Investment Policy - Long Term (Group II Foundation that pools its investments with a Group III foundation)

PREAMBLE

The goal of the investment policy is to outline the foundation's investment principles and provide guidelines to maximize return on investment in a prudent and diversified manner that will provide adequate income while ensuring requirements for distributions to qualified donees, administrative fees and the preservation of the value of capital over the long term are carried out. The investment policy shall also ensure that the foundation conforms to the requirements of applicable Federal, Territorial and Provincial Statutes and Legislation including the Income Tax Act (Canada) and the Trustee Act.

Roles and Responsibilities

The Board of Directors is responsible for reviewing and approving the Investment Policy, for ensuring compliance with the policy and for monitoring the performance of the results on a quarterly basis.

The Board of Directors will appoint an Investment Committee to develop the Investment Policy Statement. The Investment Committee will be responsible for investing funds as per the Investment Policy, prior to an Investment Manager being engaged. The committee is responsible for reporting to the Board the performance of the investments on a quarterly basis, according to the return objectives in accordance with the policy. The Investment Committee is required to inform the Board if the committee at any time feels that the performance expectations cannot be met or that the investment guidelines in the Investment Policy restrict performance. No portion of the portfolio will be loaned directly to any individual.

The Investment Committee will recommend to the Board, when it is appropriate, to hire an Investment Manager. The Investment Committee is responsible for conducting a search for the Investment Manager, as required, and to forward recommendations to the Board. The search will be conducted through a Request for Proposal format. Proposals will include: understanding of the requirements of the Investment Manager, applicable investment fees, reports to be prepared, performance and experience in managing funds, broad investment approach and services to be offered.

The Investment Manager is required to comply with the Code of Ethics and Standards of Professional Conduct as adopted by the CFA Institute.

The committee quarterly will monitor the performance of the Investment Manager according to established criteria in the Investment Policy Statement, agreed to jointly by the committee and the manager. The Investment Manager will participate in the establishment and the review of the Investment Policy Statement. The Investment Committee will approve investment recommendations made by the Investment Manager. If a majority of the committee is not available, the chair of the committee is authorized to approve the recommendation of the Investment Manager, within the guidelines of the Investment Policy Statement.

The Investment Manager is required to:

• Provide a review of the portfolio's performance as well as expectations on the economic and financial market outlook and related investment strategies on a quarterly basis to the Investment Committee, such report to be presented to the Board by the Chair of the committee.
• Notify the Investment Committee promptly in writing of any significant changes in the policies, procedures, personnel, ownership or any similar areas of the investment firms.
• Inform the Investment Committee if the Manager at any time feels that the performance expectations cannot be met or that any guidelines contained herein restrict performance.
• Disclose any material interest in any investment or the proposed transaction.
• Provide a letter of compliance, within 4 weeks at the end of each quarter, detailing and explaining any investment guidelines contained in the policy which have been breached and/or confirming compliance.

 The Investment Policy Statement will include the following:

• Overall total return objective, measured on a four-year moving average basis, to achieve a maximum rate of return consistent with prudent investments in order to meet the Spending and Capital Preservation Policy guidelines
• Provision of income for distribution while addressing the foundation's administrative fee and the preservation of capital
• Consideration of safety of capital, liquidity and long term capital growth
• Identification of eligible asset classes, asset allocation, and appropriate level of diversification
• Performance benchmarks in each asset class

Canadian Law and Regulatory Compliance

The Board will identify the provincial or territorial trust and charitable-property law governing each fund and will exercise the applicable prudent-investor standard. For an Ontario charitable corporation, this includes the Trustee Act and the Charities Accounting Act and regulations, subject to the terms of the gift and any lawful delegation to an investment agent.

The investment program will consider liquidity, preservation of capital, total return, diversification, costs, conflicts, environmental and other relevant factors, restricted-gift terms and the annual disbursement quota. Investment authority may be delegated only under a written mandate with selection, monitoring, reporting and termination criteria. The Board remains responsible for oversight.

If the Foundation is a private foundation, holdings will also be monitored for the Income Tax Act excess corporate holdings rules and associated reporting and divestment obligations.

Application note: This template must be read with the Foundation's articles, bylaws, gift terms and the federal, provincial or territorial laws that apply to its incorporation, activities and operating jurisdictions. Organization-specific facts and provincial requirements require lawyer confirmation before adoption.

Monitoring: This policy will be reviewed every three years or when there is a significant change in the capital of the portfolio.

Board Acceptance: This policy was approved/reaffirmed at the_______________ Board meeting.