Conflicts of Interest | Manulife Private Wealth

Manulife Private Wealth (“MPW”) is focused on satisfying the financial needs of its clients. It seeks to do so by offering investment counselling/portfolio management services via Manulife Investment Management Limited (“Manulife IM Limited”) and distributing prospectus-exempt investment products via Manulife Investment Management Distributors Inc. (“Manulife IM Distributors Inc.”). For more information about MPW, please speak with your Investment Counsellor.

In response to new regulatory requirements, we are providing you with the enhanced conflict of interest disclosures below. This chart identifies and explains existing and reasonably foreseeable material conflicts of interest that may affect your interests as our client and how we address these material conflicts of interest in the best interest of our clients. It is important for you to read through the updated disclosure below so that you can understand the nature and extent of material conflicts of interest and assess their impact and risks to you.

MPW, as a division of Manulife IM Limited and Manulife IM Distributors Inc., as well as a part of the Manulife group of companies, faces certain actual, potential or perceived conflicts of interest in the ordinary course of its role as investment counsellor for MPW client accounts. A conflict of interest is when the interests of different parties, such as you and MPW or you and your MPW Investment Counsellor, are inconsistent or divergent. Examples of conflict of interest are when:

MPW, or your Investment Counsellor has financial or other interests that are inconsistent with your best interests as a client;
MPW, or your Investment Counsellor, may be influenced to put their own interests ahead of your interests.

We have adopted policies and procedures to assist in identifying and addressing these material conflicts of interest. MPW’s employees, including our Investment Counsellors, have an obligation to identify, report and address any existing or reasonably foreseeable conflicts of interest. We address conflicts of interest by: (a) avoidance; (b) control; or (c) disclosure (or a combination of these). If we cannot effectively address a material conflict in your best interests, or the conflict is otherwise prohibited by law, we avoid it.

Please contact your Investment Counsellor if you would like more information about these changes.

Possible Conflicts of Interest

Conflict of Interest	Address By	Management of Conflicts
Dually Registered Employees - MPW’s Investment Counsellors are generally registered with both Manulife IM Limited for portfolio management activities and Manulife IM Distributors Inc. for exempt market distribution activities, including processing trades for clients that wish to purchase one or more funds. Investment Counsellors are compensated differently depending on whether they are providing discretionary services or advising on exempt products, which may incentivize them to promote the product or service that will earn more fees.	Disclose Control	- Our fee structures for all products and services are disclosed in our account opening documents. - We adhere to our internal policies and securities legislation that require that our Investment Counsellors make investment decisions that are “suitable” and in the best interests of their clients. - Investment Counsellors adhere to Investment Policy Statement for investment decisions and we have compliance program to monitor violations.
Outside Business Activities – MPW’s employees may engage in activities outside of their employment with Manulife. These activities could result in conflicts of interest if the obligations or activities, or the time commitment required in connection with those outside activities, conflicts with the MPW’s ability to provide clients with services or puts the employees in a position of influence over clients.	Control Avoid	- MPW’s employees are required to disclose and obtain pre-approval for all outside business activities. These activities are carefully documented and assessed. Some types of outside business activities are not permitted if we determine that there is a material risk of conflict of interest with clients that cannot be addressed in the clients’ best interests. - This process serves as verification that MPW’s employees are not involved in other business ventures that may conflict with the interests of MPW or our clients.
Gifts and Entertainment – MPW Employees may be offered gifts and entertainment in connection with services provided to clients. These gifts and entertainment have the potential to influence the employee to act in a manner that is not in the best interest of clients by compromising their objectivity.	Control	- MPW employees, in accordance with MFC’s Code of Business Conduct and Ethics and Manulife Investment Management’s Code of Ethics (collectively, “Manulife’s Code of Ethics”), are generally prohibited from accepting gifts, gratuities or favours that are not for legitimate business purposes or are otherwise of substantial value. - Compliance reviews the gifts and entertainment transactions and obtains confirmation from all employees, quarterly, that they are in compliance with the guidelines.
Personal Trading – An MPW employee’s personal investment activity may be in conflict with that of MPW’s client accounts. From time to time, your portfolio may purchase a security in which an MPW employee, or a related person of an MPW employee, may have an ownership interest. Related persons of an MPW employee may also purchase a security that is held in your portfolio.	Control Avoid	- Personal trading by MPW employees is substantially restricted by Manulife’s Code of Ethics. Personal trading of certain employees and their related persons are carefully monitored by Manulife Investment Management’s Compliance department.
Referral Arrangements - A referral arrangement includes any arrangement where compensation of any form is paid or received for referring a client to or from MPW, whether directly or indirectly. MPW has referral arrangements in place with various parties and has agreed to pay referral fees for potential clients who are referred to, and become clients of, MPW. MPW, as a division of Manulife IM Limited, may from time to time direct clients to other legal entities of and Manulife Financial Corporation (“MFC”), including Manulife Bank of Canada (“Manulife Bank”), and in doing so may receive shared revenue. Such referral arrangements could result in referrals influenced by the resulting compensation or benefit, rather than the best interests of the client. For clients who are referred to Manulife Bank and credit facilities, the client’s MPW Investment Counsellor will be compensated for the sale of the credit facility and will earn more overall in investment management fees if loans are reinvested with MPW because the loan value will increase the client’s assets under management.	Disclose Control	- All referral arrangements to which MPW is a party must be in writing using MPW’s standard form Referral Agreement, and all referral fees must be recorded on MPW’s books. - For client being referred to MPW, appropriate written disclosure of the referral arrangement, in accordance with securities laws, will be provided to the referred client either by the referring advisor prior to introduction to MPW, or by MPW at the time of client account opening. - MPW will take reasonable steps to ensure that the person or company has the qualifications and registrations to provide the referred services and that a written disclosure of the referral arrangement has been created and provided to the referred client prior to either the earlier of the opening of an account or providing any services by MPW or the person or company receiving the referral. - MPW employees are strictly prohibited from entering into personal referral arrangements or paying, or receiving, referral fees directly.
Related and Connected Issuers - An entity is a related issuer to Manulife IM Limited and/or Manulife IM Distributors Inc. if, through the ownership of, or direction or control over, voting securities or otherwise: the entity is an “influential security holder” of Manulife IM Limited and/or Manulife IM Distributors Inc.; Manulife IM Limited and/or Manulife IM Distributors Inc. is an “influential security holder” of the entity issuing securities; or if Manulife IM Limited and/or Manulife IM Distributors Inc. and the entity issuing securities are related issuers of the same third person or company. An entity is an “influential security holder” in an issuer if it directly, or together with its related issuers, owns either 20% or more of the securities of the issuer and/or is entitled to cast 20% or more of the votes with respect to the election or removal or directors of the issuer. A connected issuer means an issuer or selling security holder distributing securities where the issuer or selling security holder has a relationship with a person or company (e.g. Manulife IM Limited; Manulife IM Distributors Inc.; a related issuer of Manulife IM Limited and/or Manulife IM Distributors Inc.; a director, officer or partner of Manulife IM Limited and/or Manulife IM Distributors Inc.; or a director, officer or partner of a related issuer of Manulife IM Limited and/or Manulife IM Distributors Inc.) that may lead a reasonable prospective purchaser of the securities of the connected issuer to question whether Manulife IM Limited and/or Manulife IM Distributors Inc. and the issuer/selling security holder are independent of each other for the distribution of the issuer’s securities. See Schedule A for a list of our related or connected issuers. As part of our advising activities, we advise in connection with, or exercise our discretionary authority to, the purchase or sale of securities of related and/or connected issuers (i.e. affiliated funds, for which we or our affiliates earn management fees).	Disclose Control	- Except as permitted by any regulatory relief, MPW, Manulife IM Limited and Manulife IM Distributors Inc. will not recommend or advise with respect to the securities of any related or connected issuer except in compliance with securities laws, including any client disclosure requirements. MPW will deal with the securities of related and connected issuers in accordance with the following policies: MPW will deal fairly, honestly, and in good faith with its clients; MPW will maintain operational and decision-making autonomy in the management of clients’ funds and the selection of portfolio investments; and Investment decisions will be made on the basis of the business judgement of responsible MPW Investment Counsellors uninfluenced by considerations other than the best interests of the client. - We disclose that we advise in respect of investment products managed by ourselves and our affiliates and provide clients with disclosure of our affiliates and related and connected issuers in our Important Client Information brochure. We will update this list and notify you of any material changes.
Proprietary Products – MPW offers a range of affiliated and unaffiliated funds and separately managed account (SMA) models to seek to best meet client needs. Even though the client does not pay more for affiliated products, Manulife as a whole can earn more revenue if MPW chooses affiliated products, since our affiliates would earn management and other fees. Similarly, we would have a financial incentive to choose affiliates as service providers, sub-advisers and dealers over third parties that might be more cost effective, because of the fees our affiliates could earn. In addition, we may be disincentivized to pursue remedies or enforce rights against an affiliated serve provider as opposed to a third-party service provider.	Disclose Control	- MPW performs the same level of due diligence on all our proprietary products, as well as on the unaffiliated products. - MPW will also compare our products to certain other, similar, products on the market, to ensure our products’ compensation and similar aspects are in line. - MPW strictly follows the client’s investment objectives and strategies to make investment decisions that are suitable and best fit the client’s needs.
Proxy Voting - We may vote securities we purchase on behalf of clients, which can create a potential conflict if we have a financial interest, or other relationship with the entity whose securities we’re voting. We have a potential conflict if these voting rights influence our advice to clients or influence the way we vote the securities.	Disclose Control	- To address this conflict, and due to the volume and diversity of securities held by the accounts that it manages, MPW has retained a third-party service provider, namely Broadridge ProxyEdge (“Broadridge”), to assist it with proxy voting matters. Broadridge specializes in the proxy voting and corporate governance area and provides a variety of proxy advisory and voting administration services. These services include in-depth research, analysis, and voting recommendations as well as vote execution, reporting, auditing and consulting assistance. MPW may retain other proxy voting services in place of, or in addition to, Broadridge from time to time. - MPW’s standard instruction to the third-party vendor is to vote with the vendor recommendations. MPW has the discretion to deviate from any recommendation provided by Broadridge on general policy issues or specific proxy proposals.
Compensation and Incentive Practices - MPW and its Investment Counsellors are compensated, directly or indirectly, by the sale of products and the provision of services. Different products and services have different levels of compensation. As such, there may be incentives to promote the product or service that will earn more fees. We may also be incentivized to provide clients with more services in order to earn more fees.	Control	- Our fee structures for all products and services are disclosed in our account opening documents. - We adhere to our internal policies and securities legislation that require that our Investment Counsellors make investment decisions that are “suitable” and in the best interests of their clients. - We have compliance programs in place to monitor the decisions made by our Investment Counsellors and to identify and address any issues.
Client Complaints and Dispute Resolution - A client complaint creates a potential conflict of interest because MPW may have a choice between resolving the complaint in a manner that is beneficial to its own business interests or in a manner that is beneficial to you.	Disclose Control	- We address this conflict through adherence with MPW’s complaints policy, which requires MPW to follow a procedure that requires MPW to acknowledge your complaint as soon as possible and generally to provide a decision in writing within 60 days. It also includes letting you know how to utilize the services of Ombudsman for Banking Services and Investments (“OBSI”), an independent dispute resolution mechanism, and the name and contact information for OBSI.

Conflict of Interest

Address By

Management of Conflicts

Dually Registered Employees - MPW’s Investment Counsellors are generally registered with both Manulife IM Limited for portfolio management activities and Manulife IM Distributors Inc. for exempt market distribution activities, including processing trades for clients that wish to purchase one or more funds. Investment Counsellors are compensated differently depending on whether they are providing discretionary services or advising on exempt products, which may incentivize them to promote the product or service that will earn more fees.

Disclose

Control

- Our fee structures for all products and services are disclosed in our account opening documents.

- We adhere to our internal policies and securities legislation that require that our Investment Counsellors make investment decisions that are “suitable” and in the best interests of their clients.

- Investment Counsellors adhere to Investment Policy Statement for investment decisions and we have compliance program to monitor violations.

Outside Business Activities – MPW’s employees may engage in activities outside of their employment with Manulife. These activities could result in conflicts of interest if the obligations or activities, or the time commitment required in connection with those outside activities, conflicts with the MPW’s ability to provide clients with services or puts the employees in a position of influence over clients.

Control

Avoid

- MPW’s employees are required to disclose and obtain pre-approval for all outside business activities. These activities are carefully documented and assessed. Some types of outside business activities are not permitted if we determine that there is a material risk of conflict of interest with clients that cannot be addressed in the clients’ best interests.

- This process serves as verification that MPW’s employees are not involved in other business ventures that may conflict with the interests of MPW or our clients.

Gifts and Entertainment – MPW Employees may be offered gifts and entertainment in connection with services provided to clients. These gifts and entertainment have the potential to influence the employee to act in a manner that is not in the best interest of clients by compromising their objectivity.

Control

- MPW employees, in accordance with MFC’s Code of Business Conduct and Ethics and Manulife Investment Management’s Code of Ethics (collectively, “Manulife’s Code of Ethics”), are generally prohibited from accepting gifts, gratuities or favours that are not for legitimate business purposes or are otherwise of substantial value.

- Compliance reviews the gifts and entertainment transactions and obtains confirmation from all employees, quarterly, that they are in compliance with the guidelines.

Personal Trading – An MPW employee’s personal investment activity may be in conflict with that of MPW’s client accounts. From time to time, your portfolio may purchase a security in which an MPW employee, or a related person of an MPW employee, may have an ownership interest. Related persons of an MPW employee may also purchase a security that is held in your portfolio.

Control

Avoid

- Personal trading by MPW employees is substantially restricted by Manulife’s Code of Ethics. Personal trading of certain employees and their related persons are carefully monitored by Manulife Investment Management’s Compliance department.

Referral Arrangements - A referral arrangement includes any arrangement where compensation of any form is paid or received for referring a client to or from MPW, whether directly or indirectly. MPW has referral arrangements in place with various parties and has agreed to pay referral fees for potential clients who are referred to, and become clients of, MPW. MPW, as a division of Manulife IM Limited, may from time to time direct clients to other legal entities of and Manulife Financial Corporation (“MFC”), including Manulife Bank of Canada (“Manulife Bank”), and in doing so may receive shared revenue. Such referral arrangements could result in referrals influenced by the resulting compensation or benefit, rather than the best interests of the client. For clients who are referred to Manulife Bank and credit facilities, the client’s MPW Investment Counsellor will be compensated for the sale of the credit facility and will earn more overall in investment management fees if loans are reinvested with MPW because the loan value will increase the client’s assets under management.

Disclose

Control

- All referral arrangements to which MPW is a party must be in writing using MPW’s standard form Referral Agreement, and all referral fees must be recorded on MPW’s books.

- For client being referred to MPW, appropriate written disclosure of the referral arrangement, in accordance with securities laws, will be provided to the referred client either by the referring advisor prior to introduction to MPW, or by MPW at the time of client account opening.

- MPW will take reasonable steps to ensure that the person or company has the qualifications and registrations to provide the referred services and that a written disclosure of the referral arrangement has been created and provided to the referred client prior to either the earlier of the opening of an account or providing any services by MPW or the person or company receiving the referral.

- MPW employees are strictly prohibited from entering into personal referral arrangements or paying, or receiving, referral fees directly.

Related and Connected Issuers - An entity is a related issuer to Manulife IM Limited and/or Manulife IM Distributors Inc. if, through the ownership of, or direction or control over, voting securities or otherwise:

the entity is an “influential security holder” of Manulife IM Limited and/or Manulife IM Distributors Inc.;
Manulife IM Limited and/or Manulife IM Distributors Inc. is an “influential security holder” of the entity issuing securities; or
if Manulife IM Limited and/or Manulife IM Distributors Inc. and the entity issuing securities are related issuers of the same third person or company.

An entity is an “influential security holder” in an issuer if it directly, or together with its related issuers, owns either 20% or more of the securities of the issuer and/or is entitled to cast 20% or more of the votes with respect to the election or removal or directors of the issuer.

A connected issuer means an issuer or selling security holder distributing securities where the issuer or selling security holder has a relationship with a person or company (e.g. Manulife IM Limited; Manulife IM Distributors Inc.; a related issuer of Manulife IM Limited and/or Manulife IM Distributors Inc.; a director, officer or partner of Manulife IM Limited and/or Manulife IM Distributors Inc.; or a director, officer or partner of a related issuer of Manulife IM Limited and/or Manulife IM Distributors Inc.) that may lead a reasonable prospective purchaser of the securities of the connected issuer to question whether Manulife IM Limited and/or Manulife IM Distributors Inc. and the issuer/selling security holder are independent of each other for the distribution of the issuer’s securities.

See Schedule A for a list of our related or connected issuers.

As part of our advising activities, we advise in connection with, or exercise our discretionary authority to, the purchase or sale of securities of related and/or connected issuers (i.e. affiliated funds, for which we or our affiliates earn management fees).

Disclose

Control

- Except as permitted by any regulatory relief, MPW, Manulife IM Limited and Manulife IM Distributors Inc. will not recommend or advise with respect to the securities of any related or connected issuer except in compliance with securities laws, including any client disclosure requirements. MPW will deal with the securities of related and connected issuers in accordance with the following policies:

MPW will deal fairly, honestly, and in good faith with its clients;
MPW will maintain operational and decision-making autonomy in the management of clients’ funds and the selection of portfolio investments; and
Investment decisions will be made on the basis of the business judgement of responsible MPW Investment Counsellors uninfluenced by considerations other than the best interests of the client.

- We disclose that we advise in respect of investment products managed by ourselves and our affiliates and provide clients with disclosure of our affiliates and related and connected issuers in our Important Client Information brochure. We will update this list and notify you of any material changes.

Proprietary Products – MPW offers a range of affiliated and unaffiliated funds and separately managed account (SMA) models to seek to best meet client needs. Even though the client does not pay more for affiliated products, Manulife as a whole can earn more revenue if MPW chooses affiliated products, since our affiliates would earn management and other fees. Similarly, we would have a financial incentive to choose affiliates as service providers, sub-advisers and dealers over third parties that might be more cost effective, because of the fees our affiliates could earn. In addition, we may be disincentivized to pursue remedies or enforce rights against an affiliated serve provider as opposed to a third-party service provider.

Disclose

Control

- MPW performs the same level of due diligence on all our proprietary products, as well as on the unaffiliated products.

- MPW will also compare our products to certain other, similar, products on the market, to ensure our products’ compensation and similar aspects are in line.

- MPW strictly follows the client’s investment objectives and strategies to make investment decisions that are suitable and best fit the client’s needs.

Proxy Voting - We may vote securities we purchase on behalf of clients, which can create a potential conflict if we have a financial interest, or other relationship with the entity whose securities we’re voting. We have a potential conflict if these voting rights influence our advice to clients or influence the way we vote the securities.

Disclose

Control

- To address this conflict, and due to the volume and diversity of securities held by the accounts that it manages, MPW has retained a third-party service provider, namely Broadridge ProxyEdge (“Broadridge”), to assist it with proxy voting matters. Broadridge specializes in the proxy voting and corporate governance area and provides a variety of proxy advisory and voting administration services. These services include in-depth research, analysis, and voting recommendations as well as vote execution, reporting, auditing and consulting assistance. MPW may retain other proxy voting services in place of, or in addition to, Broadridge from time to time.

- MPW’s standard instruction to the third-party vendor is to vote with the vendor recommendations. MPW has the discretion to deviate from any recommendation provided by Broadridge on general policy issues or specific proxy proposals.

Compensation and Incentive Practices - MPW and its Investment Counsellors are compensated, directly or indirectly, by the sale of products and the provision of services. Different products and services have different levels of compensation. As such, there may be incentives to promote the product or service that will earn more fees. We may also be incentivized to provide clients with more services in order to earn more fees.

Control

- Our fee structures for all products and services are disclosed in our account opening documents.

- We have compliance programs in place to monitor the decisions made by our Investment Counsellors and to identify and address any issues.

Client Complaints and Dispute Resolution - A client complaint creates a potential conflict of interest because MPW may have a choice between resolving the complaint in a manner that is beneficial to its own business interests or in a manner that is beneficial to you.

Disclose

Control

- We address this conflict through adherence with MPW’s complaints policy, which requires MPW to follow a procedure that requires MPW to acknowledge your complaint as soon as possible and generally to provide a decision in writing within 60 days. It also includes letting you know how to utilize the services of Ombudsman for Banking Services and Investments (“OBSI”), an independent dispute resolution mechanism, and the name and contact information for OBSI.

Schedule A

List of Related & Connected Issuers

The following is a list of: (i) issuers related to Manulife IM Limited; and/or (ii) issuers who may be considered to be connected to Manulife IM Limited.

Related or Connected Issuer¹	Relationship to Manulife IM Limited
Manulife Financial Corporation (“MFC”)	Through its wholly owned subsidiary, Manulife (as defined below), MFC indirectly owns 100% of the shares of Manulife IM Limited. MFC is a reporting issuer whose securities are publicly traded on the Toronto Stock Exchange, the New York Stock Exchange, the Stock Exchange of Hong Kong Limited and the Philippine Stock Exchange.
The Manufacturers Life Insurance Company (“Manulife”)	MFC wholly owns Manulife, which in turn indirectly owns 100% of the shares of Manulife IM Limited. Manulife is an issuer whose securities are publicly traded.
Manulife Holdings Berhad (“MHB”)	MFC indirectly owns 59.45% of the shares of MHB. MHB is an issuer whose securities are publicly traded on the Kuala Lumpur Stock Exchange. MHB owns 100% of Manulife Insurance Berhad and Manulife Investment Management (Malaysia) Bhd.
Manulife Mutual Funds and Manulife Exchange Traded Funds	Manulife IM Limited is the investment fund manager, portfolio advisor, registrar and/or trustee of these funds.
Manulife Investment Management Pooled Funds	Manulife IM Limited manages a family of pooled funds which are offered to certain exempt purchasers. Except as noted, Manulife IM Limited is the manager and trustee/general partner of each of these pooled funds.
Manulife Canadian Real Estate Investment Fund and Manulife Canadian Property Portfolio	Manulife indirectly owns 100% of Manulife Private Funds (Canada) Inc., the general partner of each of these limited partnerships.
Manulife U.S. Real Estate Access Fund (for Canadian High Net Worth and Taxable Investors)	Manulife indirectly owns 100% of Manulife US Real Estate Private Access General Partner Inc., the general partner of the Manulife U.S. Real Estate Access Fund.
Manulife Canadian Private Debt Fund	Manulife indirectly owns 100% of Manulife Private Debt Funds GP Canada Inc., the general partner of the Manulife Canadian Private Debt Fund.
John Hancock Life Insurance Company (U.S.A.)	MFC also indirectly wholly owns John Hancock Life Insurance Company (U.S.A.), an insurance company that has issued notes to the public.
John Hancock Funds	John Hancock offers a broad range of financial products and services, including open and closed-end investment funds that may be deemed to be related issuers. Manulife IM Limited and/or its affiliates are portfolio managers to many of the John Hancock Funds.John Hancock offers a broad range of financial products and services, including open and closed-end investment funds that may be deemed to be related issuers. Manulife IM Limited and/or its affiliates are portfolio managers to many of the John Hancock Funds.
HNRG Funds (including Hancock timber and farmland funds)	Other John Hancock wholly-owned subsidiaries include Hancock Natural Resource Group, Inc. (“HNRG”) has sponsored a number of private agriculture and timber-related investment funds.
Other Foreign Manulife Investment Management Private Markets Funds	Manulife Investment Management Private Markets (US) LLC (formerly known as Hancock Capital Investment Management), LLC, another subsidiary, has sponsored other foreign-domiciled private funds offered in Canada, and investing in asset classes including private U.S. mezzanine debt, infrastructure, private equity, and U.S real estate.
Manulife Finance (Delaware), L.P.	An indirect wholly owned subsidiary of MFC that is a reporting issuer and has also issued debt securities to the public
Manulife Finance Holdings Limited	A direct wholly owned subsidiary of MFC that is a reporting issuer and has assumed responsibility for the debt securities originally issued to the public by The Manufacturers Investment Corporation.
Manulife Bank of Canada (“Manulife Bank”)	Manulife Bank is a Schedule I federally chartered bank and an indirect wholly-owned subsidiary of MFC. Manulife Bank of Canada serves clients across Canada in all provinces and territories. With a high-quality loan portfolio, the majority of loans being in residential mortgages. Manulife Bank of Canada also offers various demand deposit products.
Manulife Trust Company (“Manulife Trust”)	Manulife Trust is a federally chartered trust company. Manulife Trust offers select deposit products in nominee name and Preferred Rate Mortgages in all Canadian provinces and territories.
Whitecap Resources Inc.	Whitecap is an unaffiliated oil company in Alberta, Canada that entered into an agreement in an all-stock transaction valued at approximately $155 million to acquire Manulife subsidiary NAL Resources Limited (“NAL”). NAL is an oil and gas company with operations in Alberta and Saskatchewan. On January 4, 2021, Whitecap issued Manulife 58.3 million Whitecap shares in exchange for all NAL shares. Manulife owns approximately 12.5% of the combined entity, and has entered into a lock-up agreement for periods of 12, 15, and 18 months from the closing date of the transaction, with one-third to be released from the lock-up after each period.

Important disclosure

1 Investment funds sponsored by non-North American affiliates are not cited and generally not sold in Canada. If such securities are offered or recommended to a particular client, additional disclosures will be made to the client.