Relationship Disclosure

General

National Instrument 31-103 – Registration Requirements, Exemptions and Ongoing Registrant Obligations requires advisers to disclose information that a reasonable investor would expect to know about the client’s relationship with the adviser, including any material conflicts the adviser or its representatives may have with a client.  These regulations require advisers to provide this disclosure to clients prior to recommending any trades.

Registration

Equinox Investment Management Ltd. (Equinox or the Firm) is registered with the Ontario Securities Commission (OSC) as a portfolio manager.  The OSC is the principal regulator of Equinox.

Equinox’s business activities

Equinox is an investment management firm that provides discretionary portfolio management and targets institutional and retail clients including novice investors. Equinox has low minimum investment thresholds and takes a systematic approach to investment allocation and selection. Equinox provides services only to clients in Ontario.

SeaCrest Wealth Management, LLC

Charles Dwight is the President of Equinox and is a registered advising representative of Equinox.  Charles Dwight also works with SeaCrest Wealth Management LLC (SeaCrest) and is a registered investment adviser with the Securities and Exchange Commission.  SeaCrest only provides investment services to clients resident in the United States.  Equinox and SeaCrest are not affiliated and operate their respective businesses independently of each other. The firms are in separate physical locations and have separate information systems to protect the confidentiality of client information.  Equinox and SeaCrest do not have any business relationship and no services are provided or obtained from one another.  Should Equinox enter into a business relationship with SeaCrest; Equinox will ensure the relationship is disclosed to clients.  In addition, Equinox has policies and procedures to identify, manage and disclose any material conflicts of interest that may exist or reasonably be expected to arise between the Firm and its clients.

Suitability of investments

Equinox is obligated under section 14.2 of National Instrument 31-103 to make a determination to ensure proposed investments are suitable for you.  Equinox will prepare an Investment Policy Statement (IPS) based on information from you relating to your investment objectives, risk tolerance, investment knowledge, financial situation, and other relevant factors to ensure the proposed investment portfolio is suitable for you. In addition, section 13.2 of NI 31-103 and anti- money laundering legislation requires Equinox to obtain information related to your identity.  All this information is collected through the Know Your Client form provided.

Fees and commissions

Equinox receives fees for advising and managing client investment portfolios. The fees are based on assets under management.  The details of the fees are clearly outlined in the fee schedule and attached to your IPS.

Client statements

Equinox will provide clients with an account statement at once every three months or on a monthly basis if directed by the client. The statement will contain all the information outlined in section 14.14 on NI 31-103.

Borrowed money

Using borrowed money to finance the purchase of securities involves greater risk than a purchase using cash resources only.  If you borrow money to purchase securities, your responsibility to repay the loan and pay interest as required by its terms remains the same even if the value of the securities purchased declines.

Dispute resolution

Equinox offers independent dispute resolution or mediation service, at the Firm’s expense, to clients to resolve a complaint made about any registered activity of Equinox. The CCO will inform a client how to contact and use the service when a complaint has been made.