Regulatory Disclosures

Memberships: Velocity Trade Limited (VTL) is regulated by the Australian Securities & Investments Commission (ASIC) and holds an Australian Financial Services Licence (AFSL) No.329813. Velocity Trade Limited is also a market participant of the Australian Securities Exchange (ASX).

VTL Policies & Procedures:

• VTL Best Execution Policy and Order Handling Disclosure
• VTL Client Agreement

Memberships: Velocity Trade Capital Ltd. (VTC), a wholly owned subsidiary of Velocity Trade Holdings Ltd., is registered as an investment dealer in the provinces of Alberta, British Columbia, Ontario, and Quebec. Velocity Trade Capital is a member of the Canadian Investment Regulatory Organization (CIRO), the Canadian Investor Protection Fund (CIPF) and a participating organization of the Toronto Stock Exchange, TSX Venture Exchange. Velocity Foreign Exchange Services Ltd. is registered with FINTRAC as a Money Services Broker. Currently providing physically delivered FX to broker dealers, institutions and corporations.

   

Related & Connect Issuers: Velocity Trade is majority owned by institutions, however, the Company’s employees and founders represent the single largest shareholder block. National Instrument 31-103 Registration Requirements and Exemptions requires a registered firm to disclose certain information to each of its clients. The specific information that must be disclosed to a client includes a list of issuers who are related or connected issuers to Velocity. Please note that Velocity does not have any related or connected issuers at this time. If Velocity does identify any related or connected issuers, a list of those issuers will be listed on this page.

Important Details of the Client Relationship: Client focused reforms to investment regulations incorporate a higher standard of conduct, with emphasis on putting the interests of clients first. Velocity Trade Capital and its Representatives commit to acting in an ethical and professional manner, with the aim of understanding and responding to customer needs. For more details about the client relationship, services, product suitability, and how Velocity manages conflicts of interest, it is important to read this document: Relationship Disclosure Information

Accessibility Statement: Velocity is committed to ensuring digital accessibility for people with disabilities. We are committed to building on the unique talents, experiences and perspectives of individuals, including employees, clients and others who have dedicated their lives to promoting accessibility.

The Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) aims to create a more accessible Ontario by identifying and, to the extent possible, eliminating barriers experienced by people with disabilities. The Integrated Accessibility Standards regulation (the “IASR”), enacted under the AODA, sets out obligations with respect to five accessibility standards in the areas of Information and Communications, Employment, Transportation, Design of Public Spaces and Customer Service.

We are continually improving the user experience for everyone and applying the relevant accessibility standards. We continue to review all of our websites for ease and accessibility. Here are some of the ways you can have a better experience doing your banking online with Velocity:

• Alternative text for images (particularly important if you use screen-reading software)
• Clear column headers making related information easy to find
• Headings to show the relative importance of information on a page
• Particular ways of communicating information other than through colour for people who cannot distinguish easily between colours
• A "Contact Us" section, which provides both a phone number and online contact information.

Velocity is further committed to ensuring that every firm employee receives equitable treatment with respect to employment, without discrimination, and receives accommodation in a timely manner where required, in accordance with the provisions of the Ontario Human Rights Code and the AODA and its regulations.

Velocity will ensure that appropriate training is provided on the requirements of the accessibility standards referred to in the IASR and on the Human Rights Code as it pertains to persons with disabilities. The training will be appropriate to the duties of the employee and refreshed when changes are made to Velocity Integrated Accessibility Standards Policy. New employees will be trained in a timely manner. Velocity will maintain a record of the training.

We are constantly looking for ways to improve. Please share your thoughts about Accessibility at Velocity using the information contained in the "Contact Us" section.

Complaint Handling: Velocity encourages you to follow the steps outlined below should you have a complaint.

1. Contact your representative at Velocity: Quite often complaints may be simple misunderstandings and can be resolved quickly over the telephone or in person. As a first step, please contact your Velocity representative if you have questions or concerns about a particular issue.
2. Submit your complaint in writing: If the problem you have is not resolved to your satisfaction after discussing with your representative at Velocity, please detail your complaint in writing and send it to the attention of the Velocity Designated Complaint Officer:

Office of the Velocity Designated Complaint Officer
100 Yonge Street, Suite 1800
Toronto, Canada
M5C 2W1

Once we have your complaint in writing it will be handled in accordance with the Velocity complaint process.

1. An acknowledgement will be sent by our Designated Complaints Officer within five (5) business days of receipt of your complaint. This acknowledgement will include a description of the next steps to be taken by Velocity, as well as other information, including a designated contact person, complaint reference number, the protocol you should follow once you have sent your complaint to us, and the timelines which we follow in order to process your complaint in a timely manner.
2. The entire process should take no longer than ninety (90) days before you are in receipt of a substantive response letter from the Designated Complaints Officer, which will include the following information:
   • A summary of your complaint;
   • Results of our investigation;
   • Final decision on the complaint, including an explanation from Velocity; and
   • A statement describing the options available to you should you not be satisfied with our response.
   Alternative options: If you have undertaken the above steps and your complaint has not been resolved to your satisfaction, please note there are other options available to you, including but limited to:
   1. Escalation to CIRO Enforcement or the Ombudsman for Banking Services;
   2. litigation or arbitration
   The Ombudsman for Banking Services will consider a client complaint at the earlier of:
   • The date the complaint substantive response is provided to the client; or
   • Ninety (90) days after the receipt of the complaint.
   More information can be found in the following brochures from CIRO: Making a Complaint, A Guide for Investors.
   • Making a Complaint: A Guide for Investors (Part 1 of 2)
   • How Can I Get My Money Back? A Guide for Investors (part 2 of 2)

Business Continuity Plan

Velocity has an established policy to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. In accordance with CIRO Rule 4700 in the event of a SBD Velocity Trade Capital is required to provide all clients with access to their assets within 48 hours following the event. Access to assets means the ability of our clients to buy, sell or redeem securities and have assets, including cash, delivered out based on the client’s instructions. In the event that we determine we are unable to continue our business, we will assure customers prompt access to their funds and securities.

Velocity has an uninterruptible power supply system to deal with temporary power outages which includes battery backup and surge protection. We also have redundant internet connections should our main connection go down. Both lines have firewalls, one line proving connectivity to the servers, the other serves as a backup, activated automatically if the primary line experiences a disruption.

VTC Policies & Procedures:

• Disclosure Statement of Rates and Fees
• VTC Best Execution Policy and Order Handling Disclosure – December 2023
• Trade Matching Statement (National Instrument 24-101)
• Relationship Disclosure
• CIPF Brochure and Publications

Memberships: Velocity Trade Limited is a wholly owned subsidiary of Velocity Trade Holdings Ltd. and registered as a Financial Service Provider FSP20003 with the Financial Markets Authority (FMA) of New Zealand.

Memberships: Velocity Trade Financial Services (Pty) Ltd is an authorised Financial Services Provider with the Financial Sector Conduct Authority of South Africa (FSCA) FSP No. 43295. Velocity Nominees (Pty) Ltd is an FSCA approved nominee and STRATE approved Transfer Secretary.

Velocity Trade International is authorised and regulated by the Financial Conduct Authority (FCA Registered Number 497263).

Velocity Trade’s fully owned subsidiary, VTC Europe B.V. (VTCE) is regulated as an investment Firm by Dutch Authority for the Financial Markets/ De Autoriteit Financiële Markten (AFM).

Remuneration policy: VTCE’s remuneration policy is designed to support key business strategies and to create a strong, performance-orientated environment. At the same time, the purpose of the policy is to attract, motivate and retain the company’s talent. The policy ensures that a significant proportion of the remuneration of executives and others is aligned with corporate performance. The variable remuneration for all employees is discretionary and designed to reward outstanding performance, is dependent on financial and non-financial criteria, and is in line with VTCE’s approach to risk. The company does not pay guaranteed bonuses. VTCE’s remuneration policy takes into account and complies with the Dutch Financial Supervision Act.

Management body: The members of the board of directors of VTCE comply with regulatory competency standards. They have been assessed and approved by the Dutch Authority for the Financial Markets in respect of their integrity and suitability. All board members will undergo constant training to ensure that they will maintain sufficient knowledge and skill levels. They will stay abreast of important industry and regulatory development to enable them to perform their duties adequately at all times.

VTCE Regulatory Reports

The content, including attachments, has been prepared by Velocity Sales and Trading personnel and is not a product of the Velocity Research Department. Any views or opinions expressed are solely those of the author and do not necessarily represent those of Velocity or any of its affiliates. This information is directed at institutional clients who have professional experience as defined by applicable law and/or regulation in the relevant jurisdiction. It is not for retail clients and it is not for distribution into any jurisdiction where this information is not permitted. Velocity trade desks are not subject to any prohibitions on trading prior to the dissemination of this information. The views are not independent or objective of the interests of the authors and other Velocity trading desks that execute orders in the financial instruments mentioned within and who may be compensated in part based on trading activity.

This information is provided on a confidential basis and may not be reproduced, distributed or transmitted in whole or in part without the prior written consent of Velocity. Information and/or other materials contained herein or attached hereto are for informational purposes only and do not constitute an offer or solicitation by anyone in any jurisdiction. The views do not include and are not intended as trading ideas or recommendations specifically tailored for the needs of any particular investor. Before acting on any information, you should consider the appropriateness of it having regard to your particular objectives, financial situation and needs and seek advice. No information set out above constitutes advice, an advertisement, an invitation, a confirmation, an offer or a solicitation, to buy or sell any security or other financial, credit or lending product or to engage in any investment activity, or an offer of any banking or financial service. Some products and/or services mentioned on this website may not be suitable for you and may not be available in all jurisdictions. All securities and financial products or instrument transactions involve risks. Past performance of any product described on this site is not a reliable indication of future performance.No part of the information provided should be construed as accounting, financial, legal, tax or other advice.

Velocity Trade may have or may in the future act in various roles including as underwriter, dealer, broker or financial advisor to issuers and may, where permitted by law, receive fees, brokerage or commission for acting in those capacities. Further, Velocity Trade and associated personnel may at any time buy, sell or hold interests in financial instruments referred to in this website. We may act as a liquidity provider or buy or sell securities and other products as principal or agent.

Due to the security risks involved in sending information over the Internet, Velocity cannot be held responsible for ensuring the confidentiality, reliability, accuracy, and integrity of this communication. This message may only be used for intended purpose of the sender and any other use by the recipient is strictly unauthorized and may not be used in any way that may have a negative adverse effect on the sender and the entities directly or indirectly associated with the sender. If you are not the intended recipient, you must not use it or take any action in reliance upon it. Please discard any paper copies, delete all electronic files of this communication, and notify the sender.

As a recipient of this message, you shall automatically be deemed to be in agreement with this disclaimer without further action, unless you otherwise advise Velocity in writing that you are not in agreement so such terms.

NOTICE REGARDING PRIVACY AND CONFIDENTIALITY: Velocity may, at its discretion, monitor and review the content of all email and voice communications, and use the information contained therein for any matter in its sole discretion.

For Canadians Only: Velocity Trade Capital Ltd. (Velocity) is a member of the Canadian Investment Regulatory Organization (CIRO), the Canadian Investor Protection Fund (CIPF) and participating member of all protected Canadian marketplaces including the Toronto Stock Exchange and TSX Venture Exchange. Pursuant to Canadian Anti-Spam Legislation, Velocity has implied consent from you as a member of the investment community with whom we have already established a relationship through business discussions or dealings, or your email address was made available to Velocity. However, if you are Canadian and wish to stop receiving any emails from Velocity, please contact the sender if you believe you have received this email in error and delete it to maintain confidentiality. Please note that this does not apply if you are an existing client, whereby CIRO or provincial/territory securities rules and regulations require us to continue to send you important electronic communications.

Velocity is committed to ensuring digital accessibility for people with disabilities pursuant to the Accessibility for Ontarians with Disabilities Act (AODA). We are committed to building on the unique talents, experiences and perspectives of individuals, including employees, clients and others who have dedicated their lives to promoting accessibility. Please share your thoughts about Accessibility at Velocity by reply to the sender or using the information on our Contact Us section.

Analyst Certification

In Velocity Research reports, Analysts confirm that all of the views expressed in their research accurately reflect the Analyst’s personal views about the subject company or companies and its or their securities. Velocity Research Analysts also certify that no part of their compensation was, is or will be, directly or indirectly, related to the specific recommendations or views in their research reports. The Analysts responsible for preparing research reports receive compensation from Velocity that is based upon various factors including Velocity Trade Capital Ltd. total revenues, a portion of which are generated by Corporate Financing activities at Velocity.

Research Disclosure

Velocity Trade Capital Ltd. (Velocity) is a member of the Canadian Investment Regulatory Organization (CIRO), the Canadian Investor Protection Fund (CIPF) and participating member of all protected Canadian marketplaces including the Toronto Stock Exchange and TSX Venture Exchange. The Research Distribution Policy of Velocity is to allow all clients that are entitled to have equal access to our research and all final research reports are disseminated to all clients and potential clients of Velocity at approximately the same time in electronic form. Clients may also receive Velocity research via third party vendors. CIRO Rule 3400 disclosures, analyst certification and other important disclosures can be found on the last page of the attached research report or obtained by writing to Velocity Trade Capital Ltd. 100 Yonge Street, Suite 1800, Toronto, Ontario, Canada, M5C 2W1.

Nothing in this research shall be construed as a solicitation to buy or sell any security or product, or to engage in or refrain from engaging in any transaction. In preparing this research, we did not take into account your investment objectives, financial situation or particular needs. Velocity sales department, trading personnel and other professionals may provide oral or written market commentary or trading strategies to our clients that reflect opinions which are contrary to the opinions expressed in this research. Before making an investment decision on the basis of this research, you need to consider, with or without the assistance of an adviser, whether the advice is appropriate considering your particular investment needs, objectives and financial circumstances. There are risks involved in securities trading. The price of securities can and does fluctuate, and an individual security may even become valueless. International investors and Wholesale Clients are reminded of the additional risks inherent in international investments, such as currency fluctuations and international stock market or economic conditions, which may adversely affect the value of the investment. This research is based on information obtained from sources believed to be reliable, but we do not make any representation or warranty that it is accurate, complete or up to date. We accept no obligation to correct or update the information or opinions in it. Opinions expressed are subject to change without notice. No member of Velocity accepts any liability whatsoever for any direct, indirect, consequential or other loss arising from any use of this research and/or further communication in relation to this research. Clients should contact registered representative at, and execute transactions through, a Velocity entity in their home jurisdiction unless governing law permits otherwise. Members of the Velocity Sales and Trading Department provide desk commentary that is not a product of the Velocity Research department and not subject to any other regulation.

This research has been prepared for the general use of the institutional clients of Velocity and must not be copied, either in whole or in part, or distributed to any other person. If you are not the intended recipient, you must not use or disclose the information in this research in any way.

If you have received this message in error or would like to be removed from this list, please click here or email us with the word 'REMOVE' in the subject line.

General Research Disclaimer

This research has been prepared for the general use of the institutional clients of Velocity and must not be copied, either in whole or in part, or distributed to any other person. If you are not the intended recipient, you must not use or disclose the information in this research in any way. If you received it in error, please tell us immediately by return e-mail and delete the document. We do not guarantee the integrity of any e-mails or attached files and are not responsible for any changes made to them by any other person. Velocity has established and implemented written policies and procedures to minimize conflicts of interest between its Clients and Velocity and its Analysts. Velocity does not allow its Analyst or household family members to hold or trade in any security on which the Analyst writes research reports. Other than what is disclosed below, Velocity is not aware of any material conflict of interest between itself and its Analyst and the Firm’s Clients. No employee, officer or director of Velocity is a director, officer or employee of the issuer or has received remuneration from the issuer, other than normal course investment advisory or trade execution services in the last 12 months. As with all employees of Velocity, a portion of the Analyst’s compensation may be derived from Investment Banking earnings. The Analyst does not receive any direct compensation from Investment Banking fees received from this issuer.

Nothing in this research shall be construed as a solicitation to buy or sell any security or product, or to engage in or refrain from engaging in any transaction. In preparing this research, we did not take into account your investment objectives, financial situation or particular needs. Velocity sales department, trading personnel and other professionals may provide oral or written market commentary or trading strategies to our clients that reflect opinions which are contrary to the opinions expressed in this research. Before making an investment decision on the basis of this research, you need to consider, with or without the assistance of an adviser, whether the advice is appropriate considering your particular investment needs, objectives and financial circumstances. There are risks involved in securities trading. The price of securities can and does fluctuate, and an individual security may even become valueless. International investors and Wholesale clients are reminded of the additional risks inherent in international investments, such as currency fluctuations and international stock market or economic conditions, which may adversely affect the value of the investment. This research is based on information obtained from sources believed to be reliable, but we do not make any representation or warranty that it is accurate, complete or up to date. We accept no obligation to correct or update the information or opinions in it. Opinions expressed are subject to change without notice. No member of Velocity accepts any liability whatsoever for any direct, indirect, consequential or other loss arising from any use of this research and/or further communication in relation to this research. Clients should contact analysts at, and execute transactions through, a Velocity entity in their home jurisdiction unless governing law permits otherwise. The date and timestamp for above share price and market cap is the closed price of the price date. #CLOSE is the final price at which the security is traded in the relevant exchange on the date indicated. Members of the Velocity Sales & Trading Department provide desk commentary that is not a product of the Velocity Research department and not subject to any other regulation

Research Dissemination Policy

The Research Distribution Policy of Velocity is to allow all clients that are entitled to have equal access to our research and all final research reports are disseminated to all clients and potential Clients of Velocity at approximately the same time in electronic form. Velocity equity research is posted to our proprietary website to ensure eligible clients receive coverage initiations and changes in ratings, targets and opinions in a timely manner. Additional distribution may be done by the sales and trading personnel via email, fax or other electronic means. Clients may also receive Velocity research via third party vendors.

Velocity also provides eligible clients with access to Velocity Verify on the Firms proprietary research portal, via email and via third-party vendors. Velocity Verify contains market insight and commentary regarding subject companies on which Velocity currently provides equity research coverage. Research Analysts may, from time to time, include short-term trade ideas in research reports and / or flash notes. A short-term trade idea offers a short-term view on how a security may trade, based on market and trading events, and the resulting trading opportunity that may be available. A short-term trade idea may differ from the price targets and recommendations in our published research reports reflecting the research analyst's views of the longer-term (one year) prospects of the subject company, as a result of the differing time horizons, methodologies and/or other factors. Short-term trade ideas are not ratings, nor are they part of any ratings system, and the firm generally does not intend, nor undertakes any obligation, to maintain or update short-term trade ideas. Short-term trade ideas may not be suitable for all investors and have not been tailored to individual investor circumstances and objectives, and investors should make their own independent decisions regarding any securities or strategies discussed herein. To receive Velocity research reports, please contact your Registered Representative. Reproduction of any research report in whole or in part without permission is prohibited.

Research ratings and recommendations

Velocity’s rating system reflects our outlook for expected performance of an issuer’s equity securities related to its peer group over the 12 months.

• Outperform rating represents a security that is expected to a return greater than its peer group.
• Neutral rating represents a security that is expected to provide a return in line with its peer group.
• Underperform rating represents a security expected to provide a return less than its peer group.

Research recommendation proportions – for the quarter ending December 31, 2023

• Outperform = 100%
• Neutral = 0
• Underperform = 0

Sensitivity Analysis: Clients receiving this report can request access to a model which allows for further in-depth analysis of the assumptions used, and recommendations made, by the author relating to the subject companies covered. To request access to ta model, please contact the Analyst.

Country Specific Research Disclosures

Australia: In Australia, research is issued and distributed by Velocity Trade Limited. Velocity Trade Limited is regulated by the Australia Securities & Investment Commission and holds an Australian Financial Service Licence (AFSL) No. 329813. Velocity Trade Limited is also a participating organization of the Australian Securities Exchange. There are robust information barriers established and maintained to protect the independence of research at Velocity. In spite of the strong controls, recipients of Velocity Research should be aware that inherent potential conflict of interests exist.

New Zealand: In New Zealand, research is issued and distributed by Velocity Trade Limited which is regulated by the Financial Service Provider FSP 20003.

United States: The Analyst that prepared this report is are not registered or qualified as research analyst with FINRA and is not subject to U.S. rules with regards to the preparation of research reports and the independence of analysts.

Velocity Trade Capital Ltd. distributes this research only to Major Institutional Investors in the United States through an SEC 15a-6 chaperoning agreement with Global Alliance Securities LLC. This research is not intended for the use of any person or entity that is not a Major Institutional investor. Any resulting transactions should be effected through a U.S. broker-dealer.

Regulation AC Certification: The Analyst that prepared this report hereby certifies that the views expressed in this report accurately reflect his personal views about the subject security and issuer. The author of this report further certifies that no part of his compensation was, is, or will be directly or indirectly related to the specific recommendation or views contained in this research report.

United Kingdom and the European Economic Area: Velocity Trade International Limited (VTI) is authorised and regulated by the Financial Conduct Authority (FCA Registered Number 497263). This report has not been approved by VTI. For purposes of section 21 of the Financial Services and Markets Act 2000 as it is being distributed only to persons who are investment professionals within the meaning of article 19 of the Financial Services and Markets Act 2000 Order 2005 and in not intended to, and should not be relied upon, by any other person.

Velocity and the Analyst that prepared this report based it on information we believe to have been reliable as of the date of publishing. We cannot be held responsible for any loss if the information was not correct or if it changed since this report was published. This report does not constitute an offer to sell or the solicitation of an offer to buy any of the securities discussed herein. Velocity has decided to absorb the cost to produce research and does not charge eligible clients for research. If you want to request archived research or past recommendations, please contact the Analyst.

This research has been prepared for the exclusive use of institutional and professional investors and should not be used or distributed to non-institutional investors. If you received this report in error, please immediately delete it and send a note by return email to the sender letting him/her know that you received it in error.

Singapore: Velocity Trade Pte. Ltd. is a Capital Markets Services Licensee with the Monetary Authority of Singapore (MAS).

South Africa: Velocity Trade Financial Services (Pty) Ltd is an authorised Financial Services Provider with the Financial Services Conduct Authority of South Africa, FSCA No. 43295.