Conflict of Interest Statement

Last updated: November 7, 2022

Flahmingo Investments Inc. (“Flahmingo”, "we" or "us") and our representatives may have interests that are inconsistent with your interests. This may give rise to an actual or perceived risk that we favour our interests over yours as our customer.

We act fairly, honestly and in good faith with you and our other customers. To this end, we avoid material conflicts of interest that we cannot effectively address and conflicts that are prohibited by law.

We have adopted policies and procedures to identify and address all remaining material conflicts in your best interests, including:

• Conflicts from relationships with third party vendors
• Conflicts arising out of competing interests among our customers
• Conflicts caused by compensation practices and incentive programs
• Conflicts due to our Flahmingo personnels’ personal interests
• Conflicts related to referral arrangements with our partners

Further details on each of the conflicts summarized above disclosed to you in this Conflict of Interest Statement. Other actual and potential material conflicts of interest, if not avoided, will be disclosed to you as they arise. Our personnel are also subject to the Flahmingo Code of Ethics as part of our policies and procedures.

1. Conflicts from relationships with third party vendors

Routing trading to third parties: Flahmingo engages the execution services of Alpaca Securities LLC ("Alpaca"), a broker/dealer registered in the United States for U.S. listed equities and options.

Alpaca routes to the following market makers for execution (this is not an exhaustive list, additional approved venues may be used):

• Virtu Americas, LLC (NITE) - Orders in US exchange issues and OTC issues are routed to NITE
• Citadel Securities LLC (CDRG) - Orders in US exchange issues and OTC issues are routed to CDRG
• Jane Street Capital, LLC (JNST) – Only orders in US exchange issues are routed to JNST. JNST is planning to offer OTC issues in the future.
• UBS Securities (UBSS) - Only orders in US exchange issues are routed to UBSS
• MCAP LLC (MCAP) - Orders in OTC ADRs are routed to MCAP are planned for the future. This firm specializes in foreign securities.

Payment for order flow: Alpaca receives revenue from third party liquidity providers based on the order flow execution received at each destination. While rebate rates are substantially similar amongst the liquidity providers they may vary based on order characteristics (such as price of execution, marketability and other characteristics). Alpaca does not negotiate with venues over rates as a condition of a venue receiving its order flow.

There is a potential conflict inherent to a market maker such as those listed above both paying for order flow and providing price improvement, as the potential source of funds for each is the same, namely the anticipated profit the market maker seeks to earn from executing or facilitating the execution of Alpaca/Flahmingo customer orders. Accordingly, from such anticipated profit, a market maker such as those listed above can (i) forgo a portion of such anticipated profit to provide price improvement; (ii) forgo a portion of such anticipated profit to pay for order flow; or (iii) retain a larger portion of anticipated profit and not provide (or provide less) price improvement or not provide (or provide less) payment for order flow. A market maker’s anticipated profit must be allocated among these three sub-categories, such that an increased allocation to any one subcategory will result in a decreased allocation to one or more of the other categories.

For clarity, Flahmingo does not receive any payment directly or indirectly from market makers in return for routing customer orders in U.S. equities pursuant to order routing arrangements.

Alpaca files quarterly reports with the U.S. Securities and Exchange Commission (SEC) as required of all brokerage firms to make publicly these reports, broken down by calendar month, containing certain required statistical information regarding the routing of held, non-directed customer orders in Regulation National Market System stocks and listed options. For each section, the report identifies the venues to which Alpaca routed the relevant orders and, for each venue, the required statistical information broken down by order type (i.e., market order, marketable limit order, non-marketable limit order and other orders). Each section of the report also contains information regarding the material aspects of Alpaca's relationship, if any, with each venue.

2. Conflicts arising out of competing interests among our customers

Flahmingo will make reasonable efforts to achieve best execution by overseeing the best execution of customers’ orders executed by Alpaca. This includes a review of Alpaca’s publicly available customer disclosure and order routing practices, and obtaining confirmation from them that they have complied with and tested their best execution policies and procedures.

Best Execution: Best execution means obtaining the most advantageous execution terms for a customer order that are reasonably available under the circumstances. Flahmingo is obligated to establish policies and procedures that are designed to achieve best execution when acting for a customer. These policies and procedures must take into consideration factors such as price, speed of execution, certainty of execution and the overall cost of the transaction, when costs are passed on to customers.

It can occur that orders entered by more than one customer at the same time are filled at different prices and at different speeds.

3. Conflicts caused by compensation practices and incentive programs

Revenue Earned by Personnel: Flahmingo personnel are compensated on the basis of salary and overall firm performance. No compensation is paid on the basis of sales at Flahmingo or assets held in customer portfolios.

Revenue Earned by Flahmingo: Different products, platforms and add-ons, and trading in certain products or on different markets may have differing levels of monthly fees. Our compensation plans do not incent our personnel to recommend specific products, services, or markets including any particular type of trading platform.

Flahmingo earns a spread on foreign exchange transactions you request in the course of funding or withdrawing funds from your account.

4. Conflicts due to our representatives’ personal interests

Outside Activities: At times, our personnel may participate in outside activities such as participating in community events, pursuing personal outside business interests or serving on a board of directors of a charity (with compensation). Before engaging in any outside activity, our policies require these individuals to disclose situations where a conflict of interest may arise and to determine how such conflicts may be addressed. Our personnel may only engage in such outside activities if approved by the Chief Compliance Officer under our policies. The approval may be subject to terms and conditions that help address perceived or actual conflicts of interest. Our personnel are also required to review, at least annually, their outside activity submission for accuracy and completeness.

Gifts and Entertainment: Our personnel are not permitted to accept gifts or entertainment beyond what we consider consistent with reasonable business practice under our policies and with applicable laws. We set maximum thresholds for permitted gifts and entertainment to avoid any perception that the gifts or entertainment will influence decision-making.

Personal Trading: Our policies require our personnel to act in accordance with applicable laws that prohibit insider trading, front running and similar conduct. Individuals may be required to obtain prior approval before making trades in their personal securities accounts. Our personnel are prohibited from accessing non-public information for their direct or indirect personal benefit.

Personal Dealings with Customers: Exceptionally, our personnel may have additional relationships or dealings with our customers. Conflicts of interest can arise where a personnel has personal financial dealings with you, such as acquiring assets outside of your investing relationship, borrowing money from or lending money to you, or exercising control over your financial affairs.

To address these conflicts, Flahmingo has policies and procedures in place which prohibit personal financial dealings with customers who are family members, other Flahmingo personnel or otherwise in a special relationship. These exceptions require the prior review and approval by the Chief Compliance Officer.

5. Conflicts related to referral arrangements

Referrals are an important part of our business. Satisfied customers may refer you or others to us and we may provide those customers with a financial incentive to do so. You may receive a CAD credit for every friend you refer and introduce to Flahmingo provided such person creates an Account, passes the know-your-customer procedures and funds their Account with a minimum of $25 CAD.

A conflict may exist in respect of this referral arrangement given the financial incentive to make a referral. There is the potential to create a conflict between your interests and those of the person making the referral because it could create an incentive for that person to refer you to Flahmingo regardless of whether the services offered by Flahmingo are appropriate for you. If a referral is made to a registrant, all activity requiring registration resulting from the referral arrangement will be provided.

You do not pay any additional charges and fees in connection with these referrals and you are not obligated to purchase any product or service in connection with a referral.