Clarus Securities Inc.

Trading Multiple Markets

With the introduction of various alternate exchanges and Alternative Trading Systems (ATSs) to the TSX (on which all TSX listed securities can be traded), policies have been developed with the objective of providing clients with best execution. Clarus is now a member of the following exchanges: TSX, TSXV, Alpha, Pure, Omega, Lynx, MatchNow, CX2 and CHI-X. To fulfill this obligation Clarus needs to consider information that is available on the TSX, the above mentioned exchanges, and ATSs.

Our Principal Marketplace for listed securities is the TSX; unless alternative agreements have been made with the client.

Best Execution
Clarus is committed to use all reasonable efforts to ensure our clients achieve the ‘best execution’ of their orders for securities that are quoted or traded on all marketplaces.

Clarus will execute each client order in the most beneficial terms available under the prevailing market circumstances at the time of the order. Factors to be considered include security price, order size, speed of execution, likelihood of execution and settlement, market center volume, liquidity and availability, overall transaction cost and any other factors deemed relevant at the time of the order. Clarus will seek to obtain the best price available for each trade executed; however market conditions and volatility may result in an execution price that differs from that quoted at the time of order entry.

Clarus regularly evaluates orders to determine which market center consistently offers the most favorable terms of execution. It is important to note that there is no one single accepted measure of best execution, rather best execution is a comprehensive assessment of the marketplace time order. This assessment takes into consideration a number of factors including price, speed of execution, liquidity, probability of execution, and opportunity for price improvements. As appropriate, we will modify and enhance our order routing practices to the benefit of our clients.

Principal Market
Our principal market place for TSX listed securities will be the TSX, unless otherwise agreed by Clarus and the clients on a specific date.

Hours of Operation
Clarus staff will be available to execute orders during the Principal Market’s hours which are 9:30am to 4:00pm EST, Monday through Friday, not including statutory Canadian Holidays. Staff may be available outside the Principal Market hours, however, Clarus cannot guarantee trade execution outside the hours of 9:30am and 4:00pm EST. While other marketplaces may operate outside of the TSX’s hours, Clarus will not guarantee any orders and/or order execution outside of the hours listed above.

Order Handling
The following will apply to orders received for TSX listed securities:
Order Execution
Certain types of orders have specific handling implications in a multiple marketplace environmental as follows:
  1. Day Orders
    A Day Order is an order to trade that expires if it is not executed the day that it is booked to the marketplace. Day Orders will be handled in accordance with regular order routing procedures. All Day Orders expire, if not filled in full, upon the close of the marketplace where last portion of the order remains effective, unless otherwise agreed to between the client and the Registered Representative.
  2. Good till Cancelled (Open) Orders
    Open orders are orders that will remain valid until a specific date of expiry. These orders will be entered in the Principal Marketplace if they are not immediately executable on an alternative marketplace at the time of entry. The order will remain in the default marketplace until executed or expiry, whichever comes first.
  3. Market Orders
    A Market Order is an order to buy or sell a security at whatever prices are available in the marketplace to help ensure a complete full fill. Upon entry to the marketplace, these orders require immediate completion. Market Orders will be handled in accordance with the regular order handling procedures. These orders will expire, if not filled in full, on the marketplace where the last portion of the order remains live, at the close of the marketplace.
  4. Limit Orders
    A Limit Order is an order for a security at a specific minimum sale price or maximum purchase price that is not to be exceeded. Limit Orders will be handled in accordance with regular order handling procedures. The order will expire, if not filled in full, upon the close of the marketplace where the last portion of the order remains live.
  5. Special Terms Orders
    Special Terms Orders are orders with specific terms that are not executable in the regular marketplace. Special Terms Orders will be executed by Clarus and will only be entered to the Special Term Market of the Principal Marketplace, unless they are immediately executable on an alternative marketplace at the time of entry. Special Terms Orders will expire at the close of the Principal Marketplace.
  6. Stop Loss Orders
    Stop Loss Orders are orders that become limit orders when a board lot is traded at, or superior to, the stop loss price on the marketplace in which the order has been booked. These orders will only be entered in the Principal Marketplace order book, and will remain there until the order is executed or expires, whichever comes first.
Extenuating Circumstances
In the event of technical or other issues that limit Clarus access to specific marketplaces, orders received will be directed to either the principal marketplace as circumstances warrant and as determined at the sole discretion of Clarus.

Disclosure of Marketplace
Orders executed on more than one marketplace will be confirmed as: “order executed on more than one marketplace”.

Amendments
Changes to this policy may be made from time-to-time at the sole discretion of Clarus. Changes will be posted to the Clarus website www.clarussecurities.com (Amended January, 2017)