Conflicts of Interest Disclosure

Sentinel Financial Group > Conflicts of Interest Disclosure

INFORMATION ON CONFLICTS OF INTEREST

We are supplying to you, as a client, enhanced disclosures outlined on the following pages, relating to existing and reasonably foreseeable material conflicts of interest that may affect you as our client. These disclosures will also speak to how these conflicts of interest are addressed in the best interest of you, our client. These disclosures apply to all of your accounts with Sentinel Financial Management Corp. (“SFMC”) Please contact either your representative/advisor at SFMC or SFMC’s Head Office at telephone number 1-800-667-3929, with any questions regarding these disclosures and/or how any material conflicts of interest may affect you.
Note that should any further material conflicts of interest be identified in the future after you have received this disclosure, or after account opening, you will be informed by SFMC in a timely manner.
It is important for you to read the attached disclosures to understand the nature and extent of material conflicts of interest and any potential impacts or risks to you.

A conflict of interest may arise where:

  • SFMC or one of its representatives/advisors has a separate business or personal interest that are different from a client’s interests;
  • SFMC or one of its representatives/advisors may be influenced to put their own interests ahead of those of a client;
  • The receipt of monetary or non-monetary benefits, or minuses, by SFMC or one of its representatives/advisors may compromise a reasonable client’s confidence; or
  • Different interests exist among clients, which result in the preferential treatment for some clients in the operation/management of their account, and the execution of their trades.

Commonly, a material conflict of interest exists if the conflict may be reasonably expected to affect either your decisions as a client or the recommendations or decisions of SFMC or one of its representatives/advisors.
SFMC seeks to identify and address material conflicts of interest through its policies and procedures. SFMC’s policies and procedures include a definition of conflicts of interest and require that if a situation arises where a material conflict of interest exists and cannot be resolved in the client’s best interest, the conflict must be avoided.

Management of conflicts of interest

  1. Relationship between SFMC and other Sentinel Companies/entities
    • SFMC is a member of the Mutual Fund Dealers Association and Saskatchewan, Alberta, British Columbia, Manitoba, and Ontario securities commissions;
    • SFMC has representatives/advisors who place their mutual fund-related business through SFMC;
    • SFMC is affiliated with Sentinel Life Management Corporation, also operating as Sentinel Life Group Benefits, and Sentinel Tax Services Inc.

    As services are provided by SFMC or one of its representatives/advisors (hereafter referred to as “we” or “us”) to you, we may enter into arrangements with these other entities noted above.

    These arrangements may give rise to conflicts of interest, and perceptions that we may be acting in the favour of the business interests of these entities. We earn our revenues from you by selling services to you.

    We will act to always treat our clients fairly and honestly in any and all dealings.

    Any material conflict of interest is managed through SFMC’s policies and procedures.

  2. The offering of both fee-based accounts and accounts with trailing commission-paying mutual funds

    SFMC offers both fee-based accounts and accounts with trailing commission-paying mutual funds to clients. Clients can decide to open either type of account with the consultation of their SFMC representative/advisor.

    Any material conflict of interest is managed through:

    • The assessment of the suitability of the account type and appropriateness, given the client’s investment needs and objectives;
    • Client discussion with their SFMC representative/advisor of the costs vs. benefits of fee-based accounts versus trailing commission-based accounts; and
    • Policies and procedures.
  3. Gifts and/or other entertainment (from third parties, clients, or other employees)

    An SFMC representative/advisor may be offered gifts and/or other forms of entertainment (monetary or non-monetary) from a third party, another client, or an employee of SFMC.

    Any material conflict of interest is managed through:

    • Disclosure and tracking;
    • Internal limits;
    • Prior approval; and
    • Policies and procedures
  4. Outside business activities of SFMC representatives and/or advisors

    An SFMC representative/advisor may be affiliated with another business, for activities other than the sale of mutual funds, outside of SFMC.

    Any material conflict of interest is managed through:

    • The need for approval;
    • Disclosure to clients;
    • Policies and procedures; and
    • Annual acknowledgement by SFMC representatives and/or advisors.
  5. SFMC representatives and/or advisors having personal financial dealings with clients

    These arrangements may include lending or borrowing money to clients, belonging to an investment club with clients or personal involvement as a partner, shareholder, director or officer of a business owned, co-owned or controlled by a shareholder.

    Any material conflict of interest is managed through:

    • Policies and procedures (as all of these activities are specifically prohibited); and
    • Annual acknowledgement by SFMC representatives and/or advisors.