Privacy Code

This Privacy Code informs you of the First Peoples Economic Growth Funds’ (FPEGF)
commitment to and policy on privacy. It tells you the ways FPEGF ensures that your privacy
and the confidentiality of your information are protected.

The objective of FPEGF’s Privacy Code is to promote responsible and transparent personal
information management practices in a manner consistent with the provisions of the
Personal Information Protection and Electronic Documents Act (Canada) and other
applicable privacy legislation.

The legal counsel of FPEGF will conduct periodic reviews of this Privacy Code to make sure
that it remains current with changing standards, technologies and laws.

Compliance with Legal and Industry Standards
FPEGF ‘Privacy Code
Purposes for the Collection, Use, Retention and Disclosure of Information About You
Key Principles
Why We Ask For Your Information
Why We Ask Others For Information About You
When We Disclose Your Information
How We Protect Your Information
Your Right To Access Your Information
Keeping Your Information Accurate
Recording Your Options
Information Regarding Website Practices
Updating This Code
Who Can Answer Your Questions About Privacy

COMPLIANCE WITH LEGAL AND INDUSTRY STANDARDS

FPEGF will make every reasonable effort to comply with industry standards and applicable
federal and provincial laws in Canada, including the Personal Information Protection and
Electronic Documents Act.

FPEGF’s PRIVACY CODE

FPEGF’s Privacy Code only applies to identifiable individuals whose personal information
FPEGF collects, uses, retains and discloses in the course of commercial activities. When we
use the words “personal information” or “information” in this Privacy Code, we mean
information about an identifiable individual, with the exception of the name, title or business
address or telephone number of an employee of an organization. Further, these terms do
not include information that does not identify particular individuals, like aggregate statistics
or anonymous data, or information which is publicly available, as specified in applicable
laws.

PURPOSES FOR THE COLLECTION, USE, RETENTION AND DISCLOSURE OF INFORMATION ABOUT YOU

The following are the purposes for the collection, use, retention and disclosure of personal
information by FPEGF:
To establish and maintain a relationship with you as a client and to provide services
to you;
To provide you with information about products, programs, services, conferences,
training resources and upcoming events that may interest you;
To administer the FPEGF’s services, to assess the quality and quantity of FPEGFs’
services, to maintain adequate accounting and tax records, and to have information
in such form as the FPEGF may reasonably require for its business needs;
To meet legal, regulatory and governmental requirements (including the
requirements of the Government of Manitoba and as the funding source of the
FPEGFs to detect and prevent fraud and to protect the interests of you, the FPEGF
and Government of Manitoba; and
To achieve any other purpose to which you have given your consent.

For clients who have not obtained a loan from FPEGF, the above-noted purposes differ in
that the FPEGF is not required to maintain accounting and tax records related to such
individuals. For loan clients, further details regarding FPEGF’s purposes for the collection,
use, retention and disclosure of personal information are outlined in your Loan Application
Form with the FPEGF.

KEY PRINCIPLES

FPEGFs’ Privacy Code consists of the following key principles, which apply to all aspects of
FPEGF’s handling of an individual’s personal information in the context of a commercial
activity, including the collection, use, retention and disclosure of such information.

A. Collecting and Using Information

FPEGFs collect and use information to establish and serve you as a client. FPEGFs gather
and use your personal information to provide you with the services you have requested.
FPEGFs collect, use, retain and disclose information about you only with your consent,
except as outlined in this Privacy Code. In obtaining your consent, whether express or
implied, the purposes for which FPEGF requires your information are outlined above. If
FPEGF purposes differ from those outlined above, the FPEGF will advise you of its new
purposes at the time of collection of your information.
FPEGF may depart from this consent principle in accordance with the limited exceptions
described in this Privacy Code, when permitted by other written and posted policies
established by the FPEGF, or where required or permitted by applicable laws (for instance,
FPEGF may disclose personal information in an emergency to protect human life or safety).
The information FPEGF collects depends on the service you have requested. For
every client, FPEGF needs your contact information (your name, address and some
identification). Here is why FPEGF needs some of the other information it asks you to
provide a birth date, this helps FPEGF identify you and ensure that no one is trying to
impersonate you.
Social Insurance Number (SIN) FPEGF uses your SIN to keep your information
separate from that of other clients with a similar name. For loan applicants, FPEGFs
use your SIN to obtain information with your consent, through the credit approval
process.
Financial Information
For loan applicants, your financial information is used to assess your eligibility for a
business loan.
Health Information
For loan applicants, FPEGF requires your health information if you wish to apply for
group creditor life insurance, as an insurance company will not provide such
coverage unless you are eligible based on your health information.
FPEGF only collects the information it needs and only uses it for the purposes
explained to you.
(Is there any surveillance of the site?)

FPEGF will only ask for the information it needs for the particular service you have
requested and will only use it for the purposes outlined in this Privacy Code or, if applicable,
outlined to you at the time of collection of your information, such as in the case of a loan
applicant. When you apply for a new service, FPEGF will indicate how it intends to use your
information if its purposes differ from those already outlined. FPEGF will advise which
information would help it to serve you but is optional for you to provide.

With your consent, FPEGF may obtain information about you from third parties.
Obtaining additional information about you from trustworthy third parties helps FPEGF
assess your eligibility for its loans and services. For example, for loan applicants FPEGF
needs to know your credit history. For this reason, FPEGF may contact other lenders or
credit bureaus to give it information on your credit history. FPEGF may also contact
employers or other personal references to verify information that you have given it. FPEGFs
will not do this without your consent, but please remember that if you do not give your
consent FPEGF will not be able to process your loan application and extend credit services to
you.

B. Releasing Information

Under no circumstances does FPEGF sell client lists or information to others. FPEGF will
release your information to outside parties only under the following circumstances:

Where FPEGF has your consent, whether express or implied.
For example, for loan applicants, FPEGF will disclose your credit history with such
other lenders or credit bureaus in order to support the credit approval process. In
such cases, FPEGF will release the information required to identify you, as well as
facts from its credit records about your repayment history.
For business clients, FPEGF may disclose your contact information to the Government
of Manitoba and other related organizations, such as the Manitoba Women’s
Enterprise Centre or the Canada/Manitoba Business Service Centre, whose programs,
services and/or products also may interest you. If you do not want FPEGF to provide
your contact information to those other related organizations, please advise FPEGF.
(May need to provide an easy opt out option like a check box or 1-800 number)
To suppliers and agents who assist FPEGF in servicing you and whom FPEGF can
reasonably trust to respect your privacy.
For example, FPEGF will disclose your name and address to a courier company
making a delivery to you at its request. In such cases, FPEGF will only make
disclosure to the extent necessary and whenever possible, require that the party
receiving this information provides reasonable assurances that they will respect the
privacy of your information in accordance with applicable laws.
When required or permitted by law to do so.
For example, FPEGF must give information in response to a valid demand, search
warrant or other legally valid enquiry or order. FPEGF may disclose information to
the authorities to serve a clear public interest and fulfill its public duty – such as to
protect against fraud or other criminal activity. FPEGF may take action to protect its
interests which may result in disclosing information to parties outside the FPEGF,
such as using agents to collect overdue accounts. FPEGF may also disclose
information under an exception to the requirement for consent expressly set out in
applicable laws, such as the exception for disclosures necessary to protect human life
or safety in an emergency.
When FPEGF needs to do so to protect its interests in the context of an existing or
potential legal or administrative proceeding.
For example, in the event of a proceeding commenced by or against FPEGF in
connection with you, FPEGF may disclose your information to its lawyers and to the
court or administrative body involved.
When required by the Government of Manitoba, as a funder of FPEGF and the source
of FPEGF investment funds.
For example, FPEGF must prepare reports for distribution to the Government of
Manitoba in order to receive funding. Although the information contained in such
reports is often de-identified data, such reports may contain personal information of
loan applicants and other clients.

C. Protecting Information

FPEGF will protect your information with appropriate safeguards and security measures.

FPEGF has reasonable security standards to protect its systems and your information
against unauthorized access and use. All employees of FPEGF are familiar with the
procedures that must be taken to safeguard client information.

FPEGF will retain your information only as long as it is legally or reasonably required by it.

The length of time FPEGF retains information varies depending on the service and the
nature of the information. This period may extend beyond the end of your relationship with
FPEGF but only for so long as it is legally or reasonably required by it. When your
information is no longer needed, FPEGF has procedures to destroy, delete, erase or convert
it to an anonymous form.

D. Providing Information Access and Accuracy

FPEGF will give you access to the information it has about you.
Most of your information is kept in FPEGF’s client file about you. Please contact FPEGF if you
wish to access any information FPEGF may have about you. FPEGF will advise you in
advance if a minimal charge will be required for conducting a search, and will do its utmost
to respond to your request within 30 days. Please note that FPEGF may not be able to
provide information about you from its records if it contains references to other persons, is
subject to legal privilege, contains information proprietary to FPEGF, is too costly to
retrieve, or cannot be disclosed for other legal reasons.

FPEGF will make every reasonable effort to keep your information accurate and up-to-date.

Having accurate information about you enables FPEGF to give you the best possible service.
You can help by keeping FPEGF informed of any changes, for instance if you move or
change telephone numbers. If you find any errors in FPEGF’s information about you, please
send FPEGF the correction in writing by mail, fax or e-mail. FPEGF will make appropriate
corrections and make sure that such corrections are conveyed to anyone it may have
misinformed. For information that remains in dispute, FPEGF will note your opinion in its file.

E. Respecting and Responding to Your Privacy Concerns

FPEGF will explain your options of refusing or withdrawing consent to the collection, use or
disclosure of your information, and will record and respect your choices subject to any legal
or contractual restrictions and reasonable notice.

Please contact FPEGF and ask to speak to the FPEGF’s Privacy Officer if you have any
questions related to your options. For example, you may refuse consent for FPEGF to do a
credit check, but the FPEGF will not be able to extend credit services to you. Once you have
a credit product, you will not be able to withdraw your consent to share your credit
experience with other lenders and credit bureaus, as this is necessary to support the credit
approval process.

FPEGF will investigate and respond to your concerns about any aspect of its handling of your
information.

If you have any concerns or questions about privacy and confidentiality – or any concerns
about the way a request for information was handled – you can take the following action.
Contact FPEGF and ask to speak to its Privacy Officer. Log on to www.firstpeoplesfund.ca to
find contact information for the FPEGF’s Privacy Officer (Perhaps actually provide the direct
and/or toll free phone number and e-mail address of the Privacy Officer right here or a link
to it).

The Privacy Officer appointed for FPEGF has the decision-making authority to resolve most
concerns. However, if you are unsatisfied with the way your complaint or request was
addressed, you may contact the Federal Privacy Commissioner at:

Office of the Privacy Commissioner
112 Kent Street
Ottawa, Ontario
K1A 1H3

INFORMATION REGARDING WEB SITE PRACTICES

The principles outlined in this Privacy Code apply to information collected through FPEGF’s
Web site, with the following qualifications.

FPEGF collects and stores your e-mail address from any communications that you may send
to it by clicking on any of its e-mail links. FPEGF may use your e-mail address to
communicate with you, if you are registering for a program, conference, training resource or
upcoming event, your e-mail indicates that a response to your inquiry is requested or if
FPEGF wishes to address a concern or complaint you may have.

Links to external sites are provided for you as a convenience and no responsibility or liability
is assumed in respect of such linked sites. These other sites may send their own cookies to
users collect data or solicit personal information. You should check the privacy policy of any
site you visit for information regarding their privacy handling practices.

UPDATING THIS CODE

Any changes to this Privacy Code or to FPEGF’s information handling practices will be
recorded in a timely manner.

We may add, modify or remove portions of this Privacy Code when we feel it is appropriate
to do so. However, FPEGF will not use any information collected prior to such changes for
any new purposes without first obtaining your consent.

Effective Date: December 9, 2009