PRIVACY POLICY

Resolution Investment Management (“Resolution”) is a division of ReSolve Asset Management Inc. (“ReSolve”) needs to collect private information from our clients and prospective clients in order to properly fulfill our duties. Understanding a client’s needs and wants, financial position and family circumstances enables us to ensure that all investment recommendations are suitable. This is both a regulatory requirement and good business. Resolution is committed to protecting our clients’ privacy and the confidentiality of their personal information in our possession. This document explains the measures we take to fulfill these commitments.

We ask our clients for no more personal information than necessary.

The “Know Your Client” information forms we ask clients to complete elicit only the information we need for contractual, regulatory and income tax requirements including: name, address, phone and fax numbers, email addresses, birth date, social insurance numbers, asset holdings and values, investment knowledge and objectives, spouse’s name and occupation, and children’s and dependents’ names and ages. Our application forms for registered retirement accounts elicit only the information needed to register these accounts with the government including: social insurance number, spouse’s or designated beneficiary’s name and birth date. We do not disclose any non-public personal information to any third party except as required by law or as outlined in this Policy.

We limit access to client’s personal information.

We record client’s personal information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords. We authorize employees to have access to client’s personal information only on a “need to know” basis. We have installed hardware and software security to keep our servers clean and secure. We maintain a duplicate copy of our data at an offsite location for disaster recovery purposes. This data is password protected. We keep paper copies of client’s personal information in filing cabinets. We keep the computers and filing cabinets in which such information is stored in areas of our business premises that are kept locked when not in use.

We use practices and polices to help prevent unauthorized disclosure of client’s personal information.

We train our employees to keep client’s personal information strictly private and confidential. We require all of our staff to sign our privacy document that obliges them to respect and protect client’s personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of client’s personal information. We shred paper documents containing client’s personal information before discarding such documents.

We expect similar safeguards from our service providers.

We may use service providers to provide us with various services such as technology, administration, printing, marketing, legal and accounting. We will require them to have a similar privacy policy or to agree to acknowledge and abide by ours.

We take privacy seriously.

ReSolve’s Chief Compliance Officer is responsible for ensuring that Resolution adheres to its privacy policy. The Chief Compliance Officer is responsible for training our employees in our privacy policies and for monitoring the fulfillment of our privacy commitments. We invite any client or prospective client to contact him for any additional clarification desired. A client wishing to review his or her personal information in our possession should send a written request to this effect to ReSolve’s Chief Compliance Officer.