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Governance

A MESSAGE FROM THE PRESIDENT

Our Principles

Our clients invest more than their money with us; they invest their trust. All of our decisions, including buying and selling stocks, flow from this understanding. We are committed to protecting and preserving our clients’ trust with the same degree of diligence and purpose of duty that we dedicate to investing their money.

Simply put, our clients’ trust gives us our purpose: to help them accumulate wealth over the long term. We fulfill that purpose by prudently investing in a diversified portfolio of low-risk value stocks. To that end, we are driven by a strong commitment to ensure that we adhere to the highest ethical standards, that the highest standard of quality is implicit in every thing we do and that our investment research is independent, objective and provides the platform for achieving consistent performance.

To achieve our purpose, we must focus on developing and retaining high-calibre investment professionals. With continuous training and upgrading, a keen sense of individual responsibility and a growing body of intellectual capital, we work on building a Sionna culture based on talent, experience and sharing.

Code of Ethics and Conduct

Sionna complies with the Code of Ethics and Standards of Professional Conduct of the CFA Institute (formerly the Association of Investment Management Research). This code sets guidelines that promote integrity, competence and dignity within the investment community worldwide. It can be found at www.cfainstitute.org.

Our Code of Ethics and Conduct establishes rules of conduct for Sionna’s employees. The objective of the Code is to ensure fair treatment of investors in products managed by Sionna: that the interests of Sionna’s clients and the investors in the investment products we manage are always placed above personal interests, which is accomplished by applying the highest standards of integrity and ethical business conduct.

Also, we have created a number of compliance measures and tools to assist our employees to perform their duties at the highest standard, including, for each employee, a complete manual of Policies and Procedures covering all aspects of managing client portfolios.

Personal Trading

Sionna’s Personal Trading policy prohibits each of our staff from purchasing Canadian securities. Transactions in foreign equities can only be made with pre-clearance from our Compliance Director.

Soft Dollars and Trading Cost Control

We minimize trading costs through negotiated commissions with our selected brokers and no longer participate in “soft dollar” arrangements with our brokers. Soft dollars are a credit given to investment counsel firms as a percentage of commissions that investment firms can use to pay certain expenses, such as a subscription to a data service. In our view, soft dollars increase transaction costs to the detriment of clients.

Among the other policies and procedures that support ethical behaviour by our staff are:

Fairness: ensures that we deal fairly, honestly and in good faith with our clients, and make every effort to ensure that every account, large or small, will, over time, receive equitable treatment in the allocation of investment opportunities;

Conflicts of Interest Disclosure Statement: requires us to identify material conflicts of interest which would be expected to arise between us and our clients;

Proxy Voting: when our clients have requested that we do so on their behalf, outlines our duty to vote on all matters that have a bearing on company value and describes our criteria for voting;

Institutional Trade Matching: in which we have established, maintain, and enforce policies and procedures designed to achieve matching in accordance with NI24-101.

These measures have assisted us with creating an ethical culture that places the interests of our clients ahead of our own. The measures have also inspired our portfolio managers to invest alongside our clients in our Pooled Funds.

Kim Shannon
President, CIO
Chief Compliance Officer

Governance: