Potential for Conflict Clause Samples

Potential for Conflict. To the extent that one affiliate determines it to be in the interests of its clients to engage the potential conflict of interest, given its indirect relationship with the other affiliates. S▇▇ and its officers and employees must ensure that if they select another affiliate to assist a S▇▇ client it is based on the determination that such other affiliate is an appropriate selection having regard to the client’s circumstances. Representatives of S▇▇ and other affiliates may from time to time act as officers of S▇▇ and may also be officers of other affiliates. All affiliates have adopted policies and procedures that minimize the potential for conflicts of interest resulting from the relationships of the officers and the affiliates, and all officers are required to observe such policies in carrying out their duties. We must ensure the fair treatment of our clients through the highest standards of integrity and ethical business conduct. The principle of fair treatment must be recognized by all employees, officers and directors of S▇▇ in order to provide a true benefit to our clients. Our clients have the right to be assured that their interests will always take precedence over the personal trading activities of S▇▇ portfolio managers and other S▇▇ access persons. In order to ensure fairness in the allocation of investment opportunities among the S▇▇ Managed Accounts and the S▇▇ Investment Funds (each a “S▇▇ Client”), S▇▇ will allocate investment opportunities with consideration to the suitability of such investments to each S▇▇ Client’s investment objectives and strategies, portfolio composition, restrictions and cash availability (even though the investment objectives and strategies are substantially the same for some of the S▇▇ Clients and cash flows of each S▇▇ Client can be substantially different given daily/monthly subscriptions and redemptions/withdrawals). As well, cash flows (subscription inflows and redemptions/withdrawals) and investment strategies can influence the allocation process in order to maintain property weightings in each S▇▇ Client account. If an investment opportunity is suitable for more than one S▇▇ Client, S▇▇ will allocate such investment opportunities equitably in order to ensure that each S▇▇ Client has equal access to the same quality and quantity of investment opportunities. To ensure fairness in the allocation of investment opportunities as between each S▇▇ Client, S▇▇ will ensure:

Potential for Conflict. ▇▇▇ and its officers and employees must ensure that if they select another affiliate to assist a ▇▇▇ client it is based on the determination that such other affiliate is an appropriate selection having regard to the client’s circumstances. Representatives of ▇▇▇ and other affiliates may from time to time act as officers of ▇▇▇ and may also be officers of other affiliates. All affiliates have adopted policies and procedures that minimize the potential for conflicts of interest resulting from the relationships of the officers and the affiliates, and all officers are required to observe such policies in carrying out their duties. We must ensure the fair treatment of our clients through the highest standards of integrity and ethical business conduct. The principle of fair treatment must be recognized by all employees, officers and directors of SAM in order to provide a true benefit to our clients. Our clients have the right to be assured that their interests will always take precedence over the personal trading activities of ▇▇▇ portfolio managers and other ▇▇▇ access persons.

Potential for Conflict. To the extent that one affiliate determines it to be in the interests of its clients to engage the potential conflict of interest, given its indirect relationship with the other affiliates. ▇▇▇ and its officers and employees must ensure that if they select another affiliate to assist a ▇▇▇ client it is based on the determination that such other affiliate is an appropriate selection having regard to the client’s circumstances. Representatives of ▇▇▇ and other affiliates may from time to time act as officers of ▇▇▇ and may also be officers of other affiliates. All affiliates have adopted policies and procedures that minimize the potential for conflicts of interest resulting from the relationships of the officers and the affiliates, and all officers are required to observe such policies in carrying out their duties. We must ensure the fair treatment of our clients through the highest standards of integrity and ethical business conduct. The principle of fair treatment must be recognized by all employees, officers and directors of ▇▇▇ in order to provide a true benefit to our clients. Our clients have the right to be assured that their interests will always take precedence over the personal trading activities of ▇▇▇ portfolio managers and other ▇▇▇ access persons.

Potential for Conflict. To the extent that one Sprott Registrant determines it to be in the interests of its clients to engage the services of, or invest in financial products offered by, another Sprott Registrant, it could be subject to a potential conflict of interest, given its indirect relationship with the other Sprott Registrants. ▇▇▇ and its officers and employees must ensure that if they select another Sprott Registrant to assist a ▇▇▇ client it is based on the determination that such other Sprott Registrant is an appropriate selection having regard to the client’s circumstances. Representatives of ▇▇▇ and other Sprott Registrants may from time to time act as officers of ▇▇▇ and may also be officers of other Sprott Registrants. All Sprott Registrants have adopted policies and procedures that minimize the potential for conflicts of interest resulting from the relationships of the officers and the Sprott Registrants, and all officers are required to observe such policies in carrying out their duties. There will be three individuals who will be dually licensed with both SPW and ▇▇▇, namely: ▇▇▇▇ ▇. ▇▇▇▇▇▇ Chief Executive Officer and Ultimate Designated Person Chief Executive Officer, Senior Portfolio Manager and Ultimate Designated Person ▇▇▇▇▇ ▇. ▇▇▇ Vice-President, Sales and Marketing President ▇▇▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇▇▇ Chief Compliance Officer and Alternate Designated Person Chief Compliance Officer and Operations ▇▇▇ and SPW propose to manage potential conflicts associated with the dual registration of the individuals in the following manner: · Each dually registered individual will have sufficient time in their work week to fully and properly discharge their responsibilities at SPW and ▇▇▇. · In order to protect client confidentiality, each dually registered individual shall be prohibited from disclosing any confidential client information to any person other than the staff of the relevant entity or for the purpose of performing the relevant services for the client. We must ensure the fair treatment of our clients through the highest standards of integrity and ethical business conduct. The principle of fair treatment must be recognized by all employees, officers and directors of ▇▇▇ in order to provide a true benefit to our clients. Our clients have the right to be assured that their interests will always take precedence over the personal trading activities of ▇▇▇ portfolio managers and other ▇▇▇ access persons.