Last updated on August 1, 2026

Conflicts of Interest 

We take reasonable steps to identify and respond to material conflicts of interest and conflicts that are reasonably foreseeable, between CI Direct Investing, individuals acting on our behalf, and our clients. We are required to inform you (by way of a current disclosure) of the nature and extent of a material conflict and how we address it, in a timely manner, at the time of account opening and in certain cases again prior to the activity being undertaken. If we cannot effectively address a material conflict in your best interest, or the conflict is otherwise prohibited by law, we avoid it. 

A conflict of interest arises when the interests of different persons, particularly your interests and those of CI Direct Investing or any of our employees, including for these purposes our directors, partners, and other employees, are incompatible or divergent. As a result, situations may arise that may influence, or be perceived to influence, CI Direct Investing or one of our Wealth Advisors to act in their own interests or those of a related entity and not in our clients’ best interests. 

Generally, a conflict of interest is material if the conflict may be reasonably expected to influence either your decisions as a client in the circumstances, and/or the recommendations or decisions of CI Direct Investing or its employees in the circumstances.

Accordingly, conflicts of interest may occasionally arise between: 

• you as our client and CI Direct Investing
• you and other whom we represent: or
• CI Direct Investing and our related and associated companies and issuers

We respond to conflicts of interest in a fair and transparent manner consistent with the best interests of our clients. We have implemented policies and procedures designed to assess, address, and manage those potential conflicts of interest using three basic mechanisms to do so, depending on the circumstances: 

1. Avoiding Conflicts of Interest – We avoid conflicts which are prohibited by law, as well as material conflicts that we cannot effectively control in your best interest, or if they give rise to serious potential impact to CI Direct Investing, its employees, or its clients. Some conflicts cannot be avoided, including those conflicts that are inherent in our relationship with CI Financial and with our affiliates arising out of our membership in the CI Financial organization. In situations that we do not or cannot avoid a conflict of interest, where our interests may compete with yours, we will always give your interests priority over ours. 
2. Controlling Conflicts of Interest – We manage acceptable conflicts or those we cannot avoid through several means, depending on the conflict. We address the conflict to minimize its impact and risks to you and our other clients. Generally speaking, we manage conflicts by: (i) requiring our employees to comply with various policies and procedures, including the CI Code of Conduct, which are designed to ensure our employees follow ethical and client-first business practices; (ii) physically separating different business functions and restricting the internal exchange of information; (iii) reducing the possibility of one part of our organization inappropriately influencing another; (iv) employing a compensation structure that does not incentivize our Wealth Advisors to favour one product over another that may be more suitable to the client; (v) internal audit processes to ensure clients are properly informed of potential conflicts of interest; and (vi) establish and use manual and electronic surveillance and supervision to monitor the application of conflict control measures. 
3. Disclosing Conflicts of Interest – An important method of conflict management, but not the only method, is to provide you with information about material conflicts and how we address them in order for you to factor this information into your decision making. 

CI Direct Investing is committed to ensuring that your interests always have precedence. CI Direct Investing seeks to ensure effective management of any situation that could give rise to a conflict of interest. In cases where a material conflict exists between CI Direct Investing and our client(s), we will address the conflict in the best interest of our clients, and we will disclose these conflicts to our clients in a timely manner upon identification of the conflict. 

In this section we share with you: 

• The material conflicts of interest we have identified. 
• An explanation of risks to clients associated with each conflict. 
• How we have addressed the conflict in your best interest. 

Conflicts of interest related to CI Direct Investing being part of CI Financial Organization 

CI Investment Services Inc., with division CI Direct Investing which operates and services your account, is a wholly owned subsidiary of CI Financial Corp. (previously defined as “CI”). A principal business of CI is the management, marketing, distribution and administration of mutual funds, segregated funds and other fee-earning investment products for Canadian investors through its wholly owned subsidiary, CI Investments Inc, also known as CI Global Asset Management (previously defined as “CI GAM”).  

In the course of providing services to you, we may from time to time advise you with respect to the purchase or sale of securities from or to, or issued by, persons or companies which are related or connected to us (collectively, “CI Products”), defined below. We will carry out such services in the ordinary course of business in accordance with usual practices and procedures and with all applicable regulatory requirements.  

If you invest in CI Products, CI will, through its ownership of the CI affiliates, profit from ongoing asset management fees that are described in applicable Fund Facts and other offering documents. These transactions and arrangements may give rise to conflicts of interest; however, we will only enter into transactions or arrangements where they are permitted under securities laws. 

In this context, CI Direct Investing and our employees manage any potential conflict of interest in compliance with the regulatory requirements. Additionally, CI GAM will periodically review its products to ensure they maintain competitive in the market. A recommendation to invest in CI Products will only be made in your best interest based on suitability criteria consistent with your investment objectives, financial, personal circumstances and other considerations required under the regulatory requirements.  

Some CI Direct Investing portfolios are sub-advised by CI GAM or may contain CI GAM investment products  

We have engaged CI GAM as our sub-adviser for certain portfolios. These portfolios are managed primarily using CI Products and may only include third party investment funds as an alternative where CI GAM considers there is no CI Products suited for its portfolio’s mandate. By choosing CI Products for these portfolios, we have not considered other securities that may have characteristics, such as cost structure or past performance, that may be similar or superior to the to the CI Products.  

Given that CI GAM is an affiliate entity, the inclusion of CI Products in these portfolios may be perceived as a conflict of interest. We mitigate this conflict by consistently applying the same in-depth securities evaluation process for any CI GAM-advised portfolios as we do for third party investment funds approved for our portfolio offering. 

CI Direct Investing employees do not receive any incentives for recommending or selecting CI Products or CI GAM-advised portfolios. 

CI Investment Services Inc. is related to other subsidiaries of CI 

Securities legislation requires us to inform clients if we have any principal shareholders, officers, partners or directors who are also principal shareholders, officers, partners or directors of another securities registrant. As well, we must provide clients details of the policies and procedures adopted to minimize the potential for conflict of interest resulting from these relationships. 

CI is also a principal shareholder of the following Canadian securities registrants or service providers to securities registrants. Directors and officers of CI Investment Services Inc. may be directors or officers of one or more of these entities. 

• Aligned Capital Partners Inc. 
• CI Assante Wealth Management Inc.
• Assante Estate and Insurance Services Inc.
• Northwood Family Office Ltd.
• CI Investments Inc.
• CI Private Counsel LP 
• CI Coriel Capital Inc. 

Each of CI, CI Investment Services Inc., and the related registrants is a separate legal entity which carries on its business independently. Conflicts of interest resulting from the above relationships are minimized in a number of ways. 

A “related” issuer means a person or company that influences, or is influenced by, another person or company. A “connected” issuer is a company that has business or other relationship with CI Investment Services Inc., that, in connection with a distribution of securities of the issuer, is material to a prospective purchaser of the securities. This is disclosed at account opening, and subsequent purchase or sale transactions shown on account statements. 

CIIS has conflict of interest policies and complies with all applicable regulatory restrictions in dealing with its affiliates. CI Direct Investing’s policies and procedures are monitored under the guidance of the compliance department. 

CI Investment Services Inc. may retain related service providers 

CI Investment Services Inc. may enter into arrangements with its affiliates respecting such matters as the provision of support, custodial, investment management services, distribution of products and services, and client referrals. 

Due to the relationship between CI Investment Services Inc. and its affiliates, it may be incentivized to engage related service providers as opposed to third party service providers. All business conducted by CIIS with affiliates is agreed to in writing. CI Direct Investing conducts due diligence and ongoing monitoring of related service providers in the same way as it does unrelated service providers. Related service providers maintain systems of internal controls and supervision which are independent or functionally independent from the CI Investment Services Inc., including separate management and personnel who perform the custodial and investment management functions. 

Conflicts of interest related to CI Direct Investing compensation 

CI Direct Investing receives compensation through the management fees charged to you for your account which are set out in your managed account agreement. CI Direct Investing is a division of CI Investment Services Inc., and other divisions of CI Investment Services Inc. may receive interest on cash balances that may be held in your account. 

Depending on how you are introduced to CI Direct Investing and the value of your assets invested, your management fee rate may differ than if you were to sign up directly from our website. Your fees are explained to you in the managed account agreement when you sign up. If you have an existing relationship with an introducing representative, you may agree to pay this introducing representative service fees, which we will collect from your account and remit to your representative. You do not need to pay service fees to your introducing representative if you want to open an account with us, but you will open your account through our regular account opening procedures. 

Our management fee differentials are due to our relationships with our referral partners and their clients and the different costs we have in providing our services to our various groupings of clients. 

Conflicts of interest related to compensation of CI Direct Investing employees 

CI Direct Investing and its employees do not accept gifts, benefits, compensation, or consideration that creates, or might reasonably be expected to create, a material conflict of interest. 

Conflicts of interest related to outside activities 

Our directors, officers, and investment advisors may engage in business activities that are outside CI Direct Investing’s securities related business activities (“outside activity”) only if they have received prior approval from us to do so. You should be aware that our employees may provide other products and services that are outside of his/her affiliation with CI Direct Investing. These are not considered securities-related and are the responsibility of the employee alone. They may also be employees, officers and/or directors of affiliates, or may also be officers or directors of public companies.  

We will, as best as possible, monitor all outside activity to ensure the activity doesn’t impair our ability to serve you and is consistent with our duty to deal fairly, honestly, and in good faith with you.  

We will investigate and follow up on written client complaints relating to an outside activity. CI Direct Investing makes no representations or warranties and assumes no liability in connection with any outside activities of our directors, officers, and investment advisors.  

If you have any questions, please contact CI Direct Investing’s Chief Compliance Officer at 1-877-310-1088. 

Conflicts of interest related to employee personal trading 

CI Direct Investing employees could put themselves in a situation of conflict of interest by carrying out transactions in their personal account using confidential information about CI Direct Investing or its clients, acquired in the performance of their duties. CI Direct Investing manages these potential conflicts by ensuring our employees act in accordance with our personal trading policy and applicable laws.  

Conflicts of interest related to referral arrangements 

We may enter into referral arrangements with affiliated or non-affiliated registrants and non-registrants, some of which are related registrants to CI Direct Investing, so that we may provide portfolio management services to referred clients. We may provide “referral fees” (as such term is defined in applicable securities laws) to the referrer. A referral fee is any benefit provided to the referrer for the referral. We may negotiate the referral fee with the referrer. You should know that referral fees or benefits provided to a referrer creates an incentive for those referrers to refer you to us and gives rise to conflicts of interest for those referrers that they must manage in your best interests. We will inform all referred clients about our referral arrangements, including the benefits we provide to the referrers. Since we receive management fees from clients referred to us, who we accept as our clients and who agree to our services, we are incented to enter into referral arrangements and also to accept referred clients as our clients. We manage our conflicts of interest in this regard, in the best interests of clients by following our same rigorous procedures in collecting financial and personal information about clients and ensuring that an account with us, and any chosen portfolio, is suitable for that client and puts that client’s interests first. 

In some circumstances we may agree to develop an online platform for our referral partners to provide ease of access to the Platform for referred clients. We may receive a fee from our referral partners in respect of this service. This relationship also creates incentives for us to accept these clients, which we manage through the rigorous procedures described above. 

CI Direct Investing may also receive a referral fee for referring its clients to other service providers. The purpose of referrals is to introduce our clients or potential clients to qualified persons who are best suited to help them achieve their financial objectives. 

If a referral arrangement is in place, we will provide you with a written disclosure at the time you commence to open an account with us with full particulars of the conflicts and how we manage them. We will provide you with the specific details of the arrangement, including: 

• the name of our referral partner; 
• the purpose and material terms of the referral arrangement, including the nature of the services to be provided by each party – generally our referral partners are not permitted to give you any advice about our services or our portfolios, including any curated portfolios we develop with the referral partner; 
• any conflicts of interest resulting from the relationship between the parties to the referral arrangement and from any other element of the referral arrangement; 
• the method of calculating the referral fee or benefits and, to the extent possible, the amount of the fee or benefits; 
• the category of registration of each registrant that is a party to the agreement, with a description of the activities that the registrant is authorized to engage in under that category and, giving consideration to the nature of the referral, the activities that the registrant is not permitted to engage in under that category.