Gluskin Sheff + Associates Inc. (the “Company”) provides a company Website, a Twitter account, a LinkedIn account and any other online content or social media account (the “Sites”) for informational purposes only. By accessing any of the Sites, you accept and agree to be bound by and comply with the terms and conditions set out herein (the “Terms”). If you do not accept and agree to the Terms, you should not use any of the Sites.
Information provided on the Sites (the “Information”), including hyperlinks or references to other sites, is believed to be reliable and accurate at the time it is posted. However, the Company does not guarantee that the Information is accurate, complete or current at all times. Such Information is provided on an “as is” and “as available” basis and the Company does not guarantee that access to the Sites will be uninterrupted, timely, secure or error free. The Company does not make any express or implied warranties, representations, endorsements or conditions with respect to the Sites or the Information, including without limitation, warranties of merchantability, operation, usefulness, completeness, reliability or fitness for a particular purpose or that no viruses or other contaminating properties will be transmitted to your computer system. It is your sole responsibility to take precautions to ensure that your computer is adequately protected from computer viruses or other destructive properties. You are responsible for evaluating the adequacy, accuracy, reliability, completeness and relevance of any Information.
The Information may contain technical inaccuracies or typographical errors and may be modified at any time without notice. As such, you agree to review the Terms regularly. Your continued access or use of the Sites will constitute your acknowledgment of any modified terms and conditions and your agreement to abide and be bound by any changes to the Information or the Sites.
The Company cannot ensure the privacy and confidentiality of any communications over the Internet. As a result, the Company advises you to not transmit any confidential or sensitive information to the Company over the Internet. The Company is not responsible for any damages that may arise if you choose to transmit confidential or sensitive information via this medium.
The Information is not intended to constitute financial, investment, accounting, legal or tax advice and, should not be relied upon in that regard. As expressed above, the contents of the Sites are for informational purposes only and you should consult with a professional prior to acting on any Information.
In no event will the Company be responsible or liable to you or any other party for any direct, indirect, special, incidental or consequential damages, or any other damages arising out of or relating to the use of, misuse of or inability to use the Sites (or a website linked to the Sites). Without limiting the foregoing, the Company will not be responsible or liable for any loss of revenue, profit or prospective economic advantage resulting from the use of, misuse of or inability to use the Site (or a website linked to the Sites), even if advised of the possibility of such damages or such damages are reasonably foreseeable.
Neither the Sites nor the Information constitute an offer or solicitation by the Company to buy or sell any products or services of any kind whatsoever including, without limitation, securities or any other financial instrument of any issuer.
No endorsement or approval of any third parties or their advice, opinions, information, products or services, either by way of a link to other Web sites or otherwise, is expressed or implied by any Information.
References to specific securities and their issuers are not intended and should not be interpreted as recommendations to purchase, sell or hold such securities. The Company’s products and strategies may or may not include the securities referenced, and if such securities are included, no representation is being made that they will continue to be included.
All product and service marks are the trade marks of their respective owners. All of the Company’s trade marks used on the Sites are used under license. You may display, download or print the Information for your own personal and non-commercial purposes provided that all copyright and other proprietary notices contained on the Information are not modified or removed.
Any action arising out of these Terms or the Sites shall be subject to the jurisdiction of the Province of Ontario.
The Sites are a forum where civility should prevail. While the Company may monitor third-party postings we may or may not review them before they are displayed. A third-party post is the view and responsibility of the poster, not the Company. We cannot guarantee the appropriateness, accuracy or usefulness of a third-party posting or of any third-party link. It is unlawful to post unauthorized or copyrighted materials.
The Company is an SEC-registered investment adviser and we therefore cannot publish or otherwise disseminate testimonials about our products or services. Please refrain from such postings. You should keep discussions to the economic or other themes mentioned, and refrain from commenting, positively or negatively, on the Company, its products and services, or its employees. We reserve the right to screen or remove any postings.
You represent and warrant to the Company that you will not use the Sites for any purpose that is unlawful or prohibited by these Terms, including but not limited to attempting or actually (i) disrupting, impairing or otherwise interfering with the operation or integrity of the Sites or circumventing any of the Sites’ security systems; (ii) collecting information about other users of the Sites; or (iii) systematically extracting Information contained in the Sites to populate databases or other sites.
You should use reasonable caution in evaluating information on or available through the Sites. We reserve the right to remove any post at any time for any reason where the Sites’ technology permits. If we do not remove a post that does not mean the Company endorses its content or view. We also reserve the right to alter, edit or adapt a third-party post. All posts to the Sites become the unrestricted property of the Company.
Any hyperlinks or referenced websites on the Sites are for your convenience only. These hyperlinks may connect or lead you to third parties’ websites. Any descriptions of, references to, or links to other products, publications or services do not constitute an endorsement, authorization, sponsorship by or affiliation with the Company with respect to any linked site or its sponsor, unless expressly stated by the Company. Any such information, products or sites have not necessarily been reviewed by the Company and are provided or maintained by third parties over whom the Company exercises no control. The Company expressly disclaims any responsibility for the content, the accuracy of any information, or the quality of any products or services provided by or advertised on these third-party sites. The Company reserves the right to terminate any hyperlink at any time.
Gluskin Sheff has developed and implemented policies governing how we will achieve accessibility through meeting the requirements under Ontario’s Integrated Accessibility Standards. These policies include Information and Communication, Employment and Customer Service policies.
Descriptions of these policies are available upon request and arrangements will be made to provide them in an accessible format if required.
Gluskin Sheff will provide accommodation, upon request, for applicants with disabilities in our recruitment and selection process.
Gluskin Sheff will receive and respond to feedback regarding the manner in which it provides information about the company and its products and services to people with disabilities. Upon request, we will arrange for the provision of accessible formats and communication supports. If you wish to provide feedback please contact a representative at Gluskin Sheff.
Gluskin Sheff has developed a multi-year accessibility plan which outlines the requirements under Ontario’s Integrated Accessibility Standards and what actions have or will be taken to meet our obligations.
IMPORTANT NOTICE FOR NON-CANADIAN PERSONS AND INVESTORS
The information contained in the Sites is directed only at, and any securities and financial services being offered are available only to, persons resident in Canada and such other jurisdictions where they may be legally offered. The Company provides investment advisory services on a discretionary basis to non-Canadian persons and Investors (including U.S. Persons) where permitted by law.
The Sites and any Information therefrom should not be considered as an offer to sell or a solicitation to buy the Company’s investment funds to any person residing in the United States of America or any other jurisdiction in which such an offer or solicitation is unlawful.
Nothing contained within the Sites shall constitute an offer or solicitation to anyone in the United States of America or any jurisdiction where such an offer or solicitation is not authorized or to any person to whom it is unlawful to make such a solicitation.
If you choose to access the Sites from outside of Canada, you acknowledge that the Information is intended for use by persons resident in Canada only. Any products or services referred to on the Sites are provided in accordance with local law. Your use of the Information shall occur on your own initiative and you are responsible for compliance with applicable local, national or international laws.
FORWARD LOOKING STATEMENTS
The Sites may contain forward-looking statements (within the meaning of applicable securities laws) relating to the Company’s business and the environment in which it operates. Forward-looking statements are identified by words such as “believe”, “anticipate”, “expect”, “intend”, “plan”, “will”, “may” and other similar expressions. These statements are based on the Company’s expectations, estimates, forecasts and projections. They are not guarantees of future performance and involve risks and uncertainties that are difficult to control or predict. The risks and uncertainties related to the Company are discussed in the Company’s regulatory filings available on the Company’s website and at www.sedar.com. There can be no assurance that forward-looking statements will prove to be accurate as actual outcomes and results may differ materially from those expressed in these forward-looking statements. Readers, therefore, should not place undue reliance on any such forward-looking statements. Further, a forward-looking statement speaks only as of the date on which such statement is made. The Company undertakes no obligation to publicly update any such statement or to reflect new information or the occurrence of future events or circumstances.
Last Updated: July 8, 2020
Being Accountable, Open and Transparent
How We Collect Information
We may collect information about you in writing, electronically or verbally. This information may be collected through account applications or other forms, or through conversations or other correspondence with you.
Information We Collect and How We Use It
When you register for an account on our website or choose to access our services, you may be asked to provide certain “personal information” (as defined under Privacy Legislation) about yourself, including your name, address, birth date, phone numbers, mailing addresses, email addresses, income, social insurance or social security number, employment and occupational data, company affiliations, medical history, lifestyle, residency or other personal identification numbers.
We collect this and other information about you in order to properly identify you, to contact you or your designated representatives, to understand your investment needs, to make appropriate investment decisions on your portfolio, to manage the administration of your account, to provide you with financial and insurance products and services, to inform you of services we offer that may be relevant to you and to satisfy legal, regulatory, custodial and tax reporting requirements.
Collecting Only Essential Information
We collect only the information about you that we need for the purposes identified. Our accounting, compliance and client service personnel are aware that only information necessary for the opening and operating of your investment account is to be requested and collected. With your permission, your health and lifestyle information may also be collected for the purposes of determining the suitability of insurance products or services.
Obtaining Your Consent
We collect, use or disclose your personal information with your permission for the purpose identified, or as required or permitted under applicable law. Your permission may be expressed in writing or be implied and you may give it to us verbally, electronically, or through your authorized representative.
How We Limit the Disclosure of Your Information
Confidentiality of client information is a fundamental principle of our firm. No employee may release confidential client information, including the fact that a person either is or is not a client of the firm, unless required by law or with the client’s express consent.
We will not disclose your personal information to third parties, except to the extent required to fulfill the purposes we have set out or as required by applicable law. We use service providers located in Canada and the United States in various aspects of the services we provide to you, including, but not limited to, custodians, transfer agents, fund accounting, administrators, storage facilities, information technology providers, auditors, lawyers and other third parties. We also use administrative service providers outside of Canada who may access personal information stored in databases located in Canada and the United States. These third parties are only provided with the information necessary to perform the required services, and we require under written agreement that these third parties protect the privacy of your information. Gluskin Sheff will not sell your personal information.
All employees of Gluskin Sheff are accountable for safeguarding and maintaining the privacy of all personal information under their control. Our accounting, compliance, client service and administration personnel have been appropriately instructed and trained to ensure that account information, when requested, is only supplied to people who are expressly authorized by you to receive it. Our systems identify whether there are any such authorized recipients other than yourself for your account. To maintain awareness of our policies and practices in this regard, annually we have all of our employees sign a confidentiality agreement affirming their undertaking to faithfully abide by these practices. To satisfy regulatory requirements, personal information will be retained for at least seven years.
Using Appropriate Safeguards
In the course of establishing a secure environment for the operation of our investment management and insurance related activities, Gluskin Sheff has implemented a number of steps to safeguard the integrity of all client personal information. For example:
– hard copies of account documentation for open and recently closed accounts are stored in locked cabinets which are available only to those staff that need to work with this material;
-protection of Gluskin Sheff’s premises is secured through limited access only to those in possession of secure pass cards;
-archival documents are stored with reliable third parties offsite at secure premises;
-personal information in the form of electronic data is stored within our computer systems using firewalls, passwords and transmission encryption programs; and
-All electronic data is backed up daily at an offsite storage facility which maintains industry standard security systems.
Cookies and Other Tracking Devices
You may adjust your browser settings to reject cookies if you so choose. If you wish to view the cookies which reside in your computer or change your browser settings to reject all cookies or ask for your approval before accepting them, use the preferences settings in your browser. If you do decide to disable our cookies, you may not be able to take full advantage of certain features available on our website.
Withdrawing Your Consent
You may also opt out of receiving promotional emails from Gluskin Sheff by following the instructions in those emails. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.
Ensuring Accuracy and Accessibility of Your Information
Staff who are in regular contact understand that they have a responsibility to update the central database whenever they learn of changes in your personal information. As well, update forms are circulated periodically to give you the opportunity to revise your personal information.
You may access your personal information that we have on file by contacting your client service representative or writing to the Privacy Officer at the address indicated below. Gluskin Sheff will be pleased to explain how your information is used and correct or amend any information which is determined to be incorrect or deficient.
Responding to Inquiries and Complaints
If you have questions or complaints with respect to our privacy policies and practices or if you wish to request access to, or correction of, your personal information under our care and control, please contact the Privacy Officer at:
Gluskin Sheff + Associates Inc.
Bay Adelaide Centre
333 Bay Street, Suite 5100
Toronto ON M5H 2R2
Attention: Privacy Officer
Inquiries or complaints will be dealt with promptly. The Privacy Officer will acknowledge your query, investigate and provide you with a response within 30 days.
Right to File a Complaint
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3
Important Information about the Cayman Islands Data Protection Law, 2017
Effective September 30, 2019, the Cayman Islands Data Protection Law, 2017 (the “DPL”) gives rights to natural persons (wherever they are resident) whose personal data is processed by or on behalf of one or more of the Gluskin Sheff-sponsored funds domiciled in the Cayman Islands (the “Funds”). The following notice contains important information about the processing of personal data provided by individuals (or their representatives) in the context of an investment in the Funds.
The Funds are data controllers as that term is used in the DPL The Fund(s) process personal data (and will engage third parties to process personal data) in administering or managing the Fund, processing your subscription and investment in the Fund, sending you statements relating to your investment and facilitating the transfer of funds, and administering and facilitating any other transaction, between you and one or more of the Funds.
The processing is necessary for compliance with applicable legal or regulatory obligations, including undertaking investor due diligence and onboarding checks, carrying out know your client, anti-money laundering and counter-terrorist financing checks, verifying the identity and addresses of our investors (and, where applicable, their beneficial owners), complying with requests from regulatory, governmental, tax and law enforcement authorities, carrying out audits, maintaining statutory registers, preventing and detecting fraud, complying with the United States Foreign Account Tax Compliance Act and other comparable legislation and complying with applicable sanctions and embargo legislation, and in pursuance of the Funds’ legitimate interests, or those of a third party to whom your personal data are disclosed, such as seeking legal advice, pursuing and defending claims (whether domestic or foreign), and ensuring compliance with the Funds’ internal policies and procedures, but in all cases only where the Funds have considered that the processing is necessary and, on balance, the Funds’ legitimate interests are not overridden by your legitimate interests, rights or freedoms.
Your personal data may be transferred to or processed outside of the Cayman Islands to a country which may not afford a similar degree of protection to your personal data as the Cayman Islands. In such circumstances, the Funds will seek to ensure that a similar degree of protection is afforded to your personal data by using one of the lawful bases for such transfer or processing set out in the DPL including the use of model contracts.
For more information about the processing of your personal data, please contact firstname.lastname@example.org. For information about the DPL, please consult the website of the Cayman Islands data protection supervisory authority at www.ombudsman.ky.
Gluskin Sheff has selected its Board members for their experience and skills. Potential conflicts of interest may arise as a result of common directorship between Gluskin Sheff and an issuer in which accounts or funds managed by Gluskin Sheff may invest. In addition, from time to time, a director, officer or key personnel of Gluskin Sheff may act as a director or officer of an issuer in which accounts or funds managed by Gluskin Sheff may invest. Below is a list of issuers for which a director, officer or key personnel of Gluskin Sheff acts as a director and/or officer.
GS+A North American All-Cap Fund
GS+A Premium Income Fund
GS+A Premium Income Trust
GS+A U.S. Equity Fund (formerly GS+A U.S. Premium Income Fund)
GS+A U.S. Equity Fund II (formerly GS+A U.S. Equity Fund)
GS+A International Fund
GS+A Dividend Distribution Fund
GS+A Global Special Situations Fund
GS+A Enhanced Bond Fund
Blair Franklin Global Credit Fund (MFT) (formerly GS+A Tactical Fixed Income Fund II)
Onex High Yield Bond Fund (Canada) (formerly GS+A Enhanced Yield Fund)
GS+A High Interest Cash Fund
Blair Franklin Global Credit Fund LP
GS+A Premium Income Fund (Delaware) LP
GS+A U.S. Equity Fund (Delaware) LP
GS+A International Fund (Delaware) LP
GS+A Enhanced Bond Fund (Delaware) LP
Blair Franklin Global Credit Fund (Delaware) LP (formerly GS+A Tactical Fixed Income Fund (Delaware) LP)
Blair Franklin Global Credit Fund (Cayman) (formerly GS+A Tactical Fixed Income Fund (Cayman))
Blair Franklin Global Credit Master Fund (Cayman) LP (formerly GS+A Tactical Fixed Income Master Fund (Cayman) LP)
Onex Senior Credit Fund (Canada)
Onex Fox GS LP
Onex Fox GS Feeder LP
OCP Senior Credit Partners, LP
OCP Senior Credit Fund International, Ltd.
Onex Senior Loan Opportunities Fund I, LP
Onex Senior Loan Opportunity International Fund I, LLC
Onex Structured Credit Opportunities Partners I, LP
Onex Structured Credit Opportunities International Fund I, LLC
Onex Credit High Yield Bond Fund, LP
Onex Credit High Yield Bond Fund (Onshore Feeder), LP
Onex Credit High Yield Bond Fund (Offshore Feeder), LLC
Jeld-Wen Holding, Inc.
Clarivate Analytics PLC
GS+A Government Bond Duration Fund
GS+A U.S. Dollar High Interest Cash Fund
Onex Capital Solutions (Luxembourg) Feeder, SCSp
Onex Capital Solutions, LP
Onex Falcon Direct Lending BDC Fund
Onex Falcon Direct Lending Cayman Fund, LLC
Onex Falcon Direct Lending Fund
This Conflicts of Interest disclosure provides investors with information about the conflicts we face or may face, and the policies we have adopted to address those conflicts in the best interests of our clients. Please read here.