Client Service Policy, Governance & Compliance Framework

1. Purpose and Scope

This policy establishes the governance, compliance, and client service standards of Neurostrat Advisory. It defines how clients are selected, how engagements are governed, and how risks, ethics, and regulatory obligations are managed across all activities in Canada and Québec.

This policy applies to all partners, associates, advisors, and third parties acting on behalf of the firm.

2. Guiding Principles

Our client service approach is anchored in integrity, independence, accountability, and long-term value creation. We are committed to delivering work that is ethically sound, compliant with applicable laws, and aligned with the broader interests of clients, stakeholders, and society.

3. Regulatory and Legal Compliance (Canada & Québec)

We operate in accordance with all applicable federal and provincial regulations, including but not limited to:

• Privacy and data protection laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Québec’s Law 25

• Anti-corruption, anti-money laundering, and anti-terrorist financing requirements under Canadian law

• Applicable tax, corporate, and commercial regulations

• Industry-specific regulatory frameworks where relevant

We ensure that all engagements meet legal and regulatory obligations in the jurisdictions in which we operate.

4. Client Selection Framework

We apply a structured and consistent process to evaluate all potential clients and engagements. Client acceptance decisions are based on the following dimensions:

Strategic Alignment
The client’s objectives and mandate must align with our expertise, values, and long-term positioning.

Reputational and Ethical Considerations
We assess the integrity of the client, leadership, and business practices, including potential reputational risks.

Regulatory and Legal Risk
We evaluate exposure to legal, compliance, or jurisdictional risks, including cross-border considerations.

Engagement Impact
We consider the broader implications of the work, including potential societal, environmental, and stakeholder impact.

Operational Feasibility
We assess whether we have the capability, independence, and capacity to deliver effectively.

The firm reserves the right to decline or discontinue engagements that do not meet these criteria.

5. Engagement Governance and Oversight

All client engagements are subject to defined governance protocols:

• Clear scoping, contractual agreements, and defined deliverables

• Partner-level accountability for engagement quality and outcomes

• Escalation mechanisms for high-risk or complex engagements

• Periodic internal reviews to ensure alignment with policy and standards

Select engagements may be reviewed by an internal governance or risk committee where additional oversight is required.

6. Risk Management and Compliance Controls

We maintain a proactive risk management approach that includes:

• Pre-engagement risk screening

• Ongoing monitoring of engagement risks

• Documentation and audit trails for key decisions

• Internal compliance checks where necessary

Where risks exceed acceptable thresholds, engagements are restructured, escalated, or declined.

7. Confidentiality, Data Protection, and Privacy

We maintain strict controls to protect client information:

• Compliance with PIPEDA and Québec Law 25 requirements

• Secure handling, storage, and transmission of sensitive data

• Confidentiality obligations applicable to all team members

• Access controls based on role and necessity

Client data is used solely for the purpose of delivering agreed services.

8. Conflicts of Interest and Independence

We actively identify and manage conflicts of interest:

• Pre-engagement conflict checks

• Restrictions on serving competing clients in sensitive matters

• Disclosure and mitigation protocols where potential conflicts arise

Where conflicts cannot be effectively managed, we decline or withdraw from the engagement.

9. Pro Bono and Non-Profit Engagements

This policy applies equally to pro bono and non-profit work. All such engagements are subject to the same standards of due diligence, risk assessment, and governance as commercial engagements.

10. Professional Standards and Accountability

All team members are expected to:

• Adhere to the firm’s Code of Conduct

• Complete required compliance and ethics training

• Exercise professional judgment and escalate concerns when necessary

Non-compliance with this policy may result in disciplinary action, including termination of engagement or affiliation.

11. Continuous Improvement

We continuously strengthen our governance, risk, and compliance capabilities to reflect evolving regulatory requirements and industry best practices. This ensures that our client service model remains robust, responsible, and future-ready.

12. Policy Governance

This policy is reviewed periodically and updated as required to ensure continued alignment with Canadian and Québec regulatory standards and the firm’s strategic direction.