General Disclaimer & Web Usage

Marvin W Nickel is a Certified Financial Planner® and a Chartered Investment Manager®. Marvin is an Investment Representative for Sentinel Financial Management Corp. Marvin is also a Designated Representative for The Wealth Legacy Group Inc. (WLG) The Wealthy Edge® is a registered trademark of WLG.

Marvin provides a number of financial services to individuals, families and businesses. Please ensure you have an understanding as to which entity below is being represented.

Sentinel Financial Management Corp.

Marvin is registered as a Investment Representative in the provinces of British Columbia, Alberta, Saskatchewan and Manitoba. Through Sentinel Financial Management Corp., Marvin offers a wide array of private debt and equity offerings. Marvin also offers money management services through carefully selected portfolio management firms by way of a Relationship Referral Agreement.

The Wealth Legacy Group Inc.

As a Designated Representative for The Wealth Legacy Group, Marvin offers retirement, goals-based, investment and insurance planning. Marvin is also licensed in the provinces of British Columbia and Alberta as a Life/A&S agent and offers numerous insurance related products including annuities, guaranteed investment accounts, segregated funds, life, disability, and critical illness insurance through various insurers. Marvin also offers money management services by way of Relationship Referral Agreements. Additional business activities include Health Spending Accounts for Corporations, Mortgage Referrals with Manulife Bank and SmartCap Mortgage and Guaranteed Investment Certificates offered by 32 financial institutions through GIC Direct. The WLG is marketed using The Wealthy Edge® and Nickel Financial Consulting trade names.

Use of Website

The communication is published by Nickel Financial Consulting. Any commentaries and information contained in this communication are provided as a general source of information and should not be considered personal investment advice. Information on this website is not intended to provide legal, accounting, investment or tax advice, and should not be relied upon in that regard. Past performance is not an indicator of future returns and references to performance on this site are provided as historical benchmarks only. You are responsible for ensuring that you are appropriately informed about any securities, taxation or other legislation or law that could affect your investment decisions.

Website Usage Terms and Conditions

If you continue to browse and use this website, you are agreeing to comply with and be bound by the following terms and conditions of use, which together with our privacy policy govern Nickel Financial Consultant’s relationship with you in relation to this website.

If you disagree with any part of these terms and conditions, please do not use our website. The use of this website is subject to the following terms of use:

• The content of the pages of this website is for your general information and use only. It is subject to change without notice.

• This website may use cookies to monitor browsing preferences.

• Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.

• Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.

• This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.

• All trade marks reproduced in this website which are not the property of, or licensed to, the operator are acknowledged on the website.

• Unauthorized use of this website may give rise to a claim for damages and/or be a criminal offence. • From time to time this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).

• Every effort is made to keep the website up and running smoothly. However, Nickel Financial Consulting  – The Wealth Legacy Group Inc  – Sentinel Financial Management Corp. takes no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control.

• Your use of this website and any dispute arising out of such use of the website is subject to the laws of Canada.

Investment Disclaimer

The communication in the website is for information purposes only and is not, and under no circumstances to be construed as an invitation to make an investment in any securities, nor does it constitute a public offering to sell securities or any other products described herein.

Cash Distribution Funds

Unless duly noted, payment of distributions and distribution breakdown is not guaranteed and may fluctuate. The payment of distributions should not be confused with a fund’s performance, rate of return, or yield*. If distributions paid by the fund are greater than the performance of the fund, then your original investment will shrink. Distributions paid as a result of capital gains realized by a fund and income and dividends earned by a fund are taxable in your hands in the year they are paid. Your adjusted cost base will be reduced by the amount of any returns of capital. If your adjusted cost base goes below zero, then you will have to pay capital gains tax on the amount below zero.

Exempt Market Issuers

The exempt market products described on this website are issued and offered only by their respective issuers pursuant to an information statement or similar offering document. The information statements and other documents pertaining to products that are contained on this website are produced by the issuer of such products and not by Sentinel Financial Management Corp. Sentinel Financial Management Corp. has taken no steps to independently verify, and expressly disclaims any liability for, any information contained in such information statements and other documents.

Portfolio Manager Commentaries: Videos/ Newsletters/ Blogs/ Fund Commentaries

Nothing in any commentary should be considered a recommendation to buy or sell a particular security. Any specific securities discussed are intended as an illustration of the portfolio manager’s security selection process. The portfolio manager may sell these securities at any time, or purchase securities that have previously been sold. The securities may increase or decrease in value after the date hereof, and the portfolio may accordingly gain or lose money on the investment in the securities. The statements by the portfolio managers in their commentaries are intended to illustrate their approach in managing the funds, do not necessarily reflect the views of Sentinel Financial Management Corp. or Marvin Nickel and should not be relied upon for any other purpose. Any statement contained in a commentary that pertains to the future presents the portfolio manager’s current view regarding future events and is included for the purpose of illustrating the portfolio manager’s investment strategy, current beliefs and positioning of the portfolio. Actual future events may differ from these views. Neither Sentinel Financial Management Corp., Marvin Nickel nor the portfolio manager undertakes any obligation to update this information.

Non-Canadian Investors

The securities described on this website may legally be sold in Canada. None of the securities described on this website have been registered or qualified for sale under the laws of any foreign jurisdiction and in particular, such securities have not been registered under the United States Securities Act of 1933. This site should not be considered an offer to sell or a solicitation of an offer to buy securities to any United States Person (as defined for the purposes of the United States Securities Act of 1933) or in any other jurisdiction in which such an offer or solicitation is unlawful. Financial products described on this website will not be sold to any person residing outside Canada unless such sales are permitted under the law of their jurisdiction. Any investor or prospective investor should contact his or her legal or financial advisor for further details.

Forward-looking Statements

The information contained in this website may include estimates, projections and other “forward-looking statements”, which are generally expressed in the future tense, or using words such as “expect”, “anticipate”, “believe” or “may”, whether or not they are expressly identified as forward-looking statements. Any such statements pertaining to our investment products were based on assumptions that we believed to be reasonable at the time, but which may prove to be incorrect. As a result, any forward-looking statements may prove to be incorrect and actual performance may differ materially from that predicted in any forward looking statements. Sentinel Financial Management Corp. and Marvin Nickel assume no obligation to update forward-looking statements.

Privacy Policy

CLIENT PRIVACY POLICY

Collection, Use and Disclosure of Personal Information

Scope and Application of Policy

Marvin Nickel (Nickel) and his related entities are committed to protecting and maintaining the accuracy, confidentiality and security of your personal information as a client of Nickel. This Client Privacy Policy describes the personal information Nickel collects from or about you, how we use that information, and to whom and in what circumstances we disclose that information.

This Client Privacy Policy (“Policy”) applies to all commercial and business relationships in which Nickel is engaged. The Policy is intended to comply with privacy legislation relating to commercial activity in all jurisdictions in which Nickel operates, where such legislation is in force. In Canada, to the extent that Nickel operates in provinces that have not adopted privacy legislation, this policy complies with federal legislation, which governs such jurisdictions.

Collection, Use and Disclosure of Personal Information

For purposes of this Client Privacy Policy, personal information means any information about an identifiable individual, other than the person’s business title or business contact information when collected, used or disclosed in the course of commercial activity, to conduct business with you or provide services or products to you.

The type of information we collect about you includes the following:

• Information such as your name, home address, telephone number and e-mail address

• Social Insurance Number, identity card number, or other government identification number

• Copies of any agreements you enter into with us

• Information that you provide to us, such as your preferences, identities of your advisors and decision-makers, feedback and comments

• Credit and financial information

• Verifying your identity in order to grant website access

Nickel uses the personal information above for different purposes relating to the management of his business and his relationship with you. These purposes include, but are not limited to the following:

• Establishing, maintaining and managing a business relationship with you so that we may provide you with services or products that you have requested

• Enabling us to comply with your requests such as preferred method of communication

• Sharing your personal information with a party representing you, such as your investment representative, financial planner or to other third parties at your direction/consent

• Enabling us to review the products and services that we provide to you so that we may understand your requirements for our products and services and improve our products and services

• Sharing your personal information within Pinnacle and/or its affiliates for purposes of contacting you in your role as an investor, including informing you of investment opportunities

• Protecting our business from error, fraud, theft and damage to our goods and property

• Enabling us to comply with applicable law or regulatory requirements (including tax requirements)

• Safeguarding and protecting Pinnacle’s confidential information

• Other purposes reasonably required for the management of our business relationship with you and the management of Pinnacle’s business

Nickel shares your personal information with its employees, auditors, contractors and consultants and other parties, including Nickel’s subsidiaries and affiliated companies who require such information to assist us with administering our business relationship with you. These include third parties that provide services to us or on our behalf, third parties that collaborate with Pinnacle in the provision of services to you and third parties with whom we contract to perform our services.

In addition, your personal information may be disclosed or transferred to another party (including to another affiliate of Nickel) in the event of a change in ownership of, or a grant of a security interest in, all or part of Pinnacle through a sale transaction or some other form of business combination, merger or joint venture. We will disclose personal information in these circumstances only when the third parties agree to use such personal information solely for the purposes evaluating and carrying out the transaction and, with respect to that information, to act in manner consistent with the principles articulated in this Client Privacy Policy.

Nickel may contract with third parties located in one or more countries outside of Canada, including potentially in the United States of America or the European Union, to provide Nickel with processing, storage or other administrative or data-related services. Please be advised that in that case your information may be transferred to, processed, used and stored in those countries, and that the governments, courts or law enforcement or regulatory agencies located in those countries may be able to obtain disclosure of your information through the laws of, or pursuant to a lawful order made in, those countries.

Consent

We require your consent to collect, use and disclose your personal information in accordance with this Policy. Consent may be expressed or implied. Express consent may be given orally or in writing, including electronic transmission. Implied consent is consent that can be reasonably inferred by your action or inaction. By providing us with the personal information described in this Policy, we assume you have impliedly provided Nickel with your consent to collect, use and disclose your personal information in accordance with this Policy.

You may withdraw or limit your consent to Nickel’s collection, use and disclosure of your personal information at any time, subject to your legal and contractual obligations you may have to us as a result of our business relationship. You must provide reasonable notice of the withdrawal of your consent. All communications with respect to the withdrawal or limitation of your consent should be directed to Nickel in writing.

In some circumstances, Nickel is entitled, or required, to disclose your personal information without your consent. These circumstances include, but are not limited to:

• Protecting your health or safety

• The disclosure is necessary for an investigation or proceeding

• The disclosure is required or authorized by law

• The disclosure is required to comply with a subpoena, warrant or order of a court or other body authorized to compel production of the information

• The disclosure is to a public body and relates to an investigation of an offence

• The disclosure is to a lawyer who is representing Nickel

• The disclosure is required to respond to an emergency

• Where the personal information is publicly available

Accuracy and Retention of Personal Information

Nickel endeavors to ensure that any personal information in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If your personal information changes or you believe information we have about you is not accurate, please notify us as soon as reasonably possible. Any request to verify or correct your personal information must be made in writing to Marvin Nickel. In some circumstances, we may not agree to your request to change your personal information, but will instead append an alternative text to the record in question.

We keep your personal information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of your business relationship with us but it will only be for as long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date and to comply with applicable law and regulatory requirements. When we no longer require your personal information, we will either destroy or erase it, or we will make it anonymous such that it cannot be associated with or tracked to you.

Safeguarding Personal Information

Nickel is committed to protecting the security of your personal information. We endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Access to Your Personal Information

You may ask to see the personal information we have about you. A request to review your personal information must be made in writing to Marvin Nickel. Nickel will endeavor to provide the information requested within a reasonable time from the date of the written request, or within the time otherwise required by law.

If you make a request to review your personal information, we may request specific information from you to enable us to confirm your identity and right to access such information. We may also require information that would assist us in locating your personal information. We may charge a fee to access your personal information; if so, we will notify you of that fee at the time you make your request or within a short time thereafter.

Nickel reserves the right to decline to provide access to personal information in certain circumstances. These include, but are not limited to, circumstances where the information requested:
• Would disclose personal information, including opinions, about another individual

• Would disclose Nickel’s trade secrets or other confidential business information

• Is subject to lawyer-client privilege

• Is not readily retrievable and the burden or cost of providing it would be disproportionate to the value of the information

• Does not exist or cannot be found

• Could result in serious harm to the individual requesting it, serious harm to the life, safety or health of another person, or serious emotional harm or embarrassment to another individual

• May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions

• May be or is required to be withheld by other legislation

Where information requested will not or cannot be disclosed, Nickel will provide the reasons for non-disclosure.

Cookie Policy

Nickel uses cookies and similar technologies such as JavaScript and HTML (“cookies”) on its websites to facilitate and improve your online experience.

How We Use Cookies

When you visit pinnaclewealth.ca, your web browser will automatically download cookies to your device. Cookies allow for faster loading of website content and allows our site to help you navigate efficiently to obtain the information and services you have requested. Cookies also allow our site to remember your preferences such as language selection and help you to view information that is most relevant to your interests. Nickel’s third party content manager server uses cookies can to store session data so you can leave Nickel’s website, come back, and remain logged in.

Revisions to this Policy

Nickel may amend this Client Privacy Policy from time to time to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Policy on our website at pinnaclewealth.ca. We encourage you to review the website on a regular basis. Any changes to this Policy will be effective as of the date posted on the website.

Interpretation of this Policy

The Privacy Officer has the responsibility and authority to interpret and administer this Policy. This Policy does not create or confer any additional rights or obligations to those imposed under provincial or federal privacy legislation. Should there be, in a specific case, any inconsistency between this Policy and applicable provincial or federal privacy legislation, then this Policy will be interpreted to give effect to and comply with such privacy laws.