Legal & Regulatory

TERMS OF USE AND DISCLOSURES

By accessing this site, you signify your agreement with and understanding of the following terms of use and legal information pertaining to both this website and any information contained in it. This website is offered to you conditional; on your acceptance without modification of the terms, conditions, and notices contained herein. Your use of this site constitutes your agreement to all such terms, conditions, and notices. Polar Asset Management Partners (“Polar”) reserves the right to change the terms, conditions, and notices under which this site is offered.

INFORMATION ON THIS WEBSITE

The information provided on this website is for general informational purposes only. This website, and any information contained in it, is not, and under no circumstances is to be construed as, an invitation to make an investment in any funds (“Funds”) advised by Polar, nor does it constitute a public offering, solicitation or an offer to sell the Funds or buy or sell any other securities. It should not be relied upon when evaluating the merits of a potential investment in any securities. Performance data represents past performance and is not indicative of future performance.

Applications for the Funds will only be considered on the terms of the applicable offering memorandum and access to information about the Funds is limited to eligible investors who, among other requirements, qualify as accredited investors within the meaning of their respective local laws.

Facts and information provided on this website are believed to be accurate at the time they are posted. Although every effort has been made to ensure that the material contained herein is accurate, Polar does not guarantee its accuracy or completeness. Changes may be made at any time to the information on this website without prior notice. As such, Polar and its affiliates do not accept responsibility for any loss arising from the use of, or reliance on, the information contained herein.

This website provides links to other websites and resources. Such links are provided for your reference only. We do not control these sites and resources, and are not responsible for their availability, content or delivery of services. External sites are not bound by Polar’s online privacy policy; they may have their own policies or none at all. The inclusion of the links to other websites does not imply any approval or endorsement of the material on such websites.

PRIVACY POLICY

The following constitutes Polar’s privacy policy. Any questions arising from the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) as it applies to our day to day activity or questions from clients may be referred to Polar’s Chief Compliance Officer who is also designated as the firm’s “Privacy Officer” (as required by PIPEDA). We may amend this Privacy Policy from time to time to take into consideration changes in legislation or other issues that may arise. The most current version of the privacy policy will posted on this website.

PIPEDA outlines ten privacy principles, which form the basis of Polar’s privacy policy:

1. Accountability:
Polar’s Chief Compliance Officer is designated as the firm’s Privacy Officer. The Privacy Officer is responsible for ensuring compliance with PIPEDA throughout the firm.

2. Purpose:
Information collected from clients when new accounts are opened is restricted to that which is required by our regulators and as well as is required in order to provide the services requested by our clients.

3. Consent:
The knowledge and informed consent of the client providing the information must be obtained except where exempted by law.

4. Limited Collection:
The collection of personal information is limited to that which is necessary for the purposes identified to the client by the organization. The information is obtained by fair and lawful means only.

5. Limited Use, Disclosure and Retention:
Personal information may not be used or disclosed for purposes other than those for which it was collected, except with the informed consent of the individual or as required by law. Personal information will be retained only as long as necessary to fulfill these purposes or as long as required by our regulators.

6. Accuracy:
Personal information must be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

7. Security:
The personal information we collect is to be retained centrally in our client accounts files. Access to the area is restricted to employees of the firm.

8. Transparency and Awareness:
Polar will make its policies and practices regarding the collection, handling and retention of personal information available upon request.

9. Individual Access:
Upon request, an individual will be advised of the existence, use and disclosure of his or her personal information. They will also be given access to the information provided to Polar. An individual may also challenge the accuracy or completeness and provide amendments in the case of errors.

10. Recourse:
An individual may address a challenge concerning compliance with the above principles to Polar’s Privacy Officer, who can be reached at 416-367-4364 or at the following address:

Polar Asset Management Partners
Chief Privacy Officer
401 Bay Street, Suite 1900
P.O. Box 19
Toronto, Ontario M5H 2Y4

MAKING A COMPLAINT

Polar Asset Management Partners is registered as a securities dealer and may open accounts for clients to provide investment services. If you are a retail investor and have an account with Polar, you should feel comfortable contacting us whenever you have a question concerning these services.

Please feel free to contact us via telephone (416-367-4364) or by mail with your questions or comments. If you have a complaint we invite you to speak to the Chief Compliance Officer or to submit the details of your complaint in writing at the following address:

Polar Asset Management Partners
Compliance Department
401 Bay Street, Suite 1900
P.O. Box 19
Toronto, ON M5H 2Y4

In order to allow us to analyze your complaint, please include the following details when you contact us:
• Your name, contact information, and account number as well as the particular circumstances and details of your complaint, including all relevant dates.
• All relevant documentation, including details of meetings and/or discussions following those meetings that might clarify the situation.

We will acknowledge the receipt of your complaint in writing within 5 business days, giving you the name and the contact information of the person analyzing the complaint. Should you have any questions concerning the advancement of the file, we invite you to contact this person directly. We will strive to address your concerns and settle your complaint fairly and quickly.

We will contact you in writing at the latest 90 days after our investigation begins detailing the results and conclusions of our inquiry as well as the options available to you if the problem has not been resolved to your satisfaction.

If you are an investor in one of the funds managed by Polar purchased through an investment advisor at a securities dealer other than Polar, the responsibility for suitability of investments rests with that securities dealer. Therefore, in such cases, you must contact them with respect to any complaint you have about your investment.

Polar Asset Management Partners
Compliance Department
401 Bay Street, Suite 1900
P.O. Box 19
Toronto, ON M5H 2Y4

STATEMENT OF POLICIES

The securities laws of the Canadian Provinces and Territories require securities dealers and advisers, when they trade in or advise with respect to their own securities or securities of certain other issuers to which they, or certain other parties related to them, are related or connected, to do so only in accordance with particular disclosure and other rules. These rules require dealers and advisers, prior to trading with or advising their customers or clients, to inform them of the relevant relationships and connections with the issuer of the securities. Clients and customers should refer to the applicable provisions of these securities laws for the particulars of these rules and their rights or consult with a legal adviser.

Polar Asset Management Partners (Polar) will engage in activities as an investment dealer and may consider providing underwriting services. Polar will not, for any managed accounts or funds advised by Polar, make purchases of securities issued by its related issuers. If, in the course of its activities, Polar acts as agent or provides advice for the purchase or sale of securities of related or connected issuers, it will: 1. Disclose these facts in writing to purchasers and/or sellers of such securities; and 2. Comply with its standard practices and procedures in effect and in accordance with applicable legislation.

Polar provides fund management and investment advisory services to, and earns management and performances fees from, the entities listed below. Polar Multi-Strategy Fund (Canada), Polar Long/Short Fund (Canada), Polar Micro-Cap Fund, Polar Multi-Strategy Fund (Canada-I) and Polar Long/Short Fund (Canada-I) each an open-ended investment trust created under the laws of the Province of Ontario, and are related issuers to Polar.

ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT (AODA)

Polar is committed to providing an accommodating and inclusive environment for all individuals including our clients/customers, employees, job applicants, suppliers, and any visitors who may enter our premises, access our information or use our services. As an organization, we respect and uphold the requirements set forth under the Accessibility for Ontarians with Disabilities Act (2005), and its associated standards and regulations.

Polar has developed a Multi-Year Plan and certain policies and procedures to meet our obligations under the AODA. Our Multi-Year Plan and Accessibility policies are available for your review.

To review a full version of Polar’s Acessibility policies, please click here

To review Polar’s Multi-Year Plan, please click here

Clients who wish to provide feedback on Polar’s on the services provided to clients with disabilities can access Polar’s Client Feedback form here.

Should you wish to access these documents in a different format, please contact: Jennifer Schwartz, (416)369-8576, jschwartz@polaramp.com

 

DISCLOSURE REQUIREMENTS OF THE AIFMD