Responsible investment policy

Approval date: February 12, 2026

PURPOSE OF THE POLICY

This policy formalizes consideration of Environmental, Social and Corporate Governance (ESG) factors when material into the investment process at MD Financial Management (MDFM). As part of our responsibility to act in the best interests of our clients, the consideration of ESG factors in the investment process is a component of delivering long-term investment performance for our clients. As a fiduciary, MDFM relies on this Policy to govern its responsible investment activities in accordance with the stated investment objectives of the portfolio offering documents and investment policy statements. MDFM does not rely on the Scotiabank Enterprise ESG Risk Framework.

SCOPE

This Policy applies to all portfolios managed internally by the 1832 Asset Management (1832 AM) investment team, which is the Portfolio Manager for the MDFM investment funds and MDPIM pools (collectively the “Funds”), across all asset classes, sectors, themes and countries in which we invest.

PRINCIPLES FOR RESPONSIBLE INVESTMENT

To formally reflect our commitment to responsible investing, MDFM is a signatory to the United Nations supported Principles for Responsible Investment (PRI). As a signatory we have committed to adhering to six voluntary principles defined by global institutional investors and the United Nations:

• Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes.
• Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices.
• Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest.
• Principle 4: We will promote acceptance and implementation of the Principles within the investment industry.
• Principle 5: We will work together to enhance our effectiveness in implementing the Principles.
• Principle 6: We will each report on our activities and progress towards implementing the Principles.

DEFINITIONS

Responsible investing: is an approach to investing that incorporates ESG factors into investment decisions.

Environmental factors: Refers to issues impacting the natural environment, including climate change, greenhouse gas emissions, resource depletion and water scarcity, waste and pollution, biodiversity and deforestation, among others.

Social factors: Can refer to issues centered around people (i.e. employees and communities) and can include but are not limited to; working conditions (including modern slavery and child labour), local communities (including indigenous communities or other vulnerable groups), health and safety, employee relations and diversity.

Governance factors: Refers to issues regarding how companies are managed and governed, including: executive pay, bribery and corruption, political lobbying and donations, board diversity and structure, tax strategy and risk management, among others.

CONSIDERATION OF ESG INTO THE INVESTMENT PROCESS & ACTIVE OWNERSHIP PROCEDURES

Responsibility for incorporating ESG factors into the investment process resides with the 1832 AM Multi-Asset Management team as fiduciaries for client mandates. We believe the considerations of ESG factors can have an impact on the long-term performance of investments. As fundamental investors, our investment managers may, where material, take ESG factors into consideration when assessing the potential for investments to assist in achieving the investment objective of the mandate. We do not generally exclude any particular investment based on ESG factors alone, with the exception of investment in companies that manufacture tobacco or tobacco related products or whose primary business is cannabis or cannabis related products.

Meetings and direct engagement between our investment professionals and the current or potential entities in which they invest can be an important part of the fundamental investment process at 1832 AM. When our investment professionals engage with entities it can help develop a deeper understanding, including relevant ESG-related issues. Direct engagement can facilitate better-informed investment decisions, while also allowing our investment professionals to communicate views and concerns to those entities.

Proxy voting is an important part of MDFM’s fiduciary duty to clients, and an important part of the investment process. MDFM has established formal proxy voting guidelines. In all cases, proxies are voted in a manner consistent with the best interests of our clients.

At the firm level, 1832 AM’s risk oversight process will also review ESG factors as part of the regular review of investment portfolios.

REPORTING

A copy of our Responsible Investment Policy will be made publicly available.