RegulatoryDisclosuresDated September 30, 2020

INTRODUCTION..................................................................................................................................................................................................................................................... 2

DESJARDINS GLOBAL ASSET MANAGEMENT INC. STATEMENT OF PRINCIPLES ON CONFLICTS OF INTEREST................................................................................ 2

YOUR PROTECTION............................................................................................................................................................................................................................................. 5

HANDLING OF COMPLAINTS............................................................................................................................................................................................................................... 8

FAIRNESS POLICY................................................................................................................................................................................................................................................ 10

DECLARATION OF RISK....................................................................................................................................................................................................................................... 12

TABLE OF CONTENTS

INTRODUCTIONThis document is intended to provide clients with all the information they would consider important about their relationship with Desjardins Global Asset Management Inc. (“DGAM”), as required by section 14.2 of Regulation 31-103 Respecting Registration Requirements, Exemptions and Ongoing Registrant Obligations (“Regulation 31-103”).

DGAM is an indirect wholly owned subsidiary of the Fédération des caisses Desjardins du Québec (the “Federation”). Its head office is located in Montréal, in the province of Québec, where it is registered in accordance with the applicable securities legislation as a portfolio manager, an investment fund manager, an exempt market dealer and a derivatives portfolio manager. DGAM is also registered, with non-resident status, as a portfolio manager and/or an investment fund manager and/or an exempt market dealer and/or an adviser in the following provinces and territories: Alberta, British Columbia, Manitoba, Nova Scotia, Saskatchewan, New Brunswick, Newfoundland and Labrador, Northwest Territories, Nunavut, Prince Edward Island and Yukon. In Ontario, DGAM is registered as a portfolio manager, an investment fund manager, an exempt market dealer and a commodity trading manager. DGAM is regulated by the Autorité des marchés financiers du Québec (the “AMF”), within the meaning of “regulator” set out in Regulation 31-103. DGAM is also registered as a Securities Company with the Financial Services Commission in Barbados.

DGAM offers its clients investment advisory services under discretionary portfolio management agreements in the following sectors:

– Management of managers: selection and monitoring of external managers for specific mandates

– Financial strategy and asset allocation: management of equity investments according to effective systematic protocols

– Securities investments: management of fixed-income security portfolios

– Asset management through DGAM Funds (the “Funds”): a family of private funds sold exclusively to qualified investors under a prospectus exemption

DGAM also offers the following services:

– Real estate investments: acquisition, development and sale of real estate assets

DGAM wishes to assure its clients that it scrupulously preserves confidentiality and protects personal information. Moreover, it takes all necessary measures to ensure and preserve the accuracy, confidentiality, security and privacy of its clients’ personal information.

This document will be updated as necessary and will be available on the DGAM website at www.dgam.ca. You can always request a copy from the company representative you deal with, and we will mail you a copy free of charge.

DESJARDINS GLOBAL ASSET MANAGEMENT INC. STATEMENT OF PRINCIPLES ON CONFLICTS OF INTEREST

1. Objective of this document

DGAM diligently complies with the regulations applying to its activities. The primary objectives of these regulations are to protect clients and the integrity of financial markets.

It is important to DGAM that its clients be informed of existing or potential conflicts of interest that could arise in the course of its activities. A conflict of interest arises when the interests of different parties, namely a client and DGAM or one of its representatives (directors, officers, partners, employees or agents) are incompatible or diverge.

The operations of DGAM and its representatives are governed by a Code of Ethics which its representatives must read every year and declare that they have done so. Representatives must attest to reading the compliance handbook when updated.

DGAM is registered as a portfolio manager, an investment fund manager, an exempt market dealer and a derivatives portfolio manager with the AMF. DGAM is also registered, with non-resident status, as a portfolio manager and/or an investment fund manager and/or an exempt market dealer and/or an adviser in the following provinces and territories: Alberta, British Columbia, Manitoba, Nova Scotia, Saskatchewan, New Brunswick, Newfoundland and Labrador, Northwest Territories, Nunavut, Prince Edward Island and Yukon. In Manitoba, DGAM is also registered as an advisor. In Ontario, DGAM is registered as a portfolio manager, an investment fund manager, an exempt market dealer and a commodity trading manager. DGAM is also registered as a Securities Company with the Financial Services Commission in Barbados.

As part of the management of its clients’ discretionary accounts, DGAM may retain the services of other dealers or advisors to which it is related or connected. In addition, DGAM may buy or sell or make recommendations in respect of:

a) Securities which it or a person of its group owns

b) Securities for which DGAM or a person of its group participates in the investment

c) Securities of a related or connected issuer

d) Securities of an issuer with a director, officer, partner, employee or agent of DGAM or Desjardins Group as its director, officer, partner, employee or agent

DGAM will do so in accordance with the regulations applicable to such transactions and always in the best interest of its clients.

In the case indicated in paragraph (d) above, DGAM will not carry out transactions involving such issuer, unless the client in question has been given advance notice and expressly authorized the transaction in writing.

With this document, DGAM informs you of the nature and scope of the conflicts of interest that may affect the services it offers you.

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

2

2. Definitions

For the purposes hereof, the terms below have the following meanings:

“Related issuer” means, in relation to DGAM, an issuer that has a decisive influence on DGAM or on an issuer connected to DGAM, or that is subject to the decisive influence of DGAM. “Influence” in that context means the power to exert a meaningful influence on the management and policies of DGAM, alone or together with other persons or companies, through the ownership of voting stock or any other means.

“Connected issuer” means, in relation to DGAM, an issuer, or any issuer connected thereto, that is in a situation of indebtedness to (i) DGAM, (ii) an issuer connected to DGAM, (iii) a director or an officer of DGAM, or (iv) a director or officer of an issuer connected to DGAM.

This also means, in relation to DGAM, an issuer, or any issuer connected thereto, in a relationship with any of the abovementioned persons—the existence of the relationship constituting important information for a potential underwriter as part of a distribution by the issuer. Thus, an issuer is a Connected issuer of DGAM if, in a debt situation or other type of relationship, a potential underwriter of securities of the connected issuer could challenge the independence of DGAM vis-à-vis such issuer.

3. Issuers related or connected to DGAM

The entities listed below may be considered as issuers related or connected to DGAM. In addition, DGAM may offer its discretionary management services to these Related or Connected issuers, or use their services.

Capital Desjardins Inc.: A wholly owned subsidiary of the Federation, this company is responsible for issuing its own securities on capital markets and investing the proceeds in securities issued by Desjardins caisses.

Capital régional et coopératif Desjardins (“CRCD”): Investment funds whose investment fund manager and portfolio manager is Desjardins Capital Management Inc., a wholly owned subsidiary of the Federation. CRCD raises development capital through public offerings and allocates the funds to cooperatives and businesses. Desjardins Trust Inc. is the custodian of CRCD.

Fiera Capital Corporation: A public company in which Desjardins Financial Corporation Inc., a wholly owned subsidiary of the Federation, holds an interest through Fiera Capital L.P. Fiera Capital Corporation is registered as a portfolio manager and investment fund manager. Fiera Capital Corporation acts as a portfolio sub-manager for certain Desjardins Funds.

Fiera Capital Mutual Funds: A family of mutual funds for which Fiera Capital Corporation is the investment fund manager and promoter. Fiera Capital Corporation is registered as a portfolio manager and can act in that capacity on behalf of Fiera Capital Mutual Funds. The latter are reporting issuers.

Fédération des caisses Desjardins du Québec: The Federation is the cooperative entity responsible for strategic policy, oversight, coordination, treasury operations and development for Desjardins Group. It provides its member caisses with a variety of services, including certain technical, financial and administrative services. In addition, the Federation offers a range of financial services to the Desjardins Group, governments, organizations in the public and parapublic sectors, individuals, and medium and large businesses. It meets the financial needs of the caisses and other components of the Desjardins Group. In this regard, it is mandated to provide institutional funds for the Desjardins network and to play a financial agent role, in particular by providing interbank exchange services, including the financial settlement of compensation. Its activities in the Canadian and international markets complement those of other Desjardins Group entities.

Desjardins Funds: A family of mutual funds for which Desjardins Investments Inc. is the investment fund manager and promoter. Desjardins Funds are reporting issuers. Desjardins Trust Inc. is the trustee and custodian of Desjardins Funds. DGAM is the portfolio manager of the Desjardins Funds.

Desjardins Investments Inc. (“DI”): An indirect wholly owned subsidiary of the Federation. DI is registered as an investment fund manager.

Desjardins Trust Inc.: An indirect wholly owned subsidiary of the Federation, this company is a deposit institution.

DGAM Funds: A family of investment funds focused on institutional clients, for which DGAM is the investment fund manager and portfolio manager. DGAM Funds are not reporting issuers. Desjardins Trust Inc. is the trustee and custodian of DGAM Funds.

Desjardins Exchange Traded Funds (“ETF”): A family of exchange traded funds for which DGAM is the investment fund manager and portfolio manager. Desjardins ETFs are reporting issuers. Desjardins Trust Inc. is the trustee of the Desjardins ETFs.

DIM Private Funds (“DIM Funds”): A family of investment funds for which Desjardins Investment Management Inc. is the investment fund manager and promoter. DIM Funds are not reporting issuers.

Desjardins Investment Management Inc. (“DIM”): DIM, an indirect wholly owned subsidiary of the Federation, is registered as a portfolio manager in Québec, Alberta, Ontario, British Columbia, Newfoundland and Labrador and New Brunswick and as investment fund manager in Québec, Newfoundland and Labrador and Ontario within the scope of the DIM Private Funds management. DIM is also registered as a derivatives portfolio manager in Québec. Private funds are only available for DIM’s clients in provinces where DIM is registered as a portfolio manager. DIM provides discretionary portfolio management and offers private investment pools and funds to its clients.

NEI Funds, Northwest & Ethical Investments (“NEI Funds”): A family of mutual funds for which Northwest & Ethical Investments is the investment fund manager and portfolio manager. NEI Funds are reporting issuers. Desjardins Trust Inc. is the custodian of NEI Funds.

Northwest & Ethical Investments (“NEI Investments”): A 100% owned subsidiary of Aviso Wealth Inc. NEI Investments is a mutual fund company registered as an investment fund manager and portfolio manager and it acts as such for NEI Funds.

Aviso Wealth Inc.: A co-owned subsidiary of Desjardins Financial Holding Inc. and a partnership consisting of five provincial Credit Union Centrals and CUMIS, Aviso Wealth is a national integrated financial services company serving the wealth management needs of virtually all of Canada’s credit unions as well as a range of independent financial organizations. Aviso Wealth Inc. wholly owns NEI Investments.

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

3

Desjardins Securities Inc. (“DS”): A wholly owned subsidiary of Desjardins Financial Holding Inc., itself an indirect wholly owned subsidiary of the Federation. DS is registered as a securities dealer and offers a full range of securities brokerage products and services. DS uses the trade name “Desjardins Online Brokerage” for its discount brokerage activities. Discount brokerage products and services are consolidated under the trademark “Disnat”.

Desjardins Securities International Inc. (“DSI”), a DS subsidiary, is a brokerage registered with the Financial Industry Regulatory Authority (“FINRA”) and the Securities and Exchange Commission (“SEC”).

4. Separate businesses

Potential conflicts of interest are minimized by the fact that, although Desjardins Group has an interest in the above-mentioned issuers, they all have separate operations, a separate management and a separate board of directors that is formed independently.

5. Issuers unrelated to DGAM

Conflicts of interest may also arise in the relationships between DGAM and other issuers that are neither related nor connected to it, for example, trusts, partnerships, special purpose vehicles or conduits that issue asset-backed commercial paper.

In such a situation, the practices and procedures in effect and in accordance with regulations will be applied.

Shared premises with Desjardins Group entities

DGAM is a separate entity from the Fédération des caisses Desjardins du Québec, the Fédération des caisses populaires de l’Ontario inc., and their caisses. In some cases, the premises of these entities are located at the same address and in the same offices. DGAM representatives perform their duties solely on behalf of DGAM. In addition, unless DGAM informs the client otherwise, the securities bought through DGAM have the following features:

a) They are not guaranteed by a government deposit insurer

b) They are not guaranteed by the caisses

c) Their value may fluctuate

DGAM representatives

In carrying out their usual duties, DGAM representatives may find themselves in situations where their personal interests are in conflict with those of a client.

DGAM representatives must disclose to the clients concerned any conflict of interest and any personal interest in a security or other investment that can be expected to affect their ability to advise such clients objectively and impartially.

DGAM representatives must also disclose to their employer any situation that can be reasonably expected to hinder them in their duty toward their employer or in their ability to provide objective and impartial advice.

6. Procedures to reduce conflicts of interest

DGAM takes reasonable measures to identify all material conflicts of interest that exist or that can be reasonably expected to arise. It assesses the level of risk associated with each conflict and avoids any situation involving a serious conflict of interest or a risk that is too great for its clients or the integrity of markets. In any other conflict of interest situation, DGAM ensures that appropriate measures are put in place to effectively control the conflict.

DGAM ensures that fair and reasonable policies exist and are implemented to manage conflicts of interest specific to its management activities, such as fair allocation of securities, use of voting rights, compensation and expense allocation practices, confidentiality of information, trade allocation and best execution.

DGAM’s Code of Ethics and Compliance Manual establish, as a fundamental principle, standards that guide the conduct of DGAM representatives and prohibit them, for example, from:

– Using the confidential information acquired in the course of or in carrying out their duties, or taking advantage of a situation so as to obtain a benefit of any kind

– Giving or accepting gifts, entertainment or compensation that could influence decisions to be made in carrying out their duties

– Engaging in outside activities that could interfere or conflict with their duties at DGAM

– Entering into financial transactions with DGAM clients on a personal basis

– Giving trade orders that knowingly conflict with the interests of DGAM clients and

– Engaging in any activity or holding an interest in any business or participating in any partnership that could hinder or appear to hinder their independence in judging what is in DGAM clients’ best interest

DGAM representatives must disclose to the clients concerned any conflict of interest and any personal interest in a security or other investment that can be expected to affect their ability to advise such clients objectively and impartially.

DGAM representatives must disclose to their employer any situation that can be reasonably expected to interfere with their duty toward their employer or their ability to provide objective and impartial advice.

DGAM ensures that its employee compensation practices are not incompatible with its obligations to its clients.

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

4

Other conflicts of interest

Other real or potential conflicts of interest may arise at any time. DGAM undertakes to take the necessary steps to identify and deal with such situations in a fair and reasonable manner.

This statement of principles on conflict of interest will be updated in the event of any new conflict of interests. The most current version of this statement is available at all times on DGAM’s website at the following address: www.dgam.ca.

7. Referral arrangements

Referral arrangements with members of the same financial group

As part of its activities, DGAM may enter into referral arrangements with business partners. These business partners may be members of the same financial group, the Desjardins Group. As of today, DGAM has not signed any referral arrangements with business partners.

Other Referral arrangements

DGAM may enter into arrangements whereby it pays or receives compensation for referral of clients. The following information is communicated to the customer in writing before the opening of the account or the provision of services:

– the name of each party to the referral arrangement;

– the purpose and material terms of the arrangement, including the nature of the services to be provided by each party;

– existing conflicts of interest or reasonably predictable ones arising from the relationship between the parties and from any other element to the agreement;

– the method of calculating the referral fee and, to the extent possible, the amount of the fee;

– the registration category of each registrant that is a party to the arrangement, with a description of the activities that each is authorized to engage in under that category and, giving consideration to the nature of the referral, the activities that the registrant is not permitted to engage in;

– if a referral is made to a registrant, a statement that all activity requiring registration resulting from the referral arrangement will be provided by the registrant receiving the referral; and

– any other information that a reasonable client would consider important in evaluating the agreement.

As of today, DGAM has not signed any referral arrangements with third parties.

If there is a change in the information provided above, DGAM ensures that the written information relating to this change is provided to each customer concerned as soon as possible, but no later than the thirtieth day before the date on which a referral fee is paid or received.

This conflict of interest policy statement will be updated if new conflict of interest situations arise. The most up-to-date version of this declaration is available at all times on the DGAM website at the following address: www.dgam.ca

YOUR PROTECTION

1. Protecting your personal information

DGAM has adopted a personal information protection policy (“Privacy Policy”) which is part of the guidelines and rules established by Desjardins Group on protection of personal information to ensure the confidentiality and protection of all personal information collected, held, used or conveyed by Desjardins Group and its components. With this Privacy Policy, DGAM wishes to establish specific rules for its particular areas of activities.

The Privacy Policy, whose broad lines are set out herein, explains how DGAM protects personal information when providing investment services. It also describes the principles applied and measures implemented to protect personal information in the context of its activities in Canada.

2. Purpose

DGAM is not only committed to respecting the law, it also takes all matters related to the protection of personal information very seriously and is committed to taking the necessary steps to ensure and preserve the accuracy, confidentiality, security and privacy of personal information. Adoption of and compliance with a privacy policy prove this concern and should increase clients’ confidence in DGAM.

3. Terminology

For purposes of applying the Privacy Policy, the following words and expressions shall mean:

CLIENTA person or an authorized representative who uses or intends to use a DGAM investment product or service.

COLLECTIONThe act of gathering, acquiring or obtaining personal information from any source, including third parties, by any means whatsoever.

CONSENTFree and informed agreement to what is done or suggested. Consent may be express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require the organization seeking a person’s consent to make any inferences. Implied consent occurs when the actions or the inaction of a person make it reasonable to deduce that there is consent.

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

5

DESJARDINS GROUPCollectively all the components of the Desjardins Group.

DESJARDINS GROUP COMPONENTSThe Federation, its member caisses, any auxiliary member participating in the Federation, such as the Fédération des caisses populaires de l’Ontario inc. and its affiliated caisses, and any subsidiaries owned directly or indirectly by the Fédération des caisses Desjardins du Québec and its member caisses.

INVESTMENT PRODUCTS AND SERVICESEncompass, but are not limited to financial services, including services of: a derivatives portfolio manager, an exempt market dealer, an investment fund manager and a portfolio manager.

NAME LISTA list of names, addresses or telephone numbers of physical persons, who may or may not have a common denominator.

PERSONAL INFORMATIONAny information about an identifiable individual or that allows the identification thereof, in any form whatsoever, which has been provided to DGAM by this individual, generated by a component of Desjardins Group, or collected from a third party in compliance with the Privacy Policy and applicable laws.

THIRD PARTYAn individual or organization other than a component of Desjardins Group.

4. Collection, use and communication

Subject to requirements set out in applicable laws, DGAM collects, uses and conveys personal information on clients for the following purposes:

a) to provide a client with the products and services purchased;

b) to establish a client’s profile;

c) to understand a client’s needs;

d) to determine whether the products and services purchased by a client meet his or her needs;

e) to recommend, establish and manage products and services meeting a client’s needs;

f) to conduct marketing activities;

g) to meet securities industry standards regarding the “know your client” rule;

h) to adopt security measures, as required;

i) to comply with laws and regulations in general, with the latter requiring identity document information for the purpose of administering these laws, as well as with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act;

j) to comply with foreign laws, as required; and

k) to detect and prevent fraud.

DGAM may use information related to an individual’s investments for the purpose of informing the individual about other DGAM investment products and services.

An individual’s personal information may be passed on to DGAM agents or subcontractors, or to service providers, for services such as data entry, preparation or sending of statements, or processing of claims. In such circumstances, DGAM prohibits use of this information for purposes other than providing the service in question. These subcontractors and service providers must also agree to take all necessary measures to protect personal information when services are being provided. In the case where some agents, subcontractors and service providers of DGAM are located abroad, and even though DGAM requires contractual clauses related to protection of the individual’s personal information, DGAM remains subject to the requirements of foreign laws that could legally force the disclosure of this information.

An individual’s personal information may be passed on to self-regulatory organizations that regulate DGAM’s activities.

In compliance with applicable laws and regulations, and for the purposes permitted thereunder, DGAM may disclose certain personal information to another Desjardins Group component for purposes that include risk management with respect to the prevention, detection and investigation of fraud, money laundering, terrorist financing and similar risks.

5. Retention

DGAM may, subject to applicable laws, retain in its files an individual’s personal information, including of a client or an authorized representative of a client, as long as required for the above-mentioned purposes, even if an individual ceases to be a client or an authorized representative of a client.

6. Consent

Subject to exceptions provided or permitted by applicable laws, DGAM does not collect, use or pass on personal information for the purposes set out in the “Collection, Use and Communication” section, except with each individual’s prior consent. This consent is given by individuals at various times when an investment service is provided, in particular in account opening applications and agreements with DGAM.

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

6

If DGAM collects personal information from a third party or contacts it to verify or complete personal information, it does so, subject to applicable laws, only with the individual’s prior consent. Except in the above-mentioned cases, each time DGAM passes on any information in compliance with the Privacy Policy, it keeps in its records, where it is reasonable to do so, the nature of this information, the date on which it was sent, and the identity of the third party or Desjardins Group component to which it was provided. Exceptions to this rule are personal information passed on for current operations, such as sending information to companies acting as proxies for DGAM, as well as the production of statements and other documents intended for Revenu Québec, the Canada Revenue Agency, or their United States counterparts, and the updating of data with the authority concerned, or communications with third parties for non-sufficient fund cheques.

Subject to legal and contractual obligations, individuals may refuse to consent to the collection, use or conveyance of their personal information or may withdraw consent at any time. If individuals do not want DGAM to collect, use or convey their personal information for any purpose whatsoever, they need only contact their DGAM representative or make a request in writing. If individuals decline to give or withdraw such consent, however, DGAM may not be able to provide or continue to provide them with certain products, services or information that is likely to interest them or that they have requested.

7. Name lists

DGAM may establish and pass on to third parties, or to other components of the Desjardins Group, name lists for purposes of commercial or philanthropic prospecting. Individuals that are clients may at any time ask DGAM or other Desjardins Group components to strike their name from such lists.

8. Depersonalized information

DGAM may use and convey information for purposes of statistical study, market analysis or segmentation, provided that the individual can in no way be identified and that no link can be established between the individual and the information used or conveyed.

9. Accuracy of information and correction

DGAM makes every reasonable effort to ensure the updating, accuracy and integrity of personal information it holds. It is, however, the responsibility of each individual to inform DGAM promptly of any change of name or address or any other material change to be made to the personal information on the individual. If an individual believes that any personal information on him/her is inaccurate or erroneous, DGAM encourages the individual to seek access to his/her file to check the accuracy of this information. This provides the opportunity to make any corrections or updates that may be required.

10. Rights of access

Subject to applicable legal restrictions, individuals may at any time ask to be informed of the existence, use or conveyance of their personal information. For individuals to gain access to their own personal information, they need only contact or write to their DGAM representative. For security purposes, individuals must provide proof of identity before gaining access to their personal information by demonstrating knowledge of specific personal information (date of birth, account number, personal identification number (PIN), etc.).

Upon receiving a request for access, DGAM will convey to the individual the information it holds on him/her within 30 days of receiving the request, unless an extension of this time period is provided under applicable legislation. If fees are required for accessing information, the individual is advised beforehand and may, if he/she wishes, withdraw the request or challenge whether the fees are reasonable.

Any individual with a sensory disability may have access, upon request to DGAM, to his/her personal information in a format enabling this information to be read or heard, if such a format is available. If such a format is not available, DGAM will convert the pertinent personal information into the required format if it is reasonable to do so.

If an individual’s request for access is denied, DGAM must, subject to applicable legislative restrictions, inform the individual, by means of written notice within 30 days of receiving the request, of the reasons for denying the request.

11. Protective measure

Always with the aim of maintaining confidence, DGAM has introduced measures to ensure and maintain the confidentiality, security and privacy of personal information.

DGAM employees must read the Privacy Policy and agree to comply with it and to respect the privacy of its individuals’ personal information.

As mentioned above, subcontractors and service providers dealing with DGAM must agree to protect the confidentiality and privacy of personal information conveyed to them for purposes of the services they provide.

DGAM has also established substantial security measures to protect its data systems. Only certain authorized persons have access to the internal facilities where personal information is received, processed or stored at DGAM. Moreover, data systems and data handling procedures are subject to appropriate security measures, such as passwords, data encryption, control of access to applications and databanks, firewalls, anti-virus systems and intrusion detection systems, which are continuously reviewed to guarantee the security of operations and the confidentiality of processed data.

When DGAM deems that it no longer needs personal information for the purposes for which it was collected, it destroys or erases the information, subject to applicable laws and in compliance with DGAM’s policies on internal storage and destruction.

12. Complaints and recourse

DGAM has designated a person in charge of answering complaints and recourse regarding personal information that DGAM may hold. Please refer to the “Handling of Complaints” section for more information.

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

7

13. Questions

Individuals may address any questions or concerns pertaining to its personal information protection practices at any time to DGAM by simply contacting their DGAM representative or making a request in writing.

14. Modifications to the policy

DGAM reserves the right to modify its Privacy Policy at any time. The policy is to be posted on the Desjardins Group website.

HANDLING OF COMPLAINTS

1. What you should know about DGAM and its handling of complaints

DGAM, in cooperation with the Desjardins Group Ombudsman, has established efficient measures for handling client complaints, in order to comply with the quality standards set out by the applicable regulations.

Alleged misconduct includes: breach of confidentiality, theft, fraud, misappropriation or misuse of funds or securities, forgery, unsuitable investments, false or misleading information or unauthorized trading, other unauthorized financial dealings as well as unapproved activities engaged outside of DGAM.

For any dissatisfaction concerning customer service, please contact your DGAM representative.

2. Filing a complaint with DGAM

Complaints may be filed in writing to the following address:

Compliance, Complaints and Litigation DepartmentDesjardins Global Asset Management100, rue des CommandeursLévis (Québec) G6V 7N5

We recommend that your written complaint includes details of the grievance, a description of the alleged prejudice, and the requested corrective measure. If you are having difficulty in formulating your complaint, you can consult the Autorité des marchés financiers (AMF) website for tools to help you in this regard: www.lautorite.qc.ca/en/file-complaint-conso.html.

3. Steps following receipt of a complaint

i) Appointment of an advisor of the Compliance, Complaints and Litigation department to your file.

ii) Acknowledgement of receipt sent to the complainant within 5 business days.

iii) The person responsible for your file proceeds with his/her review and conducts an investigation. His/her contact information is available on the acknowledgement of receipt.

iv) A detailed response to the complaint is sent by mail as soon as possible and no later than 90 calendar days following receipt of the complaint. The answer includes a summary of the complaint, the results of the investigation, the final decision with an explanation and the other options for you in case you are unsatisfied with the decision.

v) In the event that the Compliance, Complaints and Litigation department is not able to provide you with a response within the 90-day period, it will contact you within that timeframe to inform you of the reasons for the delay and the new expected response time.

You can request, at any time, that the Chief Compliance Officer forward a copy of your file to the Autorité des marchés financiers. You can also send your file directly to the AMF at the following address:

Québec:Autorité des marchés financiers800, Square Victoria, 22e étageC.P. 246, tour de la BourseMontréal (Québec) H4Z 1G3

Notice to clients residing outside Québec

Clients residing outside Québec may file their complaint with one of the following DGAM agents:

Alberta:Field LLPDaniel A. Downe400, 444 7 Ave S.W.Calgary, Alberta T2P 0X8403 232-1754ddowne@fieldlaw.com

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

8

British Columbia:DesjardinsEmily Caputo401 West Georgia Street, Suite 1050Vancouver, British Columbia V6B 5A1

Manitoba:MLT Aikins LLPMr. Brent C. Ross (Richmond J. Bayes)360 Main Street – 30th FloorWinnipeg, Manitoba R3C 4G1204 957-4681bross@aikins.com

Nova Scotia:McInnes CooperBarristers & SolicitorsDavid A. Graves1300-1969 Upper Water StreetPurdy’s Wharf Tower IIP.O. Box 730Halifax, Nova Scotia B3J 2V1902 425-6500david.graves@mcinnescooper.com

Ontario:Desjardins Financial Security Life Assurance CompanyAlexandre White95 St. Clair, 7th FloorToronto, Ontario M4V 1N7416 926-2700 ext. 5590033

Saskatchewan:McDougall Gauley LLPMe Ronald L. Miller500-616 Main StreetSaskatoon, Saskatchewan S7H 0J6306 525-7200rmiller@mcdougallgauley.com

New Brunswick:Fédération des caisses populaires acadiennes limitéeMr. Marc Roy295 St. Peter Blvd WestP.O. Box 5554Caraquet, New Brunswick EW1 1B7506 726-4000marc.roy@acadie.com

Newfoundland and Labrador:Benson BuffettMr. Jeffrey P. BensonAtlantic Place, Water StreetSuite 900, P.O. Box 1538St. John’s, Newfoundland and Labrador A1C 5N8709 570-7224jbenson@bensonbuffett.com

Nunavut:Michael Chandler Law OfficeMichael ChandlerBuilding 2416P.O. Box 2021Iqaluit, Nunavut X0A 0H0867 979-3505mchandler@qiniq.com

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

9

Prince Edward Island:Campbell, Lea, Barristers & SolicitorsMr. Kenneth L. Godfrey65 Water StreetSuite 400, P.O. Box 429Charlottetown, Prince Edward Island C1A 1A3902 566-3400dlarsen@campbelllea.com

Northwest Territories:Peter C. Fuglsang & AssociatesPeter C. Fuglsang4405 – School Draw AveP.O. Box 2459Yellowknife, Northwest Territories X1A 2P8867 920-4344fuglsang@ssimicro.com

Yukon:Austring, Fendrick & FairmanLorne N. Austring3081 Third AvenueWhitehorse, Yukon Y1A 4Z7867 668-4405info@lawyukon.com

4. Other recourse available within Desjardins Group

If you are not satisfied with the conclusion reached by Compliance, Complaints and Litigation department, you can contact the Desjardins Group Ombudsman (“Ombudsman”).

Upon written request, DGAM’s Compliance, Complaints and Litigation Department can forward a copy of your file to the Ombudsman, which will serve as your final recourse within Desjardins Group. Once it has received all the necessary information, the Ombudsman will review your file within 90 days. You can also send them your file directly, at the following address:

Desjardins Group OmbudsmanFédération des caisses Desjardins du Québec1 Complexe DesjardinsP.O. Box 7, Desjardins StationMontréal, Québec H5B 1B2

5. Other means for investors to seek compensation

You also have access to the following solutions:

AMF’s mediation servicesThe AMF, Québec’s regulatory agency within the financial sector, offers a free mediation service available only to customers who reside in Québec.

After attempting to resolve your complaint with DGAM, you can forward a copy of your complaint file to the AMF. Participation in this process is on a voluntary basis, thereby requiring consent from both the client and DGAM.

For more information on mediation services:

1-877-525-0337 www.lautorite.qc.ca renseignementsconsommateur@lautorite.qc.ca

Legal actionYou may also present your case in court.

Prescriptive periods: Please be aware that there are delays established by law to pursue legal recourse. A lawyer may help explain your options and recourse. Once said prescriptive period has expired, you may no longer pursue specific recourse options.

Preserving your FileAs with any financial question, you should keep a detailed file containing documents such as account opening application forms, contracts and account statements. Document any steps you undertake to resolve your complaint and keep copies of letters, faxes, e-mails and notes taken during conversations or meetings.

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

10

FAIRNESS POLICYDGAM undertakes to ensure the fair distribution of investment opportunities between clients. The transactions carried out on behalf of its clients are executed under the best conditions with brokers and in a fair and equitable manner for all its clients, in accordance with their investment policy.

Transactions carried out for a number of clients on the primary and/or secondary market are allocated on a pro rata basis determined in advance. Orders are then executed using the average price and average commission rate. When orders are partially executed or the quantity is deemed negligible, the portfolio manager assigned to the account may reallocate the allocation to another client or remit it to the broker.

In the execution process, DGAM considers other factors that can influence the choice of a broker for a transaction, such as service quality, commission rate, reputation, financial responsibility and speed of execution. A periodic review of all brokers with whom DGAM deals is conducted.

DGAM strives to act reasonably and fairly with all its clients, taking into account their investment policies and avoiding conflicts of interest or favouritism between clients. When making an investment decision, regardless of cash flow and portfolio allocation, the portfolio manager must determine whether all clients, for whom the mandates are similar, must participate in the transaction so that all have access to the same investment opportunities.

DGAM has implemented a procedure to fairly allocate the amount obtained in a new issue, specifically when it is less than expected. This procedure complies with the elements described in section 14.10 of Policy Statement to Regulation 31-103:

a) the method for allocating price and commission among client orders when transactions are aggregated, including in blocks;

b) the method for allocating trading blocks and initial public offerings among client accounts, as part of its service offering;

c) the method for allocating blocks of operations and initial public offerings among partially executed client orders, including pro rata, as part of its service offering.

Fixed income transaction may apply to multiple mandates. The allocation will then have to be completed and documented according to the liquidity and investment strategy (sector, duration, yield, etc.) of each mandate. In the event that the portfolio manager is required to change the initial allocation following a full or partial allocation, the reasons for this change will need to be documented and approved by the asset class manager.

In the event that the initial amount of the transaction order is not received at the time of the trade, a pro-rated distribution of the quantity must be applied.

For actively managed mandates, a prorated percentage of the initial executed order will be applied for each client. The distribution will be at the average execution rate. In the case where a distribution is an exception to the pro rata rule, the factors used to justify the allocation will have to be documented and approved by the asset class manager.

For passive mandates, the portfolio manager will need to ensure that portfolio weights are in line with the replicated index.

For new issues, the portfolio manager may determine a minimum allocation for each account before submitting the order. At the time of the allocation, if the securities obtained for a participating account are below the minimum threshold allocated, the securities are distributed among the other participating portfolios.

DGAM has not participated and has no intention to participate in initial public offerings. Should the activities change, the essence of this procedure would be applied.

In its role as portfolio manager, DGAM is called upon to carry out transactions on behalf of its business partners and clients. Given its fiduciary role and the regulatory framework in which it operates, DGAM has a duty to regulate its negotiating practices. As a result, DGAM has a rigorous process for executing and monitoring stock and derivative transactions (futures, forward contracts, currencies, options, swaps) in order to comply with the principle of best execution.

DGAM is responsible for achieving the best possible result for all its partners and customers by acting fairly and honestly and taking into account the different variables that can influence the execution of transactions. DGAM must also ensure that its trading strategies are appropriate based on market conditions and must allocate transactions equitably among the accounts of its clients.

DGAM has the authority to select the brokers by which the trades will be executed and the rates to be paid for these brokerage services. The choice of a broker or counterparty must be made in the interests of the client, taking into account the above-mentioned listed factors.

DGAM’s negotiating teams have put in place best execution processes based on their respective needs and established checklists. These processes take into account the characteristics of the market and the nature of the products being traded while allowing the ability to demonstrate how the best execution principles are applied in their respective sectors.

DGAM conducts a review of brokers or counterparties at least once a year to approve the list and establish an allocation budget for all classes of assets traded. The criteria used may include: the financial strength and reputation of the broker, the ability and efficiency of execution, the competence on block trading, the price, the speed and certainty of execution, the transaction global cost, access to underwriting and secondary market offerings, conflict resolution, and the quality of communication means and tools. DGAM also regularly monitors the results obtained by the various brokers with whom it deals with transactions made for customers.

The overall cost of the transaction may include, as the case may be, all costs associated with access to an order or the execution of a transaction that are the responsibility of the customer, including costs arising from the negotiation of securities in a particular market, “jitney” fees, i.e., any fees paid by one broker to another to access negotiations and settlement costs.

The authorities expect DGAM to make reasonable efforts to use the mechanisms that provide information on orders and operations. Reasonable efforts include the use of information displayed by the information processor or, in the absence of an information processor, an information provider.

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

11

DGAM identifies all actual, potential or apparent conflicts of interest and communicates them to its clients via this document through the section “Desjardins Global Asset Management Inc. Statement of Principles on Conflicts of Interest.” The statement of principles on conflict of interest is updated as soon as a change occurs and this update is posted on the DGAM website. In addition, at least annually, when the Business Relationship Manager meets with his/her client, the Business Relationship Manager must provide a copy of this document. The information thus communicated:

a) is highlighted and written in a precise, clear and explicit manner for the clients;

b) explains the conflict of interest and its possible effect on the services offered to customers.

Certain conflicts of interest may involve confidential information or commercially sensitive information, or “privileged information” under securities law provisions relating to insider trading. In these cases, DGAM must assess whether alternative methods exist to address the conflict of interest adequately.

DGIA employees also comply with any conflict of interest disclosure requirements prescribed by law, regulations, and any regulations of organizations overseeing their activities, and they must respect any prohibition of action when there is a conflict of interest.

This policy may be revised from time to time to reflect changes in regulatory requirements and industry practices.

DECLARATION OF RISK

Introduction

According to Regulation 31-103, the manager is required to describe the types of risks the client should take into account when establishing a new business relationship with DGAM. The manager is also required to disclose the nature and scope of the specific investment-related risks about which a reasonable investor would expect to be informed. This document outlines the investment-related risks identified by the manager; the information is not exhaustive, but rather intended strictly for information purposes.

Nature of risks

The main risks associated with portfolio management, whether the investments are held directly or through a mutual fund (“fund”), are described below.

Any investment in securities may result in a capital loss by virtue of its speculative nature. The risks associated with the strategies and methods used can increase during periods of speculative activity or unusual market volatility.

General risks related to markets and returns

There is no guarantee that the investment approach used will be effective or that the investment objectives will be achieved. Nor is there any guarantee that the investments in your portfolio or the funds will generate income or added value. Although the diversification and selection process used by DGAM is expected to mitigate risks, the portfolio or the fund may sustain considerable losses.

The value of your portfolio, like the net asset value of a fund, will fluctuate with general conditions prevailing on debt, equity and commodity markets, as well as with exchange rates and various political, economic and social situations, capital market instability and the financial performance of issuers of the securities that constitute or underlie the investments held by the portfolio/fund.

The success of any investment activity depends on the general economic situation, which can influence interest rates and volatility; it also depends on the volume of transactions and the time investors choose to invest in equity and other markets. Unexpected volatility or illiquidity on markets in which DGAM holds an interest could hinder its ability to achieve its objectives or cause it to sustain losses.

Despite the significant volume of transactions in securities and other financial instruments, markets for certain financial instruments have limited transparency and liquidity, which can be a disadvantage for DGAM in terms of obtaining the listed price and executing trades at the desired price.

If your assets are invested in DGAM Funds, it is important for you to know that these funds must comply with certain regulatory requirements, but are not subject to all the disclosure obligations or regulations applicable to public mutual funds.

Income tax considerations

The after-tax return of an investment in a fund for an investor required to pay tax in Canada or internationally will depend in part on the composition of the distributions paid by the fund (which can be wholly or partially taxable or, in certain cases, constitute a non-taxable capital refund). The composition can vary over time, which influences the after-tax yield of your investments. The taxation rates applicable to the different types of income could also change following amendments to government policies.

Dividends and other distributions, including deemed dispositions, from securities in the portfolio may be taxable in Canada or internationally; the investor may not necessarily deduct all or a portion of such tax from his or her local income or apply it to a foreign tax credit on his or her local tax expense.

Borrowing

DGAM may temporarily borrow money on behalf of DGAM Funds and clients, to meet redemption demands or settle portfolio operations. If the market falls before the securities can be sold to raise the liquidity to reimburse the loans, the net asset value of the portfolio/fund will decrease and the other investors will feel the impact. Based on your investment policy, DGAM has the right to contract debts backed by its assets and intends to exercise this right.

Illiquidity

Some securities may be illiquid because they are infrequently traded; as a result, there is no guarantee that the portfolio/fund will be able to liquidate such investments.

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

12

Currency

If your investment policy so permits, DGAM can use futures and foreign currency options as hedges against currency fluctuations. However, DGAM is not required to do so, and there is no guarantee that such hedges will be effective under the circumstances.

Custodian

Desjardins Trust Inc. is the Custodian of the portfolio assets of DGAM Funds pursuant to an agreement entered into with DGAM on May 24, 2013 and as amended on April 1st, 2018. The Custodian performs this activity from its head office in Montréal. Desjardins Trust Inc. may use the services of sub-custodians, especially to facilitate trading in securities outside Canada, in accordance with Canadian securities legislation. DGAM Funds’ portfolio assets are held in Canada by the Custodian or a sub-custodian, or outside Canada by the Custodian or a sub-custodian, if appropriate, in order to facilitate trading of the DGAM Funds’ assets outside of Canada. As for DGAM clients, they resort to their own custodian.

Risks related to margin transactions and counterparty risk

The portfolio/fund may be exposed to the risk of default by the counterparties with which the transactions are carried out.

If the securities provided to a broker to guarantee margin transactions lose value, the broker will issue a margin call; DGAM will then be required to deposit additional assets with the broker or another counterparty, or the securities given as a guarantee may have to be liquidated to offset the loss. In the event of a sudden drop in the value of its assets, the portfolio/fund may be unable to liquidate the assets quickly enough to reimburse the margin debt.

Short selling

If your investment policy so permits, DGAM may engage in short selling, i.e., in selling a security not held by the portfolio/fund in the hope of subsequently buying the same security (or an exchangeable security) back at a lower price. To deliver the security to the buyer, the portfolio/fund must borrow the security then buy it back at a later date to return it to the lender. Short selling involves the risk of a theoretically unlimited increase in the price of a security.

Suspension of trading

Stock markets generally have the right to suspend or limit trading of any financial instrument. In the event of such a suspension, the financial instrument in question may not be liquidated and the portfolio/fund could thus sustain losses.

Financial leverage

If your investment policy so permits, DGAM can use financial leverage. Although financial leverage improves the chance of achieving a better return, it also increases the risk of loss. The risks associated with leveraging vary for each buyer according to his or her specific situation.

DGAM is not a lending institution and consequently does not grant its clients loans.

Derivatives

If your investment policy so permits, DGAM can invest in derivatives intended to hedge its interest in underlying markets so as to modify or reproduce the return of securities, commodities, interest rates, indices or specific markets with or without leverage.

Derivatives generally involve counterparty risk or the risk of losing all or part of the value of the investment, in particular because of the volatility of interest rates and credit risks, economic factors and activities on domestic and global markets. Derivatives can include substantial leverage that could considerably worsen the repercussions of market fluctuations and result in losses greater than the value of the investment. Derivative transactions are sometimes carried out over the counter or between dealers. Participants in these markets are generally not subject to regulatory oversight like participants in regulated stock markets. Unless otherwise indicated by your investment policy, nothing prevents DGAM from dealing with a particular counterparty or carrying out all its transactions with a single counterparty.

Limited ability to liquidate investments in DGAM Funds

Investors in a DGAM Fund do not have any public market for the shares offered hereunder and no market is expected to be created for that purpose. To redeem shares, the investor must complete and sign the redemption form and forward it to DGAM. DGAM Fund shares may not be transferred or resold. In addition, under the specific exceptional circumstances described in the Declaration of Trust, share redemption could be suspended for a certain period.

Potential effects of share redemption

Requests to redeem a significant volume of shares could require the Fund to liquidate its investments more quickly than desirable in order to raise the amounts required to fund the redemptions and achieve a market position that faithfully reflects a lower asset base. A drop in the value of the redeemed and outstanding shares could ensue.

Amendments to laws

There is no guarantee that Canadian or foreign laws, in particular legislation governing securities, investments and taxation, as well as the administrative policies and practices of governments and regulatory agencies will not be amended in a way that could adversely affect your investments.

REGULATORY DISCLOSURES DATED SEPTEMBER 30, 2020

13

Desjardins Global Asset Management Inc.Contact usMontreal area: 514-350-8686 Elsewhere in Canada and the US:1-877-353-8686

The Desjardins brand is a trademark of the Fédération des caisses Desjardins du Québec, used under licence.