CASL Policy

Policy Statement

This document sets forth the policy of RDIGS and is designed to provide reasonable assurance that

• A consistent process is followed with respect to the dissemination of commercial electronic messages to RDIGS clients and prospective clients in Canada
• RDIGS employees sending commercial electronic messages from and/or to a computer system(s) in Canada comply with the requirements of CASL. The RDIGS Anti-Spam Policy (“Anti-Spam Policy”) and related procedures (the “CASL Procedures”) require that all RDIGS employees sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada comply with CASL, and seeks to ensure that all CEMs sent by or on behalf of RDIGS, or using a RDIGS email address or using a device owned or provided by RDIGS, comply with CASL

Policy Details

The Anti-Spam Policy describes RDIGS’s commitments relating to the provisions of CASL and electronic messages of a commercial nature sent to RDIGS clients, prospective clients, and others, as applicable. From time to time, RDIGS may implement additional policies, procedures and/or practices as it relates to anti-spam measures.

Application

This Policy applies to RDIGS employees who may be sending CEMs from and/or to a computer system(s) in Canada or to an electronic address that will be accessed from a computer system in Canada. With respect to RDIGS’s operations, the Anti-Spam Policy has been adopted in compliance with the requirements of CASL, and RDIGS is committed to complying with CASL. All other RDIGS policies and procedures will be interpreted in a manner that is consistent with the Anti-Spam Policy and that promotes compliance with CASL to seek to deter damaging and deceptive forms of spam from occurring in Canada.

Consent

RDIGS obtains express, opt-in consent, unless a verifiable basis for implied consent or an exception to consent exists, before sending a CEM to anyone who has not had an existing business relationship with RDIGS within two years before the date on which the CEM is sent. Unless a valid documented basis for implied consent or an exception to consent exists, RDIGS also obtains express, opt-in consent for the sending of CEMs to RDIGS prospects. The request for consent cannot be in an electronic message unless there exists a basis for implied consent to send the message. The request for consent must be sought separately within a communication (e.g. through a separate action such as affirmatively checking a checkbox) and cannot be bundled as a term of acceptance of an agreement. A verbal consent is acceptable where a record of the details of the consent is maintained in a database.

Form and Content of CEMs

• All CEMs are required to comply with the form and content requirements of CASL, generally described as follows:
  identifies the sender;
• The sender’s mailing address;
• The sender’s telephone number or email address or link to a webpage; and
• An unsubscribe mechanism or withdrawal of consent from receiving CEMs from RDIGS and its subsidiaries and affiliates. RDIGS takes steps to require that any third-party service provider who sends CEMs on behalf of RDIGS complies with CASL.

Storage of Relationship Details

A key component of complying with CASL involves maintaining records of RDIGS’s relationships with clients and prospective clients. Each business unit of RDIGS is required to create and maintain in the business unit’s Client Relationship Management (CRM) system (including, but not limited to, Benchmark, Salesforce), verifiable records documenting the relationships giving rise to implied consent, and verifiable records of express, opt-in consents obtained from RDIGS clients and prospective clients. “Clients” are defined as those organizations or individuals who have at least one open account or a contractual relationship with RDIGS at the relevant time. Organizations or individuals who have closed their last remaining account or terminated their contract with RDIGS are not considered RDIGS clients for purposes of this Policy. Implied consent or express, opt-in consent is obtained in accordance with the CASL Procedures and recorded in the applicable CRM system in order to track the client and prospect relationships. Records of express, opt-in consent and records documenting the relationships giving rise to implied consent are retained for a minimum of three years after RDIGS ceases sending CEMs to the RDIGS client or prospect. Commercial Electronic Messages All RDIGS employees sending CEMs from and/or to a computer system(s) in Canada are required to comply with this Policy and related CASL procedures and processes. A “CEM” is defined as an electronic message that includes content (for instance, text, hyperlinks, images or attachments) that:

• promotes, offers or advertises RDIGS or RDIGS’s products or services, or employees, or contacts;
• solicits business for RDIGS or RDIGS’s employees or contacts; and
• any other similar message that encourages participation in commercial activity.

Examples include promotional event invitations (e.g., webcasts or RDIGS events), marketing newsletters, etc.

The following messages do not have to comply with the

Requirements applicable to CEMs:

• Messages sent to RDIGS clients about their business;
• internal communications about RDIGS’s business (including communications with RDIGS offices outside Canada);
• legally required notices, such as messages that are sent to comply with a regulatory requirement (e.g., material changes, required account activity information, etc.);
• responses to requests, inquiries or complaints.
  Messages that RDIGS employees email each other internally using a device that RDIGS owns or provides, or using a RDIGS email address, should be related to RDIGS. RDIGS employees may not internally email each other offers, promotions, advertisements, or referrals unrelated to RDIGS business without the internal recipient’s verbal consent.

Compliance by Third Parties

All third-party contracts with service providers who may send CEMs on behalf of RDIGS must contain contractual clauses obligating the service provider to comply with CASL including the form and content requirements of CEMs.

Unsubscribe Mechanism

CEMs that are not exempt from requirements applicable to CEMs noted above are required to include a form of unsubscribe mechanism to facilitate the withdrawal of consent or do-not-contact requests within a period of time and in a manner that would allow RDIGS to process that request within 10 days of the date on which the unsubscribe, withdrawal of consent or do-not-contact request was made. This information should be maintained in the applicable database that tracks the client and prospect relationships. All emails sent by employees will be compliant with CASL and will include the option to ‘unsubscribe.’ You can ‘unsubscribe’ from our Commercial Electronic Messages at any time by visiting unsubscribe or by emailing dpo@rdigs.com with ‘Unsubscribe’ in the subject line.