CAPSTONE ASSET MANAGEMENT INC.

Website LEGAL DISCLOSURES

Legal Notice and Terms of Use

These website terms and conditions of use (the "Terms") constitute a legal agreement between you and Capstone Asset Management Inc. ("Capstone," "we," "us," or "our"). The following Terms govern your access to and use of www.capstoneassets.ca (the "Website") and all content, functionality, and services offered therein.

BY ACCESSING OR USING THE WEBSITE, YOU ACCEPT AND AGREE TO BE BOUND BY THESE TERMS AND OUR PRIVACY POLICY. IF YOU DO NOT AGREE TO THESE TERMS, YOU MUST NOT ACCESS OR USE THE WEBSITE.

1. General Information

Capstone Asset Management Inc. is registered as an investment fund manager, portfolio manager and exempt market dealer in British Columbia and other Canadian jurisdictions. Our principal regulator in Canada is the British Columbia Securities Commission.

Our Registration:

• Portfolio Manager: British Columbia, Alberta, Manitoba, Ontario, Quebec and Newfoundland and Labrador

• Investment Fund Manager: British Columbia, Manitoba, Ontario, Quebec and Newfoundland and Labrador

• Exempt Market Dealer: British Columbia, Alberta, Saskatchewan, Manitoba, Ontario, Quebec, New Brunswick, Nova Scotia and Newfoundland and Labrador

Capstone is a privately-held investment management firm and our head office is located at #210 - 19923 80A Avenue, Langley, British Columbia, V2Y 0E2.

Information provided on this Website is intended for informational purposes only and should not be considered investment, financial, legal, tax or accounting advice, and should not be relied upon in that regard. Many factors unknown to Capstone may affect the applicability of any statement or comment made on this Website to your particular circumstances. You should not rely on the information for investment, financial, legal, tax or accounting advice. You should directly consult your financial professional or other advisors before acting on any information. Information on this Website should not be construed as an offer or solicitation by Capstone to provide investment management services or to buy or sell any products.

2. Products and Services

We offer comprehensive investment management services to individual and institutional clients. As a portfolio manager, we offer investment management services through discretionary managed accounts, as well as through investment funds and other pooled investment vehicles established and managed by us.

We also act as investment fund manager for funds that are “investment funds” for securities law purposes and funds that are not “investment funds” for securities law purposes, such as CSET and CSELP.

Capstone as an Exempt Market Dealer (EMD) is regulated by provincial securities authorities and must adhere to strict registration, compliance, and operational standards, including financial stability, client verification, and disclosure requirements. As an EMD, we distribute securities to qualified investors in reliance on exemptions from prospectus requirements under applicable securities laws. Clients purchasing securities through us in our capacity as an EMD will have a non-discretionary client relationship with us. There may be restrictions on your ability to liquidate securities of our funds. Any such restrictions will be set out in the disclosure document that you receive in connection with your investment. The content of this Website relating to exempt market products is solely for the purpose of providing information. It is not to be construed as a public offering of securities in any jurisdiction of Canada. The offering of exempt market products may be made pursuant to an Offering Memorandum or Information Memorandum and to those investors, who meet certain eligibility or minimum purchase requirements.

The Capstone mutual funds and ETFs (the “Public Funds”) are sold to the public by simplified prospectus in all provinces and territories of Canada. Important information about each Public Fund is contained in its simplified prospectus, Fund Facts or ETF Facts documents, which should be read carefully before investing.

For more information regarding our investment products contact your investment advisor.

3. Jurisdiction of Investors

Capstone products and services are only offered in jurisdictions where they may be lawfully offered for sale. All products and services are subject to the terms of applicable agreements.

This Website and its contents should not be considered an offer to sell or a solicitation to buy securities to any person residing in the United States or in any other jurisdiction in which such an offer or solicitation is unlawful, or to any other person to whom it is unlawful to make a solicitation. Investment products managed by Capstone will not be sold to any person unless such sales are permitted under the laws of the applicable jurisdiction. Capstone is not engaging in or holding itself as engaging in the business of advising others as to the investing in or buying or selling of securities in any jurisdiction where it would be unlawful for it to do so. Investors should contact their financial advisors for further details.

4. Rate of Return/Performance Disclaimer

Commissions, trailing commissions, management fees and expenses all may be associated with fund investments. Please read the prospectus or any offering documents before investing. The indicated rates of return are the historical annual compounded total returns net of fees and expenses payable by the fund (except for figures of one year or less, which are simple total returns) including changes in security value and reinvestment of all dividends/distributions and do not take into account sales, redemption, distribution or optional charges or income taxes payable by any security holder that would have reduced returns. Funds and performance are not guaranteed, their values change frequently, and past performance may not be repeated.

5. Forward-Looking Statements

This Website may contain forward-looking statements which reflect our current expectations or forecasts of future events. Forward-looking statements include statements that are predictive in nature, depend upon or refer to future events or conditions, or include words such as "expects", "anticipates", "intends", "plans", "believes", "estimates", "preliminary", "typical", and other similar expressions. In addition, these statements may relate to future corporate actions, future financial performance of a fund or a security and their future investment strategies and prospects. Forward-looking statements are inherently subject to, among other things, risks, uncertainties and assumptions which could cause actual events, results, performance or prospects to differ materially from those expressed in, or implied by, these forward-looking statements. These risks, uncertainties and assumptions include, without limitation, general economic, political and market factors in North America and internationally, interest and foreign exchange rates, the volatility of global equity and capital markets, business competition, technological change, changes in government regulations, changes in tax laws, unexpected judicial or regulatory proceedings, catastrophic events and the ability of Capstone to attract or retain key employees. The foregoing list of important risks, uncertainties and assumptions is not exhaustive. Please consider these and other factors carefully and not place undue reliance on forward-looking statements.

The forward-looking information contained on this Website is current only as of the date the statement was made. There should not be an expectation that such information will in all circumstances be updated, supplemented or revised whether as a result of new information, changing circumstances, future events or otherwise.

6. Biblically Informed Investment Approach

For certain investment funds, Capstone's investment approach incorporates a proprietary "Biblically Informed Overlay" analysis that seeks to identify companies managed in ways consistent with Biblical principles and Capstone's Biblical worldview. This approach involves both negative screening criteria and positive alignment criteria as detailed in the applicable fund documentation.

Negative Screening - We exclude companies exceeding thresholds for revenue from:

• Adult Entertainment (>1% of revenue)

• Abortion services or abortifacient drugs (zero tolerance)

• Alcohol and Tobacco (>5% of revenue)

• Non-Medically Regulated Cannabis (zero tolerance)

• Gambling (>5% of revenue)

• Controversial Weapons Manufacturing (>5% of revenue)

• Human Exploitation (zero tolerance)

Positive Alignment - We seek companies demonstrating:

• Respect for Human Life and Dignity

• Environmental Stewardship

• Community Engagement

• Biblically Consistent Conduct

There can be no guarantee that all investments will align with every investor's interpretation of Biblical values. The funds' Biblically informed investment approach may cause them to underperform or outperform similar funds that do not consider Biblical values. There can be no guarantee that portfolio companies will align with all investors' interpretations of Biblical values.

7. Material Conflicts of Interest Disclosure

Canadian securities laws require us to identify and address material conflicts of interest in our clients' best interests. We have identified the following material conflicts:

Proprietary Products Only

The Conflict: As an exempt market dealer, we offer only the investment products managed by Capstone and certain third-party investment products the issuers of which have entered into a distribution agreement.

How This May Impact You:

• Our product shelf is limited to Capstone-managed offerings and a small number of third-party issues

• We do not conduct comparative analysis against non-proprietary products

• Our suitability assessments do not consider the broad universe of third-party products

How We Address This Conflict:

• We do not receive dealer compensation or sales commissions

• Our representatives do not receive sales-based compensation

• We conduct thorough suitability assessments for each investment

• We maintain rigorous product due diligence procedures

• We encourage clients to seek independent advice if desired

Related and Connected Issuers

Certain entities and funds managed by Capstone are considered connected or related issuers:

CEO Common Ownership: The CEO of Capstone indirectly controls 100% of Capstone's voting rights and has ownership interests in Capstone Mortgage Services Ltd., which acts as mortgage administrator for certain Capstone mortgage funds.

How We Address This:

• All recommendations based solely on suitability assessments

• Same due diligence standards apply to all products

• Strict confidentiality policies prevent unauthorized information sharing

• No preferential treatment for connected party products

Fair Allocation of Investment Opportunities

When investment opportunities are limited, we ensure fair treatment through:

• First-come, first-served allocation methodology

• Prohibition on preferential treatment

• Documentation of all allocation decisions

• Pro-rata distribution when offerings are oversubscribed

Additional Conflicts

We have policies addressing:

• Personal trading by employees (pre-clearance requirements and restricted lists)

• Outside business activities (prior approval required)

• Gifts and entertainment (strict limits apply)

• Referral arrangements (full disclosure provided)

• Performance-based fees (suitability takes precedence)

• Management fee negotiations (standard fee schedule with limited exceptions)

Referral Arrangements

We have referral arrangements with certain third parties:

• Referring parties are not registered under securities laws

• Capstone is solely responsible for all registrant obligations

• Referring parties receive no direct compensation for referrals

• They may receive certain indirect benefits disclosed in offering documents

• Full details provided to affected clients separately

8. Account Types and Services

Managed Accounts: For discretionary portfolio management services, client assets are held at qualified custodians. We have trading authority but cannot transfer assets except in limited circumstances.

Exempt Market Investments: We do not hold client assets. Subscription monies go directly to fund accounts and ownership is recorded on fund registers.

Account Statements: Provided quarterly (or monthly upon request) showing:

• Transaction details

• Holdings and cash balances

• Investment performance (annually)

• Charges and compensation report (annually)

9. Fees and Compensation

Management Fees: Set out in investment management agreements or fund offering documents. We may offer limited fee negotiations based on specific criteria.

Transaction Charges: We generally do not charge commissions or trading fees. Any applicable charges are disclosed before transactions.

Our Compensation:

• Management fees from managed accounts, or

• Management fees from our funds

• Certain funds may include performance fees as detailed in the offering documents

• No dealer compensation or sales commissions

Impact of Fees: All fees reduce investment returns and compound over time as deductions from overall value.

10. Know Your Client and Suitability

If you purchase investment products or services directly from us, we are required by law to:

• Establish your identity

• Understand your financial circumstances, investment objectives, knowledge, time horizon and risk tolerance

• Ensure all investments are suitable and put your interests first

• Update this information regularly

If you purchase Capstone products through a third-party dealer, the above requirements are the responsibility of your dealer.

Trusted Contact Person: Individual clients are encouraged to provide a trusted contact we can reach in cases of suspected financial exploitation or diminished capacity.

11. Investment Risks

All investments involve risks that may include but are not limited to:

• Capital Risk: Potential loss of invested money

• Market Risk: Value fluctuations due to market changes

• Liquidity Risk: Difficulty selling investments quickly

• Concentration Risk: Our funds typically hold 20-30 securities

• Biblically Responsible Investment Risk: May perform differently to similar funds without values-based restrictions

• Currency Risk: For foreign investments

• Operational and Cybersecurity Risks

Specific risks for each investment are detailed in offering documents.

12. Additional Regulatory Disclosures

Anti-Spam Legislation: We obtain consent for commercial electronic messages. You may unsubscribe anytime.

Tax Reporting: We comply with FATCA and CRS requirements. Information about U.S. taxpayers and foreign tax residents is reported to CRA for exchange with foreign tax authorities.

Independent Review Committee: The IRC reviews conflict of interest matters for our public mutual funds. Annual reports available at our Website.

Trade Confirmations: Provided promptly for exempt market transactions with required transaction details.

Performance Benchmarks: Available upon request to assess investment performance against relevant indices.

13. Use of Website

You may use the Website only for lawful purposes and in accordance with these Terms. You agree not to use the Website:

• In any way that violates applicable laws or regulations

• To transmit any harmful, offensive, or unlawful material

• To interfere with or disrupt the Website's operation

• To attempt unauthorized access to any portion of the Website

14. Third-Party Links

The information contained on the pages of this Website is subject to modification and update from time to time without notice. Capstone does not guarantee or ensure either the accuracy, completeness, currency or authenticity of any Website content, functionality, or your transmission of any content from the Website to you.

Certain aspects of the Website have been prepared by persons independent from Capstone. Other sites that may be accessed from this Website by hypertext links are entirely independent of our Website. The inclusion of any site acknowledgments, identification of any person or entity on the Website, or any hypertext link to another person or entity shall not, in any manner, be construed as an endorsement of such person's or entity's site, products, services, or contributions to the Website.

Other sites which may provide access to this Website by hypertext links are entirely independent of our Website. Any direction by a third party to this Website shall not, in any manner be construed as an endorsement by Capstone of such party's site, products or services.

15. Login IDs, User IDs and Passwords

If you have been issued a Login ID and/or an access code to enable you to access the non-public areas of this Website, you are solely responsible for all activities that occur in connection with your Login ID and ensuring the safety and security of the access codes. You are not permitted to use the access codes for any purposes other than to receive the particular service offered by Capstone for which the access codes were issued. You are not authorized or permitted to share the access codes with any other party. Please notify Capstone immediately if you become aware of any disclosure, loss, theft or unauthorized use of your Login ID.

16. Intellectual Property

Certain names, words, titles, phrases, logos, icons, graphics or designs or other content in the pages of this Website may constitute trade names, registered or unregistered trademarks or service marks (collectively, the "trademarks") of Capstone or of third parties and are used under licence by Capstone. However, the display of the trademarks on this Website does not imply that a licence has been granted to any third party. All goodwill generated from the use of the trademarks on any website will enure to Capstone's benefit.

All information on this Website is protected under the copyright laws of Canada. The information is for your personal, educational and non-commercial use only and may be used and reproduced provided that it is not modified and that you maintain all copyright and other notices contained on the Website. The contents of the Website may not be otherwise used, copied, redistributed, reproduced, republished, stored in any medium, retransmitted, modified or broadcasted, in any form.

Nothing in this document shall be construed as conferring any right or licence under any copyright of Capstone or any other person who owns the copyright in the content provided on our Website.

Capstone disclaims any and all liability that may result from any unauthorized reproduction or use of the information from this Website.

Any unauthorized downloading, retransmission, or other copying or modification of trademarks and/or the contents of this Website may be a violation of any law that may apply to trademarks and/or copyrights and could subject the violator to legal action.

17. Privacy and Confidentiality

Capstone cannot ensure the privacy and authenticity of any information or instructions you send to us or that we send to you over the Internet. Capstone will not be responsible for any loss or damages you may incur if you communicate confidential information to us over the Internet or if we communicate such information to you at your request.

Email over the Internet is not a secure medium and privacy cannot be assured. Email communication is not confidential, is subject to possible interception or loss, and is also subject to possible alteration. Capstone is not responsible for and will not be liable for any loss or damages in connection with an email containing personal or confidential information sent by you to Capstone, or an email by Capstone to you at your request.

18. Disclaimers and Limitations of Liability

THE WEBSITE AND ALL CONTENT ARE PROVIDED "AS IS" WITHOUT WARRANTIES OF ANY KIND. CAPSTONE DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, CAPSTONE SHALL NOT BE LIABLE FOR ANY DAMAGES ARISING FROM YOUR USE OF THE WEBSITE, INCLUDING DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES.

Unless otherwise expressly indicated, all information is unaudited and there is no representation that the financial information has been prepared in accordance with generally accepted accounting principles.

Furthermore, Capstone does not represent or warrant that the Website will be available and meet your requirements, that access will be uninterrupted, that there will be no delays, failures, errors (including typographical) or omissions or loss of transmitted information, that no viruses or other contaminating or destructive properties will be transmitted or that no damage will occur to your computer system. You have the sole responsibility for adequate protection and backup of data and/or equipment and to take reasonable and appropriate precautions to scan for viruses or other destructive properties.

19. Modifications

Capstone reserves the right to modify these Terms at any time without notice. Your continued use of the Website constitutes acceptance of any modifications.

20. Governing Law

These Terms are governed by the laws of British Columbia and applicable federal laws of Canada. Any disputes shall be subject to the exclusive jurisdiction of the courts of British Columbia.

Privacy Policy

Capstone Asset Management Inc. ("Capstone") is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, disclose, and protect personal information.

What is Personal Information?

Personal information is any information about an identifiable individual, including name, address, email, social insurance number, financial information, and investment details.

Collection and Use of Personal Information

We collect personal information when you:

• Open an account with us

• Use our website or mobile applications

• Communicate with us

• Attend our events

• Subscribe to our communications

We use personal information to:

• Establish and manage your accounts

• Process transactions

• Provide investment management services

• Meet legal and regulatory requirements

• Communicate with you about products and services

• Improve our services

Disclosure of Personal Information

We may disclose personal information to:

• Service providers (custodians, recordkeepers, auditors)

• Regulatory authorities as required by law

• Your authorized representatives

• Financial advisors and dealers

We do not sell personal information to third parties.

Safeguarding Personal Information

We maintain physical, electronic, and procedural safeguards to protect personal information, including:

• Secure office facilities

• Encryption of sensitive data

• Access controls and authentication

• Employee training and confidentiality agreements

Your Rights

You have the right to:

• Access your personal information

• Request corrections to inaccurate information

• Withdraw consent (subject to legal requirements)

• Lodge complaints with privacy authorities

Contact Information

Privacy Officer
Capstone Asset Management Inc.
#210 - 19923 80A Avenue
Langley, British Columbia V2Y 0E2
Email: compliance@capstoneassets.ca
Phone: 1 (855) 437-7103

Complaint Handling Policy

Capstone is committed to addressing client complaints fairly and promptly. If you have a complaint:

Step 1: Contact us directly:

• Phone: 1 (855) 437-7103

• Email: compliance@capstoneassets.ca

• Mail: Chief Compliance Officer, Capstone Asset Management Inc., #210 - 19923 80A Avenue, Langley, BC V2Y 0E2

Step 2: We will acknowledge your complaint within 5 business days and provide a substantive response within 90 days.

Step 3: If you remain unsatisfied, you may contact:

• Ombudsman for Banking Services and Investments (OBSI): 1-888-451-4519

• British Columbia Securities Commission: 604-899-6500

Contact Us:
Capstone Asset Management Inc.
#210 - 19923 80A Avenue
Langley, British Columbia V2Y 0E2
Tel: (604) 546-1500
Toll Free: 1 (855) 437-7103
Email: compliance@capstoneassets.ca
Website: www.capstoneassets.ca

Investment Review Committee (IRC)

Each member of the IRC is independent of Capstone in that none has a direct or indirect material relationship with Capstone, a fund or any of their respective associates or affiliates. The purpose of the IRC is to review the decisions made on behalf of each fund to purchase, sell or continue to hold securities of a related company and to form an opinion whether such decisions were, and continue to be, in the best interest of the fund and: (a) represent the business judgment of the fund’s portfolio advisor, uninfluenced by considerations other than the best interests of the fund, (b) have been made free from any influence by a related company and without taking into account any consideration relevant to a related company, and (c) do not otherwise exceed the limitations of applicable law. The IRC will advise the Canadian securities regulators if the IRC determines that any investment does not meet the criteria described above, or if any other condition of the permission to make such investments has not been satisfied, together with any action that the IRC or the fund’s portfolio advisor has taken or proposes to take following such a determination.

In carrying out their responsibilities, the members of the IRC will exercise their powers and discharge their duties honestly, in good faith and in the best interests of the funds and, in so doing, will exercise the degree of care, diligence and skill that a reasonably prudent person would exercise in the circumstances. All members of the IRC are paid a fixed annual fee which may be allocated to mutual funds under our management as determined by the Manager (generally pro rata based upon their relative net asset values). Members of the IRC are also reimbursed for their expenses which are typically nominal and associated with travel and the administration of meetings. There is no intention to pay the members of the IRC any other compensation in addition to their usual compensation as members of the IRC.

[Annual IRC Report]

Business Continuity Plan

Business Continuity at Capstone Asset Management

At Capstone Asset Management, we are committed to providing continuous service to our clients, protecting client assets, and safeguarding the integrity of our business operations. As part of this commitment, we maintain a comprehensive Business Continuity Plan (BCP) designed to enable us to respond to events that may significantly disrupt our business.

Our Business Continuity Plan

Capstone's BCP is developed to be consistent with industry standards and regulatory requirements, including those outlined in National Instrument 31-103. Key elements of our BCP will include:

• Risk assessment to identify potential threats to our operations and the likelihood and impact of those events

• Business impact analysis to determine critical systems, processes and resources needed to maintain essential services

• Alternate work facilities provisioned to support relocation and remote work in the event our primary offices are inaccessible

• Redundant data centers and networks to enable failover of critical systems and ensure data remains available to support client activities

• Detailed procedures for responding to and recovering from various disruption scenarios, from short-term power outages to region-wide disasters

• Crisis management and communication protocols to facilitate coordination with employees, clients, and business partners during a disruptive event

Our BCP addresses a range of potential business disruptions that could impact our firm. These include technology outages, cyber incidents, natural disasters, pandemics, loss of key services from critical third-party providers, and other events that may cause our facilities to be inaccessible. The BCP aims to safeguard our employees and property, protect client assets and account data, recover critical systems and processes, and allow our clients to transact business.

Client Access to Funds and Securities

A significant focus of our BCP is to ensure that clients have continued access to their funds and securities during a business disruption. Our plan outlines actions to provide clients with instructions and support for placing orders, requesting withdrawals, and accessing their account information through alternate channels if normal processes are impacted. We also maintain pre-established relationships with backup service providers to enable clients to access their funds and securities should our primary custodian or clearing firm experience an outage.

Communication During a Disruption

If a significant business disruption occurs, Capstone will use multiple methods to keep clients informed of the situation and provide instructions for conducting business with the firm. Our client communication protocols include:

• Notification of the disruption through postings on our website and client web portal

• Email and telephone outreach from our Client Services team and Advisors to impacted clients

• Activation of a dedicated Client Support Hotline to answer questions and assist with account needs

• Daily status updates until the disruption is resolved to keep clients apprised of progress

Contacting Us

If you are unable to reach Capstone through normal communication channels during a business disruption, please consult our website at www.capstoneassets.ca or call our Client Support Hotline at Toll free: 1-855-437-7103 or (604) 546-1500 for the latest information on our operational status and alternate instructions for contacting the firm, placing trades, or accessing your funds and securities.

While no contingency plan can eliminate all risk of service interruption, we continually assess and update our BCP to mitigate risks to our operations. In all cases, we aim to maintain high service quality and minimize recovery times for our valued clients. We appreciate the trust you place in Capstone Asset Management, and we take our responsibility as stewards of your assets very seriously. If you have questions about our business continuity planning, please contact your advisor or our Client Services team for more information.