The Trading Policy and Procedures (the "Policy") covers trading activities conducted by Munro. In particular, the Policy addresses procedures for trade order entry, allocations among Investment Products, other trading related issues, and the reporting and settlement process.
In order that portfolio management personnel satisfy the expectations of their clients and the fiduciary duties imposed upon them by securities legislation, portfolio management personnel are expected to:
- Deal fairly, honestly and in good faith with the Investment Products and, at all times, place the interests of the investors and clients of Munro and its subsidiaries and affiliates above personal interests;
- Ensure fairness in the allocation of investment opportunities among Investment Products;
- Comply with all laws and regulation applicable to the management of the Investment Products' portfolios. Each portfolio management employee has a duty to know, understand and comply with such laws and regulation;
- Practice and encourage others to practice in a professional and ethical manner that will reflect the high standard of care and integrity outlined in Munro's Personal Trading Policy.
- Strive to maintain and improve their competence; and
- Use reasonable care and exercise independent professional judgment where appropriate.