Terms and conditions

1. Compliance with Laws and Regulations

Planify’s business activities are subject to extensive governmental regulation and oversight and it is critical that Planify and its employees comply with applicable laws, rules, and regulations, including those relating to insider trading.

2. Conflicts of Interest

Conflicts of interest may arise when a person’s private interest interferes, or appears to interfere, with the interests of Planify, or where the interests of an employee or the firm are inconsistent with those of a client or potential client, resulting in the risk of damage to the interests of Planify or one or more of its clients. A conflict may arise, for example, if an employee takes an action or has an interest that could appear to make it difficult for the employee to conduct the employee’s responsibilities to Planify and/or the client objectively and effectively, or if such employee or any person associated with the employee, including but not limited to members of the employee’s family or household, receives an improper personal benefit, such as money or a loan, as a result of the individual’s position at Planify . Planify has adopted policies, procedures, and controls designed to manage conflicts of interest. Employees are required to comply with these and other compliance-related policies, procedures, and controls and to help mitigate potential conflicts of interest by adhering to the following standard of conduct:

• Act solely in the best interests of clients;

• Uphold Planify’s high ethical and professional standards;

• Identify, report, and manage actual, apparent, or potential conflicts of interest; and

• Make full and fair disclosure of any conflicts of interests, as may be required.

Conflicts of interest may not always be clear-cut and it is not possible to describe every situation in which a conflict of interest may arise – any question with respect to whether a conflict of interest exists, together with any actual or potential conflict of interest, should be directed to managers and L&C.

3. Insider Trading and Personal Trading

Employees and directors who have access to confidential information about Planify, its clients, or issuers in which it invests client assets, are prohibited from using or sharing that information for security trading purposes or for any other purpose except in the proper conduct of our business. All non-public information about Planify or any of our clients or issuers should be considered "confidential information." Use of material, non-public information in connection with any investment decision or recommendation or to “tip” others who might make an investment decision on the basis of this information is unethical and illegal and could result in civil and/or criminal penalties.

4. Gifts and Entertainment

Employees must act in the best interests of our clients and consider the reputation of Planify when receiving or providing any gift or entertainment. Employees are prohibited from offering, promising, giving or receiving, or authorizing others to offer, promise, give or receive anything of value, either directly or indirectly, to any party in order to improperly obtain or retain business, or to otherwise gain an improper business advantage.

In addition, strict laws (including criminal laws) govern the provision of gifts and entertainment, including meals,transportation, and lodging, to public officials. Employees are prohibited from providing gifts or anything of value to public officials or their employees or family members in connection with Planify’s business for the purpose of obtaining or retaining business or a business advantage.

5. Political Contributions

Employees are required to pre-clear political contributions.

6. Corporate Opportunities

Employees and directors:

• are prohibited from taking personal opportunities for themselves that are discovered through the use of corporate property, information, or position without the consent of L&C;

• are prohibited from using corporate property, information, or position for improper personal gain;

• may not compete with Planify either directly or indirectly; and

• owe a duty to Planify to advance its legitimate interests when the opportunity to do so arises.

7. Confidentiality

Planify’s employees and directors have an obligation of confidentiality to Planify and its clients. Confidential information includes non-public information that might be of use to competitors or that might harm Planify or its clients, if disclosed, and non-public information that clients and other parties have entrusted to Planify. The obligation to preserve confidential information continues even after employment ends. This obligation does not limit employees from reporting possible violations of law or regulation to a regulator or from making disclosures under whistleblower provisions.

8. Reporting Any Illegal or Unethical Behaviour

Every employee is required to report any illegal or unethical conduct about which they become aware, including those concerning accounting or auditing matters. Planify will not retaliate or discriminate against any employee because of a good faith report. Employees have the right to report directly to a regulator and may do so anonymously; employees may provide protected disclosures under whistleblower laws and cooperate voluntarily with regulators, in each case without fear of retaliation by Planify.

9. Equal Employment Opportunity and Harassment

The diversity of Planify’s employees is a tremendous asset. Planify is firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment of any kind. In particular, it is Planify’s policy to afford equal opportunity to all qualified applicants and existing employees without regard to race, ethnicity, religion, color, national origin, sex, pregnancy status, pregnancy-related medical conditions, gender, gender identity or expression, sexual orientation, age, ancestry, physical or mental disability, familial or marital status, political affiliation, citizenship status, genetic information, or protected veteran or military status or any other basis that would be in violation of any applicable ordinance or law. In addition, Planify will not tolerate harassment, bias, or other inappropriate conduct.