Information about our Relationship with You.

In order to help you understand who we are and what we will be doing for you as a client of Harness Investment Management Inc., we have prepared this document. It is intended to provide you with important information that you will need as we continue our relationship.

In some cases, these disclosures are things that we need to provide to you by the regulations under which we operate. But in all cases, this information will help to ensure that our relationship is based on a mutual understanding of our products and services. If we change any information significantly, we will provide you with notice before they come into effect.

This document should also be read in conjunction with the Investment Management Agreement you signed when you opened your accounts and the Investment Policy Statement to which you and your advisor have agreed. There are a number of cross references between the three documents, so it is important that you read all of them. Important information may also be contained in other documents that we have provided to you or will provide to you in the future. If you have any questions about the contents of this document or any of the other documents, please contact your advisor or us.

Who we are

Harness Investment Management Inc. is registered as a portfolio manager and an exempt market dealer in all Canadian provinces and territories. Our principal regulator is the Ontario Securities Commission. As a result, our services are available only for investors who are permitted to hold Canadian investment accounts.

Our business is primarily providing discretionary investment services to individuals, corporations, trusts and other legal entities. We provide the full range of investment accounts to Canadian investors, including registered accounts, like RRSPs, TFSAs and RESPs. In addition, we may act as an exempt market dealer by marketing certain investment products to our clients or external clients.

In providing our services to you, we may employ or engage a number of outside service providers to facilitate service delivery. These may include custodians, distributors, brokers, depositories, electronic data processors, and lawyers, amongst others. Our selection process for these service providers is thorough and intended to ensure that they can deliver the services at a level that meets the level that we are required to provide to you. We also have oversight procedures to ensure that they continue to deliver the level of service that we have contractually established with them.

Custody of your assets

We do not hold the cash and securities in your accounts directly. Client assets are held in Canada in a fully disclosed, segregated account at a qualified Canadian custodian under applicable securities laws (a “custodian”). Each client account held by a custodian is insured by the Canadian Investor Protection Fund (CIPF) subject to the following limitations:

Limits for individuals

For an individual holding, the limits on CIPF protection are generally as follows:

  1. $1 million for all general accounts combined (such as cash accounts, margin accounts and TFSAs), plus
  2. $1 million for all registered retirement accounts combined (such as RRSPs, RRIFs and LIFs), plus
  3. $1 million for all registered education savings plans (RESPs) combined where the client is the subscriber of the plan.

Limits for Corporations, Partnerships and Unincorporated Organizations

The limit on CIPF protection for a corporation, partnership or unincorporated organization is generally $1 million for all accounts combined. Some exceptions apply – please see the CIPF Coverage Policy for more details:

Limits for Testamentary Trusts

For accounts held in the name of an estate, a deceased person (also known as a decedent), or the executor or administrator of the estate of the decedent, the limit on CIPF coverage is $1 million. This limit applies to all accounts held for the same decedent combined.

Limits for Inter-vivos Trusts and Trusts Imposed by Law

For accounts of inter-vivos trusts that are created by a written instrument and trusts imposed by law, the limit on CIPF coverage is $1 million. These accounts are considered to be distinct from accounts of the trustee, the settlor or any beneficiary.

Limits for Other Types of Customers

Please see the CIPF Coverage Policy for complete details.

Accounts held Jointly

Unless otherwise evidenced in writing, proportionate interest in a joint account will be presumed to be equal for all parties with an interest in the account. Each party will have CIPF protection for their interest in the joint account up to the limit that applies to all of their general accounts combined. In most cases, this limit is $1 million.

We have trading authority over client assets held at one or more custodians, but do not have access to client assets held there and are not authorized to transfer securities into or out of client accounts. Each custodian is independent of Harness Investment Management and is required to segregate client assets from its own assets and is subject to regulatory oversight, minimum capital and insurance requirements. A custodian may hold securities on behalf of the client in its name, as nominees of the client. A custodian may appoint sub-custodians to hold client assets in foreign jurisdictions or to hold client assets other than cash or securities. Client assets are subject to risk of loss: (i) if a custodian becomes bankrupt or insolvent; (ii) if there is a breakdown in their information technology systems; or (iii) due to the fraud, willful or reckless misconduct, negligence or error of the custodian or its personnel. We have reviewed each custodian’s reputation, financial stability, relevant internal controls and ability to deliver custodial services and have concluded that their system of controls and supervision is sufficient to manage risk of loss to client assets in accordance with prudent business practice.

Fund Securities

Securities of investment funds or other issuers held by the client that are recorded on the books of the fund company or its transfer agent only in the name of the client are not held by a custodian. Fund securities are subject to the custody and recordkeeping arrangements applicable to the fund company and disclosed in the offering document of the relevant fund. Client assets are subject to risk of loss if the fund company or its custodian become bankrupt or insolvent, or the fund company, its custodian or transfer agent experiences a breakdown in its information systems. Harness has reviewed the system of controls and supervision maintained by each fund company and has concluded that their systems are sufficient to manage the risk to a client of loss in accordance with prudent business practice.

Information we collect from you

In order to provide you with the best investment advice we can, we need to have a good understanding about you, your assets and liabilities and your financial goals for the future. This information will help to ensure that the investments we recommend are suitable for you. The consideration of suitability is an ongoing process, including when you transfer portfolios to us, in our regular portfolio reviews and when you tell us that some of the information about you has changed.

The personal information that we collect is often called the Know Your Client or KYC information. It can be broken down into three broad areas:

1. Your identity

This information includes your name, address, birth date, current employment and social insurance number. It helps us verify who you are, but it is also necessary information for the creation of any registered accounts and to meet our obligations under the federal Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and other federal laws aimed at the prevention and detection of money-laundering and terrorist financing.

2. Your financial situation

This information includes your current income level, your existing investment portfolios and other assets, and any debt you may have against these. We will also collect information about your existing banking relationships. It helps us establish the base line from which we will help you reach your financial goals.

3. Your goals, priorities, liquidity needs and risk assessment

Once we have all of the other information we can begin to construct a plan. For this step, we need to understand what your financial goals are and when you expect to start taking money out of your accounts.

A crucial part of this analysis is to understand how comfortable you are with taking risks to achieve your goals. We have developed a multi-dimensional risk assessment tool that helps us to understand this element of who you are. Once we have determined a risk profile score for you, we will use it to help assess the suitability of all investment advice or actions we provide to you.

We will protect your personal information to ensure that only those inside of Harness or our service providers who need access to the information to serve you and to meet our regulatory obligations can see it. And we will protect it from external parties getting it. Please review our Privacy Policy at for further details on how we deal with your personal information and what your rights are related to the information we collect about you.

Trusted Contact Person and Temporary Holds

We will ask you for the name and contact information for a person you trust to assist us in protecting your investments. We will also ask for your consent to contact that person in certain circumstances. A trusted contact person is generally someone we would contact to confirm or make inquiries about possible financial exploitation, or if we have concerns about your mental capacity as it relates to your ability to make financial decisions (“Trusted Contact Person”). Financial exploitation generally means the use or control of, or deprivation of the use or control of, a financial asset through undue influence, unlawful conduct or another wrongful act. We may also contact your Trusted Contact Person to confirm your current contact information if we cannot reach you after multiple attempts, or to confirm the name and contact information of a legal guardian, if any. You can replace or revoke your Trusted Contact Person at any time.

Additionally, should we reasonably believe that you are in a vulnerable position and are being financially exploited or that you are experiencing diminished mental capacity which may affect your ability to make financial decisions relating to your account(s) with us, we may place a temporary hold on a particular transaction. A vulnerable position includes where an illness, impairment, disability or aging-process limitation places you at risk of financial exploitation. If we place a temporary hold on a particular transaction, we will provide you with notice, either written or verbal, explaining our reasons for the temporary hold, and at least every 30 days thereafter until the temporary hold is revoked. We may also contact your Trusted Contact Person about a temporary hold.

Your role in our relationship

It is important that you actively participate in our relationship. In particular we encourage you to:

  • Keep us fully and accurately informed regarding your personal circumstances, and promptly advise us of any change to information that could reasonably result in a change to the types of investments appropriate for you, such as a change to your income, employment status, investment objectives, time horizon or net worth.
  • Review the documentation and other information we provide to you regarding your accounts, transactions conducted in your accounts and the holdings in your portfolio.
  • Ask questions of and request information from us to address any questions you have about your accounts, transactions conducted in your accounts or the holdings in your portfolio, or your relationship with us.

Fees and other expenses

The compensation that we receive for our services differs depending on the type of account you have opened. We charge a fee that is calculated monthly based on the average daily value of your portfolios and paid monthly. Unless you indicate differently, we will deduct our fee from your investment account.  These fees are more fully described in your Investment Management Agreement.

In addition to these fees, there are a number of other operating and transactional charges that may apply. These may be for certain actions we undertake for you like account or cash transfers, or for special requests like paper account statements. The Fee Schedule attached to this document outlines our current operating and transactional charges. If we change this Schedule, we will provide you with notice of the changes before they come into effect.


You will receive regular reports from us about your accounts. The timing and frequency of the reports will vary depending on their content. It is important that you carefully review each report that is sent to you and inform us promptly if you feel that there are any errors or discrepancies or if you have any questions or concerns.

We will generally make the reports available to you electronically through our reporting portal. You will be notified by email when the reports are available.  If you would prefer to receive paper copies of any report, we will make them available to you. There will be a charge for paper statements.

Account Statements

We will provide you with account statements on a quarterly basis. You can request to receive account statements monthly. The account statement will include a record of each transaction which took place during the period as well as the name and quantity of each security held in the account. The statement will also outline the market value and position cost of each position, the cash balance in the account and the total value of the account. We may also include additional information on the statements to help you understand the current state of your portfolios.

Annual Statements

On an annual basis, we will provide you with a statement on the charges and other compensation that have been paid by you through your investment accounts. This report will include the total amount of our management fee and any other operating and transaction charges. It will also include the amount of any other compensation that we have received related to your account from other parties, including trailing commissions if applicable.

In addition, you will receive an investment performance report annually. It will include the market value of your account assets at the beginning and end of the period as well as all cash flows in and out of the account. It will also provide a percentage return for an account and your portfolio over several time frames. The report will also show the returns for a benchmark if you have chosen to use one for comparison (see below.)

A word about benchmarks

It is sometimes helpful to compare the performance of your investments against an external measure. While it is not the only way to assess performance, comparison of your performance against a valid benchmark can be a useful tool. A benchmark is generally a well-recognized and diversified index, like the S&P/TSX Composite index. In selecting a relevant benchmark, it is important that it represents a valid comparison with your investment objectives – you want to ensure that the comparison is apples to apples. Your portfolio manager will be able to advise on what a relevant benchmark might be. It is likely to be a blend of a number of broad asset class specific benchmarks that matches your agreed asset mix.

If you choose to utilize a benchmark for performance validation, the agreed-upon benchmark will be included in your Investment Policy Statement and we will include the performance of the benchmark in our regular performance report to you.


General Risks of Investing

You should be comfortable about where your money is invested. This requires you to think about and understand your own tolerance for losing money, even temporarily, and the risk level of your investments. It is important that you understand that your investments are not guaranteed. Therefore, the greatest risk to you as an investor is that you could lose all or part of your investment. Unlike bank accounts or guaranteed investment certificates (GICs), stocks, bonds, money market securities and funds are not covered by the Canada Deposit Insurance Corporation or any other government deposit insurer.

Accounts hold different kinds of investments depending on their investment mandate. The value of investments in any account will fluctuate on a daily basis, reflecting changes in interest rates, economic conditions and markets as well as company news. Therefore, the value of any portfolio’s securities may go up or down. As a result, the value of your investment when you sell it may be more or less than when you bought it.

Risk-Return Trade Off

Risk and return are closely related. This means that to obtain a higher return, you may have to accept a higher possibility of losing money. A higher risk portfolio is generally less stable and it goes up or down in value, or “fluctuates” more. The more a portfolio’s return fluctuates, the more risk is associated with the portfolio. High-risk investments generally offer higher long-term returns than safer ones. Since they fluctuate more, high risk investments may post more negative short-term returns, compared to lower-risk investments.

Risks of Using Borrowed Money (Leveraging) to Finance the Purchase of a Security

Using borrowed money to finance the purchase of securities involves greater risk than a purchase using cash resources only. If you borrow money to purchase securities, your responsibility to repay the loan and pay interest as required by its terms remains the same even if the value of the securities purchased declines.

Securities may be purchased using available cash, or a combination of cash and borrowed money. If cash is used to pay for the security in full, the percentage gain or loss will equal the percentage increase or decrease in value of the security. The purchase of a security using borrowed money magnifies the gain or loss on the cash invested. This effect is called leveraging. For example, if $100,000 of securities are purchased and paid for with $25,000 from available cash and $75,000 from borrowings, and the value of the securities declines by 10% to $90,000, your equity interest (the difference between the value of the securities and the amount borrowed) has declined by 40% (i.e. from $25,000 to $15,000).

It is apparent that leveraging magnifies gains or losses. It is important that are aware that a leveraged purchase involves greater risk than a purchase using cash resources only if you are interested in using leverage for your accounts. The point at which the additional risk from a leverage purchase becomes excessive is a determination to be made on an individual case basis by you and will vary depending on your circumstances and the security purchased.

It is also important that you are aware of the terms of a loan secured by securities. The lender may require that the amount outstanding on the loan not fall below an agreed percentage of the market value of the securities. Should this occur, you must pay down the loan or sell some of the securities so as to return the loan to the agreed percentage. In our example above, the lender may require that the loan not exceed 75% of the market value of the securities. On a decline of value of the securities to $90,000 you must reduce the loan to $67,500 (75% of $90,000). If you do not have cash available, you would have to sell securities to provide money to reduce the loan.

Cash is, of course, also required to pay interest on the loan. If you choose to use leverage for your investments, you are advised to have adequate financial resources available both to pay interest and also to repay the loan if the borrowing arrangements require such a payment.

Risks Relating to Currency

Whenever an account buys assets in a currency other than the base currency (for Canadians this is generally Canadian dollars), there are risks relating to exchange rates. As the base currency changes in value against the other currencies, the value of the portfolio securities purchased in those other currencies will fluctuate.

Some client accounts denominate the value of their securities in Canadian dollars, but invest in different currencies. The total valueof their securities will fluctuate as foreign currencies change value in relation to the Canadian dollar. Some client accounts denominate the value of their securities in both U.S. and Canadian dollars. The total value of their securities denominated in Canadian dollars will fluctuate in relation to the U.S. dollar.

Risks Relating to Interest Rate Fluctuations

Investments are affected by interest rate fluctuations. An increase in interest rates will generally result in a decrease in the value of a fixed income security. An increase in interest rates may reduce the return of accounts holding debt or fixed income securities. On the other hand, a drop in interest rates may reduce the return of money market securities.

Risk Relating to Liquidity

Liquidity refers to the speed and ease with which an asset may be sold and converted into cash. Most of the securities held by an account may be sold easily at a fair price and thus represent investments which are relatively liquid. However, an account may invest in securities which are not liquid, i.e., which may not be sold quickly or easily. Some securities may not be liquid because of legal restrictions, the nature of the investment or certain characteristics of the security. The lack of purchasers interested in a given security or market could also explain why a security may be less liquid. The difficulty of selling illiquid securities may result in a loss or a reduced return for an account.

Risks Relating to Credit

An account can lose money if the issuer of a bond or other fixed income security cannot pay interest or repay the principal when it comes due. This risk is higher if the fixed income security has a low credit rating or no rating at all. This risk also exists if there is a reduction in credit rating or changes in general economic or business conditions result in the market perceiving that the risk of a failure to meet a required payment has increased. Fixed income securities with a low credit rating usually offer a higher yield than securities with a high credit rating but they also have the potential for substantial loss. These are known as “high yield securities”.

Risks Relating to Companies Listed on Stock Markets

The value of an account will increase or decrease with the market value of the securities in it. If an account holds stocks, the value of the account will fluctuate with changes in the market value of the stocks it holds. The market value of a stock will fluctuate according to the performance of the company that issued the stock, economic conditions, interest rates, stock market tendencies and other factors. Historically, equity securities are more volatile than fixed income securities. Securities of small market capitalization companies can be more volatile than securities of large market capitalization companies.


We encourage you to contact any member of the Harness team on a regular basis to discuss your accounts and the services we are providing to you, raising any questions you might have about them. We welcome your positive comments but more importantly we welcome your negative comments. Negative comments help us to improve the quality of our products and services.

If you have a problem with your accounts, do not hesitate to contact us. Once you have contacted us, we have established policies and procedures to ensure that your complaint is dealt with promptly.

For more information about our complaint process and your options, please refer to the “What to do if you have a compliant” appendix at the end of this document. If you require more information about our handling of complaints, you may contact our Chief Compliance Officer directly.

Conflicts of Interest

What is a Conflict of Interest?

In the course of providing services to you, there may be situations in which there is an apparent difference between our interests and yours. A conflict of interest exists where the interests of different parties, such as the interests of clients and those of Harness Investment Management or the interests of two or more clients, diverge or are inconsistent. We always put your interests ahead of ours and we are driven to identify the situations in which such a conflict may arise and address them promptly. In addition, our regulators require us to take reasonable steps to identify and respond to potential conflicts of interest.  There may be a real conflict, but equally as important, is the potential that the conflict may be perceived by an outside person.  When faced with such a conflict, we will exercise the business judgment of a reasonable person, uninfluenced by considerations other than the best interests of our clients.

In exercising our judgement, we consider whether a real or perceived conflict of Interest can best be dealt with by 1) Avoiding the conflict, 2) Controlling the conflict through policies and procedures or 3) Disclosing the conflict to clients. Once we determine our course of action for an identified conflict of interest, we update our policies and procedures to ensure that all employees are familiar with their responsibilities in relation to the conflict. Some of the measures we may use include controlling the sharing of information within the company, segregating tasks and the supervisory responsibility for them and adjusting financial incentives. Finally, we may also require that the conflict be disclosed to you and that you provide us with your consent to proceed.

Conflicts of Interest related to portfolio management services

Harness performs investment advisory and portfolio management services for various accounts other than your accounts. Our services are not exclusive, and we will provide similar services to other clients and engage in other activities. We may give advice and take action concerning our other clients, which may be the same as, similar to or different from the advice given, or the timing and nature of action taken, for you. We are not obligated to purchase or sell for your accounts any security or other property which we purchase or sell for any other account if, in our sole discretion, such transaction appears unsuitable, impractical or for any reason undesirable for your accounts.

Conflicts of Interest related to Related and Connected Issuers

There is a potential for conflicts of interest to arise in situations in which Harness advises or trades in the securities of issuers which are related to or connected to us. We are required to disclose to you any related or connected issue in writing, before we make a trade or provide advice to you and, in a timely manner thereafter if there are any significant changes to this disclosure. In addition, we are required to disclose to you whether any security we recommend for you to buy, sell or hold are securities issued by Harness Investment Management, a related issuer or a connected issuer. 

A person or company is a “related issuer” of another person or company if:

  • The person is an “influential security holder” of the other person or company,
  • The other person or company is an “influential security holder” of the person or company, or
  • Each of them is a related issuer of the same third person

An “influential security holder” controls more than 20% of an issuer either alone or with others. 

A “connected issuer” is one that has a connection to a person or company through common shareowners, directors or officers.

Purpose Investments Inc. would be considered a “connected issuer” to Harness since the two companies have certain shareholders that would be considered “influential security holders” of each entity.

As a part of our business activities, we may buy or sell the securities of related/connected issuers including securities of investment funds or other securities offered by Purpose, or its affiliates, on behalf of our clients, exercise our discretionary power to buy or sell these securities pursuant to discretionary management agreements, or make recommendations in respect of these securities.  We will do so in accordance with applicable securities laws and always in the best interest of our clients. We regularly assess the available Purpose/affiliate securities to make sure our offerings remain appropriate and meet your financial needs.  We evaluate these securities using the same due diligence processes and ongoing monitoring as we use to evaluate non-Purpose funds and securities. We maintain a list of related/connected issuers which is updated regularly and is available on our website –

For client referred by Purpose Investments Financial Planning – Conflicts of Interest related to Related Wealth Advisor

In addition to the conflicts related to the types of securities Harness may invest in being issued by Purpose Investments Inc. and related companies, the client’s Wealth Advisor is also part of Purpose Investments Inc. acting in the capacity of Financial Planner.  The Wealth Advisor is paid from the assets under administration at Harness, at the client’s direction.    

Allocation of Investment Opportunities

We act for many clients and endeavour to allocate investment opportunities among all of our clients in a fair manner and not intentionally favour one client over another.  We have a trade allocation policy that is intended to ensure that allocations are determined on a basis that is fair, reasonable and equitable for all clients.

Security purchases and sales for multiple accounts may be grouped and submitted to the market together. The decision to group orders will take into consideration the investment profile of each client. When trades are grouped, each account will generally receive its pro rata share and the same blended price of each fill wherever practicable. In the event that securities are purchased for the accounts of more than one client and an insufficient number of securities are available to satisfy the purchase order, the securities available will be allocated pro rata based on the size of the accounts to the extent reasonably possible.  Trading commissions, if any, will be allocated to client account in the same manner as the security allocation. Allocations for clients will always take precedence over trading for any proprietary accounts or the accounts of our staff.

The basic purpose of this policy is to ensure fair treatment of all accounts and to avoid the appearance of favoritism or discrimination. There may be times, however, where strict application of this policy would not lead to a fair, practical and reasonable allocation. In such circumstances, allocation by a method other than this policy will be permitted, provided that such allocation produces a more fair and reasonable result.

Use of Client Brokerage Commissions/Soft Dollars

When placing orders for and on behalf of clients’ accounts, we will select brokers and dealers from whom we reasonably expect to obtain the best execution (after considering all transactions costs, research or other benefits.) Some brokers and dealers will make available research and trade execution services to us at no cost in exchange for executing a trade with them. This practice is commonly known as “soft dollar” arrangements. The use of these arrangements is permitted under applicable securities laws as long as we determine that the arrangements will be beneficial to our clients. The regulations also define what type of services can be provided to us under a soft dollar arrangement.

We have established a policy to assess when a proposed soft dollar arrangement would be beneficial to our clients. Any arrangement to which we agree is reviewed on an annual basis by senior management including the Chief Compliance Officer to ensure that the clients continue to receive a reasonable benefit from the services in relation to the total commission dollars paid.

Costs associated with soft dollar arrangements will not be applicable to investors participating in Harness’ online advice model.

Referral Arrangements

[Name] your “Wealth Advisor” and Harness are parties to an agreement (the“Shared Services Agreement”) pursuant to which your Wealth Advisor will provide valuable services to you which may include financial planning, accounting or other services to certain clients which Harness will satisfy itself  are being performed from time to time, both at the entering into of this agreement and thereafter during the term of the agreement (the “Services”), and your Wealth Advisor may introduce clients to Harness and who may then receive PM Services from Harness. The role of your Wealth Advisor as part of this arrangement is to introduce prospective clients to Harness only. Your Wealth Advisor is not permitted to have any involvement with respect to the PM Services resulting from this introduction.

In making an introduction under the Shared Services Agreement, your Wealth Advisor shall not:

a) provide any advice to you about the suitability of the products or services provided by Harness;
b) monitor the progress or performance of products of Harness which you select or are invested in; or
c) be responsible or liable in any way for the PM Services provided to you by Harness.

This arrangement has the potential to create a conflict between your interests and those of your Wealth Advisor and its representatives because it could create an incentive for your Wealth Advisor and its representatives to introduce you to Harness regardless of whether the services offered by Harness are appropriate for you.  A select number of portfolio managers employed by Harness are also employed by a Wealth Advisor Firm. If your Portfolio Manager (a) earns all or part of the Services Fee paid from your Harness Account; and (b) is employed as an advising representative of Harness and receives an annual salary from Harness and may receive a bonus fee from Harness, this is a conflict of interest as the Wealth Advisor firm is incented to recommend Harness as portfolio manager. Harness will manage this conflict on review of the suitability of each account, and will not onboard accounts not aligned to the service offering of Harness as Portfolio Manager. 

Furthermore, a conflict of interest also arises in certain circumstances where incentive compensation programs introduced by Harness from time to time, provide compensation to your Wealth Advisor out of Harness’s profits. These incentive programs may be related to an increase in Harness’ overall invested assets or other similar measures. However, the Shared Services Agreement creates no obligation, legal or otherwise, for your Wealth Advisor to refer you to Harness, and Harness is under no obligation to provide PM Services to you.

All PM Services will be provided by Harness in its capacity as portfolio manager receiving the introduction from your Wealth Advisor.

Finally, in certain circumstances, Harness may refer prospects or clients to Wealth Advisors also creating a conflict of interest.  In such circumstances, a specific disclosure will be provided to the prospect or client at the time of onboarding with the Wealth Advisor.

Personal Trading by Employees

Harness abides by a code of ethics which establishes standards of business conduct to prevent possible conflicts of interest between clients and employees, including receiving gifts and entertainment and trading for personal accounts. Every Harness employee is subject to our personal trading policies and procedures. The policies are intended to ensure that employees do not put their personal interests ahead of our clients. We encourage employees to invest alongside of our clients, but they are controls in place to ensure that they do not take advantage of their knowledge by trading in a manner that is inconsistent with our obligations to clients. Employees who have direct knowledge of client assets like investment advisors, are required to request approval for trades in their personal accounts, or accounts in which they have a beneficial interest, for most securities.

Outside Business Activities

We have developed policies and procedures to cover any activities that employees may undertake outside of Harness, including directorships and volunteer positions. These policies are intended to ensure that any outside activity does not interfere or give the appearance of interfering with the employee’s ability to act in your best interest. Employees are required to notify and have the activity approved by the Chief Compliance Officer before undertaking the outside activity.

Additional Information on Sub-Advisors

Harness offers solutions based on model portfolios. Harness has recommended that you invest in the model portfolio offered by the Sub-Adviser recommended by your Wealth Advisor. If there is no suitable portfolio available from the preferred Sub-Advisor, Harness will recommend an alternative solution. Information about all of our Sub-Advisers is available here: If you are interested in investing in a model portfolio provided by a Sub-Adviser than has not been recommended by your Wealth Advisor, contact a Harness advising representative at