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FIRM BROCHURE
(Part 2A of Form ADV)
December 10, 2025
4 Place Ville Marie, Suite 515
Montreal, Quebec H3B 2E7
Phone: (514) 394-2776
www.rempart.ca
Part 2A of Form ADV (the “Brochure”) provides information about the qualifications and
business practices of Rempart Asset Management (“Rempart” or the “Firm”). If you have any
questions about the contents of this Brochure, please contact the Chief Compliance Officer at
(514) 394-2776. The information in this Brochure has not been approved or verified by the
United States Securities and Exchange Commission (“SEC”) or by any state securities
authority.
Additional information about Rempart and its investment adviser representatives is also
available on the SEC’s website at www.adviserinfo.sec.gov.
Rempart Asset Management is an SEC registered investment adviser. Registration does not
imply any level of skill or training.
ITEM 2: MATERIAL CHANGES
Rempart Asset Management filed its last annual update to the Brochure on December 20, 2024.
Rempart continues to conduct its business activities and provide investment advisory services
in substantially the same manner as described in the last update to the Brochure. The ensuing is
only a list of changes since the last update that are or may be considered material. It does not
identify every change to the Brochure since the last update. In addition, there have been minor
word enhancements and clarifications throughout the Brochure.
There are no material changes since the Brochure was last updated on December 20, 2024.
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ITEM 3: TABLE OF COMMENTS
Item Number
Page
ITEM 2: MATERIAL CHANGES ................................................................................................................. 2
ITEM 3: TABLE OF COMMENTS ................................................................................................................ 3
ITEM 4: ADVISORY BUSINESS ................................................................................................................. 4
ITEM 5: FEES AND COMPENSATION ......................................................................................................... 5
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ....................................................... 6
ITEM 7: TYPES OF CLIENTS ..................................................................................................................... 6
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................................... 6
ITEM 9: DISCIPLINARY INFORMATION ...................................................................................................... 8
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................................................... 8
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ..... 9
ITEM 12: BROKERAGE PRACTICES ......................................................................................................... 10
ITEM 13: REVIEW OF ACCOUNTS .......................................................................................................... 11
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ....................................................................... 12
ITEM 15: CUSTODY ............................................................................................................................ 13
ITEM 16: INVESTMENT DISCRETION ...................................................................................................... 13
ITEM 17: VOTING CLIENT SECURITIES .................................................................................................... 13
ITEM 18: FINANCIAL INFORMATION ...................................................................................................... 14
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ITEM 4: ADVISORY BUSINESS
A. Description of Firm and Principal Owners
Rempart Asset Management (“Rempart” or the “Firm”) is a Canadian corporation that was
founded in 2010. Based in Montreal, Quebec, the Firm is principally owned by Douglas
Buchanan and David Stenason. In addition, Natalie Circelli also has an interest in the firm.
Rempart registered with the Securities and Exchange Commission as an investment advisor in
2010. Rempart is also registered with the Financial Markets Authority (AMF) in Quebec and the
provinces of Ontario, Alberta, and British Columbia.
Rempart’s activities with respect to non-U.S. clients may differ from those described generally
herein and Rempart may provide additional or different services to non-U.S. clients.
Furthermore, any discussion of activities with respect to non-U.S. clients is intended solely to
provide recipients a more complete understanding of Rempart’s business.
B. Types of Advisory Services Offered
Rempart specializes in discretionary investment management for individuals, private
corporations and foundations. The Firm takes a professional approach to diversified portfolio
management that features discipline, a focus on quality, and conservative risk management.
Rempart has three principal model portfolios that it utilizes when investing clients’ assets. The
Total Equity portfolio is only invested in individual equities while the Balanced and the Growth
and Income portfolios utilize both equities and fixed-income securities. Investments are
generally held for the long-term.
C. Client Tailored Services and Client Imposed Restrictions
Rempart creates investment portfolios that are tailored to the client and managed on a
segregated basis in separate accounts. The Firm does this by incorporating each client’s unique
circumstances into their own distinctive investment policy. Existing holdings, income
requirements, tax considerations, time horizon and growth objectives are all taken into
account. The individual circumstance of each investor is a key determinant in the portfolio
construction process.
Rempart may agree to abide by certain restrictions, including but not limited to restrictions on
securities or types of securities. When managing a client’s account, Rempart is not responsible
for and does not consider any securities, cash or investments not under management by the
Firm.
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D. Participation in Wrap Programs
Rempart does not participate in any wrap fee program.
E. Amount of Client Assets Managed
As of September 30, 2025, the following represents the amount of client assets under
management by the Firm on a discretionary and non-discretionary basis:
Type of Account
Discretionary
Non-Discretionary
Total:
Assets Under Management
$705,183,288
$0
$705,183,288
ITEM 5: FEES AND COMPENSATION
A. Compensation for Advisory Services
The specific advisory fees charged by Rempart will be documented in each client’s written
advisory agreement. Rempart’s standard advisory fee rates is 1.0%. Rempart bills its
management fees on a quarterly basis in arrears based on the average of the beginning and
ending values of the client’s account for the previous quarter. In certain circumstances,
advisory fees are negotiable.
B. Billing Method
Fees are deducted directly from clients’ accounts at the custodian on a quarterly basis. These
advisory fees are remitted by the custodian to Rempart. You are encouraged to verify the
accuracy of fee calculations and compare the statements provided to you by Rempart with the
statements from the custodian(s). The custodian may not verify the accuracy of the advisory
fees charged to you.
C. Other Fees and Expenses
In addition to the advisory fees paid to Rempart, clients may also incur additional fees and
charges, including securities brokerage commissions, custodial fees, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions.
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D. Termination of Services
Rempart does not bill any fees in advance. Either the client or Rempart may terminate the
Firm’s services without penalty at any time.
E. Outside Compensation for Sale of Securities
Rempart does not accept compensation for the sale of securities or other investment products
or for the recommendation of other investment advisors.
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Rempart does not charge performance-based fees (i.e., fees calculated based on a share of
capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory
client). As a result, the Firm does not engage in side-by-side management of accounts that are
charged a performance-based fee by Rempart with accounts that are charged another type of
fee (such as assets under management).
ITEM 7: TYPES OF CLIENTS
Rempart provides advisory services primarily to individuals, private corporations, and
foundations. Rempart has a minimum account size of $US 300,000.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Rempart seeks to balance two objectives - superior long-term returns and minimal risk
exposure - when investing clients’ assets. Depending on the investment objectives and risk
tolerance of clients, the Firm may utilize both individual equities (stocks) and fixed-income
securities
A. Equities
Rempart invests in companies, not markets. To this end, equity investment follows stringent
criteria, with research conducted in-house by our senior investment professionals. The primary
research focus is the generation and application of corporate free cash flow. This process is
termed “Tracking the Cash” and concentrates on companies that generate significant amounts
of free cash flow. This investment approach is backed by fundamental analysis with growth and
capital preservation being the two main goals.
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B. Fixed Income
Rempart’s fixed income investment strategy combines the objectives of capital preservation
and income generation. Investments are generally focused on government bonds as well as
high quality corporate issues. For taxable portfolios, preferred share investments may also be
considered. Investment decisions are influenced by the analysis of key macro-economic,
financial and political issues. Overall, Rempart seeks to maximize client returns while
minimizing exposure to adverse shifts in the fixed income markets.
C. Balanced Portfolios
Balanced portfolio mandates are structured with the objective of obtaining consistent returns
within a low-risk framework. Diversification is sought in both the equity and fixed income areas
and by the quality of the portfolio holdings. In determining the appropriate asset mix, longer-
term trends, including the business cycle, inflation and interest rate trends, fiscal and monetary
policies and other financial indicators are considered. The impact of these factors on the
various asset classes, in concert with the goals of high-quality growth and capital preservation,
drive the asset mix process.
D. Risks
Securities will fluctuate in value and have certain risks that are borne by the investor. In
addition, past performance is not a guarantee of future results. Therefore, clients should never
assume that future performance of any specific investment or investment strategy will be
profitable. Because of the inherent risk of loss associated with investing, Rempart is unable to
represent, guarantee, or even imply that its services and methods of analysis can or will predict
future results or insulate you from losses due to market corrections or declines.
Some risks a client should be aware of include, but are not limited, to the following:
• Market Risk: When the stock market or an industry as a whole fails, it can cause the
prices of individual securities to fall indiscriminately. This is also called systematic risk.
• Company Risk: When investing in securities, such as stocks, there is always a certain
level of company or industry-specific risk that is inherent in each company or issuer.
There is the risk that the company will perform poorly or have its value reduced based
on factors specific to the company or its industry. This is also referred to as
unsystematic risk and can be reduced or mitigated through diversification.
• Equity (Stock) Risk: Common stocks are susceptible to general stock market fluctuations
and to volatile increases and decreases in value as market confidence in and perceptions
of their issuers change. Clients are generally exposed to greater risk when holding
equities versus preferred stocks and debt obligations of the issuer.
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•
• Fixed Income Risk: When investing in bonds, there is the risk that the issuer will default
on the bond and be unable to make payments. Further, individuals who depend on set
amounts of periodically paid income face the risk that inflation will erode their spending
power. Fixed-income investors receive set, regular payments that face the same
inflation risk.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much
as a dollar next year because purchasing power is eroding at the rate of inflation.
•
• Political Risks: Companies face a complex set of laws and circumstances in each country
in which they operate. The political and legal environment can change rapidly and
without warning, with significant impact, especially for companies operating outside of
the United States.
Interest rate risk: The chance that prices of fixed income securities will decline because
of rising interest rates. Similarly, the income from fixed income securities may decline
because of falling interest rates.
• Reinvestment Risk: The risk that interest and principal payments from a bond will be
reinvested at a lower yield than that received on the original bond. During periods of
declining interest rates, bond payments may be invested at lower rates; during periods
of rising rates, bond payments may be invested at higher rates.
ITEM 9: DISCIPLINARY INFORMATION
Registered investment advisers such as Rempart are required to disclose all material facts
regarding any legal or disciplinary event that would be material to a client’s or prospective
client’s evaluation of the Firm or the integrity of its management. Rempart has not been subject
to any such legal or disciplinary event, and thus has no information to disclose with respect to
this Item.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Neither Rempart, nor any member of its management, is registered as a securities
broker-dealer, or a futures commission merchant, commodity pool operator or commodity
trading advisor.
The Firm does not have any affiliation with any related person who is a broker-dealer,
investment company, other investment advisor, financial planning firm, commodity pool
operator, commodity trading adviser or futures commission merchant, banking or thrift
institution, accounting firm, law firm, insurance company or agency, pension consultant, real
estate broker or dealer, or an entity that creates or packages limited partnerships.
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Rempart does not have any business relationships with other investment advisers that would
create a material conflict of interest.
At least one of Rempart’s clients is a high-ranking executive of a company that Rempart has
invested in on behalf of certain other clients of the firm. Rempart could potentially have an
incentive to invest in such a company’s securities for its clients, which could be a conflict of
interest. Consequently, the Firm has certain controls in place to help ensure that any such
investment made by Rempart is in the best interest of its clients and that the Firm does not
receive material non-public information from the respective executive of the company.
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING
A. Description of Code of Ethics
Rempart has adopted a Code of Ethics (the “Code”) to establish policies addressing its fiduciary
duties to its clients and to set forth general ethical principles and a standard of conduct that the
Firm requires of its employees. The Code establishes policies regarding personal trading by
employees and their immediate family members to mitigate any actual or potential conflicts of
interest. Generally, the Code prohibits personal trading in any security (subject to exceptions
set forth in the Code) while a client’s trade order is pending in that security.
Rempart has implemented procedures to monitor compliance with the provisions of the Code,
including pre-approval of personal securities transactions, the quarterly review of personal
transactions certifications, annual holdings reports, and annual compliance certifications. The
Code also contains preclearance procedures with respect to purchases of initial public offerings
and private placements. Any employee who violates the Code is subject to remedial action,
including termination of employment.
In addition, Rempart prohibits the use of material, non-public information (“inside
information”) and maintains a restricted list of securities that may not be purchased by its
employees for their own accounts or for client accounts because of the actual or possible
possession of inside information.
A copy of Rempart’s Code of Ethics is available to all clients and prospective clients upon
request.
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B. Participation or Interest in Client Transactions
From time-to-time, Rempart’s employees, in their personal securities accounts, may purchase,
sell, or otherwise enter into transactions in securities. Prior to, simultaneously with or after
such transactions, Rempart may, for its clients, purchase, sell, or otherwise enter into
transactions involving any of these same securities. To address these potential conflicts of
interest, employees are required to report their brokerage and trading accounts to Rempart
upon hire, at the time a new account is opened and annually thereafter. Employees’ personal
securities transactions are also subject to pre-approval by the Firm’s portfolio managers and
monitoring by the Chief Compliance Officer.
It is Rempart’s policy not to enter into any principal transactions or cross transactions on behalf
of client accounts. Principal transactions occur where an advisor, acting as principal for its own
account or the account of an affiliate, buys securities from or sells securities to an advisory
client. Cross transactions occur where an investment advisor arranges a transaction between
two client accounts.
ITEM 12: BROKERAGE PRACTICES
A. Factors Used to Select Custodians and/or Broker-Dealers
Rempart recommends that its U.S. clients use Raymond James Ltd (“Raymond James”) as the
custodian and broker-dealer for their advisory accounts. The factors considered by Rempart in
recommending a custodian include trade execution, brokerage commission rates, custody fees,
client service, responsiveness, and the willingness to accept accounts for U.S. persons. The
amount and quality of research provided by a custodian or broker-dealer is not a material
factor in this consideration.
Rempart will periodically review its use of custodians and broker-dealers to ensure that clients
are receiving “best execution,” which is the obligation to seek execution of securities
transactions on the most favorable terms for the client under the circumstances. Clients will not
necessarily pay the lowest commission or commission equivalent as other custodians and
broker-dealers may charge a lower commission. Rempart will not charge a premium or
commission on transactions beyond the actual cost imposed by the custodian or broker-dealer.
B. Research and Other Soft Dollar Benefits
The Firm does not have any arrangements to receive soft dollar benefits in connection with
client securities transactions. As discussed above, Rempart may receive research from
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custodians and broker-dealers but this is not a significant factor when determining which
custodian or broker-dealer to use to effect clients’ advisory transactions.
C. Brokerage for Client Referrals
Although Rempart is compensating the Firm’s custodian for U.S. clients, Raymond James, for
client referrals that were made in the past, Rempart no longer compensates Raymond James
for future referrals.
D. Directed Brokerage
Rempart does not require clients to execute transactions through a specified broker-dealer.
However, Rempart may recommend that a client utilize the services of a custodian or bank. In
cases where either Rempart or a client recommends that a specific custodian or broker-dealer
be used to execute advisory transactions, Rempart may be unable to achieve more favorable
execution of client transactions. In addition, clients may pay higher transaction costs as a result
of a broker-directed account by a client.
E. Aggregation of Orders
Rempart may aggregate (“block trade”) sale and purchase orders with other client accounts
that have similar orders being made at the same time. The Firm will only effect a block trade if
it judges that such a trade is reasonably likely to result in an overall economic benefit to the
client. Such benefits may include better transaction prices and lower trade execution costs. If all
aggregate orders do not fill at the same price, Rempart may cause the client and each similar
order to pay or receive the average prices at which the orders were filled. If such orders cannot
be fully executed under prevailing market conditions, Rempart may allocate the securities
traded among clients and each similar order in a manner which it considers equitable, taking
into account the size of the order placed, the client’s cash position, investment objective of the
account, size of the order and liquidity of the security.
ITEM 13: REVIEW OF ACCOUNTS
A. Review of Accounts
Client accounts are reviewed by Rempart on at least a quarterly basis and, in most cases,
monthly. In addition, the Firm seeks to meet with clients on a regular basis to ensure their
investment objectives are being addressed. As with the Firm’s investment approach, client
service is tailored to the individual – timely and accurate reporting, efficient handling of
administrative matters and, most importantly, access to Rempart’s senior investment
professionals – the decision makers in client portfolios. Close personal relationships between
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clients and the Firm’s senior portfolio managers ensure better customization of the investment
process, both for the development of the Investment Policy Statement and for security
selection.
B. Review Triggers
As noted above, client accounts are reviewed on a regular basis. Triggers for investment
reviews may include:
• Deposits or withdrawals
• Changes in a client’s asset mix due, for instance, to a new or exiting position
• Changes in a client’s financial situation or investment objectives
C. Regular Reports
Rempart provides quarterly reports to clients that include comprehensive portfolio valuations that
list all securities and their respective book and market values. The Firm’s reporting is flexible,
allowing customization of a client’s portfolio to their needs. If desired, portfolios can be
consolidated to provide clients with an overall view of their financial position. Further, reporting of
individual accounts can be provided to clients, as these portfolios may have differing investment
objectives (such as educational trust funds) that require separate evaluation.
Clients are urged to carefully compare statements sent by Rempart with statements sent by
other third parties, such as the statements sent by the custodian.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
As mentioned above, Rempart is compensating the Firm’s custodian, Raymond James, for client
referrals that were made in the past. The firm no longer compensates Raymond James or any
other firm for U.S. client referrals. Please see Item 12 above for more information regarding this
arrangement.
In the event that Rempart enters into new written arrangements with third parties to refer U.S.
clients to Rempart in exchange for compensation, such relationships, where applicable, will be
fully disclosed to each client to the extent required by applicable law. Rempart will verify each
person making referrals is properly registered in all appropriate jurisdictions and that all
referral activities are conducted in accordance with the Advisers Act and the rules thereunder.
Advisory fees paid to Rempart by clients who have been referred by a third-party in exchange
for compensation are not increased because of any referral relationship.
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ITEM 15: CUSTODY
Due to the fact that the Firm has the authority and ability to debit its fees directly from clients’
accounts, Rempart is deemed to have limited custody with regard to such accounts, pursuant to
Rule 206(4)-2 of the Advisers Act.
To mitigate any potential conflicts of interests, all client assets are maintained with an
independent qualified custodian. Furthermore, clients receive statements monthly directly
from the qualified custodian that holds and maintains their assets. Clients are urged to carefully
review all custodial statements and compare them to the quarterly statements provided by
Rempart. Rempart’s statements may vary slightly from custodial statements based on
accounting procedures, reporting dates, or valuation methodologies of certain securities.
ITEM 16: INVESTMENT DISCRETION
Rempart provides investment advisory services on a discretionary basis, which allows the Firm
to implement investment recommendations on behalf of its client’s accounts without requiring
their prior authorization. This authority will be granted through the execution of an advisory
agreement and the respective custodian’s account opening documents.
Clients are permitted to impose reasonable limitations on Rempart. All such limitations,
restrictions, and investment guidelines must be communicated to Rempart in writing and
included in the client’s Investment Policy Statement.
ITEM 17: VOTING CLIENT SECURITIES
It is Rempart’s policy and practice to vote proxies of investments held in clients’ accounts. The
Firm will generally vote proxies in line with a company’s management. Rempart, however, may
vote in a manner that is contrary to this general guideline if the Firm believes that doing so is in
a client’s best interest. If a proxy proposal presents a potential conflict of interest between
Rempart and a client, Rempart’s senior management will consider the potential conflict and
make a determination regarding what action should be taken and whether clients should be
notified and/or consulted.
Clients may obtain a complete copy of the proxy voting policies and procedures by contacting
Rempart in writing and requesting such information. Each client may also request, by
contacting Rempart in writing, information concerning the manner in which proxy votes have
been cast with respect to portfolio securities held by the relevant client during the prior annual
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period.
ITEM 18: FINANCIAL INFORMATION
Rempart does not require or solicit prepayment of more than $1,200 in fees per client, six months
or more in advance and therefore is not required to provide, and has not provided, a balance
sheet. Furthermore, Rempart does not have any financial commitments that may impair its ability
to meet contractual and/or fiduciary obligations to clients. Finally, the Firm has not been the
subject of a bankruptcy proceeding.
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