Mission Statement The Mission of I.A. Michael Investment Counsel Ltd. (“IAMICL”) is to ensure sound, competent, unbiased investment advice and management that adheres to fiduciary principles and the terms of any fund documents. Legal and Ethical Standards Officers and employees are expected to know and conform to all applicable laws, and to the CFA Institute’s standards of practice and code of ethics. IAMICL will maintain current knowledge of legal and ethical issues and obligations, and will endeavour to ensure awareness and compliance of all employees through educational programs from time to time. Professionalism and Integrity Officers and employees will maintain standards of professionalism and integrity. Officers and employees shall not engage in any conduct involving dishonesty, fraud, deceit or misrepresentation or commit any act that reflects adversely on their honesty, trustworthiness or professional competence. Fair Dealing with Clients IAMICL will deal fairly and objectively with all clients and prospective clients when disseminating material information of concern to such clients or when taking investment actions. IAMICL will endeavour to treat clients equally in terms of access to and timing of access to information, investment ideas, and investment products. Transactions for client accounts will in all cases have priority over transactions where IAMICL or an officer or employee of IAMICL is a beneficial holder. Conflicts of Interest IAMICL and its officers and employees will use all reasonable efforts to avoid engaging in activities that would lead to conflicts of interest. Where appropriate, IAMICL will implement systems to monitor the personal trading and other business activities of officers and employees. Any potential material conflicts will be disclosed to clients as soon as IAMICL becomes aware of them. Marketing Investment Products In the marketing of investment products or solicitation of new clients, IAMICL’s officers and employees will conform to ethical and professional standards. Disclosure should include the fair representation of risks, fair and accurate presentation of historical performance in accordance, where possible, with the Performance Presentation Standards of the CFA Institute, a full description of all fees in plain language and disclosure of the recipients of any fees. Confidentiality IAMICL will preserve confidentiality of information communicated by clients, prospective clients and others concerning any matters within the scope of the client-investment counsel relationship except where information concerning illegal activities is involved.