The content of this website does not constitute an offer or solicitation for residents in the United States or in any other jurisdiction where Sterling Mutuals Inc. is not registered or permitted to conduct business. Mutual funds provided through Sterling Mutuals Inc. Commissions, trailing commissions, management fees and expenses all may be associated with mutual fund investments. Please read the prospectus carefully before investing. Mutuals funds are not guaranteed, their values fluctuate frequently and past performance may not be repeated. Copies of the prospectus are available from your financial advisor and the mutual fund companies. Insurance products available through Sterling Insurance Agency or multiple carriers. Insurance products, financial planning, tax preparation and other related financial services that may be offered by your advisor other than mutual fund products are not the business of, or monitored by Sterling Mutuals Inc.
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.
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.
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 Canadian Investment Regulatory Organization, 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
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.
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.
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.
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.
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.
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.
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.
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.
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
Sterling Mutuals Inc. ("Sterling") takes client complaints, written or verbal, very seriously. If you have concerns regarding your account(s), your Sterling Advisor and/or one of our staff, we have developed the following detailed complaint procedures in order for us to address your concerns in a timely manner.
When submitting a complaint, written or verbal, to Sterling it is important to include a few important items regarding your account information such as: Name of your Sterling Advisor or name of applicable Staff Your account number(s) The details of your complaint and all applicable supporting documentation Your contact information You can submit your complaint: Via mail Sterling Mutuals Inc. (Attention: Som Houmphanh, Chief Compliance Officer) 1090 University Ave. West 2nd Floor Windsor, Ontario Via email complaints@sterlingmutuals.com Via fax 519-256-9730 Via phone 1-800-354-4956
Upon receiving your written or verbal complaint, Sterling will issue a letter to you acknowledging receipt within 5 business days. This Acknowledgement Letter will provide a summary of our investigation procedures and the name and contact information of the senior Compliance person assigned to investigate your concerns and will include an industry brochure that outlines alternate methods of dispute resolution available to you.
Our internal complaint handling process includes a thorough review of your complaint including reviewing all relevant supporting documentation, meeting notes and logs, and may also include an interview with you and the advisor/staff member to determine if any breach of internal or regulatory policies occurred. This review will be conducted by an appropriately qualified member of our Compliance team and may take up to 90 days to complete. If we are unable to respond within the 90 day period, we will inform you of the reason for the delay and provide an estimated timeframe for when you can expect a response.
Upon completion of our review, Sterling will release to you a detailed substantive response letter of our findings. As required by industry regulators, our response will be released within 90 calendar days after receipt of the complaint which may include an offer to resolve or deny your complaint with reasons. You will be provided an industry brochure with our substantive response letter that outlines alternate methods of dispute resolution available to you if you are not satisfied with our response. If a delay occurs and we are not able to provide a substantive response within 90 days, we will provide you with a written explanation for the delay and an expected date of completion.