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.

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.

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.

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.

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.

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.

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.

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

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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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.

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.

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:

1. ensure that he or she deals fairly in the allocation of investment opportunities among all clients;


2. always have a reasonable and adequate basis for investment recommendations made to clients supported by appropriate research and investigation;


3. exercise diligence, thoroughness and independent professional judgment in making any recommendations to clients and in taking investment action for them;


4. 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;


5. ensure that any trades done on a bulk basis are allocated amongst clients accounts fairly and equitably; and


6. 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.

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.

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.

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.

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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