Molly Giffen

Notice to Non-Canadian Investors

The information contained on this Site does not constitute an offer or solicitation to buy or sell any investment fund or other product or service to anyone in any jurisdiction in which an offer or solicitation is not authorized or is unlawful.

Burgundy provides investment advisory services to non-Canadian persons and investors (including U.S. Persons) where permitted by law. Prospective investors who are not resident in Canada should consult with Burgundy to determine if these securities may lawfully be sold in their jurisdiction. By accepting these terms you acknowledge and represent that you are an investor resident in Canada. If you are not a Canadian resident, you may return to Burgundy’s Site by declining these terms.

WHAT IS MiFID II?

The Markets in Financial Instruments Directive II (MiFID II) is a regulation that took effect January 2018 that aims to increase market transparency across the European Union (EU) through the standardization of the regulatory disclosures required for individual markets. It is one of the most significant regulatory changes to impact the global asset management industry. The MiFID II reforms cover a number of key topics including: best execution, conflicts of interest, bundled commissions and payments for research & trading.

BURGUNDY’S APPROACH TO MiFID II

At Burgundy, we follow a disciplined, bottom-up, value-driven approach to investment research, supported by intensive fundamental research. We believe that conducting our own research is the backbone of our success. From time to time we have used external research paid for using broker commissions to supplement our own research, but we do not rely on external research in our decision-making.

We always approach our decision-making with the guiding principles of fairness and transparency in mind such that all our clients are treated equally.

As of January 3, 2018, Burgundy has gone execution only on all trades and will absorb all external research costs related to our equity mandates for all clients, regardless of domicile. We will not pass these broker research commissions on to our clients, nor will our fees change as a result of this policy.

BURGUNDY ASSET MANAGEMENT LTD. BECOMES A UN PRI SIGNATORY

In September 2019, Burgundy became a signatory of the United Nations-supported Principles for Responsible Investment (UN PRI). The UN PRI is a network of international investors working to incorporate environmental, social and governance (ESG) factors into investment and ownership decisions.

Burgundy’s Investment Team employs a quality-value investment approach to preserve and grow our clients' capital over the long term. Quality-value investing is based on investing in great companies when we can buy them for less than they are worth and holding them for the long term. ESG risks can impact a business’ ability to stay great and poor practices jeopardize long-term profitability. Therefore, as long-term owners of businesses, evaluating ESG factors go hand in hand with preserving capital. Our disciplined and bottom-up approach allows ESG factors to be evaluated at the onset of the investment process.

The UN PRI aligns well with Burgundy’s approach to ESG integration. Becoming a signatory allows us to formalize our thinking on the ESG issues that have a material impact on our holding companies. As a signatory of the UN PRI, we commit to the following six principles:

• To incorporate ESG issues into investment analysis and decision-making processes
• To be an active owner and incorporate ESG issues into our ownership policies and practices
• To seek appropriate disclosures on ESG issues by entities in which we invest
• To promote acceptance and implementation of the Principles within the investment industry
• To work with the PRI Secretariat and other signatories to enhance their effectiveness in implementing the Principles
• To report on our activities and progress towards implementing the Principles