Responsible Investing

at Guardian Capital LP

Our Philosophy

At Guardian Capital LP (Guardian Capital), our core objective is to enhance long-term investment performance for our clients. An integral part of achieving this goal is our commitment to invest in companies that we believe are capable of generating long-term, sustainable growth.

We believe that investee companies are best positioned to achieve long-term, sustainable growth when they:

Engage in sustainable environmental practices

Consider the effects of their operations on clients, employees and communities

Have proper governance practices that protect the interests of all stakeholders

Our Approach

Environmental, social and governance (ESG) considerations are integrated into our investment processes and analysis of securities, and stewardship activities, which are commonly referred to as ESG Integration and Active Ownership, respectively.

ESG Integration

At Guardian Capital, ESG Integration occurs through our proprietary research processes and the analytical skills of our investment teams. Our investment teams utilize proprietary frameworks to assess material ESG factors in determining the longterm sustainability of the underlying company and the impact ESG factors are likely to have on its outlook and valuation.

Stewardship and Active Ownership

Our role as an active steward of capital is an important part of our fiduciary duty. Active Ownership practices, including corporate Engagement and Proxy Voting, are a core aspect of Guardian Capital’s stewardship approach. For more details, see Our Approach to Stewardship document.

Engagement

Discussions with companies often yield valuable insight into their business strategy, views and approach while providing an avenue for our investment teams to encourage companies to improve their sustainability practices.

Proxy Voting

When voting proxies for the companies we invest in, Guardian Capital investment teams take into consideration the investee company’s governance structure, commitment to sustainable environmental practices and consideration of social policies that foster the well-being of all stakeholders.

The implementation is unique to each investment team and each investment strategy. In the same way that there is no “one size fits all” for investing, there is no “one size fits all” for determining how ESG factors are considered in the investment process by each investment team at Guardian Capital.

LEARN MORE ABOUT RESPONSIBLE INVESTING APPROACHES

Guardian Capital LP is a signatory of the United Nations-supported Principles of Responsible Investment (UN PRI). The UN PRI does not prescribe the exclusion of any particular type of company or industry; rather it requires that, as the Manager, we are informed on the ESG issues, and that we are comfortable with the activities and practices of the companies that we invest in. Guardian’s approach to responsible investing is consistent with the framework provided by the UN PRI. Our Responsible Investing policies are publicly available on our website above.

Responsible investing is an approach to investing that incorporates ESG considerations into investment decisions. This approach may incorporate considerations beyond traditional financial information into the investment selection process, which could result in investment performance deviating from other products with comparable objectives or from broad market benchmarks. Certain prospectused ETFs and mutual funds managed by Guardian Capital LP may invest in securities such as derivatives, cash, money market instruments, asset-backed securities and commercial paper, and other similar instruments where ESG integration may not be applicable due to the nature of such instruments. The opportunity for stewardship and active engagement is more limited for funds holding the types of securities listed above as there are typically no voting rights attached. In a fund of funds structure, the bottom fund holding the portfolio securities will be the fund engaged in stewardship and/or active engagement. In the case of third-party funds used in fund of fund structures, there may be no direct engagement by Guardian Capital LP with the issuers held in those funds. Please read the fund’s prospectus for a more detailed explanation on Responsible Investing and Proxy Voting Policies.