Legal Information Canada

The information provided on this site or in any communication containing a link to this site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Euro Pacific Canada Inc. or its affiliates to any registration requirement within such jurisdiction or country. Neither the information, nor any opinion contained in this site constitutes a solicitation or offer by Euro Pacific Canada Inc. or its affiliates to buy or sell any securities or other financial instruments or provide any investment advice or service.

Safety of Assets
Euro Pacific Canada’s Business Continuity Planning Disclosure Statement
Leverage Disclosure Statement
Unclaimed Property and Assets Policy
Securities Trading on Multiple Marketplaces
Complaint Handling Procedure
Research Dissemination Policy
Use of Website Disclaimer

Safety of your Assets
At Euro Pacific Canada safe custody of your assets is secured through our participation as a member firm in the Investment Industry Regulatory Organization of Canada (IIROC) and as a member of the Canadian Investor Protection Fund. We are a type II Introducing Broker and have chosen Fidelity Clearing Canada ULC as custodian of all client assets. Fidelity has a deep history in the financial services industry in the United States and Canada.

Canadian Investor Protection Fund
Euro Pacific Canada Inc. is a member of the Investment Industry Regulatory Organization of Canada (IIROC) and therefore all funds invested with us are covered by the Canadian Investor Protection Fund. (CIPF). CIPF insures your funds against loss in the case of the insolvency or bankruptcy of an IIROC member firm. The CIPF guarantees your general accounts for up to $1 million. Registered Retirement accounts (RRSP, RRIF, LIRA, LIF) have a separate $1 million in coverage. Other accounts (ESP, trust) also benefit from their own separate $1 million in coverage. Please consult a Euro Pacific Canada Consultant for more details on CIPF coverage.

For more information about the Canadian Investor Protection Fund, please visit www.cipf.ca.

Asset Segregation
Fully paid securities are secure from all creditor claims in the unlikely event of insolvency. These securities are in fact kept in a separate secure location from all securities held by our firm and Euro Pacific Canada requires your explicit consent for any access to these securities. Regular independent audits by National audit firms, ensure segregation protocol is rigourosly followed.

Our Custodian
Fidelity Clearing Canada ULC is our custodian and responsible for the safe custody of your assets. Fidelity manages over $56 billion in mutual fund and corporate pension plan assets ($CAD, as at March 31, 2010).

Fidelity Investments has had a presence in Canada for more than 20 years, and Fidelity Clearing Canada's executive team brings you an average of 25 years in the Canadian financial services industry. Fidelity Clearing Canada is part of Fidelity's U.S.-based clearing organization, National Financial.

$3.2 trillion in total custodied assets
74.4 million customer accounts
Serves more than 5,000 financial intermediaries
Processes nearly 1 million daily trades
Nearly 30 years of service as a leading clearing provider

For more information about Fidelity Investments Canada ULC, please visit www.fidelity.ca.

How Margin Works

If we open a margin account for you, Fidelity Clearing Canada ULC ("Fidelity") will loan you money for the purpose of purchasing or holding securities subject to the terms of Fidelity and Euro Pacific Canada Inc. ("Euro Pacific Canada") Margin and Client Account Agreement. All margin loans are backed by the value of the securities in your accounts. If you were unable to pay Fidelity back the money loaned, Fidelity would sell the securities held by you to cover the loan balance. Since Fidelity, and not Euro Pacific Canada, advances the margin loan and holds the collateral securities, access to the collateral securities are managed solely by Fidelity.

RRSPs Shielded by The Royal Trust Co.
RBC Royal Bank of Canada

Euro Pacific Canada has their registered accounts shielded by The Royal Trust Co. Assets you hold at Euro Pacific Canada in RRSP, RRIF, RESP or TFSA accounts are in the safe custody of The Royal Trust Co., trustee for our registered plans and part of a $20 billion banking group. Registered accounts are separately eligible CIPF coverage.

For more information about the Canadian Investor Protection Fund, please visit www.rbc.com.

Euro Pacific Canada’s Business Continuity Planning Disclosure Statement
Euro Pacific Canada Inc. has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us
If after a significant business disruption you cannot contact us as you usually do at 416-649-4273, you should call our alternative number 888-216-9779 or go to our web site at www.europac.ca. Our clearing Firm is: Fidelity Clearing Canada ULC (“Fidelity”), 483 Bay Street, Suite 200, Toronto Ontario, M5G 2N7. If after a significant business disruption you cannot contact us through any of the means listed above, you should contact Fidelity Clearing Canada ULC at 416-216-2600 or http://clearingcanada.fidelity.com/ for instructions on how Fidelity may provide prompt access to funds, securities, entering orders and process trade-related cash and security transfer transactions.

Our Business Continuity Plan
We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our clearing firm, Fidelity Clearing Canada ULC, backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within one business day. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions
Significant business disruptions can vary in their scope such as impacting only our Firm, the building housing our Firm, the business district where our Firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe, we will transfer our operations to a local site when needed and expect to recover and resume business within 24 hours. In a disruption affecting our business district, city or region, we will transfer operations to our clearing firm if necessary, and notify you through our website www.europac.ca or our automated attendant at 416-649-4273 how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

For more information
If you have any questions about our business continuity planning, you can contact us at 416-649-4273 or www.europac.ca.

Leverage Disclosure Statement

Mutual Fund units and other securities may be purchased using available cash, or a combination of cash and borrowed money. If cash is used to pay for the purchase in full, the percentage gain or loss will equal the percentage increase or decrease in the value of the securities. The purchase of the securities using borrowed money magnifies the gain or loss on the cash invested. This effect is called leveraging.

For example, if $100,000 of mutual fund units are purchase and paid for with $25,000 from available cash and $75,000 from borrowings, and the value of the fund units declines by 10% to $90,000, your equity interest (the difference between the value of the securities and the amount borrowed) has declined by 40%, i.e. from $25,000 to $15,000.

It is important that an investor proposing to borrow for the purchase of securities be aware that a leveraged purchase involves greater risk than a purchase using cash resources only.

To what extent a leveraged purchase involves undue risk is a determination to be made by each purchase and will vary depending on the circumstances of the purchase and the securities purchased.

Financial resources required for leveraged investments

It is also important that you be aware of the terms of a loan secured by securities. The lender may require that the amount outstanding on the loan not rise above an agreed percentage of the market value of the securities. Should this occur, the borrower must pay down the loan or sell the securities so as to return the loan to the agreed percentage relationship. In our example above, the lender may require that the loan not exceed 75% of the market value of the mutual fund units. On a decline in value of the units to $90,000 the borrower must reduce the loan to $67,500 (75% of $90,000). If the borrower does not have cash available, the borrower must sell units at a loss to provide money to reduce the loan.

Money is, of course, also required to pay interest on the loan. Under these circumstances, investors who leverage their investment are advised to have adequate financial resources available both to pay interest and also to reduce the loan if the borrowing arrangements require such a payment.

Unclaimed Property and Assets Policy

Euro Pacific Canada Inc. makes reasonable effort to locate owners of unclaimed property. Euro Pacific Canada Inc. will use reasonable efforts to locate a client for six months. Reasonable efforts include one or more of (i) using on-line resources to locate the client; (ii) reviewing other Euro Pacific Canada Inc. accounts related or connected to the client that may have different contact particulars; and/or (iii) attempting to contact the client by telephone and e-mail at the clients last known telephone or e-mail address, as applicable. If the client has not been located within 12 months, the property will be designated as unclaimed.

Euro Pacific Canada Inc. must be satisfied of any claimant's identity and entitlement to any funds prior to releasing such funds. Therefore, all claims must be submitted to Euro Pacific Canada Inc. in writing and any claimant must provide at least two pieces of identification, at least one of which is photo ID. Such documentation must establish the name, signature and date of birth of the claimant. Proof of Social Insurance Number must also be obtained. All claimants will be requested to provide an adequate description of the account’s operation, including but not limited to, the date the account was opened, the type of account, the approximate value of account and trading activity, all of which will be reviewed against the account’s history. All claimants must complete an indemnity agreement prior to release of funds to such claimant.

If you believe you are an owner or a beneficiary of unclaimed property held at Euro Pacific Canada Inc., please send inquiries or claims in writing to:

Euro Pacific Canada Inc.
Attention: Compliance Department- Unclaimed Property
1501 Mc Gill College Avenue
Suite 1450
Montreal, Quebec H3A 3M8

Securities Trading on Multiple Marketplaces

The Canadian capital markets have recently evolved with the emergence of several Alternate Trading Systems (ATS) and other marketplaces which improve liquidity and provide competitive pricing to the TSX, the predominant marketplace for Canadian securities. As our client, you should be aware how we send orders to each marketplace and, further, how various order types are handled.

For the purposes of this policy, the primary marketplace for all securities listed on the Toronto Stock Exchange (TSX), whether or not the security is trading on other alternate marketplaces, will be the TSX. The TSX operates between 9:30 am (Toronto local time) and 4:00 PM (Toronto local time), Monday through Friday, not including statutory Ontario holidays. For the purposes of this policy all references to time are references to Toronto local time.

Our trading staff will be available for order execution during principal marketplaces hours. While our trading staff may also be available outside of principal marketplace hours, we will not guarantee order taking and/or trading execution outside of the hours of 9:30 am to 4:00 pm.

Order Handling

An order received prior to the opening of the principal market (9:30 am) will book to the pre-opening of the principal marketplace for execution on the opening as these orders will not route to an alternate marketplace.
An order received after the principal marketplace close (4:00 pm) will be entered to the pre-opening of the principal marketplace on the next business day as these orders will not route to an alternate marketplace.
An order received during principal marketplace operating hours will be entered immediately into the trading system and will be automatically routed to the marketplace with the best bid (in the case of a buy) or best ask (in the case of a sell) or a marketplace that has the highest probability of execution.
Any portion of an order that cannot be immediately filled will be booked to the principal marketplace and will remain booked in the principal marketplace until the order is filled, expired, changed or cancelled.

It is important to note that certain types of orders may be handled differently based on the emergence of multiple marketplaces. Accordingly, a description of how each type of order will be handled has been included below.

Market Orders

A Market Order is an order to buy or sell a security at whatever prices are available in the marketplace to help ensure a complete and full fill. These orders require immediate completion when entered on the marketplace. If not filled in full, these orders will expire on the marketplace where the last portion of the order remains live, at the close of that marketplace.

Day Orders A“Day Order” is only valid for the day on which it was entered. Day Orders will only be valid between the hours of 9:30 AM to 4:00 PM.

Good Till Cancelled Orders
Good Till Cancelled Orders will be entered into the principal marketplace. The order will remain in the principal marketplace until execution or expiry (whichever comes first) and Good Till Cancelled Orders will only last for a maximum of 30-calendar-days. The client is required to contact us if they require the order to be re-instated after the 30- calendar-day period has lapsed.

All or Nothing Orders
In a multiple marketplace environment, an All or Nothing order may not be executed due to limited volume on more than one marketplace. While the total volume on all marketplaces might complete the order, it is important to note that the All or Nothing terms apply only to the individual marketplace where the order was entered.
An All or Nothing orders received prior to the opening of the principal marketplace will be booked on the principal marketplace and routed to the best market at the time of order entry (ie. the marketplace with the best bid (in the case of a buy) or best ask (in the case of a sell) or a marketplace that has the highest probability of execution.

Special Terms Orders
Special Terms Orders are orders with specific terms that are not executable in the regular marketplace. Special Terms Order will only post to the Special Terms Market of the principal marketplace unless they are immediately executable on an alternate marketplace at the time of entry; they will expire at the close of the principal marketplace.

Stop Loss Orders
Stop Loss Orders will only be directed to the principal marketplace until executed or expiry, whichever comes first.

Trade Confirmations
As your orders may be sent to multiple marketplaces for execution you may, at times, receive a trade confirmation which indicates that your order has been executed on multiple marketplaces and details of each execution are available upon request. In these cases, you have the right to contact us and obtain information about each fill including the marketplace on which that fill was obtained.

Complaint Handling Procedure

The following outlines Euro Pacific Canada's policies and procedures for dealing with complaints.

A "complaint" is deemed to include an alleged grievance involving Euro Pacific Canada or an employee.

Examples of a complaint may include:

(a) Any written statement, including email or fax, of a client, or any person acting on behalf of a client;

(b) Any written or verbal statement from any person alleging: theft, fraud, misappropriation of funds or securities, forgery, money laundering, market manipulation, insider trading, misrepresentation, or unauthorized trading;

Complaints should be sent/ directed to:

1501 Mc Gill College Avenue
Suite 1450
Montreal, Quebec H3A 3M8
Direct: 514.940.5096
Facsimile: 514.375.1306
peter.sousaris@europac.ca

The following process has been put in place relating to the handling of client complaints:

1. If the complaint (written or verbal) is deemed to be "service–related", the complaint may be handled directly by the applicable Euro Pacific Canada supervisor or manager. All securities-related, complaints are handled by the Designated Complaints officer or by qualified Compliance staff.

2. Upon receipt of a verbal statement, if the complaint is deemed to be "regulatory-related" Euro Pacific Canada will request that the client or individual (or person lawfully acting on behalf of the client or individual) provide particulars of the complaint to Euro Pacific Canada in writing. Euro Pacific Canada's request for a written complaint may be made verbally or in writing.

3. Upon receipt of a written or verbal complaint Euro Pacific Canada's Compliance Department will immediately record the complaint in the internal compliance complaint log; and send the complaint acknowledgment letter within five (5) business days of receipt of the complaint.

4. The compliance department will contact the individuals involved in the complaint and, where appropriate and/or possible, request their information and documentation relating to the matter. Where the complaint involves allegations of serious misconduct or is a legal action, Euro Pacific Canada's Compliance Department will ensure senior management is aware of the complaint.

5. Euro Pacific Canada's Compliance Department will begin its investigation of the allegations raised in the complaint and communicate the findings/results within 90 days of receipt of the written complaint. With respect to the investigation, Euro Pacific Canada's Compliance Department will gather the facts, information and documentation in order to properly analyze and consider the complaint.

6. Once the investigation has been completed, the response letter will be prepared. Depending on the nature of the complaint, the response will be reviewed by the Designated Compliance Officer and/or Euro Pacific Canada's legal Counsel if deemed necessary.

"Service–related" complaints are those complaints which are founded on customer service issues and which are not the subject of:
-any legislation or law concerning securities or exchange contracts of any jurisdictions, inside or outside of Canada; or
- by-laws, rules, regulations, rulings or policies of any securities or financial services regulatory or self-regulatory organization in any jurisdiction.

"Regulatory–related" complaints are those complaints concerning:
(i) any matter related to securities or exchange contracts;
(ii) any matter related to the handling of client accounts or dealings with clients;
(iii) any matter that is the subject of any legislation or law concerning securities or exchange contracts of any jurisdiction, inside or outside of Canada; or
(iv) any matter that is the subject of by-laws, rules, regulations, rulings or policies of any securities or self-regulatory organization in any jurisdiction.

Research Dissemination Policy

All final research reports are disseminated to existing and potential clients of Euro Pacific Canada Inc. simultaneously in electronic form. Hard copies will be disseminated to any client that has requested to be on the distribution list of Euro Pacific Canada Inc. Clients may also receive Euro Pacific Canada Inc. research via third party vendors. To receive Euro Pacific Canada Inc. research reports, please contact your Registered Representative. Reproduction of any research report in whole or in part without permission is prohibited.

Use of Website Disclaimer

Euro Pacific Canada Inc., its subsidiaries and affiliates are not liable for any harm caused by the use of this site to any software, hardware, data or property of the user that may access, delete, damage, disable, disrupt or otherwise impede the operation or function of the users system/s through access to this site. This web-site is for informational purposes only and does not constitute a complete description of our investment services or performance. This web-site is in no way a solicitation or offer to sell securities or investment advisory services except, where applicable, in the provinces where we are registered or where an exemption or exclusion from such registration exists. Information throughout this site, whether stock quotes, charts, articles, or any other statement or statements regarding market or other financial information, is obtained from sources which we, and our suppliers believe reliable, but we do not warrant or guarantee the timeliness or accuracy of this information. Nothing on this web-site should be interpreted to state or imply that past results are an indication of future performance. Neither we nor our information providers shall be liable for any errors or inaccuracies, regardless of cause, or the lack of timeliness of, or for any delay or interruption in the transmission thereof to the user. THERE ARE NO WARRANTIES, EXPRESSED OR IMPLIED, AS TO ACCURACY, COMPLETENESS, OR RESULTS OBTAINED FROM ANY INFORMATION POSTED ON THIS OR ANY LINKED WEB-SITE.

Linked Sites: “Hypertext links” and/or "hyperlinks" to or from other Internet sites, may be included at times as a convenience to the user. Euro Pacific Canada Inc. assumes no responsibility for the content of any linked site. The fact that Euro Pacific Canada Inc. has made these links available is not an endorsement or recommendation by Euro Pacific Canada Inc. of any materials or information you may find on any linked site. Euro Pacific Canada Inc. furnishes these links for your convenience only and they should be used at your discretion. There are inherent risks in the use of any software and information found in the Internet and you acknowledge that you understand these risks before using any of these services.

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