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Privacy Policy


Heward Investment Management Inc. is registered as a Portfolio Manager with all appropriate Securities Regulatory Authorities as required in the Provinces of; Quebec (AMF), Ontario (OSC), British Columbia (BCSC), Alberta (ASC) and New Brunswick (FCNB).

Privacy Policy

As our client, you are entitled to know how we protect your personal information and how we limit its disclosure.


The collection, use and disclosure of data or information about individuals is subject to provincial and federal laws on the privacy of information. To this effect, Heward Investment Management Inc. (Heward) has designated the Chief Compliance Officer as Privacy Officer to ensure adherence with the Heward Privacy Policy, which applies to all current and former clients of our firm, including all those who invest in our Pooled funds. This privacy policy describes our policies and practices for collecting, disclosing, and safeguarding “personal information,” which may include financial or other information about you.


The knowledge and consent of the individual are required for the collection, use and disclosure of personal information, except where legally inappropriate. You provided this consent at the time you opened your account(s) with us. We collect personal information about you from the following sources:

  • Information we receive from you on our client Memorandum of Agreement form, the Schedule 3 Form (know your client “KYC” form) and Investment Policy Statement (IPS), agreement letters and other forms.
  • We also collect personal information during both formal and informal meetings, as well as during our telephone conversations with you.
  • This personal identifying information includes, but is not limited to, your name, address, date of birth, driver’s license or passport number, assets, income and any changes in your personal situation; as well as information about your transactions with us, your custodian and others, such as account balances and parties to transactions.
  • Heward will be vigilant with respect to the initial and ongoing accuracy of the personal information we collect and asks that you keep us up to date by promptly notifying us of any changes such as your mailing or email address or phone number, employment status or income needs.

Identifying Purposes

Collecting personal information about you is essential to our being able to provide the personalized services that best meet your (our Client’s) needs. While the personal information we collect may come directly from you, it may also be provided by your financial institution.

Personal information may be used:

  • To understand and assess your ongoing needs and to adjust your portfolio if warranted;
  • For client communication, service and administration including invoicing and accounting purposes;
  • For internal, external and regulatory audit purposes;
  • To comply with legal and regulatory requirements;
  • To facilitate investment transactions with other financial intermediaries;
  • In compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

Please note that if you provide personal information about others (such as employees, dependants, etc.); we assume that you have obtained their consent.

Limiting Use, Disclosure, and Retention

We do not disclose your personal information to anyone, except as permitted or required by law. This means, most importantly, that we do not sell client information, whether it is your personal information or the fact that you are our client to anyone. Instead, we use your personal information primarily to complete transactions on your behalf. Here are the details:

To complete certain transactions or account changes that you request, it may be necessary to provide identifying information to non-affiliated third parties, such as trustees or custodians and broker-dealers.

We will release your personal information if we are required by law to do so or in other limited circumstances permitted by law for example, to protect your account from fraud, or if you give us the permission to do so.

Should you wish us to share your personal information with a third party such as your accountant, auditor or consulting firm, we require written instructions describing the type of personal information you wish us to share as well as the name, address, phone, fax number and email address of the third party.

Legislation and Regulations

The Personal Information Protection and Electronic Documents Act (PIPEDA) and An Act Respecting the Protection of Personal Information in the Private Sector (Quebec) require organizations to obtain your consent to collect, use or disclose information about you.
The Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires Heward to comply with certain client identification, recordkeeping, reporting and internal compliance measures. This includes reporting suspicious transactions to Canada’s financial intelligence unit, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

What happens if you close Your Account?

If you decide to close your account(s), we will adhere to the privacy policies and procedures described in this notice. Heward is subject to legislative requirements with respect to retention periods.

Who has Access to Your Personal Information?

Disclosure of your personal information is restricted to individuals who need access in order to provide services to you.


We maintain physical, electronic and procedural safeguards that comply with Canadian regulations to protect your personal information.

Openness, Access, Recourse

Heward will make available information about its policies and practices relating to the management of personal information upon request.

You may obtain access to the personal information we hold about you at any time to review its content and accuracy. Please provide us with specific information in writing, to permit a comprehensive search through our files. Heward will respond to written requests within 30 days.

If you require more information, or have concerns, please contact our Privacy Officer at

Heward may update this policy from time to time. When we change the policy in a material way, an updated Policy will be available on the website.

Trade-Matching Statement

National Instrument 24-101 – Trade Matching and Settlement

To: All trade-matching parties providing trade orders to, acting on behalf of, or executing a trade with Heward Investment Management Inc.

This Trade-Matching Statement is being provided in accordance with National Instrument 24‑101 – “Institutional Trade Matching and Settlement” and Companion Policy 24-101CP [the “National Instrument”]. It applies to all trades that are subject to the National Instrument.

We confirm that we have established, maintain, and enforce policies and procedures designed to achieve matching in accordance with the National Instrument.

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