Statement of Policies Regarding Related and Connected Issuers

Under certain circumstances we may advise you in respect of securities transactions where the issuer of the securities or the other party to the transaction is a corporation or party having an ownership or business relationship with us.

Since these transactions may create a conflict between our interests and yours, we are required by securities laws to disclose to you certain relevant matters relating to the transactions. When we trade in or advise with respect to securities of certain other issuers to which we are related or connected, we are required to do so only in accordance with particular disclosure and other rules. Those rules require us to inform you of the relevant relationships and connections with the issuer of the securities prior to trading with or advising you.

Issuers that are related to Rothenberg Wealth Management are those that, through the ownership of or direction or control over voting securities or otherwise, exercise a controlling influence over Rothenberg Wealth Management, or Rothenberg Wealth Management exercises a controlling influence over them.

Issuers that are connected to Rothenberg Wealth Management are those that have any relationship with Rothenberg Wealth Management or any of its related issuers, or any officers or directors of either, that may lead a reasonable prospective purchaser of the securities to question if we and the issuer are independent of each other in a distribution of the connected issuers securities.

Before we advise you with respect to the purchase or sale of any securities of a related issuer, or in the course of an initial distribution of securities of a connected issuer, we will disclose the relationship to you prior to giving advice.

Before entering into a contract for the sale or purchase of the securities of a related issuer, and before accepting payment in connection with any such trade, our relationship with the related issuer will be specifically disclosed to you.

If you have given us the authority to exercise discretion in the purchase or sale of securities for your managed account, we will not exercise that discretion for the types of transactions described above unless we have disclosed the relevant relationship to you, and you have given your specific written consent.

The confirmation which is prepared and sent to you for the trade of any securities of a related issuer will contain the required disclosure.

Related Entities:

Rothenberg Wealth Management has a connection with the following entity:

• Harbourfront Wealth Management

 Connected Issuers:

Rothenberg Wealth Management has a relationship with the following issuers:

• Boston Institutional Pool
• Castlefront Global Balanced Pool
• Forsyth Private Real Estate Portfolios
• Laurier Private Equity Pool
• McCartney Low Vol Strategies
• Percy Harris Global Equity Pool
• Rockridge Private Debt & Real Estate Pool

 If you have questions or require further information with regards to the relationship between Rothenberg Wealth Management and the above listed entities or issuers, please contact our compliance department @ 1-800-811-0527.