Wentworth Financial Services, (Wentworth) has been in business since 1984. In 2008 Wentworth became a Division of Cowan Insurance Group. Worldsource Financial Management Inc. is our sponsoring mutual fund dealer. Please consult the "Client Disclosure Brochure" issued by Worldsource Financial Management Inc. for additional information concerning their Privacy Policy.

These services include:

• Personal Insurance
• Business Insurance
• Group Benefits
• Health and Disability Management
• Group Pension and Retirement Consulting
• International Programs
• Corporate Planning
• Living Benefits for Individuals
• Financial Solutions

We have designed this Privacy Policy in conjunction with Cowan Insurance Group based on the Canadian Standards Association Model Code for the Protection of Personal Information, and the Federal Personal Information Protection and Electronic Documents Act ("PIPEDA"). Within this policy, we will address how the staff, Officers and Directors of the companies of Wentworth intend to collect, use, and disclose Personal Information in the context of these principles. This policy reflects Wentworth's commitment to the privacy of our clients' Personal Information. Wentworth's collection, use and disclosure of their staff's Personal Information, is dealt with in a separate policy.

Wentworth may disclose Personal Information to any individual or organization for services that are provided to assist us in the conduct of our mandate, including an individual or organization that performs services on our behalf, but only if that individual or organization agrees to use the Personal Information solely for the purposes of performing tasks on behalf of, and under the instruction of, Wentworth and, with respect to that information, to act in a manner consistent with the relevant principles articulated in this Privacy Policy.

In order to be certain you are aware of the scope of the information to which our Privacy Policy refers, please note the following definition (as defined in PIPEDA):

Personal Information: Means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. Personal Information includes personal health information with respect to an individual, whether living or deceased, and means

1. information concerning the physical or mental health of the individual
2. information concerning any health services provided to the individual
3. information concerning the donation by the individual of any body part or any bodily substance of the individual or information derived from the testing or examination of a body part or bodily substance of the individual
4. information that is collected in the course of providing health services to the individual
5. information that is collected incidentally to the provision of health services to the individual

Personal Information for the purpose of this policy shall not include information disclosed as aggregate data. Aggregate data for the purpose of this policy, refers to data that does not reveal, and cannot be manipulated to reveal, member-specific information.

Personal Information Wentworth collects, or is provided, is used and disclosed for the purposes of conducting the services for which we provide. As part of the employment process, our staff, Directors and Officers will sign a confidentiality agreement which outlines Wentworth's expectation of its employees to act responsibly in the handling of client information.

In order to affirm our commitment to maintaining the confidentiality and privacy of our client's personal information, we have done the following:

• Wentworth management has developed and adopted this Privacy Policy and is refining our Security, and Records Retention practices.
• Wentworth has assigned a Privacy Officer(s) to provide client service on matters of privacy relating to Wentworth use, disclosure, security and retention of personal or personal health information. Wentworth Privacy Officer(s) will also be responsible for maintaining this policy and updating staff on changes to both privacy legislation and business practices.
• Wentworth has held an awareness seminar for key members of staff on privacy legislation and will continue to update all staff on privacy related issues and legislation.

Wentworth collect personal information in the course of providing services to our clients. The following is an example of circumstances in which Wentworth may be provided, or required to collect, personal information:

• property/casualty insurance applications, premium collection and claim payment
• individual claim assessments, legal processes and claim payment
• employer provided pension plan administration, pension calculations and payments, and actuarial costing
• administration and consulting for employer provided life and health benefit plans
• integrated health and disability management
• group insurance brokerage
• human resource consulting
• business succession planning
• business continuation planning
• executive financial planning

Consent to use personal information is required to be obtained at the time of its collection. If Wentworth collect the personal information directly from an individual, Wentworth will obtain express consent for the collection, use and disclosure of such information. However, Wentworth may be contracted by employers to provide third party administration of employer sponsored pension, life and health or general insurance plans. In these cases, personal information may be collected by another party before it is provided to Wentworth Where possible in these circumstances, Wentworth will take reasonable measures to require that consent for their use of the personal information has been obtained.

If Wentworth uses personal information it has collected, or has been provided, for any reasons other than those disclosed to an individual at the time consent was given, then Wentworth will seek to obtain consent for the new use of the information.

Link to Worldsource Financial Management Inc. "Privacy Consent" and "Investor Privacy Notice"

Wentworth limits its collection of personal information to that which is reasonably required to accurately complete the services for which we have been retained. We are committed to respecting the privacy of an individual's personal information and will not collect personal information which is not reasonably required.

Wentworth limits its use and disclosure of personal information to the purpose(s) described at the time the information is collected. WENTWORTH retains personal information it collects only as long as is necessary to completely fulfill our services. Wentworth maintain a records retention policy. The retention policy has been developed to meet Wentworth's record retention requirements consistent with good business practices and known industry standards.

In the event that Wentworth / Worldsource Financial Services Inc. decides to purchase, sell, reorganize or transfer the assets of a business, including any Personal Information held by that business, Wentworth client information may be subject to review for such purpose by another party. Should Wentworth or such other party wish to use any Personal Information for purposes not described herein, then consent for such use of the information will first be obtained.

Note: As is the case with all companies, Wentworth may be lawfully bound to disclose personal information for purposes other than those described at the time consent was obtained. These purposes have been described in applicable privacy legislation as those designed to protect personal and/or public interest.

Wentworth recognize that personal information can change. We encourage our clients to keep their personal information current so that we may provide the best services possible. If we are working with a company to manage a company sponsored benefit or pension plan, employee members will be required to inform their employer of any changes to their personal information. Where we have a direct client relationship, personal information can be changed as described on our website, or as directed by our staff upon inquiry by email, phone or fax.

Within a reasonable time of being notified, Wentworth will update member records to reflect changes in personal information.

Wentworth has inventoried the various ways in which we store personal information, and has taken reasonable measures to ensure the security of this information within our premises, at our offsite storage locations and in our system databases.

Furthermore, Wentworth require its staff to sign a confidentiality agreement within which is detailed the firm's expectation that staff will respect and safeguard client information. Through this agreement, employees are aware that a breach of confidentiality could result in termination of their employment.

Wentworth Privacy Officer are mandated to ensure that our Privacy Policy and internal Security and Record Retention Policies are maintained.

Should you wish to question why specific information is required our Privacy Officer is available to answer any such inquiries.

In all matters of privacy, including access requests and privacy concerns, we encourage our clients to contact our Privacy Officer:

Trish Morrissey
Executive Vice President, Operations
Cowan Insurance Group
705 Fountain Street North, PO Box 1510
Cambridge, ON N1R 5T2
Phone: 1-866-91COWAN (1-866-912-6926) or 519-650-6363 ext. 41203

Email:
Fax: 519-650-6367

It is extremely important for clients to know that they have access to their personal information. Requests for personal information held by Wentworth ., or corrections to such information, can be made by contacting the sponsoring employer or, in the case of direct client relationships, personal information can be requested or corrected by contacting our Privacy Officer by email, phone or fax. In response to such requests, Wentworth will correct or provide that personal information which can be corrected or retrieved at a reasonable cost to Wentworth Financial Services or the sponsoring employer, and will do so in a timely manner. In order to guard against fraudulent requests for access, Wentworth will require sufficient information to allow us to confirm the identity of the person making the request before granting access or making corrections.

Note: As is the case with all companies, Wentworth may be lawfully bound to deny access of an individual to their personal information. Reasons for such a denial have been described in applicable privacy legislation as those designed to protect personal and/or public interest.

Wentworth will review any and all concerns over privacy matters that are submitted to Wentworth Privacy concerns are managed by our Privacy Officer, who provide both a response to the concern as well as contact information for regulatory authorities. Wentworth .'s Privacy Officer will use any concerns to assist in measuring the effectiveness of our Privacy Policy, as well as our business practices. Amendments to our Privacy Policy will be described on our website, alongside the updated policy. Whether or not Personal Information already collected and used at Wentworth will be affected by any such amendments, will also be discussed on our website alongside the notice of the change.