Common use of Market Timing Policy Clause in Contracts

Market Timing Policy. This policy addresses issues regarding unacceptable mutual fund trading activity, specifically the market timing of mutual funds. The Canadian securities industry has identified mutual fund market timing as practices that include: • Frequent Trading - defined as the frequent buying and selling of mutual fund units; and • Price Arbitrage Trading - defined as buying and selling of mutual fund units in order to exploit inefficiencies in the pricing of mutual funds. For further clarity, “selling of a mutual fund” includes a redemption to cash and a redemption that involves a switch into units of another mutual fund in the same fund family. While many fund companies will charge an early redemption fee if a mutual fund is sold within a specified number of days of purchase, securities regulators do not specify what period of time constitutes frequent trading but consider that any repeated buying and selling of mutual funds is harmful to other unit holders, and could be perceived as being frequent trading. Market timing of mutual funds can adversely affect the mutual funds and hence the other unit holders of the fund. Market timing may present risks including interference with efficient management of a fund’s portfolio, increased brokerage, administrative and transaction costs, generation of taxable capital gains for unit holders, and increased borrowing or holding of cash reserves. All of these may lead to a dilution in the unit value or diminished returns for long term unit holders. We will not maintain accounts that use mutual fund market timing practices, through the use of Frequent Trading or Price Arbitrage Trading. If it is determined that mutual fund market timing has taken place, steps will be taken to close those client accounts. This policy does not apply to the buying and selling of money market mutual funds, provided that they trade at a fixed net asset value. Statement of Policies Respect for the Law: TD Waterhouse Canada Inc. and its officers and employees must scrupulously observe, in letter and spirit, all laws governing its business and securities activities. TD Waterhouse Canada Inc. and its officers and employees must deal fairly, honestly and in good faith with clients. Confidentiality of Client Information: Confidentiality of client information is a fundamental principle of our firm. TD Waterhouse Canada Inc. may release confidential client information only in accordance with the Privacy Agreement and the Privacy Code – “Protecting Your Privacy” of TD Bank Group, of which TD Waterhouse Canada Inc. is a part. Misuse of Confidential and Insider Information: The misuse of confidential information or misuse of any insider information not generally disclosed, for personal gain or for the benefit of anyone else, is prohibited and grounds for immediate dismissal of an employee. TD Waterhouse Canada Inc. or its affiliates may, at times, have material information relating to certain securities which neither the client nor TD Waterhouse Canada Inc. or its affiliates may, under law, use for the benefit of an account. Conflicts of Interest: To maintain public confidence and respect, we have adopted policies and procedures to assist us in identifying and controlling any conflicts of interest that we may face.

Market Timing Policy. This policy addresses issues regarding with regard to unacceptable mutual fund trading activity, specifically the market timing of mutual funds. The Canadian securities industry has identified mutual fund market timing as practices that include: • Frequent Trading - defined as the frequent buying and selling of mutual fund units; and • Price Arbitrage Trading - defined as buying and selling of mutual fund units in order to exploit inefficiencies in the pricing of mutual funds. For further clarity, “selling of a mutual fund” includes both a redemption to cash and a redemption that involves a switch into units of another mutual fund in the same fund family. While many fund companies will charge an early redemption fee if a mutual fund is sold within a specified number of 90 days of purchase, securities regulators do not specify what period of time constitutes frequent trading but consider that any repeated buying and selling of mutual funds is harmful to other unit holders, and could be perceived as being frequent trading. Market timing of mutual funds can adversely affect the underlying mutual funds and hence the other unit holders of the fund. Market timing may present risks including including, but not limited to, interference with efficient management of a fund’s portfolio, increased brokerage, administrative and transaction costs, generation of taxable capital gains for unit holders, and increased borrowing or holding of cash reserves. All of these may lead have the affect of leading to a dilution in the unit value or diminished returns for long term unit holders. We TD Waterhouse will not maintain accounts that use mutual fund market timing practices, either through the use of Frequent Trading or Price Arbitrage Trading. If If, in a review, it is determined that mutual fund market timing has taken place, steps will be taken to close those client accounts. This policy does not apply to the buying and selling of money market mutual funds, provided that they trade at a fixed net asset value. Statement of Policies STATEMENT OF POLICIES Respect for the Law: TD Waterhouse Canada Inc. and its officers and employees must scrupulously observe, in letter and spirit, all laws governing its business and securities activities. TD Waterhouse Canada Inc. and its officers and employees must deal fairly, honestly and in good faith with clients. Confidentiality of Client Information: Confidentiality of client information is a fundamental principle of our firm. TD Waterhouse Canada Inc. may release confidential client information only in accordance with the Privacy Agreement and the Privacy Code – “Protecting Your Privacy” of TD Bank GroupTD, of which TD Waterhouse Canada Inc. is a part. Misuse of Confidential and Insider Information: The misuse of confidential information or misuse of any insider information not generally disclosed, for personal gain or for the benefit of anyone else, is prohibited and grounds for immediate dismissal of an employee. TD Waterhouse Canada Inc. or its affiliates may, at times, have material information relating to certain securities which neither the client nor TD Waterhouse Canada Inc. or its affiliates may, under law, use for the benefit of an account. Conflicts of Interest: To maintain public confidence and respect, we have adopted policies and procedures to assist us in identifying and controlling any conflicts of interest that we may face.

Market Timing Policy. This policy addresses issues regarding unacceptable mutual fund trading activity, specifically the market timing of mutual funds. The Canadian securities industry has identified mutual fund market timing as practices that include: • Frequent Trading - defined as the frequent buying and selling of mutual fund units; and • Price Arbitrage Trading - defined as buying and selling of mutual fund units in order to exploit inefficiencies in the pricing of mutual funds. For further clarity, “selling of a mutual fund” includes a redemption to cash and a redemption that involves a switch into units of another mutual fund in the same fund family. While many fund companies will charge an early redemption fee if a mutual fund is sold within a specified number of days of purchase, securities regulators do not specify what period of time constitutes frequent trading but consider that any repeated buying and selling of mutual funds is harmful to other unit holders, and could be perceived as being frequent trading. Market timing of mutual funds can adversely affect the mutual funds and hence the other unit holders of the fund. Market timing may present risks including interference with efficient management of a fund’s portfolio, increased brokerage, administrative and transaction costs, generation of taxable capital gains for unit holders, and increased borrowing or holding of cash reserves. All of these may lead to a dilution in the unit value or diminished returns for long term unit holders. We will not maintain accounts that use mutual fund market timing practices, through the use of Frequent Trading or Price Arbitrage Trading. If it is determined that mutual fund market timing has taken place, steps will be taken to close those client accounts. This policy does not apply to the buying and selling of money market mutual funds, provided that they trade at a fixed net asset value. Statement Governing Principles for the Operation of Policies Your Account by TD Waterhouse Canada Inc. Respect for the Law: TD Waterhouse Canada Inc. (TDWCI) and its officers and employees must strive to scrupulously observe, in letter and spirit, all laws governing its business and securities activities. TD Waterhouse Canada Inc. and its officers and employees must deal fairly, honestly and in good faith with clients. Confidentiality of Client Information: Confidentiality of client information is a fundamental principle of our firm. TD Waterhouse Canada Inc. may release confidential client information only in accordance with the Privacy Agreement and the Privacy Code – “Protecting Your Privacy” of TD Bank Group, of which TD Waterhouse Canada Inc. is a part. Misuse of Confidential and Insider Information: The misuse of confidential information or misuse of any insider information not generally disclosed, for personal gain or for the benefit of anyone else, is prohibited and grounds for immediate dismissal of an employee. TD Waterhouse Canada Inc. or its affiliates may, at times, have material information relating to certain securities which neither the client nor TD Waterhouse Canada Inc. or its affiliates may, under law, use for the benefit of an account. Conflicts of Interest: To maintain public confidence and respect, we have adopted policies and procedures to assist us in identifying and controlling any conflicts of interest that we may face.

Market Timing Policy. This policy addresses issues regarding with regard to unacceptable mutual fund trading activity, specifically the market timing of mutual funds. The Canadian securities industry has identified mutual fund market timing as practices that include: • Frequent Trading - defined as the frequent buying and selling of mutual fund units; and • Price Arbitrage Trading - defined as buying and selling of mutual fund units in order to exploit inefficiencies in the pricing of mutual funds. For further clarity, “selling of a mutual fund” includes both a redemption to cash and a redemption that involves a switch into units of another mutual fund in the same fund family. While many fund companies will charge an early redemption fee if a mutual fund is sold within a specified number of 90 days of purchase, securities regulators do not specify what period of time constitutes frequent trading but consider that any repeated buying and selling of mutual funds is harmful to other unit holders, and could be perceived as being frequent trading. Market timing of mutual funds can adversely affect the underlying mutual funds and hence the other unit holders of the fund. Market timing may present risks including including, but not limited to, interference with efficient management of a fund’s portfolio, increased brokerage, administrative and transaction costs, generation of taxable capital gains for unit holders, and increased borrowing or holding of cash reserves. All of these may lead have the affect of leading to a dilution in the unit value or diminished returns for long term unit holders. We TD Waterhouse will not maintain accounts that use mutual fund market timing practices, either through the use of Frequent Trading or Price Arbitrage Trading. If If, in a review, it is determined that mutual fund market timing has taken place, steps will be taken to close those client accounts. This policy does not apply to the buying and selling of money market mutual funds, provided that they trade at a fixed net asset value. Statement of Policies STATEMENT OF POLICIES Respect for the Law: TD Waterhouse Canada Inc. and its officers and employees must scrupulously observe, in letter and spirit, all laws governing its business and securities activities. TD Waterhouse Canada Inc. and its officers and employees must deal fairly, honestly and in good faith with clients. Confidentiality of Client Information: Confidentiality of client information is a fundamental principle of our firm. TD Waterhouse Canada Inc. may release confidential client information only in accordance with the Privacy Agreement and the Privacy Code – “Protecting Your Privacy” of the TD Bank Group, of which TD Waterhouse Canada Inc. is a part. Misuse of Confidential and Insider Information: The misuse of confidential information or misuse of any insider information not generally disclosed, for personal gain or for the benefit of anyone else, is prohibited and grounds for immediate dismissal of an employee. TD Waterhouse Canada Inc. or its affiliates may, at times, have material information relating to certain securities which neither the client nor TD Waterhouse Canada Inc. or its affiliates may, under law, use for the benefit of an account. Conflicts of Interest: To maintain public confidence and respect, we have adopted policies and procedures to assist us in identifying and controlling any conflicts of interest that we may face.

Market Timing Policy. This policy addresses issues regarding unacceptable mutual fund trading activity, specifically the market timing of mutual fundsfunds . The Canadian securities industry has identified mutual fund market timing as practices that include: • Frequent Trading - defined as the frequent buying and selling of mutual fund units; and • Price Arbitrage Trading - defined as buying and selling of mutual fund units in order to exploit inefficiencies in the pricing of mutual fundsfunds . For further clarity, “selling of a mutual fund” includes a redemption to cash and a redemption that involves a switch into units of another mutual fund in the same fund familyfamily . While many fund companies will charge an early redemption fee if a mutual fund is sold within a specified number of days of purchase, securities regulators do not specify what period of time constitutes frequent trading but consider that any repeated buying and selling of mutual funds is harmful to other unit holders, and could be perceived as being frequent tradingtrading . Market timing of mutual funds can adversely affect the mutual funds and hence the other unit holders of the fundfund . Market timing may present risks including interference with efficient management of a fund’s portfolio, increased brokerage, administrative and transaction costs, generation of taxable capital gains for unit holders, and increased borrowing or holding of cash reservesreserves . All of these may lead to a dilution in the unit value or diminished returns for long term unit holdersholders . We will not maintain accounts that use mutual fund market timing practices, through the use of Frequent Trading or Price Arbitrage TradingTrading . If it is determined that mutual fund market timing has taken place, steps will be taken to close those client accountsaccounts . This policy does not apply to the buying and selling of money market mutual funds, provided that they trade at a fixed net asset valuevalue . Statement Governing Principles for the Operation of Policies Your Account by TD Waterhouse Canada Inc . Respect for the Law: TD Waterhouse Canada Inc. Inc . (TDWCI) and its officers and employees must strive to scrupulously observe, in letter and spirit, all laws governing its business and securities activities. TD Waterhouse Canada Inc. and its officers and employees must deal fairly, honestly and in good faith with clients. Confidentiality of Client Information: Confidentiality of client information is a fundamental principle of our firm. TD Waterhouse Canada Inc. may release confidential client information only in accordance with the Privacy Agreement and the Privacy Code – “Protecting Your Privacy” of TD Bank Group, of which TD Waterhouse Canada Inc. is a part. Misuse of Confidential and Insider Information: The misuse of confidential information or misuse of any insider information not generally disclosed, for personal gain or for the benefit of anyone else, is prohibited and grounds for immediate dismissal of an employee. TD Waterhouse Canada Inc. or its affiliates may, at times, have material information relating to certain securities which neither the client nor TD Waterhouse Canada Inc. or its affiliates may, under law, use for the benefit of an account. Conflicts of Interest: To maintain public confidence and respect, we have adopted policies and procedures to assist us in identifying and controlling any conflicts of interest that we may faceactivities .