Legal Information

Sectoral Asset Management Inc. (Sectoral) recognizes that all personal information is private and confidential. Sectoral is committed to ensuring and protecting the privacy and confidentiality of its clients’ personal information. It is the intention of Sectoral, by way of this Privacy Policy, to comply with applicable privacy legislation. This policy briefly describes why and how we collect, hold, use and, if necessary, disclose your personal information. It also summarizes your right to have access to the information so as to correct same if necessary.

We reserve the right to change or update this privacy policy at our discretion.

If you have any questions about our privacy policies or your personal information, please contact Sectoral Client Services at 514-849-8777 x 250 or e-mail your questions to info@sectoral.com

We require your personal information in order to establish a relationship with you and provide you with the best possible service. For example, your signature, financial history, current financial position, social insurance number, age and other similar personal information allows us to:

• establish your identity;
• assess your eligibility for our investment products and services and our products and services suitability for you;
• continue to offer you the full range of products and services that we believe meet your changing needs;
• fulfill our obligations with respect to money laundering and anti-terrorist financing laws; and
• protect you and us from error and fraud.

Sectoral will only collect personal information as needed in order to complete necessary documentation, determine eligibility/suitability and/or to comply with legislation, regulations or policies.

Your personal information may be kept in electronic, microfilm or paper format at the offices of Sectoral or its third-party service providers. Your information may also be kept in secure off-site storage facilities. Sectoral will only retain your personal information for as long as needed in order to satisfy the stated purposes identified when the information was collected. In the event it is determined that an individual's personal information is no longer required, Sectoral will take the necessary measures to destroy, dispose, or erase the information in a manner that will ensure that the information cannot be found or used by an unauthorized party.

We may use your personal information for the following purposes:

• to identify you;
• to ensure our records are accurate;
• to establish and administer your account;
• to execute your transactions;
• to maintain, store, record and determine your account holdings and transaction records;
• to verify previously given information when necessary;
• to provide you and your representatives with account statements/information;
• to provide you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information that may be requested or needed to service your account;
• to provide you with quality customer service and support on your investment needs;
• to develop and offer additional products and services that we feel may be of interest to you;
• to protect the interests of Sectoral, such as relates to the collection of debt owed; and
• to meet legal and regulatory requirements, including investment eligibility and suitability obligations, as well as the collection of information under money laundering and anti-terrorist financing laws.

• we may have to contact other financial advisors or institutions, dealers or brokers or mutual fund companies in order to gather complete information necessary to properly service your account with us;
• we may also be compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant or other legally valid request or enquiry, including the disclosure of such information to foreign, Canadian, provincial or municipal governments, governmental agencies or organizations (for example, CRA or OSFI);
• we may disclose information to our accountants, auditors and lawyers in connection with the enforcement or protection of our legal rights, each of which is bound by its own confidentiality obligations with respect to personal information.

Our safeguards are supported by on-going communications to our employees about the importance of secure and confidential client information and the continual maintenance and periodic review of our privacy policies and procedures. While Sectoral’s employees may have access to your personal information to enable them to perform their duties in servicing you, they are subject to a strict code of conduct when it comes to such personal information and are instructed to use strict standards of care in handling personal information.

Consent of the Individual and Access to Information:
Sectoral will only use your personal information for the purposes identified in this Privacy Policy or as set out in any other agreement between Sectoral and yourself. If your personal information is required for any additional use, Sectoral will take the necessary steps in order to seek your additional consent which, in such cases, may be expressed in writing, orally or may be implied directly by yourself or your authorized representative. You may withdraw your consent for the use of your personal information by contacting Sectoral at any time subject to reasonable notice. 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.

Except in limited circumstances prescribed by law, you are entitled to access, through a written request, the personal information contained in your client record. You may verify this personal information and request that any inaccurate information be corrected. When requested and supported by sufficient identity information, Sectoral will provide you with your personal information as maintained in your client files. We recognize your right to your own information, how it is used and to whom it is disclosed. If an error or discrepancy is found in your personal information, we will act efficiently to correct the mistake. Sectoral strives to maintain accurate client information which not only helps us provide better customer service but also minimizes the potential misuse of personal information.

• the address you are connecting from;
• which pages are visited;
• what content is being downloaded; and
• the address of the web sites that you visited immediately before coming to Sectoral’s web site.

Sectoral uses this information to find out how many people visit its website and which sections of the website are visited most frequently. Sectoral may use this information to determine what type of information is most useful, improve this web site, address your specific needs, provide better customer service and for general Business Development purposes. The information may also be used to provide records of communication between Sectoral and you, and to comply with any legal and/or regulatory requirements.

Should you have a complaint or enquiry, please contact Sectoral Client Services at 514-849-8777 x 250 or e-mail your questions to info@sectoral.com

The measures outlined in this Privacy Policy are intended to provide clients with comfort that Sectoral's staff regards personal information with the utmost importance. This Privacy Policy was also created to provide the right of access to personal information and an avenue to address any concerns individuals may have about the use of their personal information.

Website Terms and Conditions
The materials on sectoral.com (the "Website"), which may include text, images, audio clips, video clips, software and other materials, are provided by Sectoral Asset Management Inc. ("Sectoral") for informational purposes only. By accessing this Website or downloading its content, you acknowledge having read the entirety of this Disclaimer and Terms and Conditions of Use, and agree to be bound, without limitation or qualification, by the terms and conditions set out in this Disclaimer and Terms and Conditions of Use. Sectoral may change the Website and the Terms and Conditions of Use at any time in its sole discretion without any notice to you. Each time you use the website, your use indicates your agreement to the Terms and Conditions of Use in current form. IF, UPON REVIEW OF THIS DISCLAIMER AND TERMS AND CONDITIONS OF USE, YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS WEBSITE, PLEASE EXIT THIS WEBSITE IMMEDIATELY.

Permitted Use
You agree that you are only authorized to visit and view this Website for your own personal/ informational use, and that you shall not duplicate, download, publish, modify or otherwise distribute the material on this Website for any purpose other than for personal, private and non-commercial use, unless otherwise specifically authorized by Sectoral to do so. You may not pass on the information contained in this Website to any person without the prior written consent of Sectoral. The information contained on this Website is subject to change and update at any time without prior notice and Sectoral may change, suspend, or discontinue your access to, or any aspect of, this Website at any time.

You understand and agree that in Sectoral's sole discretion, and without prior notice, Sectoral may without notice or liability, impose limits on certain features and services or restrict your access to all or portions of this Website, or exercise any other remedy available, if Sectoral believes that your use of this Website has violated or is inconsistent with this Disclaimer and Terms and Conditions of Use, or violates the rights of Sectoral, or any third party, or violates any applicable law. You agree that monetary damages may not provide a sufficient remedy to Sectoral for violations of this Disclaimer and Terms and Conditions of Use and you consent to injunctive or other equitable relief for such violations. Sectoral may release user information about you if required by law or subpoena.

No Investment Advice
Sectoral does not intend to provide, and is not providing, investment advice through this Website and does not represent that the securities or services discussed herein are suitable for, or will be available to, any or all investors. Nothing on this Website shall constitute an offer to sell or solicitation of an offer to buy products or services to anyone. Offers can only be made where lawful under, and in compliance with applicable law. The information provided on this Website is intended for informational purposes only and is not intended to constitute financial, investment, accounting, legal or tax advice, nor is it intended as an offer or solicitation with respect to the purchase or sale of any security. All persons and entities accessing the Website do so on their own initiative and are responsible for compliance with applicable local laws and regulations. You should consult directly with a representative of Sectoral or your other advisors to determine which products and services are available to you.

Caution About Forward-Looking Statements
Certain statements contained on this Website may constitute "forward looking" statements and are subject to risks and speak only as of the date such statements are made When used on this Website, such statements include such words as "anticipate", "believe", "could", "estimate", "expect", "intend", "may", "plan", "predict", "project", "scheduled", "will", "would" and other similar terms and phrases, including references to assumptions. . Sectoral assumes no obligation to update or revise the forward-looking statements contained on this Website to reflect new events or circumstances. Forward looking statements should not be read as assurances or guarantees of future performance or results. Accordingly, readers are cautioned not to put undue reliance on any forward-looking statement contained on this Website.

Information Accuracy
While Sectoral uses reasonable commercial efforts to ensure that the information contained on this Website is accurate, such information is provided on an "as is" and "as available" basis and may contain inaccuracies. Certain information on this Website may be provided to Sectoral by third parties, and Sectoral may not independently verify all such information. In addition, this Website could include typographical errors or out-of-date information. Sectoral does not in any way guarantee or warrant the currency, accuracy, completeness, non-infringement or authenticity of any information on this Website. SECTORAL DISCLAIMS ALL WARRANTIES AND/OR CONDITIONS, EXPRESS, IMPLIED OR STATUTORY, AS TO THE CONTENT OF, AND TO ANY MATTER RELATING TO, THIS WEBSITE, INCLUDING IMPLIED WARRANTIES AND/OR CONDITIONS OF NON-INFRINGEMENT, MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. UNDER NO CIRCUMSTANCES SHALL SECTORAL, ITS DIRECTORS, OFFICERS, EMPLOYEES, AGENTS OR REPRESENTATIVES, LICENSORS, THIRD PARTY SUPPLIERS, OR ANY OTHER PARTY INVOLVED IN CREATING, PRODUCING OR DELIVERING THIS WEBSITE BE LIABLE FOR ANY DAMAGES WHATSOEVER, INCLUDING, WITHOUT LIMITATION, DIRECT, INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES THAT RESULT FROM THE USE OF, OR INABILITY TO USE, THIS WEBSITE OR FROM INFORMATION PROVIDED ON THIS WEBSITE. THIS LIMITATION APPLIES WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, EXTRA CONTRACTUAL OR ANY OTHER BASIS, EVEN IF SECTORAL (OR ANY PARTY LISTED ABOVE) HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGE. BECAUSE SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SECTORAL’S (AND ALL SUCH PARTIES LISTED ABOVE), LIABILITY IN SUCH JURISDICTIONS SHALL BE LIMITED TO THE EXTENT PERMITTED BY LAW.

Intellectual Property
This Website is owned and operated by Sectoral. Sectoral retains all rights, title and interest on behalf of itself and (where applicable) its third party suppliers to the data, text, images and intellectual property used in this Website (the "Website Content"). You acknowledge and agree that ownership of this Website Content resides in Sectoral or its third party suppliers, and agree not to challenge, directly or indirectly, ownership in and to this Website Content, or the protection of such Website Content by national and international copyrights, trademarks, service marks, patents, patent registration rights, trade secrets, know-how or other proprietary rights and laws. Except as authorized herein, you acknowledge and agree that you may not, directly or indirectly, in any form, sell, license, rent, modify, distribute, copy, reproduce, transmit, publicly display, publicly perform, publish, adapt, edit or create derivative works from any Website Content. In addition, systematic retrieval of data or other information from this Website Content to create or compile, directly or indirectly, a collection, compilation, database or directory without Sectoral's express written permission is prohibited.

Links to other Websites and Downloadable Software
This Website contains links to facilitate your access to third party websites. Sectoral does not control any third party website and is not responsible for the contents of any linked website or any link contained in a linked website. Sectoral is providing such links to you for your convenience only and the inclusion of any link does not imply any representation, endorsement, investigation or verification by Sectoral of the linked website or information contained therein. Links to any downloadable software websites are also provided for your convenience only and Sectoral is not responsible or liable for any difficulties associated with downloading such software.

No Unlawful or Prohibited Use
As a condition of your use of this Website, you warrant to Sectoral that you will not use this Website for any purpose that is unlawful or prohibited by this Disclaimer and Terms and Conditions of Use. You are prohibited from posting or transmitting any unlawful, threatening, libelous, defamatory, obscene, scandalous, inflammatory, pornographic, or profane material or any material that could constitute or encourage conduct that would be considered a criminal offense, give rise to civil liability, or otherwise violate any law. Sectoral will fully cooperate with any law enforcement authorities or court order requesting or directing Sectoral to disclose the identity of anyone posting any such information or materials.

Indemnification
As a user of this Website, you agree to defend, indemnify and hold Sectoral harmless from any and all liabilities, costs and expenses, including attorneys' fees, arising from your use of the Website or your violation of the terms and conditions of this Legal Notice, Disclaimer and Terms of Use.

Severability
If any provision of this Legal Notice, Disclaimer and Terms of Use is invalid or unenforceable under applicable law, then it shall be, to the extent invalid or unenforceable, deemed omitted and the remaining provisions shall remain in full force and effect.

Miscellaneous
The terms and conditions of this Disclaimer and Terms and Conditions of Use constitute the entire agreement between Sectoral and the users of this Website with respect to their use of this Website. Sectoral's failure to insist upon or enforce strict performance of any provision of that agreement shall not be construed as a waiver of any right on its part. If any part of this Disclaimer and Terms and Conditions of Use is determined to be void, invalid or otherwise unenforceable by a court of competent jurisdiction, such determination shall not affect the remaining provisions hereof.

Sectoral Asset Management Inc is a financial service provider in Switzerland, providing services in the form of purchase and sales according to Art. 3 (c)(1) FinSA, to professional investors solely. Sectoral Asset Management Inc will not perform any appropriateness or suitability assessment and does not provide any services in the form of advice. According to Swiss Financial Services Act, client advisers of Sectoral Asset Management Inc must be registered with a Swiss client adviser register and the company must be affiliated with a Swiss ombudsman’s office unless an exemption to registration requirements applies. Sectoral Asset Management Inc is authorized and regulated by the AUTORITÉ DES MARCHÉS FINANCIERS (AMF) in Quebec, Canada as a Portfolio Manager, Investment Fund Manager, Exempt Market Dealer and Derivatives Portfolio Manager and is registered as Investment Adviser with the SECURITIES AND EXCHANGE COMMISSION in the U.S.

The costs and fees associated with the financial services furnished will be provided to you before the conclusion of a contract or before the purchase of an investment product.

Trading financial instruments contains opportunities but also bears risks. We recommend reading the brochure of the Swiss Bank Association (SBA) before trading financial instruments.

Prospective investors are referred to the Funds’ prospectus and KID for further information.Information on the individual financial products is available from your client advisor. We do not execute transactions on your behalf.

Conflict of Interest
Conflict of interest may occur when business interests are contrary to one another. If not mitigated, they may result in a financial disadvantage for our clients. Sectoral has adopted a policy to address actions and set forth processes to identify and manage conflicts of interest.

Client Segmentation
In accordance with the new Swiss Financial Services Act (FinSA), Sectoral Asset Management Inc, as a financial service provider, shall categorize its clients into one of the following segments: (1) Institutional Client, (2) Professional Client, (3) Retail Clients.
If you fall under one of the following categories, we will classify you as Institutional investor:

• financial intermediaries as defined in the Banking Act of 8 November 1934 (BankA), the Financial Institutions Act of 15 June 2018 (FinIA) and the CISA;
• insurance companies as defined in the ISA;
• foreign clients subject to prudential supervision as the persons listed under a and b above;
• central banks;

• public entities with professional treasury operations;
• companies/occupational pension schemes/other occupational pension institutions - with professional treasury operations;
• large companies meeting two of the following criteria: (1) balance sheet total of CHF 20 million; (2) turnover of CHF 40 million; (3) equity of CHF 2 million;
• private investment structures with professional treasury operations created for high-net-worth retail clients* (must meet the prescribed qualifying criteria)

* High-Net-Worth retail clients should satisfy one of the following criteria:

• on the basis of training, education and professional experience or on the basis of comparable experience in the financial sector, they possess the necessary knowledge to understand the risks associated with the investments and have at their disposal assets of at least CHF 500,000; or
• they have at their disposal assets of at least CHF 2 million.

If you wish to opt in and be classified under another category (Professional or Retail Investor), please contact us at heidi@sectoral.com.

Ombudsman Affiliation
Pursuant to Art. 79 para. 1 FinSA, financial service providers have the duty to inform their clients about the possibility of a mediation procedure with the ombudsman's office. This information must be provided (a) when the business relationship is entered into; (b) when a legal claim asserted by the client is rejected; (c) and at any time upon request. The ombudsman is neutral and can provide competent information as well as act as an independent mediator in disputes.
Sectoral is affiliated to Finanzombudsstelle Schweiz (FINOS)
Talstrasse 20
CH-8001 Zurich
Switzerland

This is the Cookie Policy for Sectoral Asset Management, accessible from https://www.sectoral.com

What Are Cookies
As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or 'break' certain elements of the sites functionality.

For more general information on cookies see the Wikipedia article on HTTP Cookies.

How We Use Cookies
We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies.

The Cookies We Set

• Site preferences cookies

In order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.

Third Party Cookies
In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

• This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
  For more information on Google Analytics cookies, see the official Google Analytics page.
• Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.
• From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.

More Information
Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren't sure whether you need or not it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.

However if you are still looking for more information then you can contact us at info@sectoral.com

Clients of Sectoral Asset Management Inc (“Sectoral”), who are not satisfied with an investment product or service, have a right to make a complaint and to seek resolution. Sectoral has procedures in place to handle written or verbal complaints received from customers in a fair and prompt manner.

Clients can make their complaint by contacting Sectoral Head Office or via email at info@sectoral.com.

Sectoral will acknowledge receipt of complaints promptly, generally within ten days upon registration of the complaint. Acknowledgement of written complaints will be received in writing. A verbal complaint may be acknowledged verbally.

Sectoral will review your complaint fairly, considering all relevant documents and information obtained from you, our records, our representatives, staff members, and any other relevant source.

Upon completing our review, we will provide you with our response, generally in writing and within 90 days unless we are waiting for additional information from you, the case is novel or complex, or there is some other reasonable cause for delay. A verbal complaint may be resolved verbally.

If you are not satisfied with our response, or we have not provided our response within 90 days, you have the option of escalating your complaint to the external and independent Ombudsman for Banking Services and Investments (“OBSI”). OBSI's services are free. For residents of Quebec, you may also request to transfer your complaint to the Autorité des marches financiers (“AMF”).

Sectoral will examine every complaint received in an impartial manner and will address the complaints received according to its regular complaint management procedures, within the context of this policy.