https://www.ontario.ca/laws/statute/90s05#BK152
“insider” means,
(a) a director or officer of a reporting issuer,
(b) a director or officer of a person or company that is itself an insider or subsidiary of a reporting issuer,
(c) a person or company that has,
(i) beneficial ownership of, or control or direction over, directly or indirectly, securities of a reporting issuer carrying more than 10 per cent of the voting rights attached to all the reporting issuer’s outstanding voting securities, excluding, for the purpose of the calculation of the percentage held, any securities held by the person or company as underwriter in the course of a distribution, or
(ii) a combination of beneficial ownership of, and control or direction over, directly or indirectly, securities of a reporting issuer carrying more than 10 per cent of the voting rights attached to all the reporting issuer’s outstanding voting securities, excluding, for the purpose of the calculation of the percentage held, any securities held by the person or company as underwriter in the course of a distribution,
(d) a reporting issuer that has purchased, redeemed or otherwise acquired a security of its own issue, for so long as it continues to hold that security,
(e) a person or company designated as an insider in an order made under subsection (11),
(f) a person or company that is in a class of persons or companies designated under subparagraph 40 v of subsection 143 (1); (“initié”)
“investment fund” means a mutual fund or a non-redeemable investment fund; (“fonds d’investissement”)
“investment fund manager” means a person or company that directs the business, operations or affairs of an investment fund; (“gestionnaire de fonds d’investissement”)
“issuer” means a person or company who has outstanding, issues or proposes to issue, a security; (“émetteur”)
“management company” means a person or company who provides investment advice, under a management contract; (“compagnie de gestion”)
“management contract” means a contract under which an investment fund is provided with investment advice, alone or together with administrative or management services, for valuable consideration; (“contrat de gestion”)
So when you check the above; They are not insiders.
