Investment

Wealth Management investment advisory and brokerage services RBC Wealth Management offers a wide variety of account programs with a broad range of features and benefits. We help meet your wealth management needs in our capacity as an investment adviser and/or a broker-dealer. This is based upon the services you request to fulfill your investment objectives. The majority of our financial advisors are able to provide both brokerage and advisory services. Some services require additional qualification and licensing. Investment advisory services RBC Wealth Management offers several programs designed to help individuals achieve their investment objectives. We focus on strategic planning issues such as asset allocation (the portfolio’s investment structure) with our clients. Through the consulting process we work with our clients to design, implement and monitor an investment plan that will help them meet their financial objectives. Programs include discretionary account management, non-discretionary advisory services, and advice in selecting money managers, mutual fund and exchange traded fund managers. When you engage us in one of these programs, we provide you with the Advisory Programs Terms & Conditions and Disclosure Document. This booklet will cover the details of the program(s) you’ve selected and, among other things, advisory services, fees, our business activities and industry affiliations, and conflicts between our interests and your interests. Asset-based fee For the majority of our advisory programs, you will pay a fee based on the value of the assets in your account. This fee is charged quarterly in advance and covers, among other things custody, execution (the cost of trades) and clearing in addition to the advice you receive from us. Your financial advisor will receive a portion of the fee you pay us. Fiduciary responsibilities Investment advisory accounts are governed by the Investment Advisers Act of 1940 (Advisers Act). We have a fiduciary duty to your account consistent with the Advisers Act. This means that we must act in your best interest when making recommendations or investment decisions for your account and that these must be consistent with your investment objectives, suitable and appropriate. When conflicts of interest arise, we must place your interests before our own. In our capacity as a broker-dealer, investment banker, and investment adviser, we routinely engage in various securities transactions for our clients which could create conflicts of interest among our duties to you and our duties to other clients. As a full service brokerdealer, on an ongoing basis and as permitted by applicable law, we may, when appropriate: • Act as dealer or principal, buy securities from, or sell securities to, a client from our own account. • Act as broker or agent, effect securities transactions for compensation for a client. • Act as broker or agent for another client, effect transactions in which your securities are sold to or bought from a brokerage client. • Recommend to clients that they buy or sell securities or investment products in which we or a related person has some financial interest. • Buy or sell for our own account securities that we also recommend to clients. RBC Wealth Management has adopted and enforces internal processes with respect to conflicts of interest between our interests and your interests. When engaging in the activities mentioned above, we treat your orders fairly and do not give our own orders preference over your orders. Where required by applicable law or exchange rules, we obtain the consent of affected clients in advance of any transactions in which RBC Wealth Management will be engaging in the activities referenced above. When we engage in these activities, all statements and/ or confirmations of such transactions contain the disclosures required by applicable law and exchange rules. Code of ethics RBC Wealth Management is committed to ensuring that in our capacity as an investment adviser as well as a brokerdealer we: • Act in the best interests of our clients and not allow personal interests of those of the organization to take precedence over the interests of our clients; • Act with due skill, care and diligence in conducting our business and all transactions and trading activities; • Preserve client confidentiality at all times; • Respect the intellectual property rights of others; • Prevent and/or fully disclose any perceived or real conflicts of interest; • Protect and promote the integrity of the market; and • Preserve honesty, integrity and trust in all communications with clients, employees and shareholders. Objectives of the RBC Wealth Management Investment Adviser Code of Ethics: • To encourage and foster an organizational and work environment that prompts the internal reporting through a defined escalation path regarding violations of the Investment Adviser Code of Ethics as related to securities transactions, personal trading activities of employees and supervisory personnel, employee behavior, and the RBC Code of Conduct; • To promote compliance with applicable securities laws, rules, and regulations through leveraging an ethically-based approach; • To promote honest and ethical conduct by all employees, financial advisors, and executives including the ethical management of actual or apparent conflicts of interest between external, personal and professional relationships; • To promote full, fair, accurate, and understandable disclosure in reports, documents, and client communications that RBC Wealth Management creates, submits, and disseminates; and • To establish accountability on the part of employees, financial advisors, and executives regarding adherence to the Investment Adviser Code of Ethics. Brokerage services RBC Wealth Management provides a variety of services related to the investment of securities. These include executing trades, custody and clearing services, and in-depth investment research. We make recommendations to our clients on what types of securities are suitable for their investment objectives as well as when to buy, hold or sell these or other securities. There is not a separate charge for these recommendations or advice. It is our responsibility to ensure our dealings with you and your accounts are fair and reasonable in light of prevailing market conditions. The fees and/or commissions we charge you may not be excessive and must comply with the laws and regulations that cover brokerage business. When placing trades for your account we may act in the capacity as a broker (agent) or as a dealer (principal). We may trade with you for our own account (as principal) or for the account of an affiliate and may earn a profit as a result. This is done by a mark-up or mark-down of the security which we buy or sell on the other side of the trade from you. This “spread” is in addition to the commissions you pay us for the trade. We may also place trades for your account with other firms or exchanges which also seek to profit from the transaction. We will receive commissions, profits on principal trades and other charges; your financial advisor will receive a portion of the commissions we receive. More information As always, it is our privilege to assist you in achieving your financial goals. We encourage you to read your account documents carefully when considering the accounts and programs available at RBC Wealth Management. Should you have questions or wish to discuss your specific investment goals and objectives, please contact your financial advisor.