Sterling Mutuals Inc. Privacy Policy

As of January 1, 2004, organizations in Canada that collect, use or disclose personal information in the course of commercial activities will have to comply with the federal Personal Information Protection and Electronic Documents Act ("PIPEDA"). As required by the legislation, Sterling Mutuals Inc. (Sterling) has put in place policies and procedures to effectively safeguard any confidential information that we have on file or collect going forward. These apply to all of the operating companies within the Sterling group, including Sterling Insurance Inc. To meet our obligations, we closely follow the ten fundamental principles set out under PIPEDA.

1. Accountability

Sterling has designated a Chief Privacy Officer ("CPO"). The CPO is ultimately responsible for personal information under the control of Sterling and is accountable for compliance with the terms and procedures of this Privacy Policy. Any individual that wishes to challenge Sterling’s procedures, or wishes to make a complaint about Sterling’s personal-information handling practices they should contact the CPO at 1-800-354-4956 or by email at privacy@sterlingmutuals.com. Contact information is set out below. Every complaint will be investigated and where a complaint is found to be justified, Sterling will take appropriate measures, including amending our policies and practices, when necessary.

2. Purpose of Collecting Personal Information

Sterling will identify the purposes for which it collects the personal information before or when we ask for the information. We will not use or disclose this information for any other purpose other than those for which it was collected.

We collect personal information to ensure that we have all information:

• to operate an account
• to provide additional services requested by the client
• to properly report account status back to the client
• to provide all required tax reporting
• to properly discharge our regulatory responsibilities with respect to suitability assessment and other securities rules
• to properly discharge our obligations under federal anti-money laundering and suppression of terrorism legislation
• to meet our obligations as a member of various self-regulatory organizations

For regulatory purposes, self regulatory organizations, including the Mutual Fund Dealers Association of Canada, and the Canadian Investor Protection Fund (collectively, "SROs") require access to personal information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by Regulated Persons. SROs collect, use or disclose such personal information obtained from Regulated Persons for regulatory purposes, including:

• Surveillance of trading-related activity,
• Sales, financial compliance, trade desk review and other regulatory audits,
• Investigation of potential regulatory and statutory violations,
• Regulatory databases,
• Enforcement or disciplinary proceedings,
• Reporting to securities regulators, and
• Information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.

3. Client Consent

Our consent form is contained in our New Client Application Form. Consent may also be required (when our clients use a product or service subsequent to account opening. An authorized representative of the client (such as a legal guardian or a person having power of attorney) can give consent. A client may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. The implications of withdrawal are set out in the applicable sections of the New Client Application Form.

4. Limiting Collection

We collect personal information only to the extent that is necessary for the purposes identified above. The personal information is collected using policies and procedures that are fair and lawful.

5. Limiting Use, Disclosure and Retention

Sterling will use or disclose personal information only for the reasons it was collected, unless a client provides consent to use or disclose it for another reason, or law requires it. Client information on file will be kept for the standard period of seven years from the final closing of the client file, or the date the last service was provided to the client.

The type of information we collect is limited to the following

• the fundamental "know your client" information contained in the Sterling New Client Application Form
• information required for tax reporting purposes
• information required to meet anti-money laundering and suppression of terrorism requirements
• other information required to meet obligations imposed by securities regulations, SRO rules or other laws

This information may be made available to related companies or third-party service providers to fulfil the purposes for which it has been collected.

The information may also be disclosed to SROs, which may use the information to review, monitor, audit or investigate Sterling’s compliance with securities rules. The information provided to the SROs may, in turn, be reported to other securities regulators, regulated marketplaces, other SROs or law enforcement agencies.

6. Keeping Information Accurate

Sterling has a responsibility to ensure that all personal information on file is accurate, complete and up-to-date. Clients may, in writing, request that their personal information be amended as appropriate.

7. Safeguarding Personal Information

Security safeguards are in place to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification regardless of the format in which it is held. Sterling’s safeguards vary depending on the sensitivity of the personal information. The highest level of protection is given to the most sensitive personal information.

8. Openness

Sterling ensures that clients have access to information regarding the policies and practices we use to manage their personal information. This information is made available in a variety of formats so it is readily available and easy to understand.

9. Access

Clients may request in writing access to their personal information. Sterling will inform the client whether the organization holds personal information and provide an account of the use that has been made of this information, as well as identify any third parties to which the information has been disclosed. When a client demonstrates the inaccuracy or incompleteness of personal information, the information will be amended as required.

10. Complaints and Suggestions

If you would like to make an inquiry, suggestion or complaint regarding Sterling’s personal information practices, please contact our Chief Privacy Officer at 1-800-354-4956 or by e-mail at privacy@sterlingmutuals.com

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