Privacy Policy

Smead Capital Management (Canada) Ltd. (“Smead Canada”, “we”, “us”, “our”) understands how important it is to investors that we protect the privacy, integrity, security and confidentiality of the personal information that has been entrusted to us. As part of our commitment to you, we have established policies regarding the collection, use, disclosure and protection of your personal information. In this policy we outline what information we have, why we need it and how it is used, shared and protected, including in connection with our cross-border operating model. We also describe your rights with respect to your own privacy.

About Our Structure
Smead Canada is the Investment Fund Manager and Portfolio Manager of the Smead Global ex-US Value Fund and the Smead US Value Fund (each, a “Fund” and, collectively, the “Funds”). Smead Canada has no employees. The Funds are distributed exclusively through registered dealer firms and their registered dealing representatives, and day-to-day fund administration, portfolio management and certain other functions are performed on Smead Canada’s behalf by SGGG Fund Services Inc. (as administrator, registrar and transfer agent), RBC Investor Services Trust (as custodian) and Smead Capital Management, Inc. (“Smead US”, as sub-adviser), in each case under Smead Canada’s oversight. This structure affects how, and by whom, your personal information may be handled, as described further below.

What personal information does Smead Canada have and why do we need it?
Personal information refers to information that identifies you. Since the Funds are distributed through registered dealers, Smead Canada does not typically open or administer individual investor accounts directly. Personal information about investors in the Funds is collected and administered primarily by your registered dealer and by SGGG Fund Services Inc., as the Funds’ administrator, registrar and transfer agent, and may include your name, address, contact information, date of birth, and account and holding information necessary to administer your investment in the Funds. Smead Canada also collects personal information directly from individuals who contact us, visit the Website, or otherwise interact with us, such as name, contact information and the nature of your inquiry.

We need this personal information in order to establish and verify identity where applicable, meet regulatory requirements, protect against error and fraud, and administer the Funds and respond to inquiries.

How does Smead Canada obtain your personal information?
Personal information relating to investors in the Funds is generally received from your registered dealer or dealing representative, or from SGGG Fund Services Inc. as the Funds’ administrator, registrar and transfer agent, with your consent. Personal information relating to other individuals is received directly from you, such as when you contact us or use the Website. You always have the option of not providing personal information that is requested, however, this may affect our or your dealer’s ability to open or maintain your investment in the Funds or to respond to your inquiry.

How is your personal information used?
Personal information is used to identify you where applicable, administer the Funds, execute transactions, and provide unitholders, or their authorized representatives, with account statements, tax receipts, and other information required or requested to service their investment. Personal information is also used in our internal business operations and to fulfill our legal and regulatory requirements, including requirements under applicable securities and anti-money laundering legislation.

When is your personal information shared?
There are limited circumstances where Smead Canada, or a service provider acting on our behalf, may share personal information with others, including:

• Service providers engaged to perform services in connection with the Funds, including SGGG Fund Services Inc. (fund administration, registrar and transfer agency), RBC Investor Services Trust (custody), Smead US (portfolio management and trading), and our auditor, Ernst & Young LLP. These service providers are provided with only the information necessary to perform the services they have been engaged to provide, and are contractually restricted from using that information for any other purpose or disclosing it to others except as permitted.
• Your registered dealer or dealing representative, in connection with servicing your investment in the Funds.
• Government agencies that regulate Smead Canada or the Funds, including the Ontario Securities Commission, other provincial securities regulators, and the Canada Revenue Agency.
• As permitted or required by law, including in response to a law, regulation, court order, subpoena, valid demand, search warrant or other legally valid request, or to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.

Cross-Border Transfer and Processing of Personal Information
Smead Canada operates under a cross-border delegated model. Smead US performs portfolio management, trading and certain other functions on Smead Canada’s behalf from the United States, under Smead Canada’s oversight. As a result, some personal information may be processed, stored, or accessed by Smead US personnel in the United States. Personal information transferred to or processed in the United States in this manner may be subject to the laws of the United States, including laws that permit U.S. government authorities to access personal information under certain circumstances. Smead Canada requires that personal information handled by Smead US in this context be subject to safeguards consistent with this policy and with Smead Canada’s Policies and Procedures Manual, but you should be aware that where information is processed outside Canada, it may be accessible to authorities in that jurisdiction in accordance with local law.

Where is your personal information kept and for how long?
Personal information may be kept in electronic or paper format at the offices of Smead Canada’s service providers, including SGGG Fund Services Inc., RBC Investor Services Trust and Smead US, in Canada and the United States, or in secure off-site storage facilities. Record retention laws and industry rules require that personal information be kept and updated for as long as an investment in a Fund is held and a service is provided, and for as long as legally necessary after that relationship ends in order to respond to any issue that may arise at a later date.

How is your information protected?
Since Smead Canada has no employees, the protection of personal information depends on the policies, procedures and safeguards maintained by Smead Canada’s service providers, including SGGG Fund Services Inc., RBC Investor Services Trust and Smead US, each of which is contractually required to maintain the confidentiality of personal information and to implement appropriate security safeguards. Smead Canada requests and reviews SOC, CSAE or equivalent reports, or other available due diligence, from its key service providers, and requires Smead US to maintain a cybersecurity governance framework, to help evidence that these safeguards are operating as expected. Personal information is generally in the form of account documentation and transaction records, which are protected by physical and electronic access controls, including passwords and access limited to personnel who need it to perform their function.

What privacy rights do you have?
Upon request, we will provide you with access to your personal information held by Smead Canada, and we will assist in directing requests relating to information held by your registered dealer or by SGGG Fund Services Inc. as applicable. We may also provide you with a list of third parties to whom your information was provided. We encourage you to review any information received from us or our service providers on a regular basis and to contact us to correct inaccurate, incomplete or outdated information. You may withdraw your consent for the use of your personal information by notifying us in writing of your intention to do so. Legal and other requirements may prevent you from withdrawing consent, and your decision to withdraw consent may mean that we, or your registered dealer, are no longer able to administer your investment in the Funds.

Further Information
These practices, and Smead Canada’s oversight of personal information handled by Smead US under the cross-border delegated model described above, are governed by Smead Canada’s internal Policies and Procedures Manual. If you have questions about how your personal information is handled, please contact us as set out below.

Contact Us
If you have any questions or concerns about this Privacy Policy, you may contact Smead Canada’s Chief Compliance Officer at:

Smead Capital Management (Canada) Ltd.
1 First Canadian Place, Suite 3400
Toronto, Ontario, Canada M5X 1A4
Email: info@smeadcap.com
Toll-free: 1-877-701-2883