Fairness Policy

Sionna Investment Managers Inc. (“Sionna”) engages primarily in managing the investment portfolios of publicly offered mutual funds, separate managed funds, pooled funds and institutional segregated accounts (“Clients”) through discretionary authority granted under management agreements with its Clients and pursuant to the provisions of applicable securities legislation.

In the allocation of investment opportunities among its Clients, Sionna’s policy is to ensure that it deals fairly, honestly and in good faith with its Clients. Securities transactions are allocated among Clients in a manner that is equitable to each and on a pro rata basis in accordance with the amount being purchased or sold by each.

As a result of Sionna’s policy respecting the allocation of investment opportunities among Client accounts, if a particular investment opportunity is considered appropriate for two or more Client accounts, a block trade may be conducted on behalf of all such Client accounts. If the block trade is completed, or only partially completed, in different lots, having different purchase or sale prices and commissions, each participating account will receive its pro rata share of the securities purchased, or the proceeds of the securities sold, as the case may be, and will pay its pro rata share of the weighted average of the purchase prices or share the proceeds of the sale on a pro rata basis at the weighted average of the sale prices and commissions paid.

Sionna’s Order Management System (OMS) only allows for pro-rata allocation in the system. If, for any reason, an investment opportunity cannot be allocated pro rata among all participating Client accounts, the Trading Desk will discuss the allocation options with the PM who initiated the trade before submitting a request to a Co-CIO and CCO to change the allocation method.  A log will be completed by the Trading Desk and submitted to the Co-CIO and CCO documenting the date, affected account(s), the security, type of allocation method used and details identifying why this type of allocation method will be used. If this request is approved, the Trading Desk user permissions will be temporarily updated in the OMS to allow for a different allocation method to be used for trades related to this specific request.

If, for any reason, an investment opportunity cannot be allocated pro rata among all participating Client accounts, every effort will be made to address any trading inequities at the next opportunity so that every account, large or small, will, over time, receive equitable treatment in the allocation of investment opportunities. Account size and the amount of cash in the account, are examples of situations that may impact the ability of the client to participate economically in a trade.

January 2024