PSP Investments has adopted a Code of Conduct for Officers, Employees and Others and a Code of Conduct for Directors (the “Codes”) which are regularly reviewed. Managing perceived, potential and real conflicts of interests is key to PSP Investments’ investment process. The Codes provide a workable process for identifying, minimizing and resolving potential conflicts of interest.
PSP Investments requires that if one of its employees or one of its Directors has a real, potential or perceived conflict of interest, such employee or director must not approve a transaction or participate in any discussions to approve it. In addition, employees must notify the Compliance Officer and directors must notify the Chair of the Board of Directors as soon as possible about any real, potential or perceived conflicts of interest. All notifications should be made in writing.