National Instrument 54-101 Communication with Beneficial Owners of Securities of a Reporting Issuer
Part 1 Definitions and Interpretation
Section 1.1 Definitions

“beneficial owner”

(1) In this instrument…“beneficial owner” means, for a security held by an intermediary in an account, the person or company that is identified as providing the instructions contained in a client response form or, if no instructions are provided, the person or company that has the authority to provide those instructions;