Statement of Policies

Principles for Responsible Investing Policy The objective of this Responsible Investing Policy (the “Policy”) is to formalize a practice of including environmental, social and governance (“ESG”) factors in the investment process for investment mandates managed by Counsel Portfolio Services (“Counsel”). We consider ESG factors as a result of our belief that companies that practice good environmental, social and corporate governance are those that end up being strong performance contributors over the long-term.

Fundamental to this Policy is our responsibility to act in the best interests of the investment funds (“Funds”). Our role is to exercise professional judgment on which ESG and non-ESG factors will be drivers of financial value and how we should approach them in order to enhance the long-term performance of our Funds. Counsel’s role is to encourage its appointed investment sub-advisors to follow similar ESG investment practices as they relate to the Counsel Investment Funds. We also recognize that formalization of our ESG approach will demonstrate alignment between our investment activities and broader social and environmental objectives of society.

Mutual funds sponsored by Counsel Portfolio Services Inc. are only qualified for sale in the provinces (except Quebec) and territories of Canada. Please read the fund’s Simplified Prospectus and speak to a Financial Advisor before investing.