/ Investor Letters

The Ravenstone Equity Fund is open to Accredited investors only. To learn more about if you qualify as an Accredited Investor please contact Ravenstone Capital at 416.322.2067 or 1.888.234.2715.

I'm an Accredited Investor

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Accredited Investor Definition (NI 45-106):

• (a) except in Ontario, a Canadian financial institution, or a Schedule III bank,
• (b) except in Ontario, the Business Development Bank of Canada incorporated under the Business Development Bank of Canada Act (Canada),
• (c) except in Ontario, a subsidiary of any person referred to in paragraphs (a) or (b), if the person owns all of the voting securities of the subsidiary, except the voting securities required by law to be owned by directors of that subsidiary,
• (d) except in Ontario, a person registered under the securities legislation of a jurisdiction of Canada as an adviser or dealer,
• (e) an individual registered under the securities legislation of a jurisdiction of Canada as a representative of a person referred to in paragraph (d),
• (e.1) an individual formerly registered under the securities legislation of a jurisdiction of Canada, other than an individual formerly registered solely as a representative of a limited market dealer under one or both of the Securities Act (Ontario) or the Securities Act (Newfoundland and Labrador),
• (f) except in Ontario, the Government of Canada or a jurisdiction of Canada, or any crown corporation, agency or wholly owned entity of the Government of Canada or a jurisdiction of Canada,
• (g) except in Ontario, a municipality, public board or commission in Canada and a metropolitan community, school board, the Comité de gestion de la taxe scolaire de l’île de Montréal or an intermunicipal management board in Québec,
• (h) except in Ontario, any national, federal, state, provincial, territorial or municipal government of or in any foreign jurisdiction, or any agency of that government,
• (i) except in Ontario, a pension fund that is regulated by the Office of the Superintendent of Financial Institutions (Canada), a pension commission or similar regulatory authority of a jurisdiction of Canada,
• (j) an individual who, either alone or with a spouse, beneficially owns financial assets having an aggregate realizable value that, before taxes but net of any related liabilities, exceeds $1 000 000,
• (j.1) an individual who beneficially owns financial assets having an aggregate realizable value that, before taxes but net of any related liabilities, exceeds $5 000 000,
• (k) an individual whose net income before taxes exceeded $200 000 in each of the 2 most recent calendar years or whose net income before taxes combined with that of a spouse exceeded $300 000 in each of the 2 most recent calendar years and who, in either case, reasonably expects to exceed that net income level in the current calendar year,
• (l) an individual who, either alone or with a spouse, has net assets of at least $5 000 000,
• (m) a person, other than an individual or investment fund, that has net assets of at least $5 000 000 as shown on its most recently prepared financial statements,
• (n) an investment fund that distributes or has distributed its securities only to
  • (i) a person that is or was an accredited investor at the time of the distribution,
  • (ii) a person that acquires or acquired securities in the circumstances referred to in sections 2.10 [Minimum amount investment], or 2.19 [Additional investment in investment funds], or
  • (iii) a person described in paragraph (i) or (ii) that acquires or acquired securities under section 2.18 [Investment fund reinvestment],
• (o) an investment fund that distributes or has distributed securities under a prospectus in a jurisdiction of Canada for which the regulator or, in Québec, the securities regulatory authority, has issued a receipt,
• (p) a trust company or trust corporation registered or authorized to carry on business under the Trust and Loan Companies Act (Canada) or under comparable legislation in a jurisdiction of Canada or a foreign jurisdiction, acting on behalf of a fully managed account managed by the trust company or trust corporation, as the case may be,
• (q) a person acting on behalf of a fully managed account managed by that person, if that person is registered or authorized to carry on business as an adviser or the equivalent under the securities legislation of a jurisdiction of Canada or a foreign jurisdiction,
• (r) a registered charity under the Income Tax Act (Canada) that, in regard to the trade, has obtained advice from an eligibility adviser or an adviser registered under the securities legislation of the jurisdiction of the registered charity to give advice on the securities being traded,
• (s) an entity organized in a foreign jurisdiction that is analogous to any of the entities referred to in paragraphs (a) to (d) or paragraph (i) in form and function,
• (t) a person in respect of which all of the owners of interests, direct, indirect or beneficial, except the voting securities required by law to be owned by directors, are persons that are accredited investors,
• (u) an investment fund that is advised by a person registered as an adviser or a person that is exempt from registration as an adviser,
• (v) a person that is recognized or designated by the securities regulatory authority or, except in Ontario and Québec, the regulator as an accredited investor, or
• (w) a trust established by an accredited investor for the benefit of the accredited investor’s family members of which a majority of the trustees are accredited investors and all of the beneficiaries are the accredited investor’s spouse, a former spouse of the accredited investor or a parent, grandparent, brother, sister, child or grandchild of that accredited investor, of that accredited investor’s spouse or of that accredited investor’s former spouse;

Disclaimer and Privacy Notice

The information and /or materials contained in Ravenstone Capital Management Inc. (“RCM”) electronic transmissions are derived from sources believed to be reliable when transmitted and are intended for the named recipient only. Information and/or materials contained therein is for informational purposes only, and does not constitute an offer or solicitation by anyone in any jurisdiction in which an offer or solicitation cannot legally be made, or to any person to whom it is unlawful to make a solicitation.

RCM reserves the right to monitor and archive all electronic communications through its network. Such electronic communications are collected and maintained in accordance with applicable federal and provincial privacy laws, and RCM’s Privacy Policy.

Conset to Electronic Delivery of Documents

By clicking Accept you consent to the electronic delivery of the documents listed below that Ravenstone Capital Management Inc. (“RCM”) elects to deliver electronically, either directly or through its service providers, as follows:

1. Reports or investment commentary as RCM may choose to provide will be delivered electronically and/or electronic notifications will be sent indicating that the documents are available for you to access pursuant to this consent.
2. All documents delivered electronically and/or notifications that electronic documents are available for you to access will be delivered by email to the address provided.
3. You understand that your consent may be revoked or changed, including any change in the electronic mail address to which documents are delivered, at any time by notifying RCM of such revised or revoked consent by telephone, regular mail or electronic mail at the contact information:

   Ravenstone Capital Management Inc.
   30 Soudan Ave., Suite 200
   Toronto, ON, M4S 1V6
   (416) 322-2067
   info@ravenstonecapital.ca
   

4. You understand that you are not required to consent to electronic delivery of the above documents. However, you may not withdraw consent for the delivery of communications mandated by applicable securities regulators, but you may opt to receive such communications by postal mail.

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Privacy Notice

Ravenstone Capital Management Inc. (“RCM”) values the privacy and security of information about our clients. We may collect and retain certain information about you in order to provide products and services to you, including portfolio management services, to facilitate investment in investment products, and to engage in marketing and advertising in relation to the products and services that we offer. We strive to protect your privacy and the confidentiality of personal information that you provide to us. Our privacy policy and personal information handling practices protect such personal information in accordance with applicable federal and provincial privacy laws.

Our collection of your personal information

Personal information refers to information that identifies you. In order to provide our products and services to you and to comply with applicable securities and other laws, we will ask you to provide certain personal information. The nature of the personal information that we collect may be different depending on the product or service we are providing to you.

Personal information is received by us from you or from your advising or dealing representative with your consent. We may also receive your information with your consent from other sources, such as our affiliates or other financial institutions, or through our website. Where you provide us with the personal information of another person (for example, your spouse), we understand you to have the consent of that person or be otherwise authorized to do so.

Our use of your personal information

We collect and use your personal information responsibly and only for the purpose for which it was collected and as otherwise permitted or required by law. Your personal information allows us to: establish your identity; open and administer your account; provide investment products and services to you; communicate with you; make you aware of other products and services (unless you have indicated that you would prefer not to receive such information); and comply with our recordkeeping, reporting and other obligations under applicable law.

Our disclosure of your personal information

We may disclose your personal information in the following circumstances:

• Service providers and agents – We may disclose your personal information to our service providers and agents, including RCM affiliates, in connection with our provision of investment products and services to you and the management and administration of your account. Our service providers and agents are obligated to maintain the confidentiality of your personal information and may not use your personal information except in connection with the product or service they are providing to RCM in connection with the investment products and services that RCM is providing to you.
• Referral arrangements – We may provide you and another party with one another’s contact information where RCM has a referral arrangement in place with that party. In these circumstances, you will be provided with any disclosures required by applicable securities laws in connection with such a referral arrangement.
• As permitted or required by law – We may disclose your personal information where it is permitted or required by law, including to securities regulatory authorities, which require information about our current and former clients from time to time.
• Reorganization – We may disclose your personal information in connection with a reorganization of RCM, such as a corporate reorganization, or merger or amalgamation with another entity, or a reorganization of our business lines, or a transfer or sale of all or a portion of RCM’s business.

Your consent

By engaging us to provide investment products or services to you, or by otherwise providing us with your personal information, you are indicating your consent to our collection, use and disclosure of your personal information in the manner described in this document.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice to permit us to effect the change, by contacting your advising or dealing representative or RCM’s Privacy Officer as noted below. Legal and other requirements may prevent you from withdrawing consent and your decision to withdraw personal information may also limit the services or products we are able to provide to you.

Location of your personal information

We store and process your personal information in Toronto, Canada. However, your personal information may be transferred to other locations, including locations outside of Canada, in which personal information is stored or processed by RCM. The laws of other countries regarding the collection, use, and disclosure of personal information may be different from the laws of Canada.

Safeguarding personal information

Safeguards are in place at RCM to protect personal information against loss and misuse, as well as unauthorized access, disclosure, copying, use, or modification regardless of the format in which it is held. Your personal information may be kept in electronic or paper format at the offices of RCM or its services providers or agents, including RCM affiliates, or in secure off-site storage facilities.

Keeping personal information accurate

RCM relies on the accuracy of the personal information provided by its clients and others. We take steps to ensure that all personal information on file is accurate, complete and up-to-date. If any information about you changes, or you have any concerns regarding the accuracy of the information about you held by RCM, please contact your advising or dealing representative or RCM’s Privacy Officer as noted below.

Access to your personal information

Upon request, we will provide you with access to your personal information as permitted or required under applicable law. In limited circumstances set out in applicable privacy law, we may be unable to provide access to certain pieces of information.

Changes to this privacy policy

RCM may amend or update its privacy policy and personal information handling practices from time to time. RCM will provide its clients with access to its updated policy.

For more information

If you have any questions or concerns regarding RCM's privacy policy or our personal information handling practices, please contact our Privacy Officer by e-mail at info@ravenstonecapital.ca or at the following address:

Ravenstone Capital Management Inc.
30 Soudan Ave., Suite 200
Toronto, ON, M4S 1V6