Foundation Policies

PREAMBLE:
The success of St. Joseph’s Healthcare Foundation in meeting the needs of St. Joseph’s Healthcare is heavily dependent on our ability to inspire confidence and trust in the minds of our donor public. People make financial contributions to our Foundation for many reasons—a personal experience of the care St. Joseph’s provides, the Hospital’s reputation for quality and compassionate care, the excellence of our healthcare staff, to name a few. But equally important in obtaining and retaining such financial support is our Foundation’s reputation for integrity and ethical fundraising practices. This policy speaks to several areas of our fundraising program and outlines the ways in which we seek to operate in the most ethical manner possible. This shows respect for our donors and clearly puts the onus on our Foundation to be open, honest and transparent in our raising, investment and disbursal of funds.

I. FINANCIAL PRACTICE AND TRANSPARENCY

1. The Foundation’s financial affairs will be conducted in a responsible manner, consistent with the ethical obligations of stewardship and all applicable laws.
2. All donations will be used to support the Foundation’s objects, as registered with the Canada Revenue Agency (CRA).
3. All restricted or designated donations will be used for the purposes for which they were given unless the charity has obtained legal authorization to use them for other purposes. Alternate uses will be discussed where possible with the donor or the donor’s legal designate. If the donor is deceased or legally incompetent and the Foundation is unable to contact a legal designate, the donation will be used in a manner that is as consistent as possible with the donor’s original intent. If necessary, the Foundation will apply to the courts or the appropriate regulatory body to obtain legal authorization to use the donation for other purposes.
4. Annual financial reports are necessary to achieve transparency and accountability to donors and the public. They are accessible on the Foundation’s website, provided upon request and will:

• • be factual and accurate in all material respects;
  • disclose the gross amount of fundraising revenues (receipted and non-receipted);
  • disclose the total amount of fundraising expenses (including salaries and overhead costs);
  • disclose all donations that are receipted for income tax purposes;
  • disclose the total amount of expenditures on charitable activities (including gifts to other charities);
  • segregate undesignated and designated funds;
  • identify government grants and contributions separately from other donations; and
  • Financial Statements will be prepared in accordance with generally accepted accounting principles and standards established by the Canadian Institute of Chartered Accountants, in all material respects (or disclose a discrepancy between the practice and GAAP).

1. The cost-effectiveness of the Foundation’s fundraising programs will be reviewed regularly by the governing board. No more will be spent on administration and fundraising than is required to ensure effective management and resource development. The Foundation will disclose its process for evaluating its spending and will comply with CRA recommended cost of fundraising guidelines.
2. The Foundation will, upon request, disclose the revenue and expense assumptions for its fundraising activity as approved by its Board in its annual budget.
3. The Foundation’s financial statements will be audited by an independent public accountant.
4. An Investment Policy Statement will be in place setting out asset allocation, procedures for investment decisions, and asset protection issues. It will be reviewed annually by our Investment Committee and by our investment counsel.
5. A Gift Acceptance Policy will be in place to provide guidance on the types of gifts our Foundation can accept. We will conform with all federal government regulations and legal requirements.
6. The Foundation will act promptly to provide information requested in its most current form. This includes audited financial statements, annual reports, our charitable business number as assigned by CRA, any information contained in the public portion of the Foundation’s most recent Charity Information Return (T3010A) as submitted to CRA, a copy of the Foundation’s investment policy, a list of the names of our governing board.
7. The Foundation will provide information that will add to the public's understanding of and confidence in our operations, methods, and costs of fundraising by publishing an annual and or donor impact report and make available on our website the Charity Information Return and audited financial statements. If we release a financial summary or extract, it is clearly related to and consistent with the information provided in our full financial statements including notes.
8. All eligible donations, regardless of amount, will receive an official gift receipt.

II. RESTRICTED AND DESIGNATED DONATIONS

Our Foundation prepares and issues official gift receipts for monetary gifts and for gifts in kind in compliance with all regulatory requirements. We adhere to a donor’s wishes as they relate to restricted or designated donations.

III. COLLECTION, MAINTENANCE, USE AND CONFIDENTIALITY OF DONOR RECORDS

Our Foundation complies with all relevant provisions of the Personal Information Protection and Electronic Documents Act and observes the following practices when collecting donor information, maintaining and using confidential donor records, and protecting donor anonymity:

1. We guard against making unwarranted or intrusive inquiries into a donor or prospect’s gift history or personal life and gather only information that is relevant and necessary to our fundraising efforts.
2. We make all reasonable efforts to ensure the personal information we collect is complete and accurate.
3. We require attribution for all data that we collect.
4. We encourage donors to review, correct and update personal information.
5. We require a donor’s consent before confidential information is released to outside parties.
6. We have established and follow reasonable time periods for the retention and disposal of donor information.
7. We have established special security safeguards to protect donor information and limit access to donor files.
8. We give special protection to all records pertaining to anonymous donors.
9. We recognize that our duty to ensure the confidentiality of donor records continues even after our relationship with a donor or prospect has ended.
10. We record a donor’s oral consent regarding the proposed use of their personal information when information is collected by phone.
11. We provide donors with an opportunity to remain anonymous and to request that the donor’s name and/or the amount of the gift not be publicly released.
12. We honour donors’ and prospective donors’ requests to: limit the frequency of contact; not be contacted by telephone or other technology; receive printed material concerning the organization; and discontinue contact.

Solicitation of Former Patients
A natural constituency for financial support of the Hospital is its former patients. This group comprises the “alumni” of the Hospital who have received care at St. Joseph’s. A minimum of 60 days following their discharge, we write to selected former patients inviting their financial support. We make every effort to ensure that this appeal is tasteful, appropriate, and complies with privacy legislation.

Privacy
Our Foundation has a Privacy Policy overseen by a Chief Privacy Officer.

IV. ELECTRONIC GIFTS
Technology is playing an increasing role in philanthropy. To protect the interests of donors who choose to give electronically, our Foundation adheres to the following practice:

1. Our website lists our Foundation’s full name, charitable business number, and mission clearly and immediately for online donors.
2. For those who wish to contact us other than through the website or e-mail, we clearly provide alternative contact information.
3. Eligibility for an official gift receipt is clearly outlined.
4. All precautions are taken to ensure that gifts made electronically are safe, private and secure, and that a donor’s personal information is protected.
5. Individuals who make electronic contributions are assured that any information they provide is held in strict confidence, and that this Ethical Fundraising Practices Policy is clearly listed on our website.
6. Donors who give on-line will receive communications or solicitations from the Foundation but will have a clearly identified area where they can “opt out” of receiving any future communications. Donors will also be given the opportunity to provide direction on how often they would like to be contacted and by which method, i.e.: mail, phone or email.

V. GOVERNANCE

1. Our Board of Directors reviews our fundraising practices and policies on a regular basis and monitors them for continuing relevance, legislative compliance and applicability. Adjustments are made, as required, to ensure that the maximum amount of donations possible is applied to our charitable activities in a manner that is consistent with the long-term interests of our organization and its beneficiaries.
2. Our fundraising policies, practices and expectations are clearly communicated to all staff.

VI. FUNDRAISING PRACTICES

1. 1. In accordance with all applicable laws, fundraising solicitations on behalf of the Foundation will:
   • be truthful;
   • accurately describe the Foundation’s activities and the intended use of donated funds; and
   • all fundraising solicitations by the Foundation disclose our name and the purpose for which the funds are requested. This includes address or other contact information.
2. The Foundation will be honest and clear on any claims it makes about the Hospital. It will refrain from using marketing materials or making representations that could be misleading. The Foundation will not exploit its beneficiaries. It will be sensitive in describing those it serves (whether using graphics, images or text) and fairly represent their needs and how these needs will be addressed.
3. When the Foundation conducts online solicitations, its practices will be consistent with or exceed the provisions of the Canadian Code of Practice for Consumer Protection in Electronic Commerce, which is downloadable at:
   http://www.ic.gc.ca/eic/site/cmc-cmc.nsf/eng/fe00113.html.
4. When the Foundation conducts face-to-face solicitations, its practices shall include measures to:
   • provide verification of the affiliation of the person representing the Foundation; and,
   • secure and safeguard any confidential information, including credit card information, provided by donors.
   • encourage donors to consult their professional advisors to determine the tax consequences of their gift.
5. Volunteers, employees and third-party consultants/solicitors who solicit or receive funds on behalf of the Foundation shall:
   • adhere to the provisions of Imagine Canada Standards;
   • act with fairness, integrity, and in accordance with all applicable laws;
   • adhere to the provisions of applicable professional codes of ethics, standards of practice, and all relevant Foundation policies, etc.;
   • cease solicitation of a prospective donor who identifies the solicitation as harassment or undue pressure, or who states that he does not wish to be solicited;
   • disclose immediately to the Foundation any actual or apparent conflict of interest or loyalty; and
   • Disclose upon request, whether the individual or entity seeking donations is a volunteer, employee or contracted third party.
   • not accept donations for purposes that are inconsistent with the Foundation’s objects or mission.
6. The Foundation will provide, upon request, its best available information on the gross revenue, net proceeds and costs of any fundraising activity it undertakes.
7. Paid staff or consultants will be compensated by a salary, retainer or fee, and will not be paid finders’ fees, commissions or other payments based on either the number of philanthropic contributions received or the value of funds raised.
8. The Foundation will not sell, rent or exchange its donor list.
9. The Foundation’s governing board will be informed at least annually of the number, type and disposition of complaints received from donors or prospective donors.
10. It is the policy of our Foundation to have a written complaints procedure in place to ensure that all complaints from donors or the community-at-large are handled promptly, courteously, and to the satisfaction of all parties.

VII. CONFLICTS OF INTEREST
Our by-laws include a written conflict of interest statement and we address actual or perceived conflicts of interest in the following manner:

1. We define a conflict of interest for our fundraisers and advise all fundraisers that they must act in the best interests of our organization rather than in furtherance of their personal interests or the interests of third parties.
2. We instruct all fundraisers to avoid situations where their personal interest conflicts or appears to conflict with their duties within our organization.
3. We instruct all fundraisers to evaluate their conduct in light of the impact on our organization.
4. We require our fundraisers to disclose both actual and apparent conflicts of interest.
5. Our conflict-of-interest disclosure policies are clearly articulated and we believe well understood by all staff and Directors.
6. Our staff, Directors and volunteers recognize that the duty to disclose even an “apparent” conflict of interest requires a consideration of public perception when evaluating whether a conflict of interest is present.
7. We are mindful of our fiduciary duty to ensure the disclosure of any conflict of interest that would be of material interest or relevance to a donor or which may influence a donor’s decision to give; and
8. Where a donor elects to make a gift in spite of the presence of a conflict of interest, we encourage that the donor obtain independent advice regarding their gift. Further, we encourage donors to seek independent advice if the proposed gift might significantly affect the donor’s financial position, taxable income or relationship with other family members.

VIII. FUNDRAISER COMPENSATION
Our Foundation observes the following compensation practices:

1. Fundraisers are compensated on the basis of their experience, expertise and the time requirements of the position.
2. Where a fundraiser’s performance exceeds job expectations and additional compensation is merited, eligibility for and calculation of the amount of compensation to be paid is not based on a percentage of revenue (e.g., in the form of donations, gifts, grants and similar funds) received by our organization as a result of the fundraiser’s efforts.
3. We undertake the institutional planning, board development and volunteer recruitment necessary to make our fundraising program successful over time.

CONCLUSION:
All fundraising programs undertaken by our Foundation are reviewed by the Board of Directors to ensure that they are consistent with our Vision and Mission statements, and that they comply with this Ethical Fundraising Practices Policy.

Approved by the Board of Directors February 15, 2023

1. BACKGROUND
St. Joseph's Healthcare Foundation is a registered charitable foundation established in 1970 in collaboration with St. Joseph's Healthcare Hamilton. The Foundation provides financial support to fulfill St. Joseph's Healthcare Hamilton's mission as an exemplary academic health sciences centre devoted to research, education and compassionate patient care. The Hospital, through this Foundation, relies on donations from the community to assist with capital improvements, research funding, academic infrastructure and equipment renewals and enhancements.

2. INVESTMENT POLICY STATEMENT
This Investment Policy Statement ("IPS") identifies the key factors for consideration in designing the Foundation's investment strategy and provides a set of written guidelines for the management of the investment assets. The IPS helps the Foundations' Board of Directors ("Board") and Investment Committee ("Committee") achieve their desired objectives and manage the portfolio's investment risk. Adhering to the discipline outlined in the IPS will help ensure that the Foundation stays on course with its investment strategy and avoids emotional reactions to short-term market fluctuations. The statement will be reviewed on an annual basis to ensure its continuous reflection of the Foundation's circumstances and requirements.

3. ROLES AND RESPONSIBILITIES
3.1 Board of Directors
The Foundation is managed by the Board, which is ultimately responsible for the investment of the Foundation's assets. The Board has a responsibility to:

• Act honestly and in good faith with a view to the best interest of the Foundation;
• Exercise the care, diligence and skill that a reasonably prudent person would exercise in comparable circumstances;
• Approve the IPS;
• Appoint or dismiss members of the Committee which will oversee all matters related to the investment management of the Portfolio. The committee should be composed of a least three directors who are not officers or employees of the Foundation. Members of the Committee shall be financially literate and have knowledge or experience in financial and investment matters.
• Receive the Committee's recommendations with respect to the Portfolio's Policy Statement and re-confirm or amend the Policy Statement, as appropriate, on an annual basis; and
• Review all other reports and recommendation of the Committee with respect to the Portfolio and take appropriate action.

3.2 Investment Committee
The Committee is established by the Board of the Foundation. As part of its duties, the Committee shall monitor, review and recommend to the Board changes in the Foundation's investment policy. The Committee has the responsibility to take all reasonable steps to ensure that the portfolio is properly administered, and reviewed on a regular basis to ensure its ongoing risk management remains compliant with the Federal government's criteria. In order to achieve this, the Board will, on behalf of the Foundation, delegate the following responsibilities to the Committee:

• Maintain an understanding of legal and regulatory requirements and constraints applicable to the Portfolio;
• On an annual basis, review the Foundation's IPS and make appropriate amendments;\
• Monitor the Portfolio's performance on a quarterly basis;
• Monitor the professional investment manager's performance and compliance with the IPS, as well as, each Investment Manager's compliance with any specialized instructions and mandates they have been given;
• Formulate specialized instructions and mandates for each Investment Manager, in the event that more than one Investment Manager is engaged. These instructions and mandates will derive from, reflect and be consistent with the provisions of this IPS;
• Ensure availability of cash needed for operating expenses and grants;
• Take appropriate steps to ensure that the Portfolio is rebalanced, as necessary per Section 9 of this IPS;
• Take appropriate steps to resolve conflict of interest issues as provided for in Section 12 of this IPS;
• Formulate recommendations to the Board regarding the selection, engagement or dismissal of the Manager and Custodian; and Report the Committee's activities to the Board.

3.3 Investment Managers
The Investment Manager(s) will:

• Have full discretion in day-to-day investment management of the portion of the portfolio for which they have been given responsibility, subject to this IPS and any amendments thereto, as well as, any specialized instruction and mandates issued by the Foundation;
• Ensure that all transactions are completed on a "best execution" basis;
• Have the authority to vote all proxies and, in exercising this authority, act prudently and solely in the interest of the Foundation. The Foundation retains the right to instruct the Investment Manager(s) on how to exercise voting rights but recognizes that this may not be enforceable if the subject investments are held within a pooled fund;
• Provide regular reports to and meet with the Foundation;
• Recommend to the Foundation changes to their mandate or to special instruction and mandates issued by the Foundation, that the Investment Manager(s) deem appropriate;
• Provide advice and counsel with respect to the Portfolio when called upon to do so by the Foundation;
• Exercise the care, skill and diligence that can reasonably be expected of a prudent person and adhere to the CF A institute's Code of Ethics and Standard of Professional Conduct; and
• Follow instructions regarding any pledge or other type of arrangements.

3.4 Custodian(s)
Custody of the Portfolio's assets shall be delegated to a trust company or other financial institution similarly recognized as a depository for securities. The Custodian will:

• Provide safekeeping for Portfolio assets;
• Process transactions as directed by the Investment Manager and /or the Foundation;
• Collect interest, dividends and the proceeds of cash equivalent and fixed income instrument maturities;
• Inform the Investment Manager of pending corporate actions (e.g., name changes, mergers, off lot offerings) and process instructions related to such matters;
• Deposit funds and pay expenses as directed by the Foundation;
• Maintain a record of all transactions;
• Provide regular reports to the Foundation as provided for in Section 10 of this IPS;
• Provide the Investment Manager and other agents of the Foundation with information required to fulfill their duties, or as directed by the foundation; and
• To the extent possible, provide applicable information as may be requested by the auditor.

4. DISTRIBUTION POLICES AND INVESTMENT OBJECTIVES
4.1 Return on Investments
The Foundation's objective is to generate a long-term total investment return that protects the purchasing power of the capital component, meets the operating expenditure needs of the Foundation, meets the Hospital funding needs, recovers the cost of managing and administering the funds and establishes a reserve for future market declines. Disbursements from the Foundation will be used to support the near and long-term capital requirements that support the Hospital. The timing and size of disbursements will vary.

4.2 Risk Tolerance
The Portfolio should be structured and managed so as to provide for the generation of the maximum rate of investment return while assuming an appropriate level of risk as determined by the Foundation. The risk inherent in the Portfolio can also be viewed in terms of the likelihood that it will generate negative investment returns.
The level of risk to which the Portfolio is exposed will be managed by diversifying the
Portfolio's holdings, not only in terms of asset class, but also in terms of holdings within each asset class, geographically and (to the extent feasible) by investment management style and Investment Manager.

5. INVESTMENT CONSTRAINTS
5.1 Legal and Regulatory Status
The Foundation is registered with the Canada Revenue Agency as a charitable organization.
The Foundation is subject to the provisions of the Trustee Act of Ontario, as administered by the Office of the Public Guardian and Trustee, the Charities Accounting Act, the Charitable Gifts Act, the Income Tax Act of Canada and associated regulations promulgated by the Canada Revenue Agency under the authority of that Act.

5.2 Taxation Status
The Foundation is registered as a charitable organization with the Canada Revenue Agency and as such is exempt from income tax provided it meets requirements enumerated in the Income Tax Act of Canada and associated regulations promulgated by the Canada Revenue Agency.

5.3 Investment Time Horizon
A portfolio's investment time horizon is an important factor in determining its investment strategy. The period over which a particular investment strategy can or will be maintained has a direct bearing on the likelihood that it will generate its targeted rate of return within that period and within acceptable risk parameters.
For planning and Portfolio structuring purposes, it is assumed that the investment time horizon of the Portfolio is long term (i.e. greater than ten years). It should be noted, however, that this Investment Policy Statement will be reviewed on at least an annual basis.

5.4 Liquidity Requirements
Disbursements to cover the Foundation's expenses will be made from the portfolio on a regular basis. The Foundation plans to continue annual disbursements to the Hospital to assist in meeting the Hospital's objectives.

5.5 Unique Circumstances
The Foundation's investments will be selected with a view given to the Foundation's relationship with the Sisters of St. Joseph's, which respects a philosophy encompassing social justice, environmental responsibility and humanitarian/economic values. There are no other unique circumstances that have a bearing on our asset allocation recommendation.
Specific constraints may be provided to individual investment managers through a separate Statement of Investment Policies & Guidelines.

6. ASSET MIX

Asset Class	Range	Target
Cash & Equivalents	0-15%	5%
Fixed Income Instruments	35-60%	40%
Canadian Equities	15-35%	25%
US Equities	10 - 30%	20%
International Equities	5-15%	10%

7. INVESTMENT MANAGEMENT GUIDELINES
7.1 Eligible Asset Classes- Definitions and Constraints
7.1(a) Cash Equivalents
Cash equivalents will consist of instruments with terms to maturity of 0 to 12 months and include fixed income instruments originally issued with a term to maturity in excess of 12 months.
Cash equivalents originally issued with terms to maturity of 12 months or less will have a minimum Dominion Bond Rating Service (DBRS) credit rating of R1-Mid or an equivalent rating by another wellestablished rating agency at the time of purchase and thereafter.

7.1(b) Fixed Income Instruments
Investments in the following fixed income instruments are permitted:

• Bonds;
• Debentures;
• Notes;
• Coupons and residuals; and
• Asset-backed securities.

Such instruments must be:

• Issued or guaranteed by the Government of Canada or one of its agencies;
• Issued or guaranteed by a Canadian provincial government or one of its agencies;
• Issued by a Canadian municipality or regional government;
• Issued by a Canadian corporation; or
• Issued by a foreign government or a foreign corporation.

Notwithstanding the above, "Maple Bonds", i.e. bonds denominated in Canadian dollars both in terms of interest payments and principal payments but issued by non-Canadian entities, may be held in the portfolio provided they meet the minimum credit rating standards set out below. Maple bonds should not constitute more than 10% of the market value of the fixed income asset class.
Fixed income instruments must, as a group, have a market-weighted average DBRS credit rating of A or an equivalent rating by another well-established rating agency or better at the time of purchase and thereafter. The minimum credit quality per issue shall be BBB at time of purchase.

In the event that an Investment Manager expects a downgrade in the credit rating of a fixed income instrument to below the minimum BBB credit rating, the Investment Manager shall develop a strategy for disposing of the fixed income instrument in a timely, orderly and efficient manner.

In the event that a fixed income investment held in the Portfolio experiences an unanticipated credit rating downgrade so that it falls below the minimum credit rating of BBB, the Investment Manager will sell the investment immediately. In the event that the Investment Manager wishes to retain the investment in the portfolio, the Investment Manager will contact the Committee within five business days to provide detailed information on the downgrade, as well as, the Investment Manager's rationale for retaining the investment in the Portfolio. The Committee may require that the Investment Manager dispose of the investment immediately. Alternatively, the Committee may authorize retention of the investment. In this instance, the Committee will provide the Investment Manager with a deadline by which the investment must be disposed of and the Investment Manager will provide, at a minimum, monthly updates on the investment in question, including its trading pattern and the Investment Manager's strategy for disposing of it on a timely basis. In the event of a "split" rating (i.e. a situation in which credit rating agencies assign non-equivalent ratings), the lowest rating will apply.
Investment in the securities of any single issuer should not constitute more that 5% of the market value of the Portfolio as a whole. In addition, investment in any single issuer should not constitute more that 10% of the market value of fixed income asset class. The market value of any one fixed income security shall not exceed 7% of the fixed income asset class. Fixed income instruments issued or guaranteed by the Government of Canada or one of its agencies or by a Canadian provincial government or one of its agencies are exempt from this provision.

Foreign pay bonds should not constitute more than 10% of the market value of the fixed income asset class. Government bonds should be strategically 50% of the fixed income allocation and tactically no less than 40% of the fixed income allocation.

7.1 (c) Equities
Investments in the following equity securities are permitted:

• Common stocks;
• Rights, warrants, installment receipts, convertible debentures and other instruments convertible into common stocks;
• Income trust units;
• American Depositary Receipts;
• Global Depositary Receipts; and
• Preferred Shares.

Individual equities or equities held within equity funds must be listed on a major stock exchange.

Investment in the securities of any single issuer should not constitute more that 5% of the market value of the Portfolio as a whole. In addition, investment in the securities of any single issuer should not constitute more than 10% of the market value of the equity asset class.

7.2 Additional Constraints, Inclusions and Exclusions
The lending of securities will not be permitted.

The Portfolio as a whole and each asset class represented in the Portfolio must be reasonably diversified. If more than one Investment Manager is employed,
all reasonable attempts will be made to ensure that the Portfolio is diversified in terms of investment management style.

All investments must be reasonably liquid at the time of purchase and thereafter. In the event that the Investment Manager forecasts impairment in the liquidity of an investment, the Investment Manager will make all reasonable efforts to liquidate the investment on a timely basis.

Index, mutual and pooled funds may be held in the Portfolio with the understanding that the guidelines in the Fund's offering memorandum will supersede the aforementioned guidelines. While such funds will be managed in keeping with their own investment policies, these policies must be consistent with the spirit of the IPS. In the event that there are any substantive inconsistencies between the provisions of the IPS and the policies applicable to a fund that an Investment Manager wishes to employ in the Portfolio, the Investment Manager must identify these to the Committee and receive its written approval for investing in the fund before any such investment is made. These funds will be categorized as cash equivalents, fixed income investments or equities as appropriate given their underlying securities or the capital markets to which they are intended to provide exposure.

In the event that an Investment Manager plans to make a material change to the mandate or investment policy of one or more of the Investment Manager's index, mutual or pooled funds held in the Portfolio, the Investment Manager must provide the Committee with prior notice of the revision. This notification must be provided to the Committee at least one month in advance of the proposed revision.

Derivative securities may be held in the Portfolio for hedging purposes. Derivative securities may not be used for speculative purposes.
The Committee reserves the right to instruct the Investment Manager to exclude any asset, security or category of investment and will notify the Investment Manager by written notice in the event that such restrictions are to be imposed.
Investments in the following are prohibited:

• Private placements, limited partnerships or other non-marketable equity or debt instruments;
• Lettered, legend, unregistered or other restricted stock;
• Uncovered short positions;
• Direct real estate investments;
• Commodities; and
• Derivatives other than for hedging purposes.

No investment shall be made in a non-arm's length transaction with any member of the Committee or the Board of Directors, or any employee of, or consultant, to the Committee or the Board.
Although there are currently no restrictions on the investment of funds with respect to socially responsible investing, the Committee may place constraints, limitations or requirements on the Portfolio in order to achieve specific socially responsible objectives in the future.

7.3 Donation of Securities
The Manager will liquidate gifts or donations consisting of marketable securities transferred into the portfolio as soon as practicable. The Committee, in its discretion, may make exceptions to this provision. All donations of securities will receive a receipt in the amount of the value of the securities using the closing price on the day the donation is received in the manager's account. The custodian will provide the Foundation on a timely basis with the applicable information (i.e. number of securities, closing price) necessary to provide a receipt. For any gifts of securities or privately held shares not listed on major stock exchanges, tax receipts will be issued according to CRA rules.

8. PERFORMANCE STANDARDS
8.1 Investment Returns
The Portfolio's investment performance will be measured against the performance of a "benchmark" index calculated using appropriate market indices combined in the same proportion as the Portfolio's benchmark asset mix. Funds will be rebalanced quarterly.

Asset Class	Benchmark Index	Target
Cash & Equivalents	90 Day Canadian Treasury Bills	5%
Fixed Income Instruments	DEX Universe Bond Index	40%
Canadian Equities	S&P/TSX Composite Index	25%
US Equities	S&P/TSX 300 Composite Index	20%
International Equities	MSCI World Index net of taxes	10%

The benchmark index indicates the return that a passive investor (i.e. One who invests in market indices) would earn by consistently employing the benchmark asset allocation set forth in Section 6.
The Portfolio's investment performance will be measured net of investment management fees and is expected to:

• Exceed the investment performance of the benchmark index over rolling 4-7-year periods, with an emphasis on the 7-year period; and
• Rank in the top 25% of comparable portfolios over rolling 4-7-year periods, with an emphasis on the 7- year period.

The performance of the Investment Manager relative to an appropriate peer group over rolling 4-7-year periods, with an emphasis on 4-year and 7-year periods will be evaluated annually. The performance of individual asset classes is expected to:

• Exceed the return of their corresponding benchmark indices; and
• Rank in the top 25% of the appropriate Investment Manager Performance measurement universes over rolling 4-7-year periods, with an emphasis on 4-year and 7-year periods.

Further, the Investment Manager will be evaluated in terms of:

• Compliance with the provisions of this Investment Policy Statement and any amendments thereto as well as any specialized instructions and mandates issued by the Foundation;
•  The provision of satisfactory reporting and client service.
  The Investment Committee will assess if a Request for Proposal for investment managers, or a full review is required and will notify the Board of Directors of such a recommendation in that year. A full review of the manager will be done at a minimum of every 5 years and an RFP will be done at a minimum of every 10 years.

9. REBALANCING
Rebalancing the portfolio should be done tactically and strategically at the discretion of the Investment Manager. The Investment Manager should be chosen and evaluated on their rebalancing philosophy and execution.

10. CUSTODIAN
The Custodian will provide the Foundation with statements on a monthly basis. These statements will include, at a minimum, a summary and a detailed listing of assets held in the Portfolio, as well as, a listing of transactions (including deposits, withdrawals, receipt of interest and dividends, purchases, sales, corporate actions and fees paid) that occurred in the Portfolio during the reporting period.
The Custodian's reports will provide the book value and current market value of each asset held in the Portfolio and categorizes securities by issuer type, market sector and/or industry.11. CRITERIA FOR TERMINATING AN INVESTMENT

MANAGER
The Committee will consider recommending that the Board terminate an Investment Manager when one or more of the following circumstances prevail:

• The Investment Manager's investments performance results have been below the median performance results of the appropriate Investment Manager peer group and/or the appropriate market benchmark indices for three consecutive year;
• The Investment Manager's short-term underperformance is found to be a result of a change in the Manager's investments style, process or discipline or a change in the Investment Manager's key investment personnel;
• There is a significant change in the risk profile of the Investment Manager;
• The Investment Manager's investment style is no longer appropriate given the Portfolio's requirements;
• The Investment Manager’s reporting and client service are unsatisfactory; or
• The Committee has concerns regarding the Investment Manager's ethics.

Notwithstanding the above, the Board may terminate an Investment Manager for any reason that it deems appropriate.12. CONFLICT OF INTEREST
No individual with a fiduciary responsibility will knowingly permit their interest to conflict with their duties or powers relating to investment of the Portfolio's assets or to any other matter related to the Portfolio. Any actual or perceived conflict of interest must be reported to the Foundation. Such disclosure will be made when the affected individual first becomes or ought to have become aware of the conflict or potential conflict. The Foundation, on the advice of counsel, will be the sole arbiter in determining whether the conflict of interest exists and, if it determines that a conflict does exist will take all necessary and appropriate measure to remedy the situation. Every disclosure of a conflict of interest will be recorded in the minutes of the relevant meeting of the Committee and the Board.
The failure of a person to comply with the requirements of this Section will notify itself invalidate any decision, contact or other matter.13. ADOPTION OF INVESTMENT POLICY STATEMENT

The Board of St. Joseph’s Healthcare Foundation Hamilton approved this Investment Policy Statement on February 16, 2022.