Notice to Investors
Commissions, trailing commissions, management fees and expenses
all may be associated with mutual funds investments. Please read the prospectus
before investing. Mutual Fund securities are not covered by the Canada Deposit
Insurance Corporation or by any other government deposit issuer. In the case of
the Burgundy Money Market Fund and Burgundy U.S. Money Market Fund, there can
be no assurances that these funds will be able to maintain their net asset
value per security at a constant amount or that the full amount of your
investment in these funds will be returned to you. Mutual Funds are not
guaranteed, their values change frequently and past performance may not be
repeated.
Non-Canadian Investors
This site should not be considered an offer to sell or a
solicitation to buy securities of mutual funds to any person residing in the
United States of America or in any other jurisdiction in which such an offer or
solicitation is unlawful. Securities of the mutual funds managed by Burgundy
Asset Management Ltd. (“Burgundy”) will not be sold to any person
residing outside Canada unless such sales are permitted under the law of their
jurisdiction.
Privacy Policy
1. We only ask Clients for necessary
personal information.
All of our forms are designed to obtain only information needed
for contractual, regulatory and income tax reporting requirements. In addition
we use the personal information you provide to us to thoroughly understand your
investment goals and objectives. This helps us to determine the appropriate
investments for you. For example, our Client Profile form requests:
-
Name
-
Contact information
-
Birth date
-
Social Insurance Number (SIN)
-
Asset holdings and values
-
Investment knowledge and objectives
-
Dependent and beneficiary names and contact information
For registered retirement accounts, we ask only for information to register the
accounts with the government. To help us keep our records accurate and
complete, we ask Clients to notify us of any personal information changes or
corrections.
2. We safeguard and limit access to
Clients’ personal information.
We keep Client information in a computer system, which can only
be accessed by authorized employees using secure passwords. We have installed
anti-hacking hardware to prevent unauthorized access to the computer system.
For disaster recovery purposes, we maintain a duplicate computer system in an
offsite location. This system has the same privacy and security measures as are
in our main offices. We may also keep paper copies of Client information in
filing cabinets in our office. When we need to store information offsite, the
storage firm is under contract to adhere to our privacy and security measures.
3. Outside Service Suppliers
We may use service providers to perform specialized services on
our behalf including but not limited to, issuing cheques, preparing your income
tax slips, processing transactions or other data processing. Our service
providers may at times be responsible for handling personal information
however, they are provided only the information necessary to perform the
required services. In addition, we require them to protect the information in a
manner that is consistent with our privacy policies and security practices.
4. We prevent unauthorized disclosure of
Clients’ personal information.
All Burgundy and Beaujolais personnel are trained to keep Client
information private and confidential. We require all of our staff to sign our
Code of Conduct, which contractually obliges them to respect and protect Client
information even if they are no longer in our employment. We prohibit
disclosure of any Client’s personal information to a third-party without
the Client’s explicit consent. We shred paper documents containing Client
information before discarding such documents. When electronically stored
personal information is no longer required for contractual or regulatory
purposes, we delete the information from our computer systems.
5. Use of information collected via the
Internet.
If you use the internet to communicate with us or you access our
website, certain information about your computer may automatically be
generated, collected and logged by Web servers. This information may include
the Internet Protocol (IP) Address assigned to your computer by your Internet
Service Provider (ISP), the type of browser you are using, the general location
of your computer, and Web pages visited. We may use this information to monitor
Web site usage, resolve technical issues, improve functionality and evaluate
Web site popularity.
6. We have a Privacy Officer.
Our Privacy Officer is responsible for monitoring the fulfillment
of our privacy commitments and for training our employees in privacy policy
matters. Clients wishing to review their personal information in our possession
or requiring further information, should send a written request to
7. We are required to make regulatory
filings, but only with your consent.
We are required to provide certain contact information of
non-prospectus fund investors to the Ontario Securities Commission ("OSC")
under the authority granted in securities legislation. This information is
collected only for the purposes of administration and enforcement of the
securities legislation. If you are an investor in a Burgundy non-prospectus
fund and you object to Burgundy’s filing of your information, you may
contact our Privacy Officer. If you have any questions about the collection and
use of this information, you may contact the OSC at the following address:

Ontario Securities
Commission

Suite 1903, Box 55, 20 Queen
Street West

Toronto, ON M5H 3S8

Public official contact
regarding indirect collection

of information:

Administrative Assistant to
the Director of

Corporate Finance

Telephone: (416) 593-8086
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Client Disclosure Statement
Burgundy Asset Management Ltd. (Burgundy) provides discretionary portfolio management
and investment counselling services (Services) to its Clients in accordance with the
Client’s Investment Policy Statement. Burgundy also acts as the manager and adviser
of certain proprietary mutual and pooled funds (Burgundy Funds). Burgundy acts as the
sole distributor and dealer with respect to the Burgundy Funds.
The securities laws of the Province of Ontario require securities advisers and dealers
when they advise with respect to or trade in their own securities or other issuers to
which they, or certain other parties related to them, are related or connected, to abide
by particular disclosure and other securities laws and regulations. These laws require
advisers and dealers, prior to trading with or advising their customers or clients, to
inform them of the relevant relationships and connections with the issuer of the securities.
The rules are outlined below; however, Clients can refer to the applicable provisions
of these securities laws for the particulars of these rules and their rights or consult
with a legal adviser.
Our Relationships
Burgundy does not itself issue securities or other assets that would be included in a
Client Portfolio. As an adviser, Burgundy may invest in or advise as to investment in
securities, which may include securities of a related or connected issuer.
A related issuer is a person or company that influences or is influenced by another
person or company. A connected issuer is an issuer of securities that has a relationship
with Burgundy that, in connection with the distribution of securities of the issuer, is
material to a prospective purchaser of the securities. If such a relationship existed, the
relationship may be material if it is likely that a reasonable prospective purchaser would
consider it important under the circumstances to their decision to purchase. Burgundy has
relationships only with issuers that are in the Burgundy Funds. The relationships exist
because Burgundy manages their investments.
A related registrant is a registered adviser or dealer under securities legislation
that has a principal shareholder, director or officer that is a principal shareholder, director
or officer of Burgundy. Burgundy does not have any related registrants.
Dealings with Related or Connected Issuers
- In trading under discretionary authority or advising with respect to investments in
its accounts or funds, Burgundy will act in accordance with its Client’s Investment
Policy Statement (IPS). In all investment decisions, Burgundy will deal fairly, honestly
and in good faith with each of its Clients.
- If Burgundy’s relationships change to add related or connected issuers other than
its proprietary Burgundy Funds:
- where Burgundy acts as your Investment Counsel, it will inform you of the relationship
before performing any of the Services; and
- where Burgundy acts as your Investment Counsel with investment discretion, it will
obtain your specific and informed written consent to such investment direction prior
to exercising discretion with respect to investments in those issuers
- When acting as your dealer, Burgundy does not charge or receive any sales charge for any
purchase of Burgundy Funds.
Allocation of Investment Opportunities
As Investment Counsel, Burgundy expressly recognizes the absolute need for fairness in the
allocation of investment opportunities among the Funds or other investment accounts that they
manage or may manage in the future. In addition, the directors, officers and employees of
Burgundy are subject to a personal trading code, which govern their personal investment
activities, and is compliant with legislation and with industry and CFA Institute standards.
In compliance with the code, directors, officers and employees may invest in the Funds in which
Burgundy client assets are invested.
Our policies are that any director, officer and employee shall:
- ensure that he or she deals fairly in the allocation of investment opportunities among
all clients;
- always have a reasonable and adequate basis for investment recommendations made to
clients supported by appropriate research and investigation;
- exercise diligence, thoroughness and independent professional judgment in making any
recommendations to clients and in taking investment action for them;
- in the event of limited availability of any particular security, such as an initial
public offering, or in the event of a limited market for any particular security,
allocate the opportunity on an equitable pro rata basis having regard to such factors
as we consider relevant in the circumstances;
- ensure that any trades done on a bulk basis are allocated amongst clients accounts
fairly and equitably; and
- seek best execution with respect to brokerage transactions, taking into consideration
both the ease and timeliness of the trade and the cost of such execution.
Use of Client Brokerage Commissions Policy
Effective February 2004, Burgundy discontinued all client-directed brokerage commissions,
as well as the use of brokerage commissions for the payment of any portfolio management systems,
trading systems or databases of any kind. Burgundy believes that not participating in “soft dollar”
or directed brokerage arrangements will ultimately result in lower commission costs for its Clients.
Burgundy may allocate commissions to selected brokers in order to obtain independent third-party
research or attend industry conferences. These services are provided as part of the investment
decision process and, as such, are of benefit to Clients. Many of the brokerage firms that Burgundy
uses provide “bundled” trading fees that cannot necessarily be separated into research and execution.
Although Burgundy may quite often disregard the research information provided, sometimes it is still
advantageous to pursue trades with these particular brokers in order to access the necessary liquidity
or trading expertise required for Burgundy to trade a position in the most efficient manner.
Burgundy’s obligation is to achieve best execution for its Clients. The price of the trade and the
commission paid are not the only indicators of “best execution.” Other items which may be considered
in judging “best execution” include:
- Avoiding excessive market impact when trading;
- Maintaining the confidentiality of investment decisions;
- Choosing appropriate brokers, taking into account a broker’s abilities, including:
- access to liquidity;
- the speed and accuracy of transaction execution;
- price/commissions charged;
- access to research conferences and company managements
Burgundy makes a good faith determination that all clients receive reasonable benefit from the use of
order execution and research goods and services received, relative to the amount of brokerage commission paid.
Burgundy makes this determination relative to its overall responsibilities for all Client accounts.
Personal Trading
Burgundy has implemented a comprehensive personal trading policy to eliminate the conflict
of interests that could arise if employees were permitted to trade in their own accounts (or
those over which they have influence) those same securities held by the firm.
To ensure that Burgundy upholds its fiduciary responsibilities to its clients, no employee is
allowed to trade until all client trades are completed. Appropriate blackout periods are invoked
as a standard practice. For any security which Burgundy may have an interest in, or is following
closely, a blackout period may also be invoked, at the discretion of the Chief Compliance Officer.
Any employee with an external personal trading account must instruct their broker/dealer to
submit a copy of their monthly brokerage statements for all accounts where the employee is
deemed to have beneficial interest, to the Chief Compliance Officer. In addition, trading
compliance is verified against a monthly trading disclosure statement, which all employees
must sign, whether they traded or not.
Gifts
The acceptance of gifts can be perceived as a conflict of interest; as such Burgundy has
established a comprehensive policy that limits the acceptance of gifts consistent with the
CFA Institute guidelines. Burgundy does not allow its employees to accept gifts or
entertainment that are reasonably expected to compromise the employee's independence or objectivity.
Directorships and Outside Employment
Burgundy has adopted the guidelines outlined in the CFA Institute's Standards of Professional
Conduct regarding the appointment of employees on the board of directors and/or committees
of external organizations. As such, employees may serve on the board of directors or other
committees of organizations/corporations so long as the employee obtains prior approval from
Burgundy’s CEO, to ensure this would not interfere or give the appearance of interfering
with an employees ability to act in the best interest of Burgundy and its clients.
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