Montrusco Bolton Investments Inc. (“MBII”) integrates ethical considerations to its investment approach

For many years, the concepts of socially responsible investing have been integrated into our investment process. We do not have ethical funds as such, but our investment team supports the values of responsible investment.

MBII believes those companies which accept their social responsibilities increase the long-term wealth of their shareholders. We encourage the leaders of the companies we invest in to develop policies on key social issues related to their activities and to establish practices set by their boards which comply with these policies in the following areas:

		Environmental impact of their activities;
		Impact of corporate strategies and decisions on the communities and people affected by their products and operations;
		Business practices with regard to recruitment, working conditions and remuneration;
		Corporate governance.

We constantly evaluate the companies we invest in as well as potential investment candidates in order to identify any of our 13 predetermined guidelines that relate to the strategy / structure, legal / compliance and management / governance of the company.

Before introducing a new investment idea into a portfolio, we consult The Heritage Foundation database: The Index of Economic Freedom (http://www.heritage.org/index/). Our objective being to invest in companies whose assets and revenues are derived mainly from the countries that promote economic opportunity and prosperity, we therefore avoid countries which do not foster an environment of economic freedom.

Proxy voting policy

The policy on shareholder proxy voting is based on an important principle, that of transparency. To avoid any conflict of interest, we must provide all relevant information for the shareholder to make informed decisions. MBII’s proxy voting policy promotes sound corporate governance in a manner that is proactive, constructive and aligned with shareholder rights.

External consultants

In addition to the detailed analysis and monitoring by the investment team, MBII engages the services of outside consultants to support its research efforts.

We use the following sources of independent analysis to further minimize the additional financial risks arising from social responsibility, environmental and corporate governance.

1. MBII is a signatory of the United Nations-backed Principles for Responsible Investment (PRI)
   
   As institutional investors, MBII has a duty to act in the best long-term interests of its clients. In this fiduciary role, we believe that environmental, social and corporate governance (ESG) issues can affect the performance of investment portfolios. We also recognize that the implementation of the PRI will enable investors to be aligned with the broader objectives of society.
   http://www.unpri.org/principles/index.php
   
   
   
2. Responsible Investment Group Inc. (more commonly known as GIR)
   
   
   • Semi-annually, GIR assesses social and environmental aspects, as well as the corporate governance of the companies held in our investment portfolios;
   • Provides recommendations upon request;
   • Produces weekly newsletter.
   http://www.gir-canada.com
   
   
   
3. Jantzi – Sustainalytics
   
   
   • Research and analysis
     • Environment;
     • Social responsibility;
     • Corporate governance.
   http://sustainalytics.com/
   
   
   
4. Glass, Lewis & Co.
   
   
   • Proxy voting solutions
     • Analysis;
     • Recommendations tailored to individual investment policies;
     • Proxy research.
   http://www.glasslewis.com/