McCartney Low Vol Strategies

The fundamental investment objective of the Fund is to create a low to medium risk solution that provides above average risk adjusted returns. The Fund will primarily invest in Canadian and foreign securities listed on North American stock exchanges, including individual equities, bonds and exchange traded funds (“ETFs”). In addition, third party fund managers may be used through their institutional offerings to diversify management style and include hedging opportunities.

The Fund is a complete diversified portfolio solution. To create diversification from traditional equity and fixed income securities third party funds may include those that employ alternative investment management strategies and hedge funds. The individual and ETFs securities are listed exclusively on North American stock exchanges and are consistent with the Fund’s investment policies and restrictions set forth in the Offering Memorandum under “Investment Policies and Restrictions”. Investments in equity and ETF securities are not restricted by market sector, market capitalization or liquidity.

From time to time, the Manager may sell securities short, implement pairs trading strategies, invest in derivatives and may use leverage. The Fund, whether long, short or through derivatives, will primarily invest in securities of issuers listed on stock exchanges. The Fund may also hold any portion of its assets in cash or short-term money market investments as is determined necessary or advisable from time to time.

This information transmitted is intended to provide general guidance on matters of interest for the personal use of the reader who accepts full responsibility for its use, and is not to be considered a definitive analysis of the law and factual situation of any particular individual or entity. As such, it should not be used as a substitute for consultation with a professional accounting, tax, legal or other professional advisor. Laws and regulations are continually changing and their application and impact can vary widely based on the specific facts involved and will vary based on the particular situation of an individual or entity. Prior to making any decision or taking any action, you should consult with a professional advisor. The comments and information pertaining to the McCartney Low Vol Strategies (“The Portfolio”) are not to be construed as a public offering of securities in any jurisdiction of Canada. The offering of units of The Portfolio is made pursuant to the Offering Memorandum and only to investors in Canadian jurisdictions. Important information about The Portfolio is contained in the Offering Memorandum available through Willoughby Asset Management.

Commissions, trailing commissions, management fees, performance fees and expenses all may be associated with investments in The Portfolio. Investments in The Portfolio are not guaranteed, the values change frequently and past performance may not be repeated. Unit values and investment returns will fluctuate and there is no assurance that The Portfolio can maintain a specific net asset value. Mutual funds are not guaranteed, their values change frequently and past performance may not be repeated.

Harbourfront Wealth Management Inc. (“Harbourfront”) has relationships with related and /or connected issuers, which may include the securities or funds discussed in this commentary and are disclosed in our Statement of Policies Regarding Related and Connected Issuers. This policy is included in your new client package, on our website, or can be obtained from your investment advisor on request. The rate of return is used only to illustrate the effects of the compound growth rate and is not intended to reflect future values of the investment or returns on investment. Commissions, trailing commissions, management fees and expenses all may be associated with mutual fund investments. Please read the Offering Memorandum before investing.

This pool is available to clients of Harbourfront Wealth Management Inc. (“Harbourfront”) only, as outlined in the fund offering documents, available on our website at willoughbyasset.com. Harbourfront is an affiliate of the Fund Manager, the exclusive distributer of the fund, and receives fees for its advisory services as detailed in the Offering Memorandum. The Pool is a related or connected issuer to Harbourfront, as described in the Harbourfront Relationship Disclosure document and the Statement of Policies Regarding Related and Connected Issuers, which can be accessed at harbourfrontwealth.com.