1. BEST EXECUTION OBLIGATION

IIROC dealer members are obligated to establish policies and procedures that are designed to achieve best execution when acting for a client. BBS diligently pursues the execution of each client order on the most advantageous terms for the client. The primary factors in determining the most advantageous trade for the client are the price at which the trade would occur, the speed of execution, the certainty of execution and the overall cost of the transaction.

2. GOVERNANCE & OVERSIGHT

The BBS Best Execution Committee has oversight of the BBS Best Execution Policy. BBS is committed to reviewing its best execution policies and procedures and those of its trading services providers annually, or when advised of a material change, to ensure they remain effective and will correct any deficiencies identified in the course of its review.

3. ORDER ROUTING AGREEMENTS

Marketplace Trading Hours

Hours of operation for trading in publicly listed securities are between 9:30 am and 4:00 pm (Eastern Time) Monday through Friday, excluding statutory holidays. Our trading staff is available for order execution between the hours of 8:00 a.m. and 5:00 p.m., Eastern Standard Time ("EST"), Monday through Friday, not including statutory holidays. Pre-market and after-hours trading facilities are available in limited situations.

Marketplace Fees and Rebates

BBS may pay marketplace fees or receive marketplace rebates when routing certain orders to certain marketplaces. Costs associated with those fees paid may be passed on to the client. Please review Commission Structure on website for more details.

3.1 Listed Equities – Canadian Equity and Options Order Flow

Marketplace

BBS is committed to make reasonable efforts to ensure that clients achieve the best execution of their orders to buy or sell Canadian listed securities that are quoted or traded on Canadian marketplaces. The Canadian equity market is composed of multiple marketplaces, including traditional exchanges and Alternative Trading Systems (ATSs). BBS is a participant of the Toronto Stock Exchange (TSX), the TSX Venture Exchange (TSX-V), TSX-Alpha Exchange, Aequitas Neo Exchange, Nasdaq CXC & CX2, The Canadian Securities Exchange (CSE), and Omega. The same security may be traded on multiple marketplaces. Listed Derivative trading in Canada is facilitated through the Montreal Exchange.

Default Order Handling

BBS trading system is connected to Smart Order Router (“SOR”), which will ensure that our clients receive the best price for their orders. BBS does not allow direct market access for client orders, except DEA clients.

Pre-Open

All pre-market orders are routed to Chi-X SOR if they are routable there. CSE/PURE exclusive symbol will be routed to ITG SOR.

Continuous Session

All day orders except CSE/PURE exclusive symbols are sent to ITG SOR during trading hours for all Canadian markets. CSE/PURE exclusive symbols will be routed to CSE/PURE with price protection. GTC and GTD orders during trading hours are sent to ITS SOR.

Post-Close

Generally, after-market client orders are queued until the next day. But after-market client orders using application platforms, such as IRESS and ITS, are routed to Chi-X SOR until 5PM. For more information, please refer to ITG's Best Execution Disclosure: https://www.virtu.com/regulatory-disclosures/ under Canada Regulatory Disclosures

3.2 Listed Equities – US Equity and Options Order Flow

BBS has entered into order routing and services agreements with US trading partners, who are subject to similar best execution obligations under US securities law requirements.

4. OVER THE COUNTER ("OTC") FIXED INCOME FAIR PRICING

BBS trades most fixed income orders through CBID, a marketplace for retain fixed income orders operated by Perimeter Markets Inc., a member of IIROC. In order to ensure the prices are fair and reasonable, BBS checks at least two sources of liquidity, including markets like CBID, public quotation services and other dealers and market participants. BBS will not execute a trade at what it considers to be an unfair or unreasonable price, taking into account recent trading prices, intervening events that might affect the security’s price and transaction prices for similar securities considering such factors as yield, credit quality, features and ratings.

5. CONFLICTS DISCLOSURE

The parent company of BBS Securities Inc. is a shareholder of Aequitas Innovations Inc. The parent company of Aequitas, Neo Exchange, has representation on the Aequitas Board of Directors. As a Canadian registered investment dealer bound by both internal and external requirements respecting the handling of client orders in a manner that provides each client with the most advantageous execution terms available, BBS will consider as part of its order routing protocol, execution opportunities on the Aequitas Neo Exchange. BBS may receive payment in the form of a rebate for routing client orders in US equities and options pursuant to the order routing arrangement. Any remuneration that BBS receives for directing orders to any market center reduces the execution costs for BBS and will not accrue to client’s account. BBS does not direct its orders to specific trading services providers in order to receive such rebate; all orders are routed through pre-determined processes as described in this disclosure.