The Code of Conduct establishes policies, guidelines and procedures to govern the conduct of officers and employees and is intended to provide a workable framework that ensures that officers and employees have a full understanding of PSP Investments' principles and values to assist them in determining appropriate business practices and behaviour.

The Code of Conduct addresses such matters as honesty and integrity; compliance with the law generally; the use of confidential information; the entertainment of and by third parties and the giving and receipt of gifts; membership in non-profit and professional associations; and the use of PSP Investments' assets and facilities.

The Code of Conduct also establishes conflict of interest standards and procedures with which officers and employees must comply. These comprehensive policies and procedures address such issues as the requirement for full disclosure of the securities owned by officers and employees; how and when a conflict may arise and the manner in which conflicts are to be handled; the disclosure of confidential information; the duty to report breaches of the Code of Conduct; the establishment of a restricted list of securities and trading in securities generally; and the duty to provide a personal statement of all securities purchased or sold. The Board of Directors' Audit and Conflicts Committee monitors the application of the Code of Conduct.

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