A Message from Sionna’s Founder

Our Principles

At Sionna, we recognize that our clients have invested more than assets with us; their very first investment decision is to invest their trust. All other considerations, such as evaluating investment returns or asset allocation strategies, flow from that initial investment. We are committed to protecting and preserving our clients’ trust with the same degree of diligence and purpose of duty that we dedicate to their other, more tangible, invested assets.

Simply put, our clients’ trust gives us our purpose: to help them to accumulate wealth. We focus on providing downside protection and delivering long-term, above-average returns by applying a disciplined value investing process. To that end, we are driven by a strong commitment to ensure that the highest ethical standards are adhered to, that the highest standard of quality is implicit in everything we do, and that our investment research is independent and objective and provides the platform for achieving consistent performance.

We also recognize that, to achieve our purpose, we must focus on developing and retaining high-calibre investment professionals. Through continuous training, individual responsibility and assembling a body of intellectual capital, our people are able to leverage their own talents by drawing on the skills, experience and strengths of others within a culture of excellence.

The organizational principle upon which Sionna is founded is adherence to the highest standards of quality and ethical conduct. This principle ensures that we maintain a culture of excellence and forms the bedrock upon which our clients’ trust in us is based and the cornerstone of our relationships with them.

Code of Ethics and Conduct

Sionna complies with the Code of Ethics and Standards of Professional Conduct of the CFA Institute. This code sets guidelines that promote integrity, competence and dignity within the investment community worldwide. It can be found at 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: the interests of Sionna’s clients are always placed above personal interests – by applying the highest standards of integrity and ethical business conduct.

Also, we have created a number of compliance measures and tools to help our employees 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 team.

Best Execution and Soft Dollars

When placing orders for and on behalf of clients’ accounts, Sionna will select those brokers and dealers from whom they reasonably expect to obtain the best execution (after considering all transaction costs and research or other benefits).

Sionna uses a limited soft dollar policy, allowing for the procurement of third-party investment research using a portion of brokerage commissions for payment – which is valuable to the investment decision-making process and adheres to the regulations stipulated by securities regulators. A copy of Sionna’s best execution and soft dollar policies may be obtained upon request.

Institutional Trade Matching

Sionna confirms that we establish, maintain and enforce policies and procedures designed to achieve matching in accordance with National Instrument 24-101.

Conflicts of Interest

Under securities regulations, Sionna, in each of its registrant roles, is required to identify material conflicts of interest expected to arise between Sionna (including each individual, acting on its behalf) and its clients. Further, if a reasonable investor would expect to be informed of the nature and extent of an identified conflict of interest, Sionna must do so. The purpose of the Conflicts of Interest Disclosure Statement is to provide Sionna clients with a description of such conflicts a registrant firm with roles as advisor, investment fund manager and dealer might encounter, and the measures Sionna has taken to prevent, avoid and mitigate such conflicts.

Proxy Voting

Public companies call on holders of their securities to vote on a wide range of matters relating to those companies. In most cases, these matters are proposed by management; however, shareholders also make proposals. Some of Sionna’s clients prefer to exercise their own votes as shareholders. Where our clients have requested that we do so, Sionna takes responsibility to vote on all matters that have a bearing on company value as part of its fiduciary duty to our clients.

The measures listed above have assisted us with creating an ethical culture that places the interests of our clients ahead of our own. This enables us to help clients achieve their goals by pursuing excellence in everything we do.

Kim Shannon
Founder & Co-Chief Investment Officer