OPB’s Statement of Investment Policies and Procedures prohibits any OPB member, officer, employee, portfolio manager or other person appointed to carry out duties and responsibilities on behalf of OPB (an “OPB Agent”) to knowingly permit his or her interest to conflict with his or her duties and powers in respect of the Ontario Public Service Pension Plan (the “Plan”). A conflict of interest includes any direct, indirect, actual or perceived material pecuniary interest of an OPB Agent in any investment in which OPB participates or proposes to participate. Any such conflict of interest is required to be disclosed by the OPB Agent to the Secretary of OPB. To the extent any investment matter requires the approval or vote of any committee of OPB, such OPB Agent must declare his/her conflict of interest and refrain from participating in the discussion or voting on such investment matter.
In addition, both the SIPP and the applicable Canadian pension legislation prohibits, subject to specific legislative exemptions, OPB from directly or indirectly lending its money to or investing its money in, or entering into a transaction with a person or entity that is considered a “related party” to the Plan.