August 31, 2016 Research #18 Hemp-based pet foods Company Details True Leaf Medicine International Ltd. 100 Kalamalka Lake Road, Unit 32 Vernon, BC V1T 9G1, Canada Phone: +1 778-389-9933 Email: [email protected] www.trueleaf.com Shares Issued & Outstanding: 53,263,203 True Leaf starts production, sales and marketing in Europe, backed by first major purchase order Today, True Leaf Medicine International Ltd. announced a significant purchase order from PetsCorner, the second largest pet store chain in the UK, which will sell the True Hemp product line in all its 174 stores and has plans to expand by another 70 stores by late 2017. As PetsCorner is a leading pet brand in the UK, other brands may now follow, more of such orders could be on the horizon. For True Leaf, today’s purchase order officially marks the start of production, sales and marketing in Europe. On August 2, True Leaf Pet Europe LLC SARL, a subsidiary based in Luxembourg, was established in order to work in close proximity to European clients and markets, build networks, as well as develop sales (in European currency) and distribution performance. Test runs have been completed and production runs are now scheduled to build inventory for today’s order. Production and sales of the True Hemp product line are already underway in Canada and the US, whereas the company has recently added an online shop on its TrueLeaf.com site. With revenues now being generated on two continents, True Leaf emerges as a global brand, while also showing increased engagement in becoming one of Canada’s next licenced medical marijuana producers. Chart Canada (CSE) Canadian Symbol (CSE): MJ Current Price: $0.265 CAD (August 30, 2016) Market Capitalization: $14 million CAD Chart Germany (XETRA) German Symbol / WKN: TLA / A14NM1 Current Price: €0.175 EUR (August 30, 2016) Market Capitalization: €9 million EUR 2 Research #18 | True Leaf Medicine International Ltd. True Leaf‘s CEO, Darcy Bomford, who owns around 50% of all company shares, commented in today‘s press-release: “We’re on our way to becoming a truly global brand. Our product was the only hemp-focused pet treat at Interzoo® [the world’s largest bi-annual exhibition of supplies for pets with 40,000 attendees, held May 26-29 in Nuremburg, Germany], and it drew a lot of interest. PetsCorner® was one of those companies. The PetsCorner® order is a great start to our sales in Europe; they are true innovators in the UK market and we look forward to working with them to grow our brand.” Rockstone is impressed by the speed and dedication that the entire True Leaf team puts together to establish its innovative product line as a globally thriving brand. While not resting on their laurels, following the remarkable feedback they have been receiving from pet owners and pet foods specialists worldwide, the company announced on August 11 to launch 2 new hemp-based products for pets: “The innovative True Hemp™ soft chews for pets that are generating a buzz in the pet food industry will soon be joined by two new companion products that will give consumers new ways to deliver the benefits of hemp to their pets. True Leaf Pet, the producer of True Hemp™ soft chews, chose the SuperZoo mega pet show in Las Vegas last week to launch True Hemp™ ‘Sticks’ and True Hemp™ ‘Oil’, adding to its popular hemp-based functional product line. Says True Leaf Pet CEO Darcy Bomford, “The entire product line will offer the powerful True Hemp™ Hip + Joint, Calming and Health formulations in the same ratio for all three delivery formats: chews, sticks and oil.” Hemp is the main functional ingredient in each product, which provides a source of Omega 3, 6, 9 and also GLA - a substance known to support the body’s response to inflammation. Other active ingredients are added to support the functionality of the hemp in each formu- la, including innovative ingredients like green lipped mussel from New Zealand, DHA from algae and an amino acid from green tea for a calming effect. True Hemp™ ‘Sticks’ contain the same levels of hemp and other active ingredients as True Hemp™ Chews. They are grain-free with salmon for added omega 3s and are formed into a rigid ‘stick’ shape that is popular with consumers. True Hemp™ ‘Oil’ is an innovative blend of hemp, coconut and salmon oil that can be added directly onto a pet’s daily food. Through a patented process, the active ingredients are suspended in the oil blend to achieve the same ratio of active ingredients per measure as a True Hemp™ chew. The unique formulation provides beneficial omega 3 from both plant and ocean sources, plus MCTs (medium chain triglycerides) from liquid coconut oil. “We now have a full range of products that provide support for joint function, calming and overall good health in a variety of formats,” said Mr. Bomford. “Soft chews for picky or older dogs that are easy to chew and digest, hard sticks for more active dogs in a popular ‘dental stick’ style format, an oil blend with all of our active ingredients, plus healthy coconut and salmon oils. Additional product formats not only increase our retail shelf presence and order sizes, but also appeals to a wider consumer audience which ultimately strengthens our brand,” explained Mr. Bomford. Independent retailers attending SuperZoo underscored that analysis, responding enthusiastically to the extensions to the True Hemp™ product line. According to Mr. Bomford, True Hemp™ Sticks and Oil will be available throughout North America later this year via True Pet’s established distribution channels to the specialty pet marketplace.“ 3 Rockstone is also impressed by the dedication of True Leaf‘s Chairman, Michael Harcourt (former Premier of British Columbia and Mayor of Vancouver), who sent a letter to all stakeholders on July 25 providing an update on True Leaf‘s recent transformation and remarkable milestones. Shortly thereafter, he sent a formal letter to the Cannabis Legalization & Regulation Secretariat on August 18, making recommendations on the future production and distribution of legalized marijuana in Canada. Justice Minister Jody Wilson-Raybould has established a task force to advise the Canadian government on how best to move forward with its plan to legalize marijuana. Chaired by Anne McLellan, former deputy prime minister and health and justice minister, the task force is seeking public input and will advise the government on the design of the legislation and the regulatory framework for a new system of marijuana sales and distribution. True Leaf Medicine International Ltd. is one of 400-plus companies in the process of applying for a licence to produce and distribute medical marijuana under the previous government’s Marijuana for Medical Purposes Regulations (MMPR) program. The new plan to legalize marijuana will replace the MMPR process. True Leaf Chair Michael Harcourt, the former Premier of British Columbia, has written a letter to the task force outlining the company’s vision for a new plan, calling for both recreational and medical marijuana to be produced and distributed via the same system. Mr. Harcourt’s case and supporting points are as follows: As the federal government contemplates the means by which it will implement its laudable commitment to legalize marijuana, a task force has been created to advise on the design of a new system. The Task Force is seeking the views of Canadians on issues that are key to that design. They will then provide the federal government with a final report. This letter represents True Leaf Medicine International Inc.’s response to the call for public input. Research #18 | True Leaf Medicine International Ltd. PRODUCTION Among the Canadians most knowledgeable about the safe and secure production and distribution of marijuana are those companies, including our own, which have applied to become licensed producers of marijuana for medical purposes. As one of the 416 applicants in the queue as of June 28, 2016, we agree with the government’s discussion paper that this current regime could be effectively adapted for the full-scale production of marijuana in Canada. Of course, this process was established to produce marijuana for medical purposes under regulation (MMPR), but it has also generated a repository of knowledge, expertise and skill that can be seen as a formidable asset as the government contemplates wider legalization. There are currently 33 licensed producers who have been through an exhaustive seven-part process, and as mentioned above, another 416 who are currently working their way through the rigors of the process, which include screening, security clearance, review, pre-licence inspection and, finally, licensing. Along the way, attrition has been extensive. Hundreds have been refused, rejected, or withdrawn. In a number of cases, products have been recalled to protect client safety. This is a comprehensively and carefully regulated sector, unlike the ad hoc blossom of illegal dispensaries around the country, which have sprouted up to be in position for legalization. Whatever the ultimate fate of those dispensaries, the quality and safety of the product has to remain paramount – and the MMPR companies provide a readymade source of supply that will comply with the strictest safety standards. The discussion paper points out that the relatively small numbers of medical marijuana users suggests that adopting the current model would not be in the public interest in the context of the larger number of users expected in a legalized market. Yet in addition to the licenced producers, there are more than 400 applicants at various stages in the queue, and prior to the change in government, movement through the process was characteristic- ally slow. An intensified focus on resolving partially-completed applications will serve to increase supply, while ensuring the quality of that supply. As well, companies with licences have untapped capacity allowing for production increases. While using an adapted version of the current model may lead to a limitation in the supply at the outset, starting from scratch or instituting a parallel process will undoubtedly introduce troubling uncertainty in quality and security of the supply (at least), as has been the case in the US states legalizing marijuana for the public. The current model, which the discussion paper calls the market-driven competitive model, offers the best start, with a large number of qualified, screened and cleared sources of supply ready to scale up and address the demand. DISTRIBUTION Turning to distribution: A number of options have been outlined in the discussion paper, including the through-the-mail system currently used in the distribution of marijuana for medical purposes. Another possibility is modeling the distribution system after the alcohol or cigarette distribution system. One of the key considerations is protecting young Canadians by keeping marijuana out of the hands of children and youth. While these systems have merit, it is time to acknowledge that marijuana is a unique substance that is sought for its medicinal as well as its recreational benefits, unlike other controlled substances. There is an outside-the-box argument to be made that marijuana distribution should be controlled by or grounded in a coalition of health care professionals, including doctors, naturopathic doctors and pharmacists. Today, even the illegal dispensaries often go through the formality of requiring the approval of a licensed health professional as a condition of purchase. While this may amount to window dressing, the idea of a licensed dispensary, for both medical and recreational marijuana, is worth further consideration. A network of licensed dispensaries already exists – pharmacies. A licenced system including some of the more professionally run dispensaries and 4 Research #18 | True Leaf Medicine International Ltd. alternative health care practices, carefully integrating health care considerations into the recreational marijuana narrative, may prove surprisingly beneficial immediately and in the long run. RECOMMENDATIONS Production of the medicinal and recreational supply, other than plants grown for personal use, can be most effectively, safely and securely supplied by commerciallicenced producers. Now that the MMPR process is scheduled for change, we see this as an opportune time to licence more of the already screened, qualified and cleared applicants in anticipation of increased demand. Distribution of medical and recreational supply should be worked out co-operatively between Ottawa and the provinces. In BC, it will likely occur through a combination of Liquor Control Board outlets and private facilities. We recommend that pharmacies and alternative medical practices, as well as licenced existing dispensaries, be included in the distribution network for recreational as well as medical supply. Naturopathic doctors are professionally trained practitioners and herbalists; they are experts in both the historical uses of plants as well as modern pharmacological mechanisms. Therefore, we recommend that prescription for medical marijuana should expand beyond medical doctors to include both naturopathic doctors and pharmacists. Production and distribution issues aside, more research is needed on both recreational and medicinal use. True Leaf Medicine International Inc. sees the need for evidence-based research on the most effective dosages and strains required for the various applications of medicinal marijuana: pain management, nausea from cancer treatment, and epilepsy, among others. We are prepared to work further with our contacts in the medical community, along with pain management centres and organizations such as the Canadian Arthritis Society. If you are interested in discussing these ideas further, we would be pleased to do so. Sincerely, Michael Harcourt Chair, True Leaf Medicine International Ltd. To interview Mr. Harcourt or True Leaf CEO Darcy Bomford, please contact: Danielle Johnson Associate, BreakThrough Communications E: [email protected] P: (604) 803-0341 Ex-premier Harcourt pumped about legalizing pot plan, likes PM‘s ‘gutsy‘ moves By Ian Mulgrew on August 26, 2016 for the Vancouversun Former premier-turned-pot-proponent Mike Harcourt couldn’t have sounded happier and more optimistic than if he just blew a big blunt. “I did use marijuana in the ’60s and early ’70s but haven’t used it since,” he laughed. “I’m into wine — and a beer after a good tennis match. But from my experience of the last 13 years as a partial quadriplegic — 20 per cent of my body is still paralyzed — and I work with Rick Hansen and the disabled community, so I’ve seen the suffering and the pain, that people with spinal-cord injuries and other disabled people go through, and I think there are real benefits to cannabis.” Injured in a 2002 fall at his Pender Island cottage, the avuncular erstwhile mayor 5 of “Vansterdam on the Pacific” and NDP leader now is chair of Lumby-based True Leaf Medicine International Inc., one of 400-plus firms in the regulatory pipeline to produce medicinal cannabis. The new Liberal administration, however, has announced it will legalize pot and recently appointed a task force to report on how that should happen next spring. Harcourt this week wrote to Ottawa urging it to use the existing “onerous” vetting process for producers and the same distribution system for medical and recreational cannabis. His unique perspective should carry some weight. “I’ve seen this issue from the angle of being a criminal defence lawyer for 15 years and how destructive the laws were then, particularly around marijuana,” he explained. “I saw it as chair of the (Vancouver) police board for three terms and as premier. My riding was Mount Pleasant with the Downtown Eastside … I’ve been around the issues of drugs for a long time from an inside-the-system viewpoint, not just thinking about it as a citizen who thinks the marijuana laws are wrong and haven’t worked.” Finally, he said, Ottawa is on the right road. “I think it was gutsy for the prime minister and the Liberals to take on this issue,” Harcourt said. “I think there is a pretty good consensus in the country (that) there is a better way to deal with this, and we’re starting to move in the right direction.” As with alcohol under the Constitution, he thinks Ottawa will maintain health responsibilities for cannabis but devolve authority for recreational pot to the provinces and territories. There are 33 licensed producers who have survived the exhaustive seven-part screening and security clearance licensing process and serve the medical market. But many more will be needed to meet recreational demand. Research #18 | True Leaf Medicine International Ltd. “You’ve got a system up and operating, and potentially another 400 companies who could and should supply both the recreational and medicinal market with a product that will comply with the strictest safety standards,” Harcourt maintained. “(Medical cannabis) is a comprehensively and carefully regulated sector, unlike the ad hoc blossom of illegal dispensaries around the country.” In B.C., Harcourt envisions regulated producers such as True Leaf selling via the liquor distribution branch supplemented by private outlets (as happens with alcohol), naturopaths, pharmacists, doctors and licensed existing dispensaries. If you want to grow your own, that would be OK, he added. “It’s like people in my own community, the Italian community, used to make their own wine, still do,” Harcourt said. “What the heck! I think people who have the capacity to do that (grow cannabis) and want to do that, why not?” He didn’t think many patients would grow their own because most have special pain management issues that require particular strains of the plant: “It’s quite ailment specific and doing it on your own is hard to do.” He predicted that the “wild west” in Vancouver, Toronto and other cities — where dispensaries have opened willy-nilly in defiance of the still-in-place criminal prohibition — will soon end. government that is dealing with it intelligently instead of you-know-the-evilof-weed hysteria that has been going on since 1938 in the U.S. with huge tragic, terrible consequences for millions of people.” Business licence and zoning requirements are essential elements to any new scheme for regulating and distributing the drug: “I think it can be worked out quickly and well.” He said the biggest problem he saw south of the border was the conflict between individual states’ legalization legislation and federal laws that say marijuana is illegal. “So banking institutions can’t deal with producers or retailers,” Harcourt said. “I think we can have a better system in Canada because we have a national [email protected] Twitter.com/ianmulgrew 6 Research #18 | True Leaf Medicine International Ltd. True Leaf (MJ): A Multi-Pronged Approach to Capitalizing on Cannabis By Ryan Allway on August 25, 2016 for CannabisFN.com The North American cannabis industry is expected to grow at a nearly 30% pace to reach $20.7 billion in size by 2020, according to Research and Markets. While investors have many options to capitalize on this growth, few are as diversified as True Leaf Medicine International Ltd. (CSE: MJ) (FSE: TLA). The company targets U.S., Canadian and European markets with Hemp-based products for pets from its True Leaf Pet division and hopes to be supplying Canadians with Medical Marijuana from its True Leaf Medicine division upon Canadian government approval. In this article, we will take a closer look at True Leaf Medicine International and why investors may want to consider it for their portfolios. Near- & Long-term Plans True Leaf Medicine International was founded in 2013 to become a licensed producer of medical marihuana under Canada’s MMPR program. The company was an early applicant in July, 2013 and has worked its way through to the ‘Security Clearance’ stage with Health Canada. With an ideal location supported by the community and a strong team in place, the company expects more progress with its application as the Canadian government transitions to a new program called the ‘ACMPR’ (Access to Cannabis for Medical Purposes Regulations) this August. In the meantime, the company decided to forge ahead in a sector where its management team shared a common passion – pets. True Leaf Pet was formed to capitalize on growing demand for hemp and cannabinoid-based therapies for animals suffering from a range of conditions. The hemp-based nature of the company’s products means they aren’t subject to the same restrictions as marijuana and can be sold throughout the United States and Canada. The company has already launched a line of functional hemp-based dog chews under the True Hemp™ brand names: CALMING, HIP + JOINT and HEALTH. According to a growing body of research, these products may help with anxiety and joint pain, as well as providing an antioxidant and cognitive boost. Apart from the hemp-derived components, these chews contain active ingredients like green lipped mussel, turmeric root, L-theanine, DHA from whole-cell algae, pomegranate extracts and more. Growing Revenue According to the American Pet Products Association, U.S. consumers spent over $60 billion on their pets last year alone. These figures include nearly $15 billion spent on pet supplies and over-thecounter medicine, which represents True Leaf Medicine’s core revenue opportunity. attending the trade show responded enthusiastically to the new products since they provide an alternative delivery mechanism for older pets that may be pickier when it comes to accepting new formulations. The company is focused on building its in-store and online presence across the United States, Canada, and Europe, as well as expanding its digital marketing efforts across North America over the coming quarters. In addition to these core markets, management has expressed an interest in expanding its presence into New Zealand, Australia, and parts of Asia where consumers may respond well to hemp-based therapies for pet ailments. Looking Ahead The company remains in the very early stages of commercialization, but revenue continues to grow as more distribution is secured and their products reach pet stores. Through its network of distributors, the products are now available to over 9000 independent pet stores throughout North America. The company has also secured a European manufacturing partner and launched a European version of the same product line at the Interzoo® pet industry show in Nuremburg Germany last May. Distribution in that market is expected to commence in September 2016. True Leaf Medicine International Ltd. (CSE: MJ) (FTA: TLA) represents a compelling opportunity within the burgeoning cannabis industry. With exposure to human and pet markets, the company aims to build a diversified company that’s unified by its goal to improve quality of life. The North American cannabis market is estimated to reach $20 billion in size by 2020, while consumers spend nearly $20 billion on pet supplies and over-thecounter medications. In early August, the company attended the SuperZoo trade show in Las Vegas, Nevada – one of the largest pet trade shows in the world – where it unveiled its new TrueHemp™ Sticks and TrueHemp™ Oil formats. Independent retailers Ryan Allway For more information, visit the company’s website at www.trueleaf.com. About Ryan Allway Mr. Allway has over a decade of experience in the financial markets as both a private investor and financial journalist. 7 Research #18 | True Leaf Medicine International Ltd. Previous Coverage Research #17 “True Leaf just started to take root (to grow big thereafter)“ Research #16 “New sales channel for the market buzz: True Leaf products now also sell online“ Research #15 “Hemp for Dogs: True Leaf from Canada brings a special treat to the worlds leading trade-show Interzoo“ Research #14 “True Leaf pushes the gas pedal and brings True Hemp to Europe“ Above store in Dorking, 35 km from London, is one of PetsCorner‘s most successful stores in the UK. Research #13 “True Leaf conquers the US Pet Food Market” Research #12 “True Leaf To Sell HempBased Products in 3500 Stores in the US” Research #11 “True Leaf‘s Product Line Now Available in 47 Canadian Retail Stores” Research #10 “True Leaf‘s Selling Fast” PetsCorner is a Sussex based pet retailer currently trading from 174 stores with over 1,000 members of staff throughout England, with a funded expansion plan to have over 200 stores across the UK within the next 10 years. Pets Corner also operates a pet product and pet food business called Great&Small that sells to retailers in the UK and exports worldwide. Research #9 “True Leaf Expands to Europe” Research #8 “True Leaf Unveils New Product Line” Research #7 “Another Key Piece for the True Leaf Puzzle” Research #6 “True Leaf Pet’s Hemp Chew Product Line to be Distributed Across Canada” Research #5 “Interview with True Leaf‘s CEO Darcy Bomford“ Research #4 “One Step Closer Becoming A Licenced Medical Marijuana Producer“ Research #3 “On its way to production“ Research #2 “True Leaf To Enter The Pet Food Market With Hemp Products In Fall of 2015“ Research #1 “True Leaf Medicine International Ltd. Goes Public“ 8 Disclaimer and Information on Forward Looking Statements: All statements in this report, other than statements of historical fact should be considered forward-looking statements. Much of this report is comprised of statements of projection. Statements in this report that are forward looking include that True Leaf Medicine International Ltd. or any other company or market will perform as expected; that True Leaf will start producing saleable products; that True Leaf or its partner(s) can and will start producing and selling any kinds of products; that the company can raise sufficient funds for product development and/or production; that any of the mentioned plans are valid or economic. Such statements involve known and unknown risks, uncertainties and other factors that may cause actual results or events to differ materially from those anticipated in these forward-looking statements. Risks and uncertainties respecting medical marijuana and/or hemp-focussed companies are generally disclosed in the annual financial or other filing documents of True Leaf Medicine International Ltd. and similar companies as filed with the relevant securities commissions, and should be reviewed by any reader of this report. In addition, with respect to True Leaf Medicine International Ltd., a number of risks relate to any statement of projection or forward statements, including among other risks: the receipt of all necessary approvals and permits; the ability to conclude a transaction to start or continue product development and distribution; uncertainty of future market regulations, capital expenditures and other costs; financings and additional capital requirements for development, construction, and operating of a facility; the receipt in a timely fashion of further permitting for its legislative, political, social or economic developments in the jurisdictions in which True Leaf Medicine International Ltd. carries on business; operating or technical difficulties in connection with production or development activities; the ability to keep key employees, joint-venture partner(s), and operations financed. There can be no assurance that such statements will prove to be accurate, as actual results and future events could differ materially from those anticipated in such statements. Accordingly, readers should not place undue reliance on forward-looking information. Rockstone and the author of this report do not undertake any obligation to update any statements made in this report. Research #18 | True Leaf Medicine International Ltd. Disclosure of Interest and Advisory Cautions: Nothing in this report should be construed as a solicitation to buy or sell any securities mentioned. Rockstone, its owners and the author of this report are not registered broker-dealers or financial advisors. Before investing in any securities, you should consult with your financial advisor and a registered broker-dealer. Never make an investment based solely on what you read in an online or printed report, including Rockstone’s report, especially if the investment involves a small, thinly-traded company that isn’t well known. The author of this report is paid by Zimtu Capital Corp., a TSX Venture Exchange listed investment company. Part of the author’s responsibilities at Zimtu is to research and report on companies in which Zimtu has an investment. So while the author of this report is not paid directly by True Leaf Medicine International Ltd., the author’s employer Zimtu will benefit from appreciation of True Leaf Medicine International Ltd.’s stock price. In addition, the author owns shares of True Leaf Medicine International Ltd. and would also benefit from volume and price appreciation of its stock. In this case, True Leaf Medicine International Ltd. has one or more common directors with Zimtu Capital Corp. Thus, multiple conflicts of interests exist. Therefore, the information provided herewithin should not be construed as a financial analysis or recommendation but strictly as an advertisment. The author’s views and opinions regarding the companies featured in reports are his own views and are based on information that he has researched independently and has received, which the author assumes to be reliable. Rockstone and the author of this report do not guarantee the accuracy, completeness, or usefulness of any content of this report, nor its fitness for any particular purpose. Lastly, the author does not guarantee that any of the companies mentioned in the reports will perform as expected, and any comparisons made to other companies may not be valid or come into effect. Please read the entire Disclaimer carefully. If you do not agree to all of the Disclaimer, do not access this website or any of its pages including this report in form of a PDF. By using this website and/or report, and whether or not you actually read the Disclaimer, you are deemed to have accepted it. Information provided is educational and general in nature. Analyst Profile and Contact Stephan Bogner (Dipl. Kfm. FH) Mining Analyst Rockstone Research 8050 Zurich, Switzerland +41-44-5862323 [email protected] Stephan Bogner studied at the International School of Management (Dortmund, Germany), the European Business School (London) and the University of Queensland (Brisbane, Australia). Under supervision of Prof. Dr. Hans J. Bocker, Stephan completed his diploma thesis (“Gold In A Macroeconomic Context With Special Consideration Of The Price Formation Process”) in 2002. A year later, he marketed and translated into German Ferdinand Lips‘ bestseller („Gold Wars“). After working in Dubai for 5 years, he now lives in Switzerland and is the CEO of Elementum International AG specialized in duty-free storage of gold and silver bullion in a high-security vaulting facility within the St. Gotthard Mountain Massif in central Switzerland. Rockstone is a research house specialized in the analysis and valuation of capital markets and publicly listed companies. The focus is set on exploration, development, and production of resource deposits. Through the publication of general geological basic knowledge, the individual research reports receive a background in order for the reader to be inspired to conduct further due diligence. All research from our house is being made accessible to private and institutional investors free of charge, whereas it is always to be construed as non-binding educational research and is addressed solely to a readership that is knowledgeable about the risks, experienced with stock markets, and acting on one’s own responsibility. 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