Not saying we differ much in understanding but just for clarification, Zenith is a Venture Issuer which is defined as a Reporting Issuer that does not have its securities listed on TSX or (a whole list of exchanges or as I have seen defined elsewhere as recognized by the OSC). As we know, the OTC is not one of these qualifying exchanges.
A letter that I received in 2016 from iTrade stated, "We have recently been advised by the company they have completed the required filing with Canada Revenue Agency (CRA) to be considerd a Public Corporation. Therefore the shares of Zenith Epigenetics are now deemed to be a Qualified Investment". ZCC has since taken the reporting status with ZEL just being a wholly owned subsidiary of ZCC.
From Brad Cann, Zenith CFO back then also, " Notwithstanding that the shares of a corporation may not be listed on a designated stock exchange in Canada, the corporation may still be a public corporation if it so elects. Paragraph (b) of the definition of "public corporation" in subsection 89(1) provides that a corporation that complies with prescribed conditions relating to share ownership and trading, and that makes the required election, is a public corporation as of the time the election is made." At that time, Brad said they had made the first election and would soon make the second as it was due. The iTrade letter confirmed that it had been made to deem Zenith a public company.