 50 0.1 1,100,000 300,000 Montero Mining and Common Shares levy, Jamie 4 2020-08-07 10 0.13 118,500 100,000 Exploration Ltd. Montero Mining and Common Shares levy, Jamie 4 2020-08-10 10 0.13 175,500 57,000 Exploration Ltd. Montero Mining and Common Shares levy, Jamie 4 2020-08-11 10 0.13 318,500 143,000 Exploration Ltd. Montero Mining and Common Shares Thomson, Andrew 4 2020-08-10 10 0.14 147,000 2,000 Exploration Ltd. Montero Mining and Common Shares Thomson, Andrew 4 2020-08-11 10 0.124 155,000 8,000 Exploration Ltd. Montero Mining and Common Shares Thomson, Andrew 4 2020-08-12 10 0.12 163,000 8,000 Exploration Ltd. Montero Mining and Common Shares Thomson, Andrew 4 2020-08-10 10 0.13 103,500 7,000 Exploration Ltd. Montero Mining and Common Shares Thomson, Andrew 4 2020-08-11 10 0.13 109,500 6,000 Exploration Ltd. Morguard Corporation Common Shares Taylor, Stephen Ronald 4 2020-08-05 00 22,730 Morguard North American Trust Units Taylor, Stephen Ronald 6 2020-08-05 00 4,500 Residential Real Estate Investment Trust Morguard Real Estate Units Taylor, Stephen Ronald 6 2020-08-05 00 29,631 Investment Trust Morneau Shepell Inc. Common Shares Liptrap, Stephen 5 2020-08-14 10 29.218 17,500 1,000 Mullen Group Ltd. Common Shares Mullen Group Ltd. 1 2020-08-10 38 9.7903 233,100 33,300 Mullen Group Ltd. Common Shares Mullen Group Ltd. 1 2020-08-11 38 9.6985 266,400 33,300 Mullen Group Ltd. Common Shares Mullen Group Ltd. 1 2020-08-12 38 9.8462 299,700 33,300 Mullen Group Ltd. Common Shares Mullen Group Ltd. 1 2020-08-13 38 9.7131 333,000 33,300 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-02-12 10 0.13 60,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-02-12 10 0.13 60,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-02-13 10 0.13 20,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-02-13 10 0.13 20,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-02-18 10 0.13 20,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-02-18 10 0.13 20,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-07-24 11 0.08 10,091,000 2,500,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-08-04 10 0.095 10,071,000 -20,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-08-05 10 0.095 9,916,000 -155,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-08-06 10 0.095 9,788,000 -128,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-08-07 10 0.095 9,495,000 -293,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-08-10 10 0.095 9,297,000 -198,000 Murchison Minerals Ltd. Common Shares Cudney, Robert Douglas 3 2020-08-11 10 0.09 9,180,000 -117,000 Murchison Minerals Ltd. Warrants Cudney, Robert Douglas 3 2020-07-24 11 0.12 7,930,000 1,250,000 MYM Nutraceuticals Inc. Options Linden, Robin 4, 5 2020-08-07 50 0.065 4,100,000 3,400,000 MYM Nutraceuticals Inc. Options Steinberg, Howard 4, 5 2020-08-07 50 0.065 5,750,000 2,750,000

August 20, 2020 (2020), 43 OSCB 6649

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed MYM Nutraceuticals Inc. Options Tabisz, Edward 4 2020-08-07 50 0.065 1,200,000 800,000 MYM Nutraceuticals Inc. Options Wiener, Michael 4 2020-07-31 00 MYM Nutraceuticals Inc. Options Wiener, Michael 4 2020-08-07 50 0.065 4,700,000 4,700,000 MYM Nutraceuticals Inc. Options Wolf, Robert Thomas 4 2020-07-31 00 MYM Nutraceuticals Inc. Options Wolf, Robert Thomas 4 2020-08-07 50 0.065 1,800,000 1,800,000 Nanotech Security Corp. Options Green, Andrew Richard 5 2020-05-25 00 Nanotech Security Corp. Options Green, Andrew Richard 5 2020-08-10 50 300,000 300,000 NatureBank Asset Common Shares O'Loughnane, Guy 3 2020-08-10 10 0.02 4,301,000 84,000 Management Inc. Neo Performance Materials Options Karayannopoulos, 4, 5 2017-12-01 00 Inc. Constantine Efthymios Neo Performance Materials Options Karayannopoulos, 4, 5 2020-08-12 50 61,165 61,165 Inc. Constantine Efthymios Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-02 38 1,900 1,900 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-03 38 2,800 900 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-06 38 3,300 500 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-07 38 3,500 200 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-08 38 4,800 1,300 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-09 38 5,400 600 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-10 38 5,824 424 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-13 38 8,324 2,500 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-14 38 10,424 2,100 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-15 38 11,624 1,200 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-16 38 13,224 1,600 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-17 38 13,724 500 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-20 38 14,524 800 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-21 38 17,224 2,700 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-22 38 18,124 900 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-23 38 20,724 2,600 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-28 38 22,224 1,500 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-29 38 22,924 700 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-30 38 25,324 2,400 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-31 38 26,724 1,400 Inc. Inc. Neo Performance Materials Common Shares Neo Performance Materials 1 2020-07-31 38 0 -26,724 Inc. Inc. Nerds On Site Inc. Subordinate Voting Regan, Charles Donald 4, 5 2020-08-13 10 0.045 497,424 76,667 Shares Nerds On Site Inc. Subordinate Voting Smit, Jacques Antonius 4 2020-08-13 10 0.045 600,000 100,000 Shares New Found Gold Corp. Common Shares 2176423 Ontario Ltd. 3 2020-08-11 00 25,250,000 New Found Gold Corp. Common Shares ANDERSON, JOHN 4 2018-04-20 00 New Found Gold Corp. Options ANDERSON, JOHN 4 2018-04-20 00 New Found Gold Corp. Options ANDERSON, JOHN 4 2019-12-19 50 0.5 450,000 450,000 New Found Gold Corp. Options ANDERSON, JOHN 4 2020-05-23 50 1.075 500,000 50,000 New Found Gold Corp. Options ANDERSON, JOHN 4 2020-08-11 50 1.4 550,000 50,000

August 20, 2020 (2020), 43 OSCB 6650

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed New Found Gold Corp. Warrants ANDERSON, JOHN 4 2018-04-20 00 New Found Gold Corp. Common Shares Hennigh, Quinton Todd 4 2020-08-11 00 New Found Gold Corp. Common Shares Hennigh, Quinton Todd 4 2020-08-11 10 15300 15,300 15,300 New Found Gold Corp. Options Hennigh, Quinton Todd 4 2020-08-11 00 300,000 New Found Gold Corp. Options Hennigh, Quinton Todd 4 2020-08-12 50 1.4 500,000 200,000 New Found Gold Corp. Options Hennigh, Quinton Todd 4 2020-08-11 00 New Found Gold Corp. Options Hennigh, Quinton Todd 4 2020-08-11 50 1.4 200,000 New Found Gold Corp. Options Hennigh, Quinton Todd 4 2020-08-11 50 1.4 200,000 New Found Gold Corp. Options Kettell, Collin 4, 6, 5 2020-08-11 00 2,545,000 New Found Gold Corp. Options Kettell, Collin 4, 6, 5 2020-08-11 50 4,280,000 1,735,000 New Found Gold Corp. Common Shares Laviolette, Denis Roland 4, 5 2020-08-11 00 3,500,000 New Found Gold Corp. Options Laviolette, Denis Roland 4, 5 2020-08-11 00 1,700,000 New Found Gold Corp. Options Laviolette, Denis Roland 4, 5 2020-08-11 50 2,700,000 1,000,000 New Found Gold Corp. Common Shares NOVO RESOURCES 3 2020-07-31 00 15,000,000 CORP. New Found Gold Corp. Common Shares Palisades Goldcorp Ltd. 3 2020-08-11 00 New Found Gold Corp. Common Shares Palisades Goldcorp Ltd. 3 2020-08-11 00 New Found Gold Corp. Common Shares Palisades Goldcorp Ltd. 3 2020-08-11 00 New Found Gold Corp. Common Shares Palisades Goldcorp Ltd. 3 2020-08-11 00 New Found Gold Corp. Common Shares Palisades Goldcorp Ltd. 3 2020-08-11 00 46,566,425 New Found Gold Corp. Common Shares Roberts, Craig A. 4, 5 2020-08-11 00 1,250,000 New Found Gold Corp. Common Shares Roberts, Craig A. 4, 5 2020-08-11 00 250,000 New Found Gold Corp. Options Roberts, Craig A. 4, 5 2020-08-11 00 1,925,000 New Found Gold Corp. Options Roberts, Craig A. 4, 5 2020-08-12 50 1.4 3,175,000 1,250,000 New Found Gold Corp. Common Shares Sprott, Eric S. 3 2020-08-11 00 25,250,000 New Leaf Ventures Inc. Common Shares Stier, Michael Alan 4, 5 2020-02-11 00 1,500 New Placer Dome Gold Common Shares Sali, Maximilian 4, 5 2020-08-10 10 0.66 1,987,250 5,000 Corp. (formerly, Barrian Mining Corp.) New Placer Dome Gold Common Shares Sali, Maximilian 4, 5 2020-08-10 10 0.61 1,997,250 10,000 Corp. (formerly, Barrian Mining Corp.) New Placer Dome Gold Common Shares Sali, Maximilian 4, 5 2020-08-11 10 0.09 25,000 Corp. (formerly, Barrian Mining Corp.) New Placer Dome Gold Common Shares Sali, Maximilian 4, 5 2020-08-11 10 0.59 2,022,250 25,000 Corp. (formerly, Barrian Mining Corp.) New Tech Minerals Corp. Common Shares Naughty, Blair Lawrence 3 2020-07-14 10 0.03 7,611,500 116,000 New Tech Minerals Corp. Common Shares Naughty, Blair Lawrence 3 2020-08-11 10 0.035 7,369,500 -299,000 New Tech Minerals Corp. Common Shares Naughty, Blair Lawrence 3 2020-08-12 37 3,684,750 -3,684,750 New Tech Minerals Corp. Common Shares Naughty, Blair Lawrence 3 2020-08-13 10 0.09 3,594,750 -90,000 New Tech Minerals Corp. Common Shares Naughty, Blair Lawrence 3 2020-07-14 10 0.03 116,000 New Tech Minerals Corp. Common Shares Naughty, Blair Lawrence 3 2020-07-16 10 0.03 57,000 New Tech Minerals Corp. Common Shares Naughty, Blair Lawrence 3 2020-08-11 10 0.035 -299,000 New Tech Minerals Corp. Common Shares Naughty, Blair Lawrence 3 2020-07-16 10 0.03 7,668,500 57,000 NextPoint Acquisition Corp. Class B Shares Amato, Frank Carmelo 4, 5 2020-07-16 00 10,000 NextPoint Acquisition Corp. Class B Shares Benjamin, Brian Anthony 4 2020-07-16 00 10,000 NextPoint Acquisition Corp. Class B Shares Coleman, George William 4 2020-07-16 00 10,000 NextPoint Acquisition Corp. Class B Shares Lane, Wendy Evrard 4 2020-07-16 00 10,000 NextPoint Acquisition Corp. Class B Shares Lederer, John Anthony 4 2020-07-16 00 10,000 NextPoint Acquisition Corp. Class A Restricted Voting Neuberger, Andrew Blair 4, 6, 5 2020-07-16 00 Units NextPoint Acquisition Corp. Class B Shares Neuberger, Andrew Blair 4, 6, 5 2020-07-16 00 NextPoint Acquisition Corp. Class B Shares NextPoint Acquisition 3 2020-07-23 00 5,863,125 Sponsor LLC NextPoint Acquisition Corp. Class B Shares NextPoint Acquisition 3 2020-08-11 15 0.0042 6,463,125 600,000 Sponsor LLC NFI Group Inc. (formerly Common Shares Cochran, Phyllis Elaine 4 2020-08-11 10 11.788 10,888 1,000 New Flyer Industries Inc.) NFI Group Inc. (formerly Common Shares Gray, Adam L. 4 2020-08-10 10 15.2 4,405,746 150,300 New Flyer Industries Inc.)

August 20, 2020 (2020), 43 OSCB 6651

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Nighthawk Gold Corp. Common Shares Cudney, Robert Douglas 3 2020-07-29 10 1.74 8,732,400 39,000 Nighthawk Gold Corp. Common Shares Cudney, Robert Douglas 3 2020-08-06 10 1.91 8,807,400 5,000 Nighthawk Gold Corp. Common Shares Cudney, Robert Douglas 3 2020-08-06 10 1.86 8,812,400 5,000 Nighthawk Gold Corp. Common Shares Cudney, Robert Douglas 3 2020-08-07 10 1.81 8,817,400 5,000 Nighthawk Gold Corp. Common Shares Cudney, Robert Douglas 3 2020-08-10 10 1.76 8,822,400 5,000 Nighthawk Gold Corp. Common Shares Cudney, Robert Douglas 3 2020-08-12 10 1.6957 8,972,400 150,000 Nomad Royalty Company Options Dutil, Annie 5 2020-08-06 00 182,700 Ltd. Nomad Royalty Company Rights Restricted Share Dutil, Annie 5 2020-08-06 00 56,300 Ltd. Units Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 51 36.56 8,061 6,000 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.243 8,011 -50 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.23 7,711 -300 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.34 6,961 -750 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.43 6,761 -200 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.3 6,561 -200 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.27 6,361 -200 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.31 6,061 -300 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.33 5,061 -1,000 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.285 4,861 -200 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.25 4,561 -300 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.244 4,461 -100 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.24 4,361 -100 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.22 3,661 -700 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.21 2,361 -1,300 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.076 2,261 -100 Richard Norbord Inc. Common Shares Dubois-Phillips, Mark 5 2020-08-07 10 42.26 2,061 -200 Richard Norbord Inc. Options Dubois-Phillips, Mark 5 2019-11-11 51 37.8 30,000 Richard Norbord Inc. Options Dubois-Phillips, Mark 5 2019-11-11 50 37.8 67,500 30,000 Richard Norbord Inc. Options Dubois-Phillips, Mark 5 2020-08-07 51 36.56 61,500 -6,000 Richard Norbord Inc. Common Shares Lampard, Robin E.A. 5 2020-08-11 51 14.93 51,734 22,700 Norbord Inc. Common Shares Lampard, Robin E.A. 5 2020-08-11 10 43 29,034 -22,700 Norbord Inc. Common Shares Lampard, Robin E.A. 5 2020-08-12 51 14.93 76,334 47,300 Norbord Inc. Common Shares Lampard, Robin E.A. 5 2020-08-12 10 42.935 29,034 -47,300 Norbord Inc. Options Lampard, Robin E.A. 5 2020-08-11 51 14.93 302,300 -22,700 Norbord Inc. Options Lampard, Robin E.A. 5 2020-08-12 51 14.93 255,000 -47,300 North American Nickel Inc. Common Shares Morrison, Richard William 4, 5 2020-08-13 16 0.07 653,191 209,858 Keith North American Nickel Inc. Common Shares Morrison, Richard William 4, 5 2014-12-17 00 514,759 Keith North American Nickel Inc. Warrants Morrison, Richard William 4, 5 2020-08-13 16 0.09 796,524 209,858 Keith Northcliff Resources Ltd. Options Cousens, Scott Dibblee 4 2020-08-10 52 150,000 -75,000

August 20, 2020 (2020), 43 OSCB 6652

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Nouveau Monde Graphite Warrants TURPIN, ARMAND 3 2020-08-11 55 4,764,667 -1,250,000 Inc. (auparavant Nouveau Monde Mining Enterprises Inc.) Novo Resources Corp. Common Shares Kirkland Lake Gold Ltd. 3 2020-06-08 10 3.22 29,785,268 -45,000 Novo Resources Corp. Common Shares Kirkland Lake Gold Ltd. 3 2020-06-09 10 3.28 29,761,568 -23,700 Novo Resources Corp. Common Shares Kirkland Lake Gold Ltd. 3 2020-06-10 10 3.24 29,717,168 -44,400 Novo Resources Corp. Common Shares Kirkland Lake Gold Ltd. 3 2020-06-11 10 3.36 29,661,168 -56,000 Novo Resources Corp. Common Shares Kirkland Lake Gold Ltd. 3 2020-06-12 10 3.266 29,620,268 -40,900 Novo Resources Corp. Common Shares Kirkland Lake Gold Ltd. 3 2020-08-06 10 3.54 29,516,968 -103,300 Novo Resources Corp. Common Shares Kirkland Lake Gold Ltd. 3 2020-08-07 10 3.49 29,413,068 -103,900 Novo Resources Corp. Common Shares Kirkland Lake Gold Ltd. 3 2020-08-10 10 3.54 29,299,368 -113,700 Novo Resources Corp. Common Shares Kirkland Lake Gold Ltd. 3 2020-08-11 10 3.42 29,212,668 -86,700 Novo Resources Corp. Common Shares Kirkland Lake Gold Ltd. 3 2020-08-12 10 3.55 29,081,568 -131,100 Nubian Resources Ltd. Common Shares Class A TREADGOLD, 4 2020-08-10 10 0.67 593,500 -9,500 voting LAWRENCE, GARNET Nubian Resources Ltd. Common Shares Class A TREADGOLD, 4 2020-08-10 10 0.66 563,000 -30,500 voting LAWRENCE, GARNET Nubian Resources Ltd. Common Shares Class A TREADGOLD, 4 2020-08-10 10 0.65 558,000 -5,000 voting LAWRENCE, GARNET Nuinsco Resources Limited Common Shares Galipeau, René Réal 4 2020-08-07 10 0.012 19,775,327 -162,713 NuLegacy Gold Corporation Warrants Anderson, James 4, 5 2020-08-13 55 1,750,000 -100,000 NuLegacy Gold Corporation Warrants Cope, Edward Leon 4 2020-08-13 55 0 -500,000 NuLegacy Gold Corporation Warrants Davidson, Alexander John 4, 5 2020-08-13 55 1,750,000 -250,000 NuLegacy Gold Corporation Warrants Lee, Danny Wayne Kent 5 2020-08-13 55 0.3 0 -50,000 NuLegacy Gold Corporation Warrants Steininger, Roger Claude 4, 5 2020-08-13 55 200,000 -100,870 Nuran Wireless Inc. Common Shares 9369-5864 Quebec, Inc. 3 2020-08-10 10 0.0303 32,587,790 -1,000,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares 9369-5864 Quebec, Inc. 3 2020-08-11 10 0.0301 31,584,790 -1,003,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares 9369-5864 Quebec, Inc. 3 2020-08-12 10 0.03 29,584,790 -2,000,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares 9369-5864 Quebec, Inc. 3 2020-08-13 10 0.03 28,084,790 -1,500,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Carrier, Alain 6 2020-08-10 10 0.0303 32,587,790 -1,000,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Carrier, Alain 6 2020-08-11 10 0.0301 31,584,790 -1,003,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Carrier, Alain 6 2020-08-12 10 0.03 29,584,790 -2,000,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Carrier, Alain 6 2020-08-13 10 0.03 28,084,790 -1,500,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Carrier, Richard 6 2020-08-10 10 0.0303 32,587,790 -1,000,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Carrier, Richard 6 2020-08-11 10 0.0301 31,584,790 -1,003,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Carrier, Richard 6 2020-08-12 10 0.03 29,584,790 -2,000,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Carrier, Richard 6 2020-08-13 10 0.03 28,084,790 -1,500,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Kruse, Stephan 6 2020-08-10 10 0.0303 32,587,790 -1,000,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Kruse, Stephan 6 2020-08-11 10 0.0301 31,584,790 -1,003,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Kruse, Stephan 6 2020-08-12 10 0.03 29,584,790 -2,000,000 (formerly 1014372 B.C. Ltd.) Nuran Wireless Inc. Common Shares Kruse, Stephan 6 2020-08-13 10 0.03 28,084,790 -1,500,000 (formerly 1014372 B.C. Ltd.) Nutrien Ltd. Common Shares Silva, Nelson Luiz Costa 4 2020-08-10 00 Nutrien Ltd. Deferred Share Units Silva, Nelson Luiz Costa 4 2020-08-10 00 O3 Mining Inc. Common Shares Tyshynski, Elijah 4 2019-07-05 00 O3 Mining Inc. Common Shares Tyshynski, Elijah 4 2020-08-11 10 2.4 10,000 10,000 Oakley Ventures Inc. Common Shares Collick, Glenn Edward 4, 5 2020-08-10 10 0.2181 625,000 -40,000

August 20, 2020 (2020), 43 OSCB 6653

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Obsidian Energy Ltd. Options Hawkins, Mark Kristian 5 2020-08-10 50 0.56 106,065 100,300 Rodger Obsidian Energy Ltd. Options Loukas, Stephen 4, 5 2018-05-11 00 Obsidian Energy Ltd. Options Loukas, Stephen 4, 5 2020-08-10 50 0.56 200,000 200,000 Obsidian Energy Ltd. Options Scott, Peter D. 5 2019-12-02 00 Obsidian Energy Ltd. Options Scott, Peter D. 5 2020-08-10 50 0.56 84,300 84,300 Obsidian Energy Ltd. Options Smith, Aaron 5 2018-07-09 00 Obsidian Energy Ltd. Options Smith, Aaron 5 2020-08-10 50 0.56 126,900 126,900 Obsidian Energy Ltd. Options Sykes, Gareth Robin 5 2019-11-20 00 Obsidian Energy Ltd. Options Sykes, Gareth Robin 5 2020-08-10 50 0.56 100,300 100,300 Olympia Financial Group Common Shares McCullagh, Neil Robert 5 2020-07-27 00 4,411 Inc. Open Text Corporation Options All OTEX Option Barrenechea, Mark James 4, 5 2020-08-10 50 45.81 2,185,357 213,680 Plans Open Text Corporation Options All OTEX Option Barrenechea, Mark James 4, 5 2020-08-10 50 45.81 2,935,357 750,000 Plans Open Text Corporation Performance Share Units Barrenechea, Mark James 4, 5 2020-08-10 56 45.73 317,590 76,540 Open Text Corporation Restricted Share Units Barrenechea, Mark James 4, 5 2020-08-10 56 45.73 218,790 98,270 Open Text Corporation Options All OTEX Option Berry, Savinay 5 2020-08-10 50 45.81 149,545 95,720 Plans Open Text Corporation Performance Share Units Berry, Savinay 5 2020-08-10 56 45.73 11,200 7,650 Open Text Corporation Restricted Share Units Berry, Savinay 5 2020-08-10 56 45.73 13,178 8,518 Open Text Corporation Options All OTEX Option Blatt, Louis Allan 5 2020-08-10 50 45.81 86,691 46,691 Plans Open Text Corporation Performance Share Units Blatt, Louis Allan 5 2020-04-20 00 Open Text Corporation Performance Share Units Blatt, Louis Allan 5 2020-08-10 56 45.73 5,470 5,470 Open Text Corporation Restricted Share Units Blatt, Louis Allan 5 2020-04-20 00 Open Text Corporation Restricted Share Units Blatt, Louis Allan 5 2020-08-10 56 45.73 4,712 4,712 Open Text Corporation Options All OTEX Option Davies, Gordon Allan 5 2020-08-10 50 45.81 290,902 118,022 Plans Open Text Corporation Performance Share Units Davies, Gordon Allan 5 2020-08-10 56 45.73 54,790 13,670 Open Text Corporation Restricted Share Units Davies, Gordon Allan 5 2020-08-10 56 45.73 32,425 11,865 Open Text Corporation Options All OTEX Option Donohue, James Prentiss 5 2020-08-10 50 45.81 160,765 45,895 Plans Open Text Corporation Performance Share Units Donohue, James Prentiss 5 2020-08-10 56 45.73 16,100 4,370 Open Text Corporation Restricted Share Units Donohue, James Prentiss 5 2020-08-10 56 45.73 10,174 4,314 Open Text Corporation Options All OTEX Option Duggan, Paul Michael 5 2020-08-10 50 45.81 183,455 48,945 Plans Open Text Corporation Performance Share Units Duggan, Paul Michael 5 2020-08-10 56 45.73 16,030 5,470 Open Text Corporation Restricted Share Units Duggan, Paul Michael 5 2020-08-10 56 45.73 19,034 4,854 Open Text Corporation Deferred Share Units Fowlie, Randy 4 2020-08-10 56 45.73 97,132 120 Open Text Corporation Deferred Share Units Fraser, David 4 2020-08-10 56 45.73 13,631 37 Open Text Corporation Options All OTEX Option Harrison, Simon David 5 2020-08-10 50 45.81 277,602 133,752 Plans Open Text Corporation Performance Share Units Harrison, Simon David 5 2020-08-10 56 45.73 30,610 13,670 Open Text Corporation Restricted Share Units Harrison, Simon David 5 2020-08-10 56 45.73 21,327 12,857 Open Text Corporation Options All OTEX Option Jamieson, John David 5 2020-08-10 50 45.81 86,198 50,594 Plans Open Text Corporation Performance Share Units Jamieson, John David 5 2020-08-10 56 45.73 18,220 5,470 Open Text Corporation Restricted Share Units Jamieson, John David 5 2020-08-10 56 45.73 11,338 4,958 Open Text Corporation Common Shares OTEX Majzoub, Muhieddine 5 2020-08-13 51 16.583 96,795 20,996 Common Open Text Corporation Common Shares OTEX Majzoub, Muhieddine 5 2020-08-13 10 43.864 84,192 -12,603 Common Open Text Corporation Options All OTEX Option Majzoub, Muhieddine 5 2020-08-10 50 45.81 428,528 127,672 Plans Open Text Corporation Options All OTEX Option Majzoub, Muhieddine 5 2020-08-13 51 16.583 407,532 -20,996 Plans Open Text Corporation Performance Share Units Majzoub, Muhieddine 5 2020-08-10 56 45.73 57,310 13,390 Open Text Corporation Restricted Share Units Majzoub, Muhieddine 5 2020-08-10 56 45.73 34,352 12,392 Open Text Corporation Options All OTEX Option McGourlay, Christopher 5 2020-08-10 50 45.81 177,761 65,423 Plans James

August 20, 2020 (2020), 43 OSCB 6654

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Open Text Corporation Performance Share Units McGourlay, Christopher 5 2020-08-10 56 45.73 22,620 7,650 James Open Text Corporation Restricted Share Units McGourlay, Christopher 5 2020-08-10 56 45.73 14,098 6,608 James Open Text Corporation Options All OTEX Option Parker, Douglas Michael 5 2020-08-10 50 45.81 98,832 45,852 Plans Open Text Corporation Performance Share Units Parker, Douglas Michael 5 2020-08-10 56 45.73 9,790 5,470 Open Text Corporation Restricted Share Units Parker, Douglas Michael 5 2020-08-10 56 45.73 6,819 4,659 Open Text Corporation Options All OTEX Option Ranganathan, Madhu 5 2020-08-10 50 45.81 520,064 155,054 Plans Open Text Corporation Performance Share Units Ranganathan, Madhu 5 2020-08-10 56 45.73 51,740 17,490 Open Text Corporation Restricted Share Units Ranganathan, Madhu 5 2020-08-10 56 45.73 32,577 15,447 Open Text Corporation Options All OTEX Option Rosen, Howard Daniel 5 2020-08-10 50 45.81 15,822 5,822 Plans Open Text Corporation Performance Share Units Rosen, Howard Daniel 5 2020-04-01 00 Open Text Corporation Performance Share Units Rosen, Howard Daniel 5 2020-08-10 56 45.73 2,190 2,190 Open Text Corporation Restricted Share Units Rosen, Howard Daniel 5 2020-04-01 00 Open Text Corporation Restricted Share Units Rosen, Howard Daniel 5 2020-08-10 56 45.73 2,557 2,557 Open Text Corporation Deferred Share Units Slaunwhite, Michael 4 2020-08-10 56 45.73 111,502 138 William George Open Text Corporation Deferred Share Units Stevenson, Katharine 4 2020-08-10 56 45.73 91,945 116 Berghuis Open Text Corporation Options All OTEX Option Stilwell, Craig Tucker 5 2020-08-10 50 45.81 226,609 80,819 Plans Open Text Corporation Performance Share Units Stilwell, Craig Tucker 5 2020-08-10 56 45.73 25,330 10,930 Open Text Corporation Restricted Share Units Stilwell, Craig Tucker 5 2020-08-10 56 45.73 25,841 8,641 Open Text Corporation Options All OTEX Option Sweeney, Brian Paul 5 2020-08-10 50 45.81 182,379 93,227 Plans Open Text Corporation Performance Share Units Sweeney, Brian Paul 5 2020-08-10 56 45.73 19,260 7,650 Open Text Corporation Restricted Share Units Sweeney, Brian Paul 5 2020-08-10 56 45.73 14,171 8,361 Open Text Corporation Deferred Share Units Weinstein, Deborah 4 2020-08-10 56 45.73 106,699 135 Orbit Garant Drilling Inc. Common Shares Veilleux, Nicole 4 2020-08-12 00 20,000 Orca Gold Inc. Common Shares Clark, Richard Peter 4, 5 2020-08-11 10 0.52 10,689,799 250,000 Orefinders Resources Inc. Options Potwarka, Jeffrey 5 2020-08-14 50 375,000 150,000 Orford Mining Corporation Common Shares Karora Resources Inc. 3 2020-08-12 11 0.09 10,393,152 -11,251,456 Origen Resources Inc. Common Shares Schellenberg, Gary David 4 2020-08-13 10 0.2 465,250 50,000 Albert Origen Resources Inc. Common Shares Schellenberg, Gary David 4 2020-08-13 10 0.2 293,250 5,000 Albert Oroco Resource Corp. Options Friesen, Robert George 4 2020-07-30 11 0.075 900,000 450,000 Oroco Resource Corp. Common Shares LEAHY, STEPHEN 4, 5 2020-08-10 10 0.68 1,865,000 -15,000 MARTIN Oroco Resource Corp. Common Shares LEAHY, STEPHEN 4, 5 2020-08-10 10 0.67 1,860,000 -5,000 MARTIN Oroco Resource Corp. Common Shares LEAHY, STEPHEN 4, 5 2020-08-11 10 0.68 1,850,000 -10,000 MARTIN Oroco Resource Corp. Common Shares LEAHY, STEPHEN 4, 5 2020-08-11 10 0.67 1,840,000 -10,000 MARTIN ORTHO REGENERATIVE Options Leduc, Claude 5 2020-07-21 50 745,000 245,000 TECHNOLOGIES INC. OSISKO GOLD Common Shares Desharnais, Guy 5 2020-08-05 00 1,914 ROYALTIES LTD OSISKO GOLD Options Desharnais, Guy 5 2020-08-05 00 38,400 ROYALTIES LTD OSISKO GOLD Rights Restricted Share Desharnais, Guy 5 2020-08-05 00 16,499 ROYALTIES LTD Units/Unités d'actions restreintes Pacific Empire Minerals Options Casswell, Kim Charisse 5 2020-08-12 50 0.19 135,000 50,000 Corp. Pacific Empire Minerals Options Donaldson, Larry Bryce 4 2020-08-12 50 0.19 600,000 200,000 Corp. Pacific Empire Minerals Options Peters, Bradley 4, 5 2020-08-12 50 0.19 1,000,000 500,000 Corp. Pacific Empire Minerals Options Reed, Douglas Leigh 5 2020-08-12 50 0.19 292,500 100,000 Corp.

August 20, 2020 (2020), 43 OSCB 6655

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Pacific Empire Minerals Options Ritchie, Rory 4, 5 2020-08-12 50 0.19 1,000,000 500,000 Corp. Palamina Corp. Common Shares Thomson, Andrew 4 2020-08-14 10 0.26 792,916 6,200 Palamina Corp. Common Shares Thomson, Andrew 4 2020-08-10 10 0.32 952,300 500 Palamina Corp. Common Shares Thomson, Andrew 4 2020-08-11 10 0.3 954,300 2,000 Palamina Corp. Common Shares Thomson, Andrew 4 2020-08-14 10 0.26 960,300 6,000 Pan American Silver Corp. Common Shares Winckler, Gillian 4 2020-08-11 10 45 17,527 -2,000 Pan Global Resources Inc. Common Shares evans, patrick charles 4 2020-08-10 10 0.3 1,631,000 25,000 Pan Global Resources Inc. Common Shares evans, patrick charles 4 2020-08-11 10 0.28 1,641,000 10,000 Pancontinental Resources Options Croft, Thomas Layton 4 2020-08-10 50 0.14 5,900,000 1,500,000 Corporation Pancontinental Resources Options Irwin, Christopher 5 2020-08-10 50 500,000 50,000 Corporation Pancontinental Resources Options Mark, Richard Joseph 4, 5 2020-08-10 50 0.14 1,925,000 125,000 Corporation Pancontinental Resources Options McMurdie, Mark Andrew 5 2020-08-10 50 0.14 1,375,000 300,000 Corporation Pancontinental Resources Options Mosher, David Vaughn 4 2020-08-10 50 2,975,000 500,000 Corporation Pancontinental Resources Options Petroff, David Michael 4 2010-08-10 50 0.14 125,000 125,000 Corporation Pancontinental Resources Options Petroff, David Michael 4 2019-01-18 50 0.8 1,425,000 50,000 Corporation Pancontinental Resources Options Whalen, Donald Alexander 4 2020-08-10 50 1,375,000 300,000 Corporation Parkland Corporation Common Shares Espey, Robert Berthold 5 2020-08-13 51 17.79 525,207 16,137 Parkland Corporation Common Shares Espey, Robert Berthold 5 2020-08-13 10 40.385 509,070 -16,137 Parkland Corporation Share Options Espey, Robert Berthold 5 2020-08-12 51 17.79 984,008 -16,137 Patagonia Gold Corp. Common Shares Patagonia Gold Corp. 1 2020-08-05 38 0.155 78,000 18,000 Patagonia Gold Corp. Common Shares Patagonia Gold Corp. 1 2020-08-05 38 0.15 118,500 40,500 Patagonia Gold Corp. Common Shares Patagonia Gold Corp. 1 2020-08-06 38 0.16 124,500 6,000 Patagonia Gold Corp. Common Shares Patagonia Gold Corp. 1 2020-08-06 38 0.155 136,000 11,500 Patagonia Gold Corp. Common Shares Patagonia Gold Corp. 1 2020-08-07 38 0.17 143,000 7,000 Patagonia Gold Corp. Common Shares Patagonia Gold Corp. 1 2020-08-07 38 0.155 145,000 2,000 Patagonia Gold Corp. Common Shares Patagonia Gold Corp. 1 2020-08-10 38 0.155 155,000 10,000 Patagonia Gold Corp. Common Shares van Tienhoven, Christopher 5 2020-08-10 10 0.16 355,822 10,000 Peak Positioning Common Shares Dumas, Mark 4 2020-07-28 37 621,490 -5,593,410 Technologies Inc. Peak Positioning Options Dumas, Mark 4 2020-07-28 37 521,300 -4,691,700 Technologies Inc. Peak Positioning Common Shares JOSEPH, Johnson 4, 5 2020-07-28 37 717,011 -6,453,096 Technologies Inc. Peak Positioning Options JOSEPH, Johnson 4, 5 2020-07-28 37 1,537,000 -13,833,000 Technologies Inc. Peak Positioning Warrants JOSEPH, Johnson 4, 5 2020-08-06 11 200,000 200,000 Technologies Inc. Peak Positioning Common Shares Landreville, Jean 5 2020-07-28 37 37,800 -340,200 Technologies Inc. Peak Positioning Options Landreville, Jean 5 2020-07-28 37 565,000 -5,085,000 Technologies Inc. Peak Positioning Warrants Landreville, Jean 5 2020-07-28 37 60,000 -540,000 Technologies Inc. Peak Positioning Warrants Landreville, Jean 5 2020-08-06 11 160,000 100,000 Technologies Inc. Peak Positioning Warrants Liang, Qiu 4 2016-05-31 00 Technologies Inc. Peak Positioning Warrants Liang, Qiu 4 2020-08-06 11 300,000 Technologies Inc. Peak Positioning Warrants Liang, Qiu 4 2020-08-06 11 300,000 Technologies Inc. Peak Positioning Warrants Liang, Qiu 4 2020-08-06 11 -950,000 Technologies Inc. Peak Positioning Warrants Liang, Qiu 4 2020-08-06 11 -9,650,000 Technologies Inc.

August 20, 2020 (2020), 43 OSCB 6656

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Peak Positioning Warrants Liang, Qiu 4 2020-08-06 11 -9,650,000 Technologies Inc. Peak Positioning Warrants Liang, Qiu 4 2020-08-06 11 1,745,000 -650,000 Technologies Inc. Peak Positioning Options Pesner, Michael 4 2020-08-07 00 Technologies Inc. Peak Positioning Options Pesner, Michael 4 2020-08-07 50 0.225 500,000 500,000 Technologies Inc. Peak Positioning Common Shares Tessier, Charles-André 4 2020-07-28 37 101,498 -913,482 Technologies Inc. Peak Positioning Options Tessier, Charles-André 4 2020-07-28 37 594,500 -5,350,500 Technologies Inc. Pembina Pipeline Common Shares Forrest, Jennifer 5 2020-08-10 10 34.1 1,400 400 Corporation Petroteq Energy Inc. Common Shares Stapleton, George T. 5 2020-08-07 00 Petroteq Energy Inc. Common Shares Stapleton, George T. 5 2020-08-07 11 0.085 1,000,000 Petroteq Energy Inc. Common Shares Stapleton, George T. 5 2020-08-07 11 0.085 1,000,000 Petroteq Energy Inc. Options Stapleton, George T. 5 2020-08-07 00 Petroteq Energy Inc. Options Stapleton, George T. 5 2020-08-07 50 3,000,000 3,000,000 Petrus Resources Ltd. Options New Options Arnell, Patrick 4 2020-08-04 52 2.22 0 -1,800 Petrus Resources Ltd. Options New Options CORMACK, Donald 4 2020-08-04 52 2.22 0 -1,800 Gordon Petrus Resources Ltd. Options New Options Gray, Don 4 2020-08-04 52 2.22 0 -2,400 Petrus Resources Ltd. Options New Options Korchinski, Neil 5 2020-08-04 52 2.22 338,401 -30,000 Petrus Resources Ltd. Options New Options White, Stephen 4 2020-08-04 52 2.22 0 -1,800 Peyto Exploration & Common Shares Robinson, Scott 5 2020-08-14 10 2.65 191,507 20,000 Development Corp. PFB Corporation Restricted Share Unit Carruthers, Bruce Malcolm 4, 5 2020-08-04 30 11.5 200,000 100,000 Plan - B. Carruthers PFB Corporation Restricted Share Unit Carruthers, Bruce Malcolm 4, 5 2020-08-05 10 11.5 150,000 -50,000 Plan - B. Carruthers PHX Energy Services Corp. Retention Awards (Cash- Athaide, Judith 4 2020-08-07 57 66,316 -186 based Only) PHX Energy Services Corp. Retention Awards (Cash- Freeman, Terrance 4 2020-08-07 57 102,509 -1,783 based Only) PHX Energy Services Corp. Retention Awards (Cash- Hibbard, Lawrence M. 4 2020-08-07 57 156,774 -497 based Only) PHX Energy Services Corp. Retention Awards (Cash- Hooks, John Michael 5 2020-08-07 57 446,467 -497 based Only) PHX Energy Services Corp. Retention Awards (Cash- Tetreault, Myron Arthur 4 2020-08-07 57 166,725 -746 based Only) PHX Energy Services Corp. Retention Awards (Cash- Thomas, Roger Dale 4 2020-08-07 57 121,543 -560 based Only) Pieridae Energy Limited Options de Freitas, Timothy 5 2018-12-21 00 (formerly Petrolia Inc.) Pieridae Energy Limited Options de Freitas, Timothy 5 2018-12-21 00 (formerly Petrolia Inc.) Pieridae Energy Limited Options de Freitas, Timothy 5 2018-12-21 00 281,686 (formerly Petrolia Inc.) Pine Cliff Energy Ltd. Common Shares Disbrow, Robert 3 2020-08-07 10 0.15 22,955,500 23,500 Pine Cliff Energy Ltd. Common Shares Hodge, Philip Blake 4, 5 2020-08-11 10 0.175 6,624,391 10,000 Pinedale Energy Limited Common Shares Class A Nielsen, Gordon 4 2020-08-11 11 125,000 -125,000 Pipestone Energy Corp. Common Shares Hoffman, Dustin Lee 5 2020-08-14 10 0.65 94,014 40,000 (formerly, Blackbird Energy Inc.) PJX Resources Inc. Options Brennan, Linda 4, 5 2020-08-12 50 0.2 2,410,000 450,000 PJX Resources Inc. Options Clare, James 5 2020-07-20 52 850,000 -200,000 PJX Resources Inc. Options Clare, James 5 2020-08-12 50 1,150,000 300,000 PJX Resources Inc. Options Del Campo, Joseph 4 2020-08-12 50 0.2 1,255,000 350,000 PJX Resources Inc. Options Hoy, Trygve 4 2020-08-12 50 0.2 647,500 325,000 PJX Resources Inc. Options Keating, John 4, 5 2020-08-12 50 0.2 2,345,000 450,000 Plateau Energy Metals Inc. Common Shares Disbrow, Robert 3 2020-08-10 10 0.3332 6,930,112 -100,000 Plateau Energy Metals Inc. Common Shares Disbrow, Robert 3 2020-08-11 10 0.3353 6,922,612 -7,500 Plateau Energy Metals Inc. Common Shares Disbrow, Robert 3 2020-08-12 10 0.3336 6,884,112 -38,500

August 20, 2020 (2020), 43 OSCB 6657

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Platinum Group Metals Ltd. Common Shares Begic, Kris 5 2020-08-10 10 2.58 22,806 -2,000 Platinum Group Metals Ltd. Common Shares Begic, Kris 5 2020-08-10 10 3.53 20,806 -2,000 Platinum Group Metals Ltd. Common Shares Begic, Kris 5 2020-08-10 10 3.41 19,606 -1,200 Platinum Group Metals Ltd. Common Shares Begic, Kris 5 2020-08-10 10 3.42 18,806 -800 Plymouth Realty Capital Common Shares Girling, W. Barry 4 2018-11-28 00 Corp. Plymouth Realty Capital Common Shares Girling, W. Barry 4 2020-07-15 16 0.05 100,000 100,000 Corp. Postmedia Network Canada Class NC Variable Voting Cooperman, Leon 3 2020-08-04 10 1.2387 7,239,882 500 Corp. Shares Postmedia Network Canada Class NC Variable Voting Cooperman, Leon 3 2020-08-06 10 1.4214 7,240,282 400 Corp. Shares Power Corporation of Options Lefebvre, Jocelyn 5 2020-08-07 00 649,452 Canada Power Corporation of Performance Share Units Lefebvre, Jocelyn 5 2020-08-07 00 75,822 Canada Power Corporation of PFC Performance Share Lefebvre, Jocelyn 5 2020-08-07 00 23,038 Canada Units Power Corporation of Subordinate Voting Lefebvre, Jocelyn 5 2020-08-07 00 Canada Shares Power Corporation of Subordinate Voting Lefebvre, Jocelyn 5 2020-08-07 00 Canada Shares Power Corporation of Subordinate Voting Lefebvre, Jocelyn 5 2020-08-07 00 50,000 Canada Shares Power Corporation of Subordinate Voting Lefebvre, Jocelyn 5 2020-08-07 00 77,432 Canada Shares Power Financial Corporation PFC Performance Share Lefebvre, Jocelyn 2 2020-08-07 00 23,038 Units PrairieSky Royalty Ltd. Common Shares Robotti, Robert Edward 4 2020-05-14 90 113 -4 PrairieSky Royalty Ltd. Common Shares Robotti, Robert Edward 4 2020-07-21 10 6.56 109 -4 Precipitate Gold Corp. Common Shares Chuang, Vivien Wei-Li 5 2020-08-11 51 50000 50,000 50,000 Precipitate Gold Corp. Common Shares Chuang, Vivien Wei-Li 5 2020-08-11 10 0.35 0 -50,000 Precipitate Gold Corp. Options Chuang, Vivien Wei-Li 5 2020-08-11 51 0.12 50,000 -50,000 Providence Gold Mines Inc. Common Shares coombes, ronald allan 4 2020-08-11 10 0.12 1,650,000 47,500 Providence Gold Mines Inc. Options coombes, ronald allan 4 2020-07-13 50 575,000 175,000 Providence Gold Mines Inc. Options coombes, ronald allan 4 2020-08-06 50 0.14 975,000 400,000 Providence Gold Mines Inc. Options Davis, Scott 5 2020-01-09 00 Providence Gold Mines Inc. Options Davis, Scott 5 2020-07-13 50 0.12 300,000 300,000 Providence Gold Mines Inc. Options Kennedy, Thomas John 4 2020-07-13 50 225,000 25,000 Providence Gold Mines Inc. Options Kennedy, Thomas John 4 2020-07-31 50 75,000 Providence Gold Mines Inc. Options Kennedy, Thomas John 4 2020-08-06 50 300,000 75,000 Pulse Seismic Inc. Common Shares Robotti, Robert Edward 4 2020-08-10 97 8,000 -61,000 Puma Exploration Inc. Options Brisson G., Ginette 5 2020-08-04 50 0.15 110,000 Puma Exploration Inc. Options Brisson G., Ginette 5 2020-08-04 50 0.15 157,500 110,000 Puma Exploration Inc. Warrants Brisson G., Ginette 5 2020-08-04 16 0.15 50,000 Puma Exploration Inc. Warrants Brisson G., Ginette 5 2020-08-04 16 0.15 116,667 50,000 Puma Exploration Inc. Common Shares Fournier, Raphael 4 2020-08-13 90 0.13 0 -200,000 Puma Exploration Inc. Common Shares Fournier, Raphael 4 2020-08-13 90 0.13 343,300 200,000 Puma Exploration Inc. Options Fournier, Raphael 4 2020-08-04 50 0.15 180,000 Puma Exploration Inc. Options Fournier, Raphael 4 2020-08-04 50 0.15 185,000 180,000 Puma Exploration Inc. Options Gosselin, Réjean 4 2020-08-12 00 Puma Exploration Inc. Options Gosselin, Réjean 4 2020-08-12 50 0.15 100,000 100,000 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2020-08-10 10 0.15 6,061,465 4,000 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2020-08-11 10 0.14 6,065,465 4,000 Puma Exploration Inc. Common Shares Robillard, Marcel 4, 5 2020-08-12 10 0.135 6,068,465 3,000 Real Matters Inc. Common Shares Cooke, Loren 7 2020-08-10 51 1.84 31,329 31,215 Real Matters Inc. Common Shares Cooke, Loren 7 2020-08-10 10 32.026 114 -31,215 Real Matters Inc. Common Shares Cooke, Loren 7 2020-08-11 51 1.84 30,054 29,940 Real Matters Inc. Common Shares Cooke, Loren 7 2020-08-11 10 31.574 114 -29,940 Real Matters Inc. Common Shares Cooke, Loren 7 2020-08-13 51 1.84 22,775 22,661 Real Matters Inc. Common Shares Cooke, Loren 7 2020-08-13 10 30.693 114 -22,661

August 20, 2020 (2020), 43 OSCB 6658

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Real Matters Inc. Options Cooke, Loren 7 2020-08-10 51 1.84 545,973 -31,215 Real Matters Inc. Options Cooke, Loren 7 2020-08-11 51 1.84 516,033 -29,940 Real Matters Inc. Options Cooke, Loren 7 2020-08-13 51 1.84 493,372 -22,661 Real Matters Inc. Common Shares Herman, William Peter 5 2020-08-10 10 32.026 9,445 -9,755 Melvin Real Matters Inc. Common Shares Herman, William Peter 5 2020-08-10 51 8 19,200 9,755 Melvin Real Matters Inc. Common Shares Herman, William Peter 5 2020-08-11 10 31.574 9,843 -9,357 Melvin Real Matters Inc. Common Shares Herman, William Peter 5 2020-08-11 51 8 19,200 9,357 Melvin Real Matters Inc. Common Shares Herman, William Peter 5 2020-08-13 51 8 26,281 7,081 Melvin Real Matters Inc. Common Shares Herman, William Peter 5 2020-08-13 10 8 -7,081 Melvin Real Matters Inc. Common Shares Herman, William Peter 5 2020-08-13 10 30.693 19,200 -7,081 Melvin Real Matters Inc. Common Shares Herman, William Peter 5 2020-08-14 51 8 19,300 100 Melvin Real Matters Inc. Common Shares Herman, William Peter 5 2020-08-14 10 30.01 19,200 -100 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-10 51 8 397,233 -9,755 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-10 51 8 9,755 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-10 51 8 9,755 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-11 51 8 387,876 -9,357 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-11 51 8 9,357 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-11 51 8 9,357 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-11 51 8 7,081 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-13 51 8 380,795 -7,081 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-13 51 8 7,081 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-13 51 8 7,081 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-14 51 8 380,695 -100 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-14 51 8 100 Melvin Real Matters Inc. Options Herman, William Peter 5 2020-08-14 51 8 100 Melvin Real Matters Inc. Common Shares Montgomery, Kimberly Sue 7 2020-08-10 51 6.11 33,338 6,800 Real Matters Inc. Common Shares Montgomery, Kimberly Sue 7 2020-08-10 10 32.026 26,538 -6,800 Real Matters Inc. Common Shares Montgomery, Kimberly Sue 7 2020-08-11 51 6.11 33,060 6,522 Real Matters Inc. Common Shares Montgomery, Kimberly Sue 7 2020-08-11 10 31.574 26,538 -6,522 Real Matters Inc. Common Shares Montgomery, Kimberly Sue 7 2020-08-13 51 6.11 31,474 4,936 Real Matters Inc. Common Shares Montgomery, Kimberly Sue 7 2020-08-13 51 30.693 26,538 -4,936 Real Matters Inc. Options Montgomery, Kimberly Sue 7 2020-08-10 51 6.11 212,751 -6,800 Real Matters Inc. Options Montgomery, Kimberly Sue 7 2020-08-11 51 6.11 206,229 -6,522 Real Matters Inc. Options Montgomery, Kimberly Sue 7 2020-08-13 51 6.11 201,293 -4,936 Real Matters Inc. Common Shares Smith, Jason 4, 5 2020-08-06 10 32.81 -82,000 Real Matters Inc. Common Shares Smith, Jason 4, 5 2020-08-06 47 32.81 3,978,384 -82,000 Real Matters Inc. Common Shares Smith, Jason 4, 5 2020-08-07 10 32.72 -8,000 Real Matters Inc. Common Shares Smith, Jason 4, 5 2020-08-07 47 32.72 3,967,384 -8,000 Real Matters Inc. Common Shares Smith, Jason 4, 5 2020-08-10 10 31.839 3,964,384 -3,000 Real Matters Inc. Common Shares Smith, Jason 4, 5 2020-08-11 10 31.455 3,961,384 -3,000 Real Matters Inc. Common Shares Smith, Jason 4, 5 2020-08-12 10 31.185 3,958,384 -3,000 Real Matters Inc. Common Shares Smith, Jason 4, 5 2020-08-13 10 30.541 3,955,384 -3,000

August 20, 2020 (2020), 43 OSCB 6659

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Real Matters Inc. Common Shares Smith, Jason 4, 5 2020-08-14 10 29.382 3,952,384 -3,000 Real Matters Inc. Common Shares Smith, Ryan Jacob 5 2020-08-10 51 1.84 31,215 31,215 Real Matters Inc. Common Shares Smith, Ryan Jacob 5 2020-08-10 10 32.026 0 -31,215 Real Matters Inc. Common Shares Smith, Ryan Jacob 5 2020-08-10 51 1.84 22,661 Real Matters Inc. Common Shares Smith, Ryan Jacob 5 2020-08-11 51 1.84 29,940 29,940 Real Matters Inc. Common Shares Smith, Ryan Jacob 5 2020-08-11 10 31.574 0 -29,940 Real Matters Inc. Common Shares Smith, Ryan Jacob 5 2020-08-13 51 1.84 22,661 22,661 Real Matters Inc. Common Shares Smith, Ryan Jacob 5 2020-08-13 10 30.693 0 -22,661 Real Matters Inc. Options Smith, Ryan Jacob 5 2020-08-10 51 1.84 625,773 -31,215 Real Matters Inc. Options Smith, Ryan Jacob 5 2020-08-11 51 1.84 595,833 -29,940 Real Matters Inc. Options Smith, Ryan Jacob 5 2020-08-13 51 1.84 573,172 -22,661 Real Matters Inc. Common Shares Walton, Kevin Alan 5 2020-08-10 51 2.4 19,509 19,509 Real Matters Inc. Common Shares Walton, Kevin Alan 5 2020-08-10 51 1.84 31,215 11,706 Real Matters Inc. Common Shares Walton, Kevin Alan 5 2020-08-10 10 32.026 0 -31,215 Real Matters Inc. Common Shares Walton, Kevin Alan 5 2020-08-11 51 2.4 18,713 18,713 Real Matters Inc. Common Shares Walton, Kevin Alan 5 2020-08-11 51 1.84 29,941 11,228 Real Matters Inc. Common Shares Walton, Kevin Alan 5 2020-08-11 10 31.574 0 -29,941 Real Matters Inc. Common Shares Walton, Kevin Alan 5 2020-08-13 51 2.4 14,163 14,163 Real Matters Inc. Common Shares Walton, Kevin Alan 5 2020-08-13 51 1.84 22,661 8,498 Real Matters Inc. Common Shares Walton, Kevin Alan 5 2020-08-13 10 30.693 0 -22,661 Real Matters Inc. Options Walton, Kevin Alan 5 2020-08-10 51 2.4 462,479 -19,509 Real Matters Inc. Options Walton, Kevin Alan 5 2020-08-10 51 1.84 450,773 -11,706 Real Matters Inc. Options Walton, Kevin Alan 5 2020-08-11 51 2.4 432,060 -18,713 Real Matters Inc. Options Walton, Kevin Alan 5 2020-08-11 51 1.84 420,832 -11,228 Real Matters Inc. Options Walton, Kevin Alan 5 2020-08-13 51 2.4 406,669 -14,163 Real Matters Inc. Options Walton, Kevin Alan 5 2020-08-13 51 1.84 398,171 -8,498 Recipe Unlimited Deferred Share Units Clark, Christy 4 2020-08-07 30 7,222 -445 Corporation (formerly Cara Operations Limited) Recipe Unlimited Deferred Share Units Gunn, Stephen 4 2020-08-07 30 3,881 -315 Corporation (formerly Cara Operations Limited) Recipe Unlimited Deferred Share Units Hodgson, Christopher 4 2020-08-07 30 16,326 -815 Corporation (formerly Cara Douglas Operations Limited) Recipe Unlimited Deferred Share Units Norris, Michael John 4 2020-08-07 30 10,995 -890 Corporation (formerly Cara Operations Limited) Recipe Unlimited Deferred Share Units Regan, Sean Paul 4 2020-08-07 30 16,326 -815 Corporation (formerly Cara Operations Limited) Recipe Unlimited Deferred Share Units Rivett, Paul 4 2020-08-07 30 3,386 -1,045 Corporation (formerly Cara Operations Limited) Recipe Unlimited Deferred Share Units Rothschild, John 4 2020-08-07 30 10,995 -890 Corporation (formerly Cara Operations Limited) Red Lake Gold Inc. Common Shares Kalt, Ryan 3, 4, 5 2020-08-11 10 0.302 5,587,000 5,000 Reko International Group Common Shares Reko International Group 1 2020-08-04 38 2.87 2,100 Inc. Inc. Reko International Group Common Shares Reko International Group 1 2020-08-04 38 2.87 2,100 Inc. Inc. Reko International Group Common Shares Reko International Group 1 2020-08-04 38 2.87 -2,100 Inc. Inc. Reko International Group Common Shares Reko International Group 1 2020-08-04 38 2.87 -2,100 Inc. Inc. Reko International Group Common Shares Reko International Group 1 2020-08-04 38 2.87 2,100 Inc. Inc. Reko International Group Common Shares Reko International Group 1 2020-08-04 38 2.87 2,100 Inc. Inc. Reko International Group Common Shares Reko International Group 1 2020-08-04 38 2.87 2,100 Inc. Inc. Reko International Group Common Shares Reko International Group 1 2020-08-04 38 2.87 0 -2,100 Inc. Inc.

August 20, 2020 (2020), 43 OSCB 6660

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Reko International Group Common Shares Reko International Group 1 2020-08-10 38 2.89 5,000 5,000 Inc. Inc. Reko International Group Common Shares Reko International Group 1 2020-08-10 38 2.89 0 -5,000 Inc. Inc. Reko International Group Common Shares Reko International Group 1 2020-08-11 38 2.9 1,900 1,900 Inc. Inc. Reko International Group Common Shares Reko International Group 1 2020-08-11 38 2.9 0 -1,900 Inc. Inc. Relay Medical Corp. Common Shares Invidx Corp 3 2020-08-12 10 14,242,052 -78,500 (formerly, ChroMedX Corp). Resverlogix Corp. Options Cann, Aaron Bradley 5 2020-05-21 52 38,300 -12,200 Resverlogix Corp. Options Kulikowski, Ewelina 5 2020-05-21 52 106,600 -3,200 Resverlogix Corp. Options Lebioda, Kenneth Eugene 5 2020-05-21 52 35,700 -11,300 Resverlogix Corp. Options MCCAFFREY, DONALD J. 4, 5 2020-05-21 52 128,700 -38,800 Resverlogix Corp. Options Sweeney, Michael 5 2020-05-21 52 63,700 -10,500 Revive Therapeutics Ltd. Options Frank, Michael 4, 5 2020-08-05 50 0.33 10,850,000 6,000,000 Richelieu Hardware Ltd. Unités d'actions différées Chabot, Lucie 4 2020-08-07 35 33.41 506 1 Richelieu Hardware Ltd. Unités d'actions différées Courteau, Robert 4, 5 2020-08-07 35 33.41 66,647 133 Richelieu Hardware Ltd. Unités d'actions différées Gauvin, Mathieu 4 2020-08-07 35 33.41 73,951 147 Richelieu Hardware Ltd. Unités d'actions différées Pomerleau, Pierre 4 2020-08-07 35 33.41 10,711 21 Richelieu Hardware Ltd. Unités d'actions différées Poulin, Marc 4 2020-08-07 35 33.41 20,904 42 Richelieu Hardware Ltd. Unités d'actions différées Vachon, Sylvie 4 2020-08-07 35 33.41 11,370 23 Ridgeline Minerals Corp. Common Shares Blady, Michael Adam 4 2020-07-31 00 406,000 Ridgeline Minerals Corp. Options Blady, Michael Adam 4 2020-07-31 00 150,000 Ridgeline Minerals Corp. Warrants Blady, Michael Adam 4 2020-07-31 00 30,000 Ridgeline Minerals Corp. Options Gieselman, Terese 5 2020-07-31 00 100,000 Ridgeline Minerals Corp. Common Shares Teal, Lewis 4 2020-07-31 00 146,704 Ridgeline Minerals Corp. Options Teal, Lewis 4 2020-07-31 00 150,000 Ridgeline Minerals Corp. Warrants Teal, Lewis 4 2020-07-31 00 5,352 Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-07 10 16.5 10,446,395 2,637 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-07 10 16.5 10,446,286 -109 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-10 10 16.5 10,446,558 272 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-10 10 16.5 10,446,479 -79 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-11 10 16.5 10,452,666 6,187 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-11 10 16.5 10,452,630 -36 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-12 10 16.62 442 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-12 10 16.52 10,453,072 442 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-12 10 16.52 10,452,617 -455 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-13 10 16.63 10,453,237 620 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-13 10 16.63 10,452,600 -637 Investment Grade Bond Management Fund Ridgewood Canadian Units Ridgewood Capital Asset 3 2020-08-13 11 16 10,649,475 196,875 Investment Grade Bond Management Fund

August 20, 2020 (2020), 43 OSCB 6661

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Ritchie Bros. Auctioneers Options Ackley, Matthew Farrell 5 2020-08-11 59 17.76 109,595 -2,000 Incorporated Ritchie Bros. Auctioneers Common Shares Driscoll, Sharon 5 2020-08-12 59 61.95 9,653 -15,000 Incorporated Ritchie Bros. Auctioneers Options Holm, Kieran 5 2020-08-11 59 22.46 90,559 -5,172 Incorporated Ritchie Bros. Auctioneers Options Holm, Kieran 5 2020-08-11 59 24.84 80,510 -10,049 Incorporated Ritchie Bros. Auctioneers Options Holm, Kieran 5 2020-08-12 59 24.07 66,285 -14,225 Incorporated Ritchie Bros. Auctioneers Options Jeter, James Jeffrey 5 2020-08-11 59 27.1 68,211 -15,000 Incorporated Ritchie Bros. Auctioneers Options Jeter, James Jeffrey 5 2020-08-12 59 14.04 66,697 -1,514 Incorporated Ritchie Bros. Auctioneers Options Jeter, James Jeffrey 5 2020-08-12 59 27.1 63,977 -2,720 Incorporated Ritchie Bros. Auctioneers Options Taylor, Kari R 5 2020-08-11 50 57.47 78,482 8,635 Incorporated Ritchie Bros. Auctioneers Rights Performance Taylor, Kari R 5 2020-08-11 56 47.77 11,939 2,303 Incorporated Share Units Ritchie Bros. Auctioneers Options Watt, Darren 5 2020-08-11 59 23.44 89,966 -3,600 Incorporated Ritchie Bros. Auctioneers Options Watt, Darren 5 2020-08-12 59 21.34 86,466 -3,500 Incorporated Riverside Resources Inc. Options Clare, James 4 2016-09-08 52 180,000 -100,000 Riverside Resources Inc. Options Clare, James 4 2017-12-14 52 180,000 -50,000 Riverside Resources Inc. Options Clare, James 4 2019-11-14 52 175,000 -55,000 RIWI Corp. Common Shares Meerkamper, Eric Heinz 5 2020-08-10 10 3.4 509,420 -7,700 RIWI Corp. Common Shares Meerkamper, Eric Heinz 5 2020-08-11 10 3.28 499,420 -10,000 Rogers Sugar Inc. Common Shares Wilkes, Stephanie Ruth 4 2020-08-11 10 4.8388 9,005 2,775 Roots Corporation Deferred Share Units Curran, Mary Ann 4 2020-07-15 56 20,842 5,609 Roots Corporation Deferred Share Units David, Gregory 4 2020-07-15 56 80,946 22,222 Roots Corporation Deferred Share Units Mavrinac, Richard P. 4 2020-07-15 56 94,459 24,573 Roots Corporation Deferred Share Units Teitelbaum, Joel 4 2020-07-15 56 86,246 22,436 Royal Road Minerals Limited Ordinary Shares HILL, JONATHAN VICTOR 4 2020-08-04 10 0.37 131,527 27,027 Rusoro Mining Ltd. Common Shares Agapov, Andre Vladimir 3, 4, 5 2020-08-14 10 0.035 88,285,167 1,000,000 Rusoro Mining Ltd. Common Shares Keep, Gordon 4 2020-08-14 10 0.035 3,683,000 452,000 Sanatana Resources Inc. Common Shares Anderson, Simon 5 2020-05-08 37 17,500 -157,500 Sanatana Resources Inc. Common Shares Anderson, Simon 5 2020-08-06 16 0.12 184,167 166,667 Sanatana Resources Inc. Common Shares Anderson, Simon 5 2020-05-08 37 4,000 -36,000 Sanatana Resources Inc. Options Anderson, Simon 5 2020-05-08 37 50,000 -450,000 Sanatana Resources Inc. Warrants Anderson, Simon 5 2020-08-06 16 83,334 83,334 Sanatana Resources Inc. Common Shares Miles, Peter Leighton 3, 4, 5 2020-08-07 16 0.12 968,121 300,000 Sanatana Resources Inc. Common Shares Miles, Peter Leighton 3, 4, 5 2020-05-06 37 1,579,888 -13,161,403 Sanatana Resources Inc. Warrants Miles, Peter Leighton 3, 4, 5 2020-08-07 16 0.2 1,150,000 150,000 Sarama Resources Ltd. Common Shares Dinning, Andrew Robert 4 2020-08-13 46 0.1342 12,450,827 54,275 Mune Sarama Resources Ltd. Common Shares Evangelista, Luigi 5 2020-08-13 46 0.1342 288,945 39,473 Sarama Resources Ltd. Common Shares Hamilton, Jack 5 2020-08-13 46 0.1342 5,796,527 41,915 Sarama Resources Ltd. Common Shares Schmiede, Paul Raymond 5 2020-08-13 46 0.1342 1,594,710 44,407 Paul Savaria Corporation Common Shares Dumoulin, Sylvain 4 2020-08-14 10 15.5 85,000 -5,000 Savaria Corporation Common Shares Ferrara, Mauro 5 2020-08-14 51 13.53 25,500 25,000 Savaria Corporation Common Shares Ferrara, Mauro 5 2020-08-14 51 13.27 50,500 25,000 Savaria Corporation Common Shares Ferrara, Mauro 5 2020-08-14 10 16.16 500 -50,000 Savaria Corporation Options Ferrara, Mauro 5 2020-08-14 51 13.53 25,000 -25,000 Savaria Corporation Options Ferrara, Mauro 5 2020-08-14 51 13.27 0 -25,000 Seabridge Gold Inc. Common Shares FCMI Parent Co. 3 2020-08-11 11 18.79 3,455,083 -266,099 Seahawk Ventures Inc. Options Ekholm, Ian Jack 3 2020-07-30 52 0 -500,000 Seven Aces Limited Common Shares Sekhri, Manu 4, 5 2013-11-21 00 Seven Aces Limited Common Shares Sekhri, Manu 4, 5 2020-08-04 90 14,213,572 14,213,572 Seven Aces Limited Common Shares Sekhri, Manu 4, 5 2020-08-10 51 1.05 17,750,094 3,536,522

August 20, 2020 (2020), 43 OSCB 6662

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Seven Aces Limited Common Shares Sekhri, Manu 4, 5 2020-08-12 36 19,237,097 1,487,003 Seven Aces Limited Common Shares Sekhri, Manu 4, 5 2020-08-04 90 0 -14,213,572 Seven Aces Limited Options Sekhri, Manu 4, 5 2013-11-21 00 Seven Aces Limited Options Sekhri, Manu 4, 5 2020-08-04 90 3,536,522 3,536,522 Seven Aces Limited Options Sekhri, Manu 4, 5 2020-08-10 51 0.5025 -3,536,522 Seven Aces Limited Options Sekhri, Manu 4, 5 2020-08-10 51 0.5025 -3,536,522 Seven Aces Limited Options Sekhri, Manu 4, 5 2020-08-10 51 1.05 0 -3,536,522 Seven Aces Limited Options Sekhri, Manu 4, 5 2020-08-04 90 0 -3,536,522 Seven Aces Limited Subscription Rights Sekhri, Manu 4, 5 2013-11-21 00 Subscription Receipts Seven Aces Limited Subscription Rights Sekhri, Manu 4, 5 2020-08-04 90 1,487,003 1,487,003 Subscription Receipts Seven Aces Limited Subscription Rights Sekhri, Manu 4, 5 2020-08-12 36 0 -1,487,003 Subscription Receipts Seven Aces Limited Subscription Rights Sekhri, Manu 4, 5 2020-08-04 90 0 -1,487,003 Subscription Receipts Shawcor Ltd. Options Tausch, Henricus Adrianus 5 2020-08-07 50 217,569 50,000 Antonius Maria Shopify Inc. Options Finkelstein, Harley Michael 5 2020-08-13 51 22.44 123,915 -790 Shopify Inc. Subordinate Voting Finkelstein, Harley Michael 5 2020-08-13 51 22.44 838 790 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Finkelstein, Harley Michael 5 2020-08-13 30 1005 48 -790 Shares Class A Subordinate Voting Shares Shopify Inc. Multiple Voting Shares Lemieux, Jean-Michel 5 2020-08-10 51 5.17 1,000 1,000 Class B Multiple Voting Shares Shopify Inc. Multiple Voting Shares Lemieux, Jean-Michel 5 2020-08-10 30 0 -1,000 Class B Multiple Voting Shares Shopify Inc. Options Lemieux, Jean-Michel 5 2020-08-10 51 5.17 34,574 -1,000 Shopify Inc. Subordinate Voting Lemieux, Jean-Michel 5 2020-08-10 36 13,751 1,000 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Lemieux, Jean-Michel 5 2020-08-10 30 1055 12,751 -1,000 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Lutke, Tobias Albin 4, 5 2020-08-10 30 1024.5 95,000 -5,000 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Phillips, John 4 2020-08-11 30 989.65 39,000 -6,000 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Phillips, John 4 2020-08-11 90 36,000 -3,000 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Phillips, John 4 2020-08-11 90 3,000 3,000 Shares Class A Subordinate Voting Shares Shopify Inc. Subordinate Voting Phillips, John 4 2020-08-11 30 1312.3 0 -3,000 Shares Class A Subordinate Voting Shares Shopify Inc. RSU Shapero, Amy Elizabeth 5 2020-08-10 57 26,890 -4,659 Shopify Inc. Subordinate Voting Shapero, Amy Elizabeth 5 2020-08-10 57 17,326 4,659 Shares Class A Subordinate Voting Shares

August 20, 2020 (2020), 43 OSCB 6663

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Shopify Inc. Subordinate Voting Shapero, Amy Elizabeth 5 2020-08-10 10 1009.9 14,683 -2,643 Shares Class A Subordinate Voting Shares Sienna Senior Living Inc. Restricted Share Units Lugowski, Mark 5 2020-04-13 00 (formerly Leisureworld Senior Care Corporation) Sienna Senior Living Inc. Restricted Share Units Lugowski, Mark 5 2020-08-12 56 3,885 3,885 (formerly Leisureworld Senior Care Corporation) Sienna Senior Living Inc. Restricted Share Units Lugowski, Mark 5 2020-08-12 56 9,712 5,827 (formerly Leisureworld Senior Care Corporation) Sierra Wireless, Inc. Restricted Share Units Aasen, Gregory D. 4 2020-08-11 56 17.14 25,745 14,184 Sierra Wireless, Inc. Restricted Share Units Abrams, Robin Ann 4 2020-08-11 56 12.92 14,184 14,184 Sierra Wireless, Inc. Restricted Share Units Anderson, James Robert 4 2020-08-11 56 12.92 14,184 14,184 Sierra Wireless, Inc. Restricted Share Units Bawa, Karima 4 2020-08-11 56 17.14 14,184 14,184 Sierra Wireless, Inc. Restricted Share Units Cochrane, Samuel Colin 5 2020-08-11 56 17.14 202,177 202,177 Sierra Wireless, Inc. Restricted Share Units Guillemette, Philippe 5 2020-08-11 56 17.14 107,465 35,460 Frederic Joel Rene Sierra Wireless, Inc. Restricted Share Units Harmon, Stephen Gregory 5 2020-08-11 56 12.92 94,560 94,560 Sierra Wireless, Inc. Restricted Share Units Jones, Russell Norman 4 2020-08-11 56 17.14 27,744 14,184 Sierra Wireless, Inc. Restricted Share Units Krause, Jason Lawrence 5 2020-08-11 56 17.14 187,428 59,100 Sierra Wireless, Inc. Restricted Share Units Link, Rene Fernando 5 2020-08-11 56 12.92 96,918 35,460 Sierra Wireless, Inc. Restricted Share Units Linton, Thomas Kenneth 4 2020-08-11 56 12.92 14,184 14,184 Sierra Wireless, Inc. Restricted Share Units Mc Court, Martin Desmond 4 2020-08-11 56 12.92 14,184 14,184 Sierra Wireless, Inc. Restricted Share Units O'Neill, Lori 4 2020-08-11 56 17.14 24,473 14,184 Sierra Wireless, Inc. Restricted Share Units Overton, Marc Anthony 5 2020-08-11 56 12.92 94,927 35,460 John McHardy Sierra Wireless, Inc. Restricted Share Units Ryan, James Patrick 5 2020-08-11 56 12.92 116,206 29,550 Sierra Wireless, Inc. Restricted Share Units Sieber, Thomas 4 2020-08-11 56 12.92 14,184 14,184 Sierra Wireless, Inc. Restricted Share Units Thexton, Kent Paul 4, 5 2020-08-11 56 17.14 571,451 307,328 Sierra Wireless, Inc. Restricted Share Units Twaalfhoven, Mark 4 2020-08-11 56 12.92 14,184 14,184 Cornelis Joseph Sierra Wireless, Inc. Restricted Share Units Waters, Gregory Lester 4 2020-08-11 56 12.92 14,184 14,184 Silver Bear Resources Plc Ordinary Shares Westdal, Christopher 4 2020-08-06 10 0.21 907,544 -110,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-13 10 0.64 1,210,500 14,500 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-13 10 0.65 1,216,000 5,500 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-14 10 0.66 1,251,000 35,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-14 10 0.65 1,303,000 52,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-14 10 0.7 1,323,000 20,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-22 10 0.664 1,353,000 30,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-22 10 0.63 1,358,000 5,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-22 10 0.64 1,363,000 5,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-22 10 0.65 1,378,000 15,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-08-13 10 1.45 1,428,000 50,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-08-13 10 1.5 1,438,000 10,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-06-30 10 0.65 50,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-06-30 10 0.67 15,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-02 10 0.7 15,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-13 10 0.64 14,500 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-13 10 0.65 5,500 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-14 10 0.66 35,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-14 10 0.66 35,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-14 10 0.65 52,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-14 10 0.65 52,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-14 10 0.7 20,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-14 10 0.7 20,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-22 10 0.664 30,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-22 10 0.63 5,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-22 10 0.64 5,000

August 20, 2020 (2020), 43 OSCB 6664

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-22 10 0.65 15,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-08-13 10 1.45 50,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-08-13 10 1.5 10,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-06-30 10 0.65 1,166,000 50,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-06-30 10 0.67 1,181,000 15,000 Silver Dollar Resources Inc. Common Shares Naughty, Blair Lawrence 3 2020-07-02 10 0.7 1,196,000 15,000 Silver Elephant Mining Corp. Common Shares without Hall, Greg 4 2020-08-12 10 0.49 213,092 -25,000 par value Silver Elephant Mining Corp. Common Shares without Hall, Greg 4 2020-08-12 10 0.485 208,092 -5,000 par value Silver Elephant Mining Corp. Common Shares without Hall, Greg 4 2020-08-12 10 0.48 203,092 -5,000 par value Silver Elephant Mining Corp. Common Shares without Hall, Greg 4 2020-08-12 10 0.465 176,592 -26,500 par value Silver Elephant Mining Corp. Common Shares without Hall, Greg 4 2020-08-12 10 0.46 148,092 -28,500 par value Silver Elephant Mining Corp. Common Shares without IGATA, MASATERU 4 2020-08-13 54 0.26 814,928 400,000 par value Silver Elephant Mining Corp. Warrants IGATA, MASATERU 4 2020-08-13 54 37,669 -400,000 Silver Viper Minerals Corp. Common Shares Cope, Gary Gordon 4 2020-08-10 10 0.61 3,817,500 10,000 SILVERCORP METALS Common Shares without Katusa, Marina 4 2020-08-10 51 232,500 215,000 INC. par value SILVERCORP METALS Common Shares without Katusa, Marina 4 2020-08-10 10 10 52,500 -180,000 INC. par value SILVERCORP METALS Options Katusa, Marina 4 2020-08-10 51 3.36 168,000 -90,000 INC. SILVERCORP METALS Options Katusa, Marina 4 2020-08-10 51 3.23 118,000 -50,000 INC. SILVERCORP METALS Options Katusa, Marina 4 2020-08-10 51 3.4 80,500 -37,500 INC. SILVERCORP METALS Options Katusa, Marina 4 2020-08-10 51 2.6 43,000 -37,500 INC. SILVERCORP METALS Common Shares without Liu, Yikang 4 2020-08-10 10 10.9 80,000 -7,500 INC. par value SILVERCORP METALS Common Shares without Simpson, Stephen Paul 4 2020-08-10 10 11.173 854,484 -15,000 INC. par value SITKA GOLD CORP. Common Shares Coe, Corwin 4, 5 2020-08-14 10 0.245 1,722,000 2,000 SITKA GOLD CORP. Common Shares Coe, Corwin 4, 5 2020-08-14 10 0.247 1,724,500 2,500 SKRR Exploration Inc. Common Shares Dahl, Sherman 4, 5 2020-08-07 10 0.31 1,126,489 5,000 SKRR Exploration Inc. Common Shares Dahl, Sherman 4, 5 2020-08-07 10 0.315 1,131,489 5,000 SKRR Exploration Inc. Common Shares Dahl, Sherman 4, 5 2020-08-07 10 0.34 1,146,045 14,556 SKRR Exploration Inc. Common Shares Dahl, Sherman 4, 5 2020-08-07 10 0.331 1,155,045 9,000 Sky Gold Corp. Options St-Amour, JC 4 2020-08-07 00 250,000 Sky Gold Corp. Options St-Amour, JC 4 2020-08-09 00 Sky Gold Corp. Options St-Amour, JC 4 2020-08-09 00 Slam Exploration Ltd. Common Shares beukman, eugene 4, 5 2020-08-11 16 0.06 416,667 416,667 Slam Exploration Ltd. Options beukman, eugene 4, 5 2020-08-11 51 150,000 Slam Exploration Ltd. Options beukman, eugene 4, 5 2020-08-11 50 590,000 150,000 Slam Exploration Ltd. Warrants beukman, eugene 4, 5 2013-07-24 00 Slam Exploration Ltd. Warrants beukman, eugene 4, 5 2020-08-11 16 208,334 208,334 Slam Exploration Ltd. Common Shares Taylor, Michael R. 4, 5 2020-08-11 16 0.06 3,587,633 700,000 Slam Exploration Ltd. Options Taylor, Michael R. 4, 5 2020-08-11 50 470,000 150,000 Slam Exploration Ltd. Warrants Taylor, Michael R. 4, 5 2020-08-11 16 1,350,000 350,000 Slam Exploration Ltd. Common Shares van der Linde, Theo 4 2017-11-07 00 Slam Exploration Ltd. Common Shares van der Linde, Theo 4 2020-08-11 16 0.06 416,667 416,667 Slam Exploration Ltd. Options van der Linde, Theo 4 2020-08-11 50 350,000 150,000 Slam Exploration Ltd. Warrants van der Linde, Theo 4 2017-11-07 00 Slam Exploration Ltd. Warrants van der Linde, Theo 4 2020-08-11 16 208,334 208,334 Slam Exploration Ltd. Options Yates, Edward Montagu 4 2020-08-11 50 470,000 150,000 SmartCentres Real Estate Class C Series 4 LP3 Goldhar, Mitchell 3 2020-08-11 11 21.6 565,782 -3,334 Investment Trust (formerly, Units Smart Real Estate Investment Trust)

August 20, 2020 (2020), 43 OSCB 6665

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed SmartCentres Real Estate Limited Partnership Units Goldhar, Mitchell 3 2020-08-11 11 20.44 3,523 3,523 Investment Trust (formerly, Class B Series 4 LP3 Smart Real Estate Units Investment Trust) SmartCentres Real Estate Limited Partnership Units Goldhar, Mitchell 3 2020-08-11 90 20.44 0 -3,523 Investment Trust (formerly, Class B Series 4 LP3 Smart Real Estate Units Investment Trust) SmartCentres Real Estate Limited Partnership Units Goldhar, Mitchell 3 2020-08-11 90 20.44 705,420 3,523 Investment Trust (formerly, Class B Series 4 LP3 Smart Real Estate Units Investment Trust) SmartCentres Real Estate Special Voting Units Goldhar, Mitchell 3 2020-08-11 11 10,439 3,523 Investment Trust (formerly, Smart Real Estate Investment Trust) SmartCentres Real Estate Special Voting Units Goldhar, Mitchell 3 2020-08-11 90 6,916 -3,523 Investment Trust (formerly, Smart Real Estate Investment Trust) SmartCentres Real Estate Special Voting Units Goldhar, Mitchell 3 2020-08-11 90 7,938,541 3,523 Investment Trust (formerly, Smart Real Estate Investment Trust) SNC-Lavalin Group Inc. Equity Swap-Long Groupe SNC-Lavalin inc. 1 2020-08-08 70 0 -1 Position 18,322 Com Shares/Exp: Aug 8, 2020 SNC-Lavalin Group Inc. Equity Swap-Long Groupe SNC-Lavalin inc. 1 2020-08-08 70 0 -1 Position 18,322 Com Shares/Exp: Aug 8, 2020 SOL Global Investments Deferred Share Units Acosta, Arena Johanna 4 2020-05-20 00 Corp. (formerly Scythian Biosciences Corp.) SOL Global Investments Deferred Share Units Acosta, Arena Johanna 4 2020-08-07 56 25,000 25,000 Corp. (formerly Scythian Biosciences Corp.) SOL Global Investments Deferred Share Units Centner, Olivier Marc 4 2020-08-01 00 Corp. (formerly Scythian Biosciences Corp.) SOL Global Investments Deferred Share Units Centner, Olivier Marc 4 2020-08-07 56 25,000 25,000 Corp. (formerly Scythian Biosciences Corp.) Sonoro Metals Corp. Common Shares Dhaumya, Salil 5 2019-12-09 00 Sonoro Metals Corp. Common Shares Dhaumya, Salil 5 2020-08-12 16 0.22 72,727 72,727 Sonoro Metals Corp. Warrants Dhaumya, Salil 5 2019-12-09 00 Sonoro Metals Corp. Warrants Dhaumya, Salil 5 2020-08-12 16 36,363 36,363 Sonoro Metals Corp. Warrants Dhaumya, Salil 5 2020-08-12 16 72,727 36,364 Sonoro Metals Corp. Common Shares Herdrick, Melvin Allen 5 2020-08-12 16 0.22 984,507 100,000 Sonoro Metals Corp. Warrants Herdrick, Melvin Allen 5 2020-08-12 16 250,000 100,000 Sonoro Metals Corp. Common Shares MacLeod, Kenneth 4, 5 2020-08-12 16 0.22 5,230,887 263,636 Sonoro Metals Corp. Warrants MacLeod, Kenneth 4, 5 2020-08-12 16 263,636 263,636 Sonoro Metals Corp. Common Shares Taylor, James Gordon 4 2020-08-12 16 0.22 1,607,000 307,000 Sonoro Metals Corp. Warrants Taylor, James Gordon 4 2019-06-27 00 Sonoro Metals Corp. Warrants Taylor, James Gordon 4 2020-08-12 16 307,000 307,000 Spanish Mountain Gold Ltd. Common Shares 2176423 Ontario Ltd. 3 2020-08-06 16 0.42 48,571,427 11,904,761 Spanish Mountain Gold Ltd. Warrants 2176423 Ontario Ltd. 3 2020-08-06 16 0.6 48,571,427 11,904,761 Spanish Mountain Gold Ltd. Common Shares Sprott, Eric S. 3 2020-08-06 16 0.42 48,571,427 11,904,761 Spanish Mountain Gold Ltd. Warrants Sprott, Eric S. 3 2020-08-06 16 0.6 48,571,427 11,904,761 Spectral Medical Inc. Common Shares Guadagni, Gualtiero Piero 5 2020-06-18 15 0.6 130,650 16,700 Guido Maria Spectral Medical Inc. Warrants Guadagni, Gualtiero Piero 5 2013-05-01 00 Guido Maria Spectral Medical Inc. Warrants Guadagni, Gualtiero Piero 5 2020-06-18 15 0.75 8,350 8,350 Guido Maria Sphinx Resources Ltd. Common Shares ryan, jeremie 4, 5 2020-08-11 90 700,000 -512,500 Sphinx Resources Ltd. Common Shares ryan, jeremie 4, 5 2020-08-11 90 1,212,500 512,500 Sphinx Resources Ltd. Options Viens, Pierre-André 4 2020-07-27 00

August 20, 2020 (2020), 43 OSCB 6666

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Sphinx Resources Ltd. Options Viens, Pierre-André 4 2020-08-12 50 0.1 175,000 175,000 SponsorsOne Inc. Common Shares Bartholomew, Gary 4 2020-08-12 10 0.02 5,008,167 5,000,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2020-08-12 11 0.02 7,526,596 4,500,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2013-12-17 00 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2013-12-17 00 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2013-12-17 00 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2015-08-24 10 0.65 -10,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2015-08-24 10 0.65 -10,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2015-09-22 10 0.48 -40,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2015-09-22 10 0.48 -40,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2015-10-08 10 0.48 -30,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2015-10-08 10 0.48 -30,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2015-11-03 11 0.4 -108,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2015-11-03 11 0.4 -108,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2015-12-04 30 0.32 108,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2015-12-04 30 0.32 108,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2016-02-10 30 0.25 -100,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2016-02-10 30 0.25 -100,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2016-07-26 10 0.1 -100,000 SponsorsOne Inc. Common Shares Bartholomew, Myles 3 2016-07-26 10 0.1 -100,000 SponsorsOne Inc. Warrants Bartholomew, Myles 3 2013-12-17 00 SponsorsOne Inc. Warrants Bartholomew, Myles 3 2020-08-12 11 0.1 2,000,000 2,000,000 SponsorsOne Inc. Warrants Vend in Bartholomew, Myles 3 2013-12-17 00 warrants SponsorsOne Inc. Warrants Vend in Bartholomew, Myles 3 2013-12-17 00 warrants SponsorsOne Inc. Warrants Vend in Bartholomew, Myles 3 2015-01-22 54 0.65 -140,000 warrants SponsorsOne Inc. Warrants Vend in Bartholomew, Myles 3 2015-01-22 54 0.65 -140,000 warrants SponsorsOne Inc. Warrants Vend in Bartholomew, Myles 3 2015-01-22 55 -193,333 warrants SponsorsOne Inc. Warrants Vend in Bartholomew, Myles 3 2015-01-22 55 -193,333 warrants SponsorsOne Inc. Common Shares Kokkinis, Sandy 5 2020-08-07 10 0.02 1,000,000 SponsorsOne Inc. Common Shares Kokkinis, Sandy 5 2020-08-07 11 0.02 1,500,000 1,000,000 SponsorsOne Inc. Common Shares Kokkinis, Sandy 5 2020-08-11 11 0.02 2,500,000 1,000,000 SRHI Inc. (formerly Sprott Options Boggio, Lenard 4 2017-02-09 00 Resource Holdings Inc.) SRHI Inc. (formerly Sprott Options Boggio, Lenard 4 2020-08-12 50 0.31 300,000 300,000 Resource Holdings Inc.) SRHI Inc. (formerly Sprott Options Dunne, Joan 4 2017-02-09 00 Resource Holdings Inc.) SRHI Inc. (formerly Sprott Options Dunne, Joan 4 2020-08-12 50 0.31 300,000 300,000 Resource Holdings Inc.) SRHI Inc. (formerly Sprott Options Lyons, Terrence 4 2017-02-09 00 Resource Holdings Inc.) SRHI Inc. (formerly Sprott Options Lyons, Terrence 4 2020-08-12 50 0.31 350,000 350,000 Resource Holdings Inc.) SRHI Inc. (formerly Sprott Options Smith, David 4 2018-05-10 00 Resource Holdings Inc.) SRHI Inc. (formerly Sprott Options Smith, David 4 2020-08-12 50 0.31 300,000 300,000 Resource Holdings Inc.) SRHI Inc. (formerly Sprott Options Staresinic, Michael 5 2017-02-09 00 Resource Holdings Inc.) SRHI Inc. (formerly Sprott Options Staresinic, Michael 5 2020-08-12 50 0.31 850,000 850,000 Resource Holdings Inc.) StageZero Life Sciences Options Glorikian, Harry 4 2020-08-10 50 0.055 2,777,920 500,000 Ltd. StageZero Life Sciences Options Howard-Tripp, James 4, 5 2020-08-07 50 0.055 13,970,000 5,000,000 Ltd. StageZero Life Sciences Options MacRae, Garth A. C. 4 2020-08-07 50 0.055 2,577,920 500,000 Ltd.

August 20, 2020 (2020), 43 OSCB 6667

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed StageZero Life Sciences Options Riggs, Rory 3, 4 2020-08-07 50 0.055 3,771,918 3,500,000 Ltd. StageZero Life Sciences Options Solomon, Carl 5 2020-08-07 50 0.055 175,000 100,000 Ltd. Stantec Inc. Common Shares Alpern, Paul Jeremy David 7, 5 2020-08-10 51 32.9 4,180 4,180 Stantec Inc. Common Shares Alpern, Paul Jeremy David 7, 5 2020-08-10 10 43.861 0 -4,180 Stantec Inc. Common Shares Alpern, Paul Jeremy David 7, 5 2020-08-10 51 32.01 6,826 6,826 Stantec Inc. Common Shares Alpern, Paul Jeremy David 7, 5 2020-08-10 10 43.794 0 -6,826 Stantec Inc. Common Shares Alpern, Paul Jeremy David 7, 5 2020-08-10 51 32.83 7,656 7,656 Stantec Inc. Common Shares Alpern, Paul Jeremy David 7, 5 2020-08-10 10 43.508 0 -7,656 Stantec Inc. Options Alpern, Paul Jeremy David 7, 5 2020-08-10 51 32.9 30,391 -4,180 Stantec Inc. Options Alpern, Paul Jeremy David 7, 5 2020-08-10 51 32.01 23,565 -6,826 Stantec Inc. Options Alpern, Paul Jeremy David 7, 5 2020-08-10 51 32.83 15,909 -7,656 Stantec Inc. Common Shares Castro, Leonardo De 7 2020-08-12 51 32.01 4,863 4,863 Oliveira Stantec Inc. Common Shares Castro, Leonardo De 7 2020-08-12 10 43.903 0 -4,863 Oliveira Stantec Inc. Common Shares Castro, Leonardo De 7 2020-08-12 51 31.75 13,564 13,564 Oliveira Stantec Inc. Common Shares Castro, Leonardo De 7 2020-08-12 10 43.772 0 -13,564 Oliveira Stantec Inc. Common Shares Castro, Leonardo De 7 2020-08-12 51 32.98 7,692 7,692 Oliveira Stantec Inc. Common Shares Castro, Leonardo De 7 2020-08-12 10 43.715 0 -7,692 Oliveira Stantec Inc. Options Castro, Leonardo De 7 2020-08-12 51 32.01 25,104 -4,863 Oliveira Stantec Inc. Options Castro, Leonardo De 7 2020-08-12 51 31.75 11,540 -13,564 Oliveira Stantec Inc. Options Castro, Leonardo De 7 2020-08-12 51 32.98 3,848 -7,692 Oliveira Stantec Inc. Common Shares Fleck, Steve Marvin 7, 5 2020-08-10 51 32.9 6,006 3,856 Stantec Inc. Common Shares Fleck, Steve Marvin 7, 5 2020-08-10 10 43.792 2,150 -3,856 Stantec Inc. Common Shares Fleck, Steve Marvin 7, 5 2020-08-10 51 32.83 11,400 9,250 Stantec Inc. Common Shares Fleck, Steve Marvin 7, 5 2020-08-10 10 43.776 2,150 -9,250 Stantec Inc. Options Fleck, Steve Marvin 7, 5 2020-08-10 51 32.9 40,218 -3,856 Stantec Inc. Options Fleck, Steve Marvin 7, 5 2020-08-10 51 32.83 30,968 -9,250 Stantec Inc. Common Shares Gomes, Robert 4 2020-08-10 51 32.9 197,454 41,702 Stantec Inc. Common Shares Gomes, Robert 4 2020-08-10 10 43.596 155,752 -41,702 Stantec Inc. Options Gomes, Robert 4 2020-08-10 51 32.9 242,805 -41,702 Stantec Inc. Common Shares Johnston, Gordon Allan 4, 7, 5 2020-08-13 51 32.9 31,792 5,574 Stantec Inc. Common Shares Johnston, Gordon Allan 4, 7, 5 2020-08-13 10 43.198 26,218 -5,574 Stantec Inc. Common Shares Johnston, Gordon Allan 4, 7, 5 2020-08-13 51 32.01 32,953 6,735 Stantec Inc. Common Shares Johnston, Gordon Allan 4, 7, 5 2020-08-13 10 43.015 26,218 -6,735 Stantec Inc. Common Shares Johnston, Gordon Allan 4, 7, 5 2020-08-13 51 32.83 36,267 10,049 Stantec Inc. Common Shares Johnston, Gordon Allan 4, 7, 5 2020-08-13 10 42.93 26,218 -10,049 Stantec Inc. Common Shares Johnston, Gordon Allan 4, 7, 5 2020-08-13 51 31.75 36,985 10,767 Stantec Inc. Common Shares Johnston, Gordon Allan 4, 7, 5 2020-08-13 10 43.039 26,218 -10,767 Stantec Inc. Common Shares Johnston, Gordon Allan 4, 7, 5 2020-08-13 51 32.98 51,218 25,000 Stantec Inc. Common Shares Johnston, Gordon Allan 4, 7, 5 2020-08-13 10 42.893 26,218 -25,000 Stantec Inc. Common Shares Johnston, Gordon Allan 4, 7, 5 2020-08-13 10 43.483 36,218 10,000 Stantec Inc. Options Johnston, Gordon Allan 4, 7, 5 2020-08-13 51 32.9 118,287 -5,574 Stantec Inc. Options Johnston, Gordon Allan 4, 7, 5 2020-08-13 51 32.01 111,552 -6,735 Stantec Inc. Options Johnston, Gordon Allan 4, 7, 5 2020-08-13 51 32.83 101,503 -10,049 Stantec Inc. Options Johnston, Gordon Allan 4, 7, 5 2020-08-13 51 31.75 90,736 -10,767 Stantec Inc. Options Johnston, Gordon Allan 4, 7, 5 2020-08-13 51 32.98 65,736 -25,000 Stantec Inc. Common Shares Kennedy, Michael Aloysius 7 2020-08-13 51 31.75 25,037 13,564 Stantec Inc. Common Shares Kennedy, Michael Aloysius 7 2020-08-13 10 43.312 13,524 -11,513 Stantec Inc. Options Kennedy, Michael Aloysius 7 2020-08-13 51 31.75 16,460 -13,564 Starcore International Mines Common Shares 2176423 Ontario Ltd. 3 2020-08-07 10 0.2296 6,786,193 -307,000 Ltd.

August 20, 2020 (2020), 43 OSCB 6668

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Starcore International Mines Common Shares Sprott, Eric S. 3 2020-08-07 10 0.2296 6,786,193 -307,000 Ltd. Starrex International Ltd. Common Shares Burns, Charles 4 2020-08-07 10 0.45 774,500 1,500 Stella-Jones Inc. Deferred Share Units Coallier, Robert 4 2020-01-15 00 (DSUs) Stella-Jones Inc. Deferred Share Units Coallier, Robert 4 2020-08-10 56 42.304 354 354 (DSUs) Stella-Jones Inc. Common Shares Harries, Rhodri 4 2020-08-12 10 45.6 5,600 600 Stella-Jones Inc. Common Shares Harries, Rhodri 4 2020-08-12 10 45.52 6,600 1,000 Stella-Jones Inc. Common Shares Harries, Rhodri 4 2020-08-12 10 45.62 7,700 1,100 Stella-Jones Inc. Common Shares Harries, Rhodri 4 2020-08-12 10 45.61 8,400 700 Stella-Jones Inc. Common Shares Harries, Rhodri 4 2020-08-12 10 9,000 600 Stella-Jones Inc. Common Shares Harries, Rhodri 4 2020-08-12 10 45.64 9,100 100 Stella-Jones Inc. Common Shares Harries, Rhodri 4 2020-08-12 10 45.65 10,000 900 Stella-Jones Inc. Deferred Share Units Harries, Rhodri 4 2020-05-07 00 (DSUs) Stella-Jones Inc. Deferred Share Units Harries, Rhodri 4 2020-08-10 56 42.304 354 354 (DSUs) Stella-Jones Inc. Deferred Share Units Laflamme, Karen 4 2020-08-10 56 42.304 673 354 (DSUs) Stella-Jones Inc. Deferred Share Units Lehman, Katherine 4 2020-08-10 56 42.304 2,302 1,771 (DSUs) Stella-Jones Inc. Deferred Share Units Manzi, James Augustus 4 2020-08-10 56 42.304 673 354 (DSUs) Stella-Jones Inc. Deferred Share Units Muzyka, Douglas 4 2019-12-16 00 (DSUs) Stella-Jones Inc. Deferred Share Units Muzyka, Douglas 4 2020-08-10 56 42.304 354 354 (DSUs) Stella-Jones Inc. Deferred Share Units Pelletier, Simon 4 2020-08-10 56 42.304 673 354 (DSUs) Stella-Jones Inc. Deferred Share Units Webster, Mary 4 2020-08-10 56 42.304 673 354 (DSUs) Steppe Gold Ltd. Common Shares 2176423 Ontario Ltd. 3 2020-08-05 00 Steppe Gold Ltd. Common Shares 2176423 Ontario Ltd. 3 2020-08-05 16 2.15 6,976,944 6,976,944 Steppe Gold Ltd. Warrants 2176423 Ontario Ltd. 3 2020-08-05 00 Steppe Gold Ltd. Warrants 2176423 Ontario Ltd. 3 2020-08-05 16 3 6,976,944 6,976,944 Steppe Gold Ltd. Common Shares Sprott, Eric S. 3 2020-08-05 00 Steppe Gold Ltd. Common Shares Sprott, Eric S. 3 2020-08-05 16 2.15 6,976,944 6,976,944 Steppe Gold Ltd. Warrants Sprott, Eric S. 3 2020-08-05 00 Steppe Gold Ltd. Warrants Sprott, Eric S. 3 2020-08-05 16 3 6,976,944 6,976,944 Stingray Group Inc. Subordinate Voting Boyko, Éric 3, 4, 5 2020-08-07 11 4.95 708,552 100,000 Shares Stingray Group Inc. Subordinate Voting Pathy, Mark 4 2020-08-06 11 5 3,761,734 200,000 Shares Stingray Group Inc. Deferred Share Units STEELE, JOHN RICHARD 4 2020-08-10 56 5.0601 11,090 1,630 (DSU) Strata-X Energy Ltd. Common Shares Hettich, David 5 2020-08-13 10 559,238 -50,000 Stuhini Exploration Ltd. Common Shares KAMIMURA, CHARLES 5 2020-08-14 16 0.55 68,500 18,500 SHIGEO Stuhini Exploration Ltd. Common Shares KAMIMURA, CHARLES 5 2020-08-14 16 0.4 315,000 50,000 SHIGEO Stuhini Exploration Ltd. Common Shares O'Brien, David Bruce 5 2020-08-14 16 0.55 1,500,000 100,000 Summa Silver Corp. Common Shares 2176423 Ontario Ltd. 3 2020-08-05 00 4,000,000 Summa Silver Corp. Common Shares 2176423 Ontario Ltd. 3 2020-08-05 16 1 9,000,000 5,000,000 Summa Silver Corp. Warrants 2176423 Ontario Ltd. 3 2020-08-05 00 Summa Silver Corp. Warrants 2176423 Ontario Ltd. 3 2020-08-05 16 1.75 2,500,000 2,500,000 Summa Silver Corp. Common Shares Konnert, Michael 4 2020-08-10 00 125,000 Summa Silver Corp. Options Konnert, Michael 4 2020-08-10 00 200,000 Summa Silver Corp. Common Shares O'Neill, Thomas 4 2020-08-05 10 1 250,000 100,000 Summa Silver Corp. Warrants O'Neill, Thomas 4 2020-02-05 00 Summa Silver Corp. Warrants O'Neill, Thomas 4 2020-08-05 10 1.75 50,000 50,000 Summa Silver Corp. Common Shares Sprott, Eric S. 3 2020-08-05 00 4,000,000 Summa Silver Corp. Common Shares Sprott, Eric S. 3 2020-08-05 16 1 9,000,000 5,000,000

August 20, 2020 (2020), 43 OSCB 6669

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Summa Silver Corp. Warrants Sprott, Eric S. 3 2020-08-05 00 Summa Silver Corp. Warrants Sprott, Eric S. 3 2020-08-05 16 1.75 2,500,000 2,500,000 Summa Silver Corp. Warrants Sprott, Eric S. 3 2020-08-05 00 Summa Silver Corp. Warrants Sprott, Eric S. 3 2020-08-05 00 Summa Silver Corp. Warrants Sprott, Eric S. 3 2020-08-05 16 1.75 2,500,000 Summa Silver Corp. Warrants Sprott, Eric S. 3 2020-08-05 16 1.75 2,500,000 Sun Life Financial Inc. Common Shares Coyles, Stephanie 4 2020-08-11 10 56.73 5,700 300 Sun Life Financial Inc. Common Shares Gupta, Ashok 4 2020-08-11 30 56.75 964 219 Superior Gold Inc. Options Brown, Tamara Lee 4, 5 2020-08-04 50 1,200,000 1,000,000 Surge Energy Inc. Common Shares Pasieka, James Murray 4 2020-08-11 10 0.32 923,834 13,342 Sustainable Infrastructure Trust Units Sustainable Infrastructure 1 2020-08-07 38 10.339 417,300 1,600 Dividend Fund Dividend Fund Sustainable Infrastructure Trust Units Sustainable Infrastructure 1 2020-08-10 38 10.396 421,800 4,500 Dividend Fund Dividend Fund Sustainable Infrastructure Trust Units Sustainable Infrastructure 1 2020-08-11 38 10.364 425,800 4,000 Dividend Fund Dividend Fund Sustainable Infrastructure Trust Units Sustainable Infrastructure 1 2020-08-12 38 10.309 427,200 1,400 Dividend Fund Dividend Fund Sustainable Infrastructure Trust Units Sustainable Infrastructure 1 2020-08-13 38 10.294 430,000 2,800 Dividend Fund Dividend Fund Swiss Water Decaffeinated Common Shares Johnston, Robert Bruce 4 2020-08-11 10 2.97 8,200 3,200 Coffee Inc. Swiss Water Decaffeinated Common Shares Tringali, Donald John 4 2020-07-20 00 Coffee Inc. Swiss Water Decaffeinated Common Shares Tringali, Donald John 4 2020-08-12 10 2.3474 3,300 3,300 Coffee Inc. Taal Distributed Information Warrants Matthews, Stefan 4 2020-08-10 55 8 0 -562,500 Technologies Inc. Taiga Gold Corp. Common Shares DIDUCK, GLEN JOHN 4, 5 2020-08-07 51 1,475,000 150,000 Taiga Gold Corp. Options DIDUCK, GLEN JOHN 4, 5 2020-08-07 51 952,500 -150,000 Taranis Resources Inc. Common Shares McChip Resources Inc. 3 2019-08-28 99 0.1 9,497,000 2,000,000 Taranis Resources Inc. Warrants McChip Resources Inc. 3 2018-09-18 00 Taranis Resources Inc. Warrants McChip Resources Inc. 3 2018-09-18 00 1,333,333 Taranis Resources Inc. Warrants McChip Resources Inc. 3 2019-08-28 99 5,333,333 2,000,000 Tarku Resources Ltd. Common Shares Lapointe, Bernard 4 2020-02-03 37 306,333 -1,684,842 (formerly ITUNA Capital Corporation) Tarku Resources Ltd. Common Shares Lapointe, Bernard 4 2020-08-12 47 190,543 -115,790 (formerly ITUNA Capital Corporation) Tarku Resources Ltd. Common Shares Termuende, Timothy Jay 4 2020-08-13 11 0.065 338,458 100,000 (formerly ITUNA Capital Corporation) Tarku Resources Ltd. Warrants Termuende, Timothy Jay 4 2020-08-13 11 0.085 119,230 100,000 (formerly ITUNA Capital Corporation) Tembo Gold Corp. Common Shares Hogel, Frank 4 2020-08-06 16 0.15 273,334 166,667 TeraGo Inc. Options Charron, David 5 2020-08-10 50 7 162,278 47,169 Tervita Corporation Options Cooper, John William 4, 5 2020-08-10 50 995,188 190,500 Tervita Corporation Rights Restricted Share Cooper, John William 4, 5 2020-08-10 56 107,900 82,900 Units (RSUs) Tervita Corporation Rights Performance Cooper, John William 4, 5 2020-08-10 56 256,967 165,800 Share Units (PSUs) Tervita Corporation Options Dawson, Robert 5 2020-08-10 50 487,697 93,400 Tervita Corporation Rights Restricted Share Dawson, Robert 5 2018-07-19 00 Units (RSUs) Tervita Corporation Rights Restricted Share Dawson, Robert 5 2020-08-10 56 40,600 40,600 Units (RSUs) Tervita Corporation Rights Performance Dawson, Robert 5 2020-08-10 56 125,872 81,200 Share Units (PSUs) Tervita Corporation Options Dietsche, Linda 5 2020-08-10 50 172,437 77,400 Tervita Corporation Rights Restricted Share Dietsche, Linda 5 2019-05-13 00 Units (RSUs) Tervita Corporation Rights Restricted Share Dietsche, Linda 5 2020-08-10 56 33,700 33,700 Units (RSUs)

August 20, 2020 (2020), 43 OSCB 6670

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Tervita Corporation Rights Performance Dietsche, Linda 5 2020-08-10 56 103,203 67,300 Share Units (PSUs) Tervita Corporation Options Erickson, Michael Steven 5 2020-08-10 50 95,771 25,100 Tervita Corporation Rights Restricted Share Erickson, Michael Steven 5 2018-07-19 00 Units (RSUs) Tervita Corporation Rights Restricted Share Erickson, Michael Steven 5 2020-08-10 56 10,900 10,900 Units (RSUs) Tervita Corporation Rights Performance Erickson, Michael Steven 5 2020-08-10 56 33,996 21,800 Share Units (PSUs) Tervita Corporation Options Landfried, Darilyn Bree 5 2020-08-10 50 103,946 26,700 Tervita Corporation Rights Restricted Share Landfried, Darilyn Bree 5 2018-07-19 00 Units (RSUs) Tervita Corporation Rights Restricted Share Landfried, Darilyn Bree 5 2020-08-10 56 11,600 11,600 Units (RSUs) Tervita Corporation Rights Performance Landfried, Darilyn Bree 5 2020-08-10 56 36,531 23,200 Share Units (PSUs) Tervita Corporation Common Shares Lisch, Vincent 5 2020-02-01 00 Tervita Corporation Options Lisch, Vincent 5 2020-02-01 00 14,151 Tervita Corporation Options Lisch, Vincent 5 2020-08-10 50 39,751 25,600 Tervita Corporation Rights Restricted Share Lisch, Vincent 5 2020-02-01 00 27,843 Units (RSUs) Tervita Corporation Rights Restricted Share Lisch, Vincent 5 2020-03-27 57 3.99 17,843 -10,000 Units (RSUs) Tervita Corporation Rights Restricted Share Lisch, Vincent 5 2020-03-31 57 3.69 15,817 -2,026 Units (RSUs) Tervita Corporation Rights Restricted Share Lisch, Vincent 5 2020-08-10 56 26,917 11,100 Units (RSUs) Tervita Corporation Rights Performance Lisch, Vincent 5 2020-02-01 00 6,078 Share Units (PSUs) Tervita Corporation Rights Performance Lisch, Vincent 5 2020-08-10 56 28,378 22,300 Share Units (PSUs) Tervita Corporation Options Rudnitski, Rhonda 5 2020-08-10 50 53,496 25,100 Kimberly Tervita Corporation Rights Restricted Share Rudnitski, Rhonda 5 2018-07-19 00 Units (RSUs) Kimberly Tervita Corporation Rights Restricted Share Rudnitski, Rhonda 5 2020-08-10 56 10,900 10,900 Units (RSUs) Kimberly Tervita Corporation Rights Performance Rudnitski, Rhonda 5 2020-08-10 56 33,996 21,800 Share Units (PSUs) Kimberly Tervita Corporation Options Watts, Shad Allan 5 2020-08-10 50 126,729 25,100 Tervita Corporation Rights Restricted Share Watts, Shad Allan 5 2018-07-19 00 Units (RSUs) Tervita Corporation Rights Restricted Share Watts, Shad Allan 5 2020-08-10 56 10,900 10,900 Units (RSUs) Tervita Corporation Rights Performance Watts, Shad Allan 5 2020-08-10 56 33,996 21,800 Share Units (PSUs) Tesoro Minerals Corp. Common Shares Elliott, David Brian 3 2013-12-17 00 Tesoro Minerals Corp. Common Shares Elliott, David Brian 3 2020-08-06 16 0.05 200,000 200,000 Tesoro Minerals Corp. Warrants Elliott, David Brian 3 2013-12-17 00 Tesoro Minerals Corp. Warrants Elliott, David Brian 3 2020-08-06 16 0.1 200,000 200,000 Tesoro Minerals Corp. Common Shares McLean, Scott 4 2020-08-12 11 0.05 366,781 200,000 Tesoro Minerals Corp. Warrants McLean, Scott 4 2020-08-12 11 250,000 200,000 Tethys Petroleum Limited Common Shares Wells, William Paul Wells 3, 4 2020-08-07 10 0.644 25,617,708 11,500 Tethys Petroleum Limited Common Shares Wells, William Paul Wells 3, 4 2020-08-10 10 0.604 25,631,708 14,000 Tethys Petroleum Limited Common Shares Wells, William Paul Wells 3, 4 2020-08-12 10 0.6 25,634,708 3,000 Tethys Petroleum Limited Common Shares Wells, William Paul Wells 3, 4 2020-08-13 10 0.6 25,644,708 10,000 TGS Esports Inc. Common Shares Khouri, Spiro 4, 5 2020-07-30 00 2,066,040 TGS Esports Inc. Options Khouri, Spiro 4, 5 2020-07-30 00 TGS Esports Inc. Warrants Khouri, Spiro 4, 5 2020-07-30 00 TGS Esports Inc. Common Shares Li, Chi Yan Carolina 4 2020-07-30 00 TGS Esports Inc. Options Li, Chi Yan Carolina 4 2020-07-30 00 TGS Esports Inc. Warrants Li, Chi Yan Carolina 4 2020-07-30 00 TGS Esports Inc. Common Shares Zhai, Tao 6 2020-07-30 00

August 20, 2020 (2020), 43 OSCB 6671

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed TGS Esports Inc. Common Shares Zhai, Tao 6 2020-07-30 00 429,559 TGS Esports Inc. Warrants Zhai, Tao 6 2020-07-30 00 200,000 THC BIOMED INTL LTD. Warrants Miller, John 3, 4 2020-08-09 55 11,447,310 -120,967 The Green Organic Options Gagne, Michel 5 2020-08-05 00 125,000 Dutchman Holdings Ltd. The Green Organic Rights Restricted Share Gagne, Michel 5 2020-08-05 00 50,000 Dutchman Holdings Ltd. Unit (RSU) The Valens Company Inc. Common Shares Smith, Anderson Paul 5 2020-05-01 00 (formerly Valens Groworks Corp.) The Valens Company Inc. Common Shares Smith, Anderson Paul 5 2020-05-01 00 108,100 (formerly Valens Groworks Corp.) The Valens Company Inc. Common Shares Smith, Anderson Paul 5 2020-08-04 10 2.05 98,100 -10,000 (formerly Valens Groworks Corp.) The Valens Company Inc. Common Shares Smith, Anderson Paul 5 2020-08-11 10 2.26 73,100 -25,000 (formerly Valens Groworks Corp.) The Valens Company Inc. Common Shares Smith, Anderson Paul 5 2020-08-11 10 2.25 63,100 -10,000 (formerly Valens Groworks Corp.) The Valens Company Inc. Common Shares Smith, Anderson Paul 5 2020-08-11 10 2.27 53,100 -10,000 (formerly Valens Groworks Corp.) The Valens Company Inc. Common Shares Smith, Anderson Paul 5 2020-05-01 00 33,300 (formerly Valens Groworks Corp.) The Valens Company Inc. Options Smith, Anderson Paul 5 2020-05-01 00 200,000 (formerly Valens Groworks Corp.) The Very Good Food Common Shares Bonnell, Drew 4, 5 2020-06-05 46 0.15 350,007 33,334 Company Inc. (formerly The Very Good Butchers Inc.) The Very Good Food Common Shares Bonnell, Drew 4, 5 2020-08-05 54 0.3 358,341 8,334 Company Inc. (formerly The Very Good Butchers Inc.) The Very Good Food Warrants Bonnell, Drew 4, 5 2020-06-05 46 175,004 16,667 Company Inc. (formerly The Very Good Butchers Inc.) The Very Good Food Warrants Bonnell, Drew 4, 5 2020-07-29 54 166,670 -8,334 Company Inc. (formerly The Very Good Butchers Inc.) The Very Good Food Warrants Greenleaf, Brian 5 2020-06-17 00 Company Inc. (formerly The Very Good Butchers Inc.) The Very Good Food Warrants Greenleaf, Brian 5 2020-08-13 46 45,000 45,000 Company Inc. (formerly The Very Good Butchers Inc.) The Western Investment Common Shares Tannas, Scott 4, 7, 5 2020-08-11 10 0.23 959,308 3,500 Company of Canada Limited The Western Investment Common Shares Tannas, Scott 4, 7, 5 2020-08-11 10 0.25 959,808 500 Company of Canada Limited The Western Investment Common Shares Tannas, Scott 4, 7, 5 2020-08-11 10 0.295 965,808 6,000 Company of Canada Limited The Western Investment Common Shares Tannas, Scott 4, 7, 5 2020-08-13 10 0.245 969,808 4,000 Company of Canada Limited The Western Investment Common Shares Tannas, Scott 4, 7, 5 2020-08-13 10 0.25 977,808 8,000 Company of Canada Limited The Yield Growth Corp. Common Shares White, Penny Olga 3, 4, 5 2020-08-10 36 16,935,721 178,221 The Yield Growth Corp. Special Warrants White, Penny Olga 3, 4, 5 2018-11-22 00 The Yield Growth Corp. Special Warrants White, Penny Olga 3, 4, 5 2020-07-29 16 0.1 178,221 178,221 The Yield Growth Corp. Special Warrants White, Penny Olga 3, 4, 5 2020-08-10 36 0 -178,221 The Yield Growth Corp. Warrants White, Penny Olga 3, 4, 5 2020-08-10 36 2,178,221 178,221 Therma Bright Inc. Common Shares Heng, Joseph, Ching-Hiang 4 2020-08-13 51 0.1 250,000 250,000 Therma Bright Inc. Common Shares Heng, Joseph, Ching-Hiang 4 2020-08-13 52 0.05 400,000 150,000 Therma Bright Inc. Options Heng, Joseph, Ching-Hiang 4 2020-08-13 51 0.1 1,490,000 -250,000

August 20, 2020 (2020), 43 OSCB 6672

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Therma Bright Inc. Options Heng, Joseph, Ching-Hiang 4 2020-08-13 51 0.1 1,340,000 -150,000 Thomson Reuters Restricted Share Units Fischer, Paul 7 2020-08-10 56 37,945 4,007 Corporation Thomson Reuters Restricted Share Units Wong, David Franklin 5 2020-06-29 00 Corporation Thomson Reuters Restricted Share Units Wong, David Franklin 5 2020-08-10 56 36,063 36,063 Corporation ThreeD Capital Inc. Common Shares Inwentash, Raquel Aspen 3 2020-08-05 10 0.23 2,243,500 21,500 ThreeD Capital Inc. Common Shares Inwentash, Raquel Aspen 3 2020-08-06 10 0.23 2,268,500 25,000 ThreeD Capital Inc. Common Shares Inwentash, Raquel Aspen 3 2020-08-07 10 0.245 2,318,500 50,000 ThreeD Capital Inc. Common Shares Inwentash, Raquel Aspen 3 2020-08-10 10 0.25 2,343,500 25,000 Timbercreek Financial Corp. Common Shares Timbercreek Financial 1 2020-07-31 38 8.44 242,792 242,792 Corp. Timbercreek Financial Corp. Common Shares Timbercreek Financial 1 2020-07-31 38 0 -242,792 Corp. Titan Medical Inc. Common Shares Delorme, Monique 5 2020-06-16 00 32,333 Titan Medical Inc. Options Delorme, Monique 5 2019-06-26 50 4.54 10,000 10,000 Titan Medical Inc. Options Delorme, Monique 5 2020-06-16 00 Titan Medical Inc. Options Delorme, Monique 5 2020-06-26 50 4.54 10,000 Titan Medical Inc. Options Delorme, Monique 5 2020-07-29 50 0.962 110,000 100,000 Toromont Industries Ltd. Options Cochrane, Jennifer 5 2020-08-11 50 134,500 17,000 Toromont Industries Ltd. Common Shares Cuddy, Mike 5 2020-08-07 10 73.25 76,599 -7,000 Toromont Industries Ltd. Options Cuddy, Mike 5 2020-08-11 50 238,835 36,335 Toromont Industries Ltd. Common Shares Hill, Wayne S. 4 2020-08-11 10 72.003 35,100 -125,000 Toromont Industries Ltd. Common Shares Jewer, Paul Randolph 5 2020-08-06 51 66.22 20,000 20,000 Toromont Industries Ltd. Common Shares Jewer, Paul Randolph 5 2020-08-06 10 73.5 0 -20,000 Toromont Industries Ltd. Options Jewer, Paul Randolph 5 2020-08-06 51 66.22 70,000 -20,000 Toromont Industries Ltd. Options Korbak, Lynn Margaret 5 2020-08-11 50 30,133 10,133 Toromont Industries Ltd. Options Malinauskas, David Allan 7 2020-08-11 50 102,928 22,928 Toromont Industries Ltd. Options McMillan, Michael Stanley 5 2020-03-01 00 Howie Toromont Industries Ltd. Options McMillan, Michael Stanley 5 2020-08-11 50 49,911 49,911 Howie Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 51 26.52 188,276 15,000 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.67 188,076 -200 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.66 187,776 -300 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.65 187,476 -300 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.63 186,876 -600 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.62 186,776 -100 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.61 186,376 -400 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.6 185,676 -700 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.59 184,776 -900 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.58 183,776 -1,000 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.57 183,076 -700 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.55 182,576 -500 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.54 181,976 -600 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.53 180,276 -1,700 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.52 178,676 -1,600 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.51 177,876 -800 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.5 176,976 -900 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.49 176,776 -200 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.47 176,376 -400 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.46 176,176 -200 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.45 175,976 -200 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.44 175,776 -200 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.43 175,276 -500 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.42 174,676 -600 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.41 174,576 -100 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.38 174,476 -100 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.36 174,076 -400

August 20, 2020 (2020), 43 OSCB 6673

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.35 173,676 -400 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.34 173,376 -300 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 10 73.32 173,276 -100 Toromont Industries Ltd. Common Shares Medhurst, Scott 4, 5 2020-08-13 51 26.52 178,505 5,229 Toromont Industries Ltd. Options Medhurst, Scott 4, 5 2020-08-11 50 10,000 Toromont Industries Ltd. Options Medhurst, Scott 4, 5 2020-08-11 50 10,000 Toromont Industries Ltd. Options Medhurst, Scott 4, 5 2020-08-11 50 680,000 100,000 Toromont Industries Ltd. Options Medhurst, Scott 4, 5 2020-08-13 51 26.52 665,000 -15,000 Toromont Industries Ltd. Options Medhurst, Scott 4, 5 2020-08-13 51 26.52 653,000 -12,000 Toromont Industries Ltd. Common Shares Ogilvie, Robert M. 4 2003-06-23 00 Toromont Industries Ltd. Common Shares Ogilvie, Robert M. 4 2020-08-06 47 140,000 140,000 Toromont Industries Ltd. Common Shares Ogilvie, Robert M. 4 2020-08-10 47 140,000 Toromont Industries Ltd. Common Shares Ogilvie, Robert M. 4 2020-08-06 47 1,630,048 -140,000 Toromont Industries Ltd. Common Shares Ogilvie, Robert M. 4 2020-08-10 47 -140,000 Toromont Industries Ltd. Common Shares Ogilvie, Robert M. 4 2020-08-11 10 72 1,215,048 -415,000 Total Energy Services Inc. Options Danyluk, Cam 5 2020-08-11 50 2.31 395,000 80,000 Total Energy Services Inc. Options Gorbach, Yuliya 5 2020-08-11 50 2.31 395,000 80,000 Total Energy Services Inc. Common Shares Halyk, Daniel Kim 4, 5 2020-08-13 10 2.25 1,450,000 10,000 Total Energy Services Inc. Options Halyk, Daniel Kim 4, 5 2020-08-11 50 470,000 95,000 Total Energy Services Inc. Options Kosich, William John 5 2020-08-11 50 2.31 395,000 80,000 George Total Energy Services Inc. Options Macson, Bradley John 5 2020-08-11 50 2.31 395,000 80,000 Total Energy Services Inc. Options Ting, Ashley Desiree 5 2019-05-17 50 9 40,000 Total Energy Services Inc. Options Ting, Ashley Desiree 5 2019-05-17 50 9 40,000 Total Energy Services Inc. Options Ting, Ashley Desiree 5 2019-05-17 50 9 40,000 Total Energy Services Inc. Options Ting, Ashley Desiree 5 2020-08-11 50 2.31 130,000 30,000 Tourmaline Oil Corp. Common Shares Rose, Mike 5 2020-08-10 10 16.25 8,646,337 10,000 Tourmaline Oil Corp. Common Shares Rose, Mike 5 2020-08-14 10 16.571 8,651,337 5,000 Treasury Metals Inc. Common Shares Bourchier, Frazer William 4 2020-08-07 00 Treasury Metals Inc. Common Shares Whittle, David Edward 4 2020-08-07 00 Treasury Metals Inc. Options Whittle, David Edward 4 2020-08-07 00 Treasury Metals Inc. Warrants Whittle, David Edward 4 2020-08-07 00 Tree Island Steel Ltd. Common Shares Doman, Amar 3, 4 2020-08-07 10 2.02 9,390,350 5,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-02 38 0.8426 276,000 103,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-03 38 0.8479 402,500 126,500 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-03 38 229,500 -173,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-06 38 0.8444 379,500 150,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-07 38 0.849 395,000 15,500 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-08 38 0.8417 495,000 100,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-09 38 0.839 642,500 147,500 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-10 38 0.8383 692,500 50,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-10 38 197,500 -495,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-13 38 0.8382 274,000 76,500 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-14 38 0.8384 424,000 150,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-15 38 0.8408 487,000 63,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-16 38 0.8451 577,000 90,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-17 38 0.8498 656,000 79,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-17 38 169,000 -487,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-20 38 0.8495 229,000 60,000 Trican Well Service Ltd. Common Shares Trican Well Service Ltd. 1 2020-07-24 38 0 -229,000 Trillion Energy International Common Shares Thompson, David 7 2020-07-31 97 0.06 125,000 Inc. (formerly Park Place Energy Inc.) Trillion Energy International Common Shares Thompson, David 7 2020-07-31 97 0.06 125,000 125,000 Inc. (formerly Park Place Energy Inc.) Trillion Energy International Common Shares Thompson, David 7 2020-07-31 36 0.05 500,000 Inc. (formerly Park Place Energy Inc.)

August 20, 2020 (2020), 43 OSCB 6674

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Trillion Energy International Common Shares Thompson, David 7 2020-07-31 36 0.05 625,000 500,000 Inc. (formerly Park Place Energy Inc.) Trillion Energy International Options Thompson, David 7 2013-11-07 00 Inc. (formerly Park Place Energy Inc.) Trillion Energy International Options Thompson, David 7 2013-11-07 00 2,175,000 Inc. (formerly Park Place Energy Inc.) Trillion Energy International Options Thompson, David 7 2020-07-31 50 0.05 2,495,000 320,000 Inc. (formerly Park Place Energy Inc.) Trillion Energy International Options Thompson, David 7 2020-07-31 50 0.09 2,995,000 500,000 Inc. (formerly Park Place Energy Inc.) Triumph Gold Corp. Common Shares ANDERSON, JOHN 4 2020-08-10 16 0.2 4,180,000 297,000 Triumph Gold Corp. Options ANDERSON, JOHN 4 2020-08-11 50 0.3 2,875,000 800,000 Triumph Gold Corp. Warrants Warrants ANDERSON, JOHN 4 2020-08-10 16 0.3 297,000 297,000 Troilus Gold Corp. Common Shares Olesinski, Thomas 4 2020-08-11 10 1.33 195,083 3,000 Tucows Inc. Common Shares Investmentaktiengesellscha 3 2020-08-12 10 64.866 1,620,627 -2,500 ft für langfristige Investoren TGV Tucows Inc. Common Shares Schwartz, Jeffrey 4 2020-08-11 51 24.96 12,375 3,750 Tucows Inc. Common Shares Schwartz, Jeffrey 4 2020-08-11 97 65.06 10,497 -1,878 Tucows Inc. Options Schwartz, Jeffrey 4 2020-08-11 51 24.96 188,750 -3,750 TWC Enterprises Limited Common Shares Sahi, Kuldip Rai 3, 4, 6, 5 2020-08-11 10 11.2 15,773,915 385,353 TWC Enterprises Limited Common Shares TWC Enterprises Limited 1 2020-08-11 38 11.2 800,000 800,000 TWC Enterprises Limited Common Shares TWC Enterprises Limited 1 2020-08-11 38 0 -800,000 U3O8 Corp. Common Shares Molesworth, Helen 4 2020-08-07 00 U3O8 Corp. Options Molesworth, Helen 4 2020-08-07 00 U3O8 Corp. Warrants Molesworth, Helen 4 2020-08-07 00 Uranium Energy Corp. Options Ballesta, Gloria 4 2020-08-13 52 2.43 255,000 -10,000 Velocity Minerals Ltd. Options Hoffman, Michael 4 2020-06-24 00 400,000 Velocity Minerals Ltd. Common Shares Kopple, Robert Charles 3 2020-08-14 10 0.3486 2,053,072 150,000 Velocity Minerals Ltd. Options Morgans, Darren Paul 5 2020-08-14 50 360,000 10,000 Versus Systems Inc. Options Chin, Kelsey 5 2020-08-07 50 494,375 101,875 Versus Systems Inc. Options Finster, Craig 5 2020-08-07 50 1,770,000 240,000 Versus Systems Inc. Options Gahagan, Michelle 4 2020-08-07 50 187,500 167,500 Versus Systems Inc. Options Peachey, Jon Alexander 5 2020-08-07 50 1,770,000 240,000 Versus Systems Inc. Options Peymani, Keyvan 4 2020-08-07 50 1,910,000 80,000 Versus Systems Inc. Options Pierce, Matthew 4, 5 2020-08-07 50 967,500 327,500 Versus Systems Inc. Options Tingle, Brian 4 2020-08-07 50 637,500 167,500 Versus Systems Inc. Options Vlasic, Paul 4 2020-08-07 50 637,500 167,500 Victory Nickel Inc. Common Shares Galipeau, René Réal 4 2020-08-07 10 0.035 28,765 -18,349 Victory Nickel Inc. Common Shares Galipeau, René Réal 4 2020-08-07 10 0.035 0 -54,710 VIQ Solutions Inc. Common Shares Gordon, Harvey 4 2020-08-13 10 3.8306 134,756 13,000 Vodis Pharmaceuticals Inc. Common Shares Good, Derek 3 2020-08-07 10 0.055 13,873,510 10,000 Vodis Pharmaceuticals Inc. Common Shares Good, Derek 3 2020-08-10 10 0.05 13,874,510 1,000 Vodis Pharmaceuticals Inc. Common Shares Good, Derek 3 2020-08-11 10 0.05 13,903,510 29,000 Vodis Pharmaceuticals Inc. Common Shares Good, Derek 3 2020-08-12 10 0.05 13,911,510 8,000 Vodis Pharmaceuticals Inc. Common Shares Good, Derek 3 2020-08-13 10 0.05 13,920,510 9,000 Vodis Pharmaceuticals Inc. Common Shares Good, Derek 3 2020-08-14 10 0.05 9,000 Vodis Pharmaceuticals Inc. Common Shares Good, Derek 3 2020-08-14 10 0.05 13,933,510 13,000 Vox Royalty Corp. (formerly Rights RSUs Floyd, Kyle 4, 5 2020-05-19 00 1,602,301 AIM3 Ventures Inc.) Wall Financial Corporation. Common Shares BJW Capital Ltd. 3 2020-08-06 10 18.5 3,676,860 200 Wall Financial Corporation. Common Shares BJW Capital Ltd. 3 2020-08-10 10 18.5 3,681,360 4,500 Wall Financial Corporation. Common Shares BJW Capital Ltd. 3 2020-08-11 10 18.5 3,681,660 300 Wallbridge Mining Company Common Shares 2176423 Ontario Ltd. 3 2020-08-06 54 0.6 134,854,063 2,500,000 Limited Wallbridge Mining Company Warrants 2176423 Ontario Ltd. 3 2020-08-06 54 0.6 0 -2,500,000 Limited

August 20, 2020 (2020), 43 OSCB 6675

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed Wallbridge Mining Company Common Shares Demers, Francois Alain 5 2020-08-14 10 0.98 820,710 -200,000 Limited Wallbridge Mining Company Common Shares Demers, Francois Alain 5 2020-08-14 51 600,000 Limited Wallbridge Mining Company Common Shares Demers, Francois Alain 5 2020-08-14 51 0.11 1,420,710 600,000 Limited Wallbridge Mining Company Common Shares Sprott, Eric S. 3 2020-08-06 54 0.6 134,854,063 2,500,000 Limited Wallbridge Mining Company Warrants Sprott, Eric S. 3 2020-08-06 54 0.6 0 -2,500,000 Limited Weekend Unlimited Common Shares Lamb, Charles 4, 5 2020-07-21 00 Industries Inc. Weekend Unlimited Common Shares Lamb, Charles 4, 5 2020-08-04 46 0.08 62,500 62,500 Industries Inc. Weekend Unlimited Options Lamb, Charles 4, 5 2020-03-25 50 0.125 350,000 350,000 Industries Inc. Weekend Unlimited Options Lamb, Charles 4, 5 2020-07-21 00 Industries Inc. West Vault Mining Inc. Common Shares Jones, R. Michael 4 2020-08-13 10 1.45 284,191 2,000 West Vault Mining Inc. Common Shares Sun Valley Gold LLC 3 2020-07-02 37 20,313,740 -182,823,660 West Vault Mining Inc. Common Shares Sun Valley Gold LLC 3 2020-08-12 11 1.15 26,822,740 6,509,000 West Vault Mining Inc. Common Shares Sun Valley Gold Master 3 2020-07-02 37 20,313,740 -182,823,660 Fund, Ltd. West Vault Mining Inc. Common Shares Sun Valley Gold Master 3 2020-08-12 11 1.15 26,822,740 6,509,000 Fund, Ltd. Western Copper and Gold Options Lang, Archibald Donald 4 2020-07-27 50 1.66 525,000 125,000 Corporation Western Copper and Gold Options Prasad, Varun 5 2020-07-27 50 1.66 425,000 175,000 Corporation Western Energy Services Common Shares Armoyan, Sime 3 2020-08-07 10 0.255 16,723,500 10,000 Corp. Western Energy Services Common Shares Armoyan, Sime 3 2020-08-07 10 0.255 16,733,500 10,000 Corp. Western Energy Services Common Shares Armoyan, Sime 3 2020-08-07 10 0.254 16,742,000 8,500 Corp. Western Energy Services Common Shares Armoyan, Sime 3 2020-08-07 10 0.245 16,754,000 12,000 Corp. Western Energy Services Common Shares Armoyan, Sime 3 2020-08-07 10 0.255 16,755,000 1,000 Corp. Western Energy Services Common Shares Armoyan, Sime 3 2020-08-11 10 0.25 16,774,000 19,000 Corp. Western Energy Services Common Shares Armoyan, Sime 3 2020-08-12 10 0.25 16,955,000 181,000 Corp. Western Energy Services Options Balkwill, Peter John 5 2020-08-13 52 370,440 -38,750 Corp. Western Energy Services Options Bowers, Jeffrey Keith 5 2020-08-13 52 742,930 -199,000 Corp. Western Energy Services Options Copeland, Donald Darrell 4 2020-08-13 52 60,310 -16,250 Corp. Western Energy Services Options Gartner, Lorne 4 2020-08-13 52 60,310 -16,250 Corp. Western Energy Services Options MacAusland, Alexander 4, 5 2020-08-13 52 1,029,560 -278,500 Corp. Roland Neil Western Energy Services Options Mathison, Ronald 4 2020-08-13 52 60,310 -16,250 Corp. Western Energy Services Options Rooney, John Ross 4 2020-08-13 52 16,250 Corp. Western Energy Services Options Rooney, John Ross 4 2020-08-13 52 60,310 -16,250 Corp. Western Troy Capital Common Shares Newbury, Andrew 5 2020-08-06 00 Resources Inc. Western Troy Capital Options Newbury, Andrew 5 2020-08-06 00 Resources Inc. Yorbeau Resources Inc. Common Shares Class A Kocisko, Terry 4 2020-08-13 10 0.06 5,075,000 50,000 ZEN Graphene Solutions Common Shares Bosse, Brian Gerald 4, 5 2020-08-13 10 0.46 175,911 10,000 Ltd.

August 20, 2020 (2020), 43 OSCB 6676

Insider Reporting

Issuer Name Security Insider Name Rel'n Transaction T/O Unit Date/Month End Acquired/ Date Price Holdings Disposed ZEN Graphene Solutions Common Shares Bosse, Brian Gerald 4, 5 2020-08-13 10 0.45 185,911 10,000 Ltd. Zonetail Inc. Common Shares Oliver, William 4 2018-11-08 00 Zonetail Inc. Common Shares Oliver, William 4 2018-11-08 22 0.18 286,200 286,200

August 20, 2020 (2020), 43 OSCB 6677

Insider Reporting

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August 20, 2020 (2020), 43 OSCB 6678

Chapter 11

IPOs, New Issues and Secondary Financings

INVESTMENT FUNDS

Issuer Name: Issuer Name: Canada Life Pathways Canadian Concentrated Equity AGF Global Opportunities Bond ETF Fund AGF Global Sustainable Growth Equity ETF Canada Life Pathways Canadian Equity Fund Principal Regulator - Ontario Canada Life Pathways Core Bond Fund Type and Date: Canada Life Pathways Core Plus Bond Fund Preliminary Long Form Prospectus dated Aug 12, 2020 Canada Life Pathways Emerging Markets Equity Fund NP 11-202 Preliminary Receipt dated Aug 13, 2020 Canada Life Pathways Emerging Markets Large Cap Offering Price and Description: Equity Fund Units Canada Life Pathways Global Core Plus Bond Fund Underwriter(s) or Distributor(s): Canada Life Pathways Global Multi Sector Bond Fund N/A Canada Life Pathways Global Tactical Fund Promoter(s): Canada Life Pathways International Concentrated Equity N/A Fund Project #3095998 Canada Life Pathways International Equity Fund Canada Life Pathways Money Market Fund ______Canada Life Pathways U.S. Concentrated Equity Fund Issuer Name: Canada Life Pathways U.S. Equity Fund DFA Global Sustainability Core Equity Fund Principal Regulator - Ontario Principal Regulator – British Columbia Type and Date: Type and Date: Amendment #1 dated August 14, 2020 to Final Simplified Preliminary Simplified Prospectus dated Aug 17, 2020 Prospectus dated October 21, 2019 NP 11-202 Preliminary Receipt dated Aug 17, 2020 Received on August 14, 2020 Offering Price and Description: Offering Price and Description: Class F Units, Class A(H) Units, Class I Units, Class A - Units, Class I(H) Units and Class F(H) Units Underwriter(s) or Distributor(s): Underwriter(s) or Distributor(s): Quadrus Investment Services Ltd. N/A Promoter(s): Promoter(s): Mackenzie Financial Corporation N/A Project #2813915 Project #3098198

______Issuer Name: Issuer Name: GreenWise Balanced Portfolio AGFiQ Global Balanced ETF Portfolio Fund GreenWise Conservative Portfolio AGFiQ Global Income ETF Portfolio Fund GreenWise Growth Portfolio Principal Regulator – Ontario Principal Regulator – Quebec Type and Date: Type and Date: Preliminary Simplified Prospectus dated Aug 12, 2020 Preliminary Simplified Prospectus dated Aug 10, 2020 NP 11-202 Preliminary Receipt dated Aug 13, 2020 NP 11-202 Preliminary Receipt dated Aug 12, 2020 Offering Price and Description: Offering Price and Description: Mutual Fund Series Units and Series F Units Class F Units, Class A Units and Class P Units Underwriter(s) or Distributor(s): Underwriter(s) or Distributor(s): N/A N/A Promoter(s): Promoter(s): N/A N/A Project #3095992 Project #3094128 ______

August 20, 2020 (2020), 43 OSCB 6679

IPOs, New Issues and Secondary Financings

Issuer Name: Issuer Name: Evolve Gold Miners Fund Ninepoint Diversified Bond Fund Principal Regulator – Ontario Ninepoint Energy Fund Type and Date: Ninepoint Global Infrastructure Fund Preliminary Long Form Prospectus dated Aug 17, 2020 Ninepoint Global Real Estate Fund NP 11-202 Preliminary Receipt dated Aug 17, 2020 Ninepoint Gold and Precious Minerals Fund Offering Price and Description: Ninepoint High Interest Savings Fund ETF Shares Ninepoint Alternative Health Fund Underwriter(s) or Distributor(s): Ninepoint International Small Cap Fund N/A Ninepoint Concentrated Canadian Equity Fund Promoter(s): Ninepoint Diversified Bond Class N/A Ninepoint Resource Class Project #3098175 Ninepoint Silver Equities Class Ninepoint Risk Advantaged U.S. Equity Index Class ______(formerly, Ninepoint Enhanced Equity Class) Issuer Name: Ninepoint Return Advantaged U.S. Equity Index Class Renaissance Canadian Balanced Fund (formerly, Ninepoint Enhanced U.S. Equity Renaissance Canadian Monthly Income Fund Class) Renaissance Canadian Growth Fund Ninepoint Focused Global Dividend Class Renaissance Canadian Equity Private Pool Ninepoint Gold Bullion Fund Renaissance Canadian Equity Private Pool Ninepoint Silver Bullion Fund Principal Regulator - Ontario Principal Regulator - Ontario Type and Date: Type and Date: Amendment #1 to Final Simplified Prospectus dated Amended and Restated to Final Simplified Prospectus August 6, 2020 dated August 7, 2020 NP 11-202 Final Receipt dated Aug 12, 2020 NP 11-202 Final Receipt dated Aug 12, 2020 Offering Price and Description: Offering Price and Description: Class A units, Class A (Pools) units, Class C units, Class F Series A Securities, Series D Securities, Series F units, Class F-Premium T4 units, Class F-Premium T6 Securities, Series FT Units, Series I Securities, Series P units, Class F-Premium units, Class I units, Class N- Units, Series PF Units, Series PFT Units, Series PT Units, Premium T4 units, Class N-Premium T6 units, Class N- Series Q Units, Series QF Units, Series QFT Units, Series Premium units, Class O units, Premium T4 Class units, QT Units, Premium class units and Premium-T6 Class units Series T Units Underwriter(s) or Distributor(s): Underwriter(s) or Distributor(s): N/A N/A Promoter(s): Promoter(s): N/A N/A Project #3071450 Project #3033523

______

August 20, 2020 (2020), 43 OSCB 6680

IPOs, New Issues and Secondary Financings

Issuer Name: Issuer Name: Canada Life North American Specialty Fund Fidelity Canadian Opportunities Fund Canada Life Canadian Dividend Fund (Laketon) Fidelity Dividend Fund Canada Life Canadian Value Fund (FGP) Fidelity Greater Canada Fund Canada Life Canadian Equity Fund (Beutel Goodman) Fidelity Special Situations Fund Canada Life Canadian Low Volatility Fund (London Capital) Fidelity American Equity Systematic Currency Hedged Principal Regulator - Ontario Fund Type and Date: Fidelity U.S. Focused Stock Fund Amendment #1 to Final Simplified Prospectus dated Fidelity U.S. Focused Stock Systematic Currency Hedged August 14, 2020 Fund NP 11-202 Final Receipt dated Aug 17, 2020 Fidelity Small Cap America Fund Offering Price and Description: Fidelity U.S. Dividend Fund D5 series securities, D8 series securities, H series Fidelity Women’s Leadership Fund securities, H5 series securities, H8 series securities, HW Fidelity Women’s Leadership Systematic Currency Hedged series securities, HW5 series securities, HW8 series Fund securities, L series securities, L5 series securities, L8 Fidelity AsiaStar® Fund series securities, N Fidelity Europe Fund series securities, N5 series securities, N8 series securities, Fidelity Global Fund Q series securities, QF series securities, QF5 series Fidelity Global Large Cap Fund securities, QFW series securities and QFW5 series Fidelity Global Concentrated Equity Fund securities Fidelity Global Concentrated Equity Currency Neutral Fund Underwriter(s) or Distributor(s): Fidelity Japan Fund N/A Fidelity NorthStar® Fund Promoter(s): (Series E5 units) N/A Fidelity International Growth Fund Project #3034790 Fidelity Global Monthly Income Fund Fidelity Tactical High Income Fund ______(Series E2T5 units) Issuer Name: Fidelity Conservative Income Fund CIBC Monthly Income Fund (Series E1T5 units) CIBC Global Monthly Income Fund Fidelity Global Balanced Portfolio CIBC Balanced Fund Fidelity Growth Portfolio Principal Regulator - Ontario Fidelity Global Growth Portfolio Type and Date: Fidelity ClearPath® 2005 Portfolio Amendment #1 to Final Simplified Prospectus dated Fidelity ClearPath® 2015 Portfolio August 6, 2020 Fidelity ClearPath® 2020 Portfolio NP 11-202 Final Receipt dated Aug 12, 2020 Fidelity ClearPath® 2025 Portfolio Offering Price and Description: Fidelity ClearPath® 2035 Portfolio Class A units, Class F units, Class O units Fidelity ClearPath® 2045 Portfolio Underwriter(s) or Distributor(s): Fidelity ClearPath® Income Portfolio N/A Fidelity Corporate Bond Fund Promoter(s): Fidelity Canadian Short Term Bond Fund N/A Fidelity Tactical Fixed Income Fund Project #3052709 Fidelity U.S. Money Market Fund Fidelity Floating Rate High Income Fund ______Fidelity Strategic Income Fund Fidelity Global Bond Fund Principal Regulator - Ontario Type and Date: Amendment #5 to Final Simplified Prospectus and Amendment #7 to AIF dated July 31, 2020 NP 11-202 Final Receipt dated Aug 12, 2020 Offering Price and Description: Series A units, Series B units, Series E1 units, Series E1T5 units, Series E2 units, Series E2T5 units, Series E3 units, Series E3T5 units, Series E4 units, Series E4T5 units, Series E5 units, Series F units, Series F5 units, Series F8 units, Series O units, Series P1 units, Series P1T5 units, Series P2 units, Series P2T5 units, Series P3 units, Series P3T5 units, Series P4 units, Series P4T5 units, Series P5 units, Series P5T5 units, Series S5 units, Series S8 units, Series T5 units and Series T8 units Underwriter(s) or Distributor(s):

August 20, 2020 (2020), 43 OSCB 6681

IPOs, New Issues and Secondary Financings

N/A Issuer Name: Promoter(s): Imperial Canadian Equity Pool N/A Imperial U.S. Equity Pool Project #2967181 Principal Regulator - Ontario Type and Date: ______Amendment #2 to Final Simplified Prospectus dated Issuer Name: August 6, 2020 Fidelity Greater Canada Class NP 11-202 Final Receipt dated Aug 12, 2020 Fidelity True North® Class Offering Price and Description: Fidelity North American Equity Class Class A Units Fidelity U.S. Focused Stock Class Underwriter(s) or Distributor(s): Fidelity Small Cap America Class N/A Fidelity U.S. Growth Opportunities Class Promoter(s): Fidelity U.S. Growth Opportunities Systematic Currency N/A Hedged Class Project #2979153 Fidelity China Class Fidelity Emerging Markets Class ______(Series P3 shares) Fidelity Global Class Fidelity Global Disciplined Equity® Currency Neutral Class Fidelity Global Large Cap Class Fidelity International Disciplined Equity® Class Fidelity International Disciplined Equity® Currency Neutral Class Fidelity NorthStar® Class Fidelity NorthStar® Currency Neutral Class Fidelity Insights Currency Neutral Class Fidelity Global Growth, Value Currency Neutral Class Fidelity Global Real Estate Class Principal Regulator - Ontario Type and Date: Amendment #2 to Final Simplified Prospectus and Amendment #3 to AIF dated July 31, 2020 NP 11-202 Final Receipt dated Aug 12, 2020 Offering Price and Description: Series A shares, Series B shares, Series E1 shares, Series E1T5 shares, Series E2 shares, Series E2T5 shares, Series E3 shares, Series E3T5 shares, Series E4 shares, Series E4T5 shares, Series E5 shares, Series F shares, Series F5 shares, Series F8 shares, Series P1 shares, Series P1T5 shares, Series P2 shares, Series P2T5 shares, Series P3 shares, Series P3T5 shares, Series P4 shares, Series P4T5 shares, Series P5 shares, Series P5T5 shares, Series S5 shares, Series S8 shares, Series T5 shares and Series T8 shares Underwriter(s) or Distributor(s): N/A Promoter(s): N/A Project #3018443

______

August 20, 2020 (2020), 43 OSCB 6682

IPOs, New Issues and Secondary Financings

NON-INVESTMENT FUNDS

Issuer Name: Issuer Name: Atlantic Power Corporation Boralex Inc. Principal Regulator - Ontario Principal Regulator - Quebec Type and Date: Type and Date: Preliminary Shelf Prospectus dated August 12, 2020 Preliminary Short Form Prospectus dated August 14, 2020 NP 11-202 Preliminary Receipt dated August 13, 2020 NP 11-202 Preliminary Receipt dated August 14, 2020 Offering Price and Description: Offering Price and Description: US$250,000,000.00 $175,032,800.00 Common Shares 5,288,000 Common Shares Debt Securities Price: $33.10 per Common Share Warrants Underwriter(s) or Distributor(s): Subscription Receipts NATIONAL BANK FINANCIAL INC. Units CIBC WORLD MARKETS INC. Underwriter(s) or Distributor(s): RBC DOMINION SECURITIES INC. - TD SECURITIES INC. Promoter(s): DESJARDINS SECURITIES INC. - BMO NESBITT BURNS INC. Project #3096372 INDUSTRIAL ALLIANCE SECURITIES INC. RAYMOND JAMES LTD. ______SCOTIA CAPITAL INC. Issuer Name: Promoter(s): Auxly Cannabis Group Inc. - Principal Regulator - Ontario Project #3095345 Type and Date: Amendment dated August 10, 2020 to Preliminary Shelf ______Prospectus dated May 13, 2020 Issuer Name: NP 11-202 Preliminary Receipt dated August 11, 2020 Docebo Inc. Offering Price and Description: Principal Regulator - Ontario $50,000,000.00 Type and Date: COMMON SHARES Preliminary Short Form Prospectus dated August 17, 2020 PREFERRED SHARES NP 11-202 Preliminary Receipt dated August 17, 2020 DEBT SECURITIES Offering Price and Description: SUBSCRIPTION RECEIPTS $75,000,000.00 WARRANTS 1,500,000 Common Shares UNITS Price: $50.00 per Common Share Underwriter(s) or Distributor(s): Underwriter(s) or Distributor(s): - CANACCORD GENUITY CORP. Promoter(s): TD SECURITIES INC. - MORGAN STANLEY CANADA LIMITED Project #3057964 GOLDMAN SACHS CANADA INC. SCOTIA CAPITAL INC. ______NATIONAL BANK FINANCIAL INC. CIBC WORLD MARKETS INC. CORMARK SECURITIES INC. EIGHT CAPITAL Promoter(s): - Project #3095532

______

August 20, 2020 (2020), 43 OSCB 6683

IPOs, New Issues and Secondary Financings

Issuer Name: Issuer Name: Enthusiast Gaming Holdings Inc. (formerly J55 Capital and Gaming Inc. (formerly theScore, Inc.) Corp.) Principal Regulator - Ontario Principal Regulator - Ontario Type and Date: Type and Date: Preliminary Short Form Prospectus dated August 11, 2020 Preliminary Short Form Prospectus dated August 12, 2020 NP 11-202 Preliminary Receipt dated August 11, 2020 NP 11-202 Preliminary Receipt dated August 13, 2020 Offering Price and Description: Offering Price and Description: $25,025,000.00 $15,000,000.00 - 10,000,000 Common Shares 38,500,000 Class A Subordinate Voting Shares Price of $1.50 per Common Share Underwriter(s) or Distributor(s): Underwriter(s) or Distributor(s): CANACCORD GENUITY CORP. CANACCORD GENUITY CORP. EIGHT CAPITAL PARADIGM CAPITAL INC. CORMARK SECURITIES INC. HAYWOOD SECURITIES INC. INFOR FINANCIAL INC. Promoter(s): SCOTIA CAPITAL INC. - Promoter(s): Project #3096381 - Project #3093452 ______Issuer Name: ______Hapbee Technologies, Inc. Issuer Name: Principal Regulator - British Columbia VSBLTY Groupe Technologies Corp. Type and Date: Principal Regulator - British Columbia Preliminary Long Form Prospectus dated August 13, 2020 Type and Date: NP 11-202 Preliminary Receipt dated August 13, 2020 Preliminary Short Form Prospectus dated August 10, 2020 Offering Price and Description: NP 11-202 Preliminary Receipt dated August 11, 2020 21,655,908 Units Offering Price and Description: Issuable on Conversion of Outstanding Debentures Minimum Public Offering: $3,500,000.00 / 29,166,666 Units Underwriter(s) or Distributor(s): Maximum Public Offering: $6,000,000.00 / 50,000,000 - Units Promoter(s): Price: $0.12 per Unit Scott Donnell Underwriter(s) or Distributor(s): Project #3096701 ECHELON WEALTH PARTNERS INC. EIGHT CAPITAL ______Promoter(s): Issuer Name: - Hydro One Limited Project #3094639 Principal Regulator - Ontario Type and Date: ______Preliminary Shelf Prospectus dated August 12, 2020 NP 11-202 Preliminary Receipt dated August 12, 2020 Offering Price and Description: $2,000,000,000.00 Common Shares Preferred Shares Debt Securities Subscription Receipts Warrants Units Underwriter(s) or Distributor(s): - Promoter(s): - Project #3095845

______

August 20, 2020 (2020), 43 OSCB 6684

IPOs, New Issues and Secondary Financings

Issuer Name: Issuer Name: Neovasc Inc. Reconnaissance Energy Africa Ltd. Principal Regulator - British Columbia Principal Regulator - British Columbia Type and Date: Type and Date: Final Shelf Prospectus dated August 12, 2020 Final Short Form Prospectus dated August 12, 2020 NP 11-202 Receipt dated August 13, 2020 NP 11-202 Receipt dated August 12, 2020 Offering Price and Description: Offering Price and Description: U.S.$100,000,000.00 Minimum Offering: $6,000,000.00 (8,571,428 Units) Common Shares Maximum Offering: $22,000,000.00 (31,428,571 Units) Preferred Shares Underwriter(s) or Distributor(s): Debt Securities HAYWOOD SECURITIES INC. Subscription Receipts Promoter(s): Units - Warrants Project #3091128 Underwriter(s) or Distributor(s): - ______Promoter(s): Issuer Name: - RIOCAN REAL ESTATE INVESTMENT TRUST Project #3087357 Principal Regulator - Ontario Type and Date: ______Final Shelf Prospectus dated August 10, 2020 Issuer Name: NP 11-202 Receipt dated August 11, 2020 Nextech AR Solutions Corp. Offering Price and Description: Principal Regulator - British Columbia $3,000,000,000.00 Type and Date: Debt Securities (Senior Unsecured) Final Short Form Prospectus dated August 12, 2020 Units NP 11-202 Receipt dated August 13, 2020 Preferred Units Offering Price and Description: Underwriter(s) or Distributor(s): Up to $15,000,000.00 - 2,307,692 Units - Price: $6.50 per Unit Promoter(s): Underwriter(s) or Distributor(s): - Mackie Research Capital Corporation Project #3090171 Promoter(s): - ______Project #3086172 Issuer Name: TFI International Inc. ______Principal Regulator - Quebec Issuer Name: Type and Date: Padlock Partners UK Fund I Amendment dated August 11, 2020 to Final Shelf Principal Regulator - Ontario Prospectus dated October 12, 2018 Type and Date: NP 11-202 Receipt dated August 11, 2020 Final Long Form Prospectus dated August 13, 2020 Offering Price and Description: NP 11-202 Receipt dated August 13, 2020 $1,000,000,000.00 Offering Price and Description: Common Shares Minimum: $15,000,000.00 of Class A Units, Class F Units, Preferred Shares Class C Units and/or Class U Units Subscription Receipts Maximum: $40,000,000.00 of Class A Units, Class F Units, Warrants Class C Units and/or Class U Units Debt Securities Underwriter(s) or Distributor(s): Units CIBC WORLD MARKETS INC. Underwriter(s) or Distributor(s): RICHARDSON GMP LIMITED - CANACCORD GENUITY CORP. Promoter(s): NATIONAL BANK FINANCIAL INC. - RAYMOND JAMES LTD. Project #2828913 Promoter(s): PADLOCK CAPITAL PARTNERS, LLC ______Project #3081966

______

August 20, 2020 (2020), 43 OSCB 6685

IPOs, New Issues and Secondary Financings

Issuer Name: Treasury Metals Inc. Principal Regulator - Ontario Type and Date: Final Short Form Prospectus dated August 13, 2020 NP 11-202 Receipt dated August 14, 2020 Offering Price and Description: 10,666,666 Common Shares and 5,333,333 Warrants Issuable upon Conversion of 32,000,000 Subscription Receipts Underwriter(s) or Distributor(s): HAYWOOD SECURITIES INC. PI FINANCIAL CORP. SPROTT CAPITAL PARTNERS LP CANACCORD GENUITY CORP. Promoter(s): - Project #3085002 ______

August 20, 2020 (2020), 43 OSCB 6686

Chapter 12

Registrations

12.1.1 Registrants

Type Company Category of Registration Effective Date

New Registration C.S.T. Asset Management Portfolio Manager August 12, 2020 Inc.

Firm Name Change From: VectorGlobal IAG Portfolio Manager August 16, 2019 Canada Inc.

To: VectorGlobal Investment Advisory Group Canada Inc.

Firm Name Change From: VectorGlobal Portfolio Manager August 16, 2019 Investment Advisory Group Canada Inc.

To: VectorGlobal Investment Advisory Group Canada ULC

Firm Name Change From: Equinox Investment Portfolio Manager February 18, 2020 Management Ltd.

To: PSC Investment Counsel Ltd.

Change in Registration First Affiliated Securities Inc. From: Mutual Fund Dealer August 13, 2020 Category and Exempt Market Dealer

To: Exempt Market Dealer

Change in Registration Forstrong Global Asset From: Portfolio Manager August 13, 2020 Category Management Inc. To: Portfolio Manager, Exempt Market Dealer and Investment Fund Manager

August 20, 2020 (2020), 43 OSCB 6687

Registrations

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August 20, 2020 (2020), 43 OSCB 6688

Chapter 13

SROs, Marketplaces, Clearing Agencies and Trade Repositories

13.2 Marketplaces

13.2.1 Canadian Securities Exchange – 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”) 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 CSE 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

Regular Hours Only (RHO) Option

CSE is proposing an RHO option on orders. The RHO option can be added to any order to restrict trading to the Primary Market regular trading hours for the security (which are typically between 09:30 AM and 4:00 PM), with "Primary Market" meaning the exchange on which a security is listed.

• RHO orders entered before the Primary Market open are queued until the Primary Market open occurs (“release time”).

• RHO orders do not participate in the opening match or CSE Closing Price Session (CCP).

• RHO orders expire from the order book at the Primary Market close of the security (“expiry time”).

• Between the release time and expiry time, orders marked RHO do not change their designated behaviour and will execute accordingly.

• The RHO option can be applied to all CSE-supported order types (including on-stops and Icebergs).

• With the exception of oddlot and special term orders, any orders with the RHO option that are entered before the Primary Market open will be defaulted to OPR Reject/Cancel if no other OPR instructions are present.

• When the RHO option orders are released from the queue at the Primary Market open, the integrity of price/time priority is maintained with the orders already present in the order book and with the queued orders relative to each other based on time of receipt. Orders entered before the queue release will maintain higher time priority than the queued orders.

Below is an example of a queue release at 9:30 AM to demonstrate price/time priority is maintained.

Visible order book just prior to 9:30AM, (prior to the release of RHO Orders)

Order Type Volume Bid Price Offer Price Volume Order Type

Non-RHO 100 10.00 10.01 100 Non-RHO Order Order

Non-RHO 100 10.00 10.02 100 Non-RHO Order Order

August 20, 2020 (2020), 43 OSCB 6689

SROs, Marketplaces, Clearing Agencies and Trade Repositories

Non-RHO 100 9.99 Order

There is an RHO Order to buy 100 shares at 10.00 in the release queue.

Visible order book after 9:30AM (following the release of RHO orders)

Order Type Volume Bid Price Offer Price Volume Order Type

Non-RHO 100 10.00 10.01 100 Non-RHO Order Order

Non-RHO 100 10.00 10.02 100 Non-RHO Order Order

RHO Order 100 10.00

Non-RHO 100 9.99 Order

The RHO Order at 10.00 gets time priority behind the other two bids at 10.00 but gets price priority ahead of the bid at 9.99.

The two non-RHO bids at 10.00 that were in the book would at this point get filled before the released RHO order.

B. Expected Implementation Date: Q4, 2020

C. Rationale and Analysis

CSE is proposing the addition of the RHO order at the request of clients who would like the option to execute other listed securities on the CSE, but only during the Primary Market trading hours.

D. Expected Impact

CSE does not anticipate any adverse impact. The proposed changes are in response to customer requests. The use of this feature is optional. Customers would expend minimal effort to include one new value for the "Time-in-Force" order entry tag. Customers wishing to make greater use of the feature through more elaborate implementations would expend additional effort.

E. Compliance with Ontario and British Columbia Securities Law

There will be no impact on the CSE’s compliance with Ontario and British Columbia securities law. The changes will not adversely affect fair access or the maintenance of fair and orderly markets. The changes are consistent with the fair access requirements set out in section 5.1 of NI21-101 as they are not confined to a limited number of marketplace participants and all marketplace participants will remain subject to the same rules and conditions.

F. Technology Changes

Clients already support a similar feature (to the one proposed) on another Canadian marketplace. CSE does not anticipate there will be any need for material technology changes.

G. Other Markets or Jurisdictions

The table below identifies where the proposed functionality is currently available in Canada:

ORDER TYPE MARKETS AVAILABLE Regular Hours Only (RHO) Order Type NEO

MEMX and CBOE also provide an RHO order type.

August 20, 2020 (2020), 43 OSCB 6690

SROs, Marketplaces, Clearing Agencies and Trade Repositories

Comments

Please submit comments on the proposed amendments no later than September 23, 2020 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 20, 2020 (2020), 43 OSCB 6691

SROs, Marketplaces, Clearing Agencies and Trade Repositories

13.3 Clearing Agencies

13.3.1 Canadian Derivatives Clearing Corporation (CDCC) – Proposed Amendments to the Rules of CDCC with Respect to the CGZ Futures Contract – OSC Staff Notice of Request for Comment

OSC STAFF NOTICE OF REQUEST FOR COMMENT

CANADIAN DERIVATIVES CLEARING CORPORATION (CDCC)

PROPOSED AMENDMENTS TO THE RULES OF CDCC WITH RESPECT TO THE CGZ FUTURES CONTRACT

The Ontario Securities Commission is publishing for public comment the proposed amendments to the CDCC Rules with respect to the Two-Year Government of Canada bond futures (“CGZ”) contract.

The purpose of the proposed amendments is to modify the nominal value of the CGZ futures from C$200,000 to C$100,000 of Government of Canada bonds with a 6% notional coupon.

The comment period ends on September 18, 2020.

A copy of the CDCC Notice is published on our website at http://www.osc.gov.on.ca.

August 20, 2020 (2020), 43 OSCB 6692

Index

Alchemist Mining Incorporated Equinox Investment Management Ltd. Revocation Order ...... 6568 Firm Name Change ...... 6687

Alli, Nayeem ESW Capital, LLC Notice from the Office of the Secretary ...... 6534 Notice of Hearing – s. 104 ...... 6533 Order ...... 6569 Notice from the Office of the Secretary ...... 6534

Aziz, Maurice First Affiliated Securities Inc. Notice from the Office of the Secretary ...... 6534 Change in Registration Category ...... 6687 Order ...... 6569 First Global Data Ltd. Bajaj, Harish Notice from the Office of the Secretary ...... 6534 Notice from the Office of the Secretary ...... 6534 Order ...... 6569 Order ...... 6569 Forstrong Global Asset Management Inc. C.S.T. Asset Management Inc. Change in Registration Category ...... 6687 New Registration ...... 6687 Georgeson Shareholder Communications Canada Inc. Canada Cannabis Corporation Decision ...... 6543 Notice from the Office of the Secretary ...... 6535 Global Bioenergy Resources Inc. Canadian Cannabis Corporation Notice from the Office of the Secretary ...... 6534 Notice from the Office of the Secretary ...... 6535 Order ...... 6569

Canadian Derivatives Clearing Corporation Horizons Absolute Return Global Currency ETF Clearing Agencies – Proposed Amendments to Order ...... 6570 the Rules of CDCC with Respect to the CGZ Futures Contract – OSC Staff Notice of Request Horizons ETFS Management (Canada) Inc. for Comment ...... 6692 Order ...... 6570

Canadian Securities Exchange Horizons Morningstar Hedge Fund Index ETF Marketplaces – Amendments to Trading System Order ...... 6570 Functionality & Features – Notice and Request for Comment ...... 6689 iAnthus Capital Holdings, Inc. Cease Trading Order ...... 6581 CDCC Clearing Agencies – Proposed Amendments to Itwaru, Andre the Rules of CDCC with Respect to the CGZ Notice from the Office of the Secretary ...... 6534 Futures Contract – OSC Staff Notice of Request Order ...... 6569 for Comment ...... 6692 Joint CSA/IIROC Staff Notice 23-327 Update on Companion Policy 51-102CP Continuous Disclosure Internalization within the Canadian Equity Market Obligations Notice ...... 6504 Notice ...... 6491 King Global Ventures Inc. Companion Policy to National Instrument 41-101 Cease Trading Order ...... 6581 General Prospectus Requirements Notice ...... 6491 Lendified Holdings Inc. Partial Revocation Order ...... 6572 Companion Policy to National Instrument 44-101 Short Form Prospectus Distributions Mercer Global Investments Canada Limited Notice ...... 6491 Decision ...... 6562

Debus, Joseph National Instrument 51-102 Continuous Disclosure Notice from the Office of the Secretary ...... 6535 Obligations Reasons for Decision ...... 6577 Notice ...... 6491

August 20, 2020 (2020), 43 OSCB 6693

Index

Ninepoint Partners LP VectorGlobal Investment Advisory Group Canada ULC Decision ...... 6565 Firm Name Change ...... 6687

Optiva Inc. Ward, Benjamin Notice of Hearing – s. 104...... 6533 Notice from the Office of the Secretary ...... 6535 Notice from the Office of the Secretary ...... 6534 Wealthsimple Digital Assets Inc. Performance Sports Group Ltd. Decision ...... 6548 Cease Trading Order ...... 6581

Picton Mahoney Asset Management Decision ...... 6537

Picton Mahoney Fortified Active Extension Alternative Fund Decision ...... 6537

Picton Mahoney Fortified Arbitrage Alternative Fund Decision ...... 6537

Picton Mahoney Fortified Arbitrage Plus Alternative Fund Decision ...... 6537

Picton Mahoney Fortified Income Alternative Fund Decision ...... 6537

Picton Mahoney Fortified Market Neutral Alternative Fund Decision ...... 6537

Picton Mahoney Fortified Multi Strategy Alternative Fund Decision ...... 6537

PSC Investment Counsel Ltd. Firm Name Change ...... 6687

RYU Apparel Inc. Cease Trading Order ...... 6581

Serrano, Silvio Notice from the Office of the Secretary ...... 6535

Start-up Crowdfunding Guide for Businesses Rules and Policies ...... 6583

Start-up Crowdfunding Guide for Funding Portals Rules and Policies ...... 6593

Start-up Crowdfunding Guide for Investors Rules and Policies ...... 6600

Strang, Peter Notice from the Office of the Secretary ...... 6535

VectorGlobal IAG Canada Inc. Firm Name Change ...... 6687

VectorGlobal Investment Advisory Group Canada Inc. Firm Name Change ...... 6687

August 20, 2020 (2020), 43 OSCB 6694