CI Financial strives to operate with responsibility and integrity in all aspects of our business. We are committed to treating our employees, clients and business partners with respect, to investing responsibly, to supporting our communities, and to reducing our impact on the environment. This section highlights some of our initiatives and achievements in these areas.


CI Financial believes that responsible investing can play a role in achieving the best risk-adjusted returns for our funds and our clients. To represent this commitment, CI Global Asset Management (“CI GAM”) is a signatory to the United Nations-supported Principles for Responsible Investment (“UNPRI”) and an associate member of Canada’s Responsible Investment Association, and has adopted a formal Responsible Investment Policy.

responsible investing

CI GAM’s approach is to integrate environmental, social and governance (ESG) factors into the investment decision-making process, which we believe enhances our analysis of investment risks and opportunities over the long term.

We employ a dedicated responsible investing team which works with our portfolio managers and analysts to examine, analyze and incorporate material ESG factors into their process. We also believe that it is more beneficial to hold positions in companies and engage with management to drive improvements in ESG performance rather than adopt an exclusionary policy.

However, in recognition of the United Nations Anti-Personnel Landmines Convention and the Convention on Cluster Munitions, we will not knowingly directly invest in companies associated with such weapons. This restriction applies to actively managed funds where CI GAM directly controls the investment strategy of the fund.

CI GAM’s Responsible Investment Process

Core Components

  • Responsible Investment Policy
  • Investment Exclusions
  • Minimum ESG Ranking Criteria
  • Third-Party ESG Data
  • Dedicated Responsible Investment Team
Core Components arrow to Process


Step 1: In-house portfolio managers have continual access to third-party ESG data

Step 2: Investment exclusions list provided to in-house portfolio managers & external investment sub-advisors on an ongoing basis

Step 3: In-house portfolio managers provided with customized ESG screens of portfolios with flagged holdings on an ongoing basis by CI’s Responsible Investment Team

Step 4: In-house portfolio managers review material flagged holdings and document findings

Step 5: Monitoring by CI’s compliance department



ESG-Focused Investment Solutions

In addition to the integration of ESG factors into our overall investment approach, CI GAM offers several investment solutions with specific ESG-related mandates. Further information is available here.

Good governance is essential to the effective and efficient operation of CI. For that reason, the Board of Directors and management are committed to maintaining a high standard of governance, which includes consideration of the governance guidelines of the Canadian Securities Administrators and best practices recommendations of the Canadian Coalition for Good Governance.

The Board is responsible for the stewardship of CI and its specific duties and functions are set out in the Board of Directors’ Mandate.

In fulfilling its mandate, the Board believes that it is important that at least two-thirds of its Directors are independent of management. As of June 2022, seven of eight Directors were considered independent. The Board believes that a diversity of views and experience enhances decision-making and enables the Board as a whole to fulfill its core responsibilities to CI and help shape strategic direction. The members of the Board collectively possess a broad range of skills, expertise, industry experience and other knowledge which contribute to the effective oversight of CI’s business.

typing on a laptop

As part of this, CI is committed to having gender diversity on the Board, its committees, and its leadership roles. Accordingly, on February 9, 2022, the Board adopted a formal Board Gender Diversity Policy. The Board’s goal is to have self-identified men or women each represent at least two directors on a Board of seven or fewer members or at least 30% of the directors on a Board of more than seven members. As of June 2022, two of eight Directors were women for a proportionate representation by women on the Board of 25%. As a result, the Board continues its efforts to reach its diversity targets as set out in the policy.

More information about our Board and the governance of CI is available on this website under “Governance.”

Ethical Business Conduct

CI is committed to doing business ethically and legally and has adopted a series of policies to foster a culture of integrity. The most important of these is the CI Financial Code of Conduct (the “Code”), which was first adopted in 2006 and most recently updated in 2021. It addresses, among other things, the following issues:

  • Acting ethically and with integrity
  • Avoiding conflicts of interest
  • Protecting confidential, personal and non-public information
  • Making sure key information is accurate
  • Respecting company resources
  • Respecting colleagues and others and keeping the workplace safe
  • Reporting concerns related to the Code.

The Code applies to Directors, officers, employees, agents and representatives of the Corporation and its subsidiaries and affiliates, who must certify annually that they have read the Code and agree to abide by it. The Code is overseen by the CI Compliance Department and the Board receives quarterly reports regarding compliance with the Code.

We have adopted other policies to ensure ethical business conduct, including an Anti-Bribery and Anti-Corruption Policy, Disclosure Policy, and Insider Trading Policy. CI’s subsidiaries maintain policies applicable to their operations, including those related to anti-money-laundering, counter-terrorist financing and sanctions, sales practices, and conflicts of interest.

CI has also established a Whistleblower Policy, under which CI Directors, officers, employees, agents and representatives may confidentially report concerns without fear of reprisal for reports made in good faith. These concerns may include issues such as violations of the Code, compliance with legal and regulatory requirements, or accounting or auditing matters.

Risk Management


Effective enterprise risk management and continual assessment of the risks confronting our business are necessary in order to ensure that CI is positioned to achieve its business objectives and to protect the assets of its clients and the company. In recognition of the importance of this function, CI has a Chief Risk Officer and a Risk Management Committee comprised of senior executives representing the company’s business units. Risk management is also overseen by the CI Board’s Audit and Risk Committee, which receives regular reports from management.

Data Privacy and Security


CI is dependent on information technology and systems to process, transmit, and store electronic information and we recognize that protecting these systems and client and company information is critical.

CI maintains a Cybersecurity Program focused on protection, detection, and response to threats. In addition to ongoing monitoring and vulnerability scans, CI’s measures are tested on annual basis by third-party specialists. Cybersecurity is also considered the responsibility of all employees, who are held accountable through the Information Security Policy and IT Acceptable Use Policy. Security awareness training is provided for all new hires and annually for all employees.

We also protect client data through a robust Privacy Risk Management Program, which ensures adherence to relevant privacy legislation, including Canada’s Personal Information Protection and Electronic Documents Act. The program is overseen by the Chief Privacy Officer and CI’s Compliance Department and supported by employee training and education.

Diversity, Equity and Inclusion

CI believes that to be competitive in a global environment, we must create a culture of trust where people know their differences are valued as they strive to be innovative without barriers. Diversity will strengthen our collective success and potential by enabling CI to attract and retain the best talent, bringing innovation and different perspectives to the table and enhancing decision-making. CI is committed to a diverse and inclusive culture where all employees feel:

  • Valued – They are appreciated and respected for their unique perspectives and talents.
  • Trusted – They make meaningful contributions and are influential in decision-making.
  • Authentic – They can bring their full selves to work and express aspects of themselves that may be different from their peers.
  • Psychologically safe – They feel free to hold differing views and make mistakes without being penalized and secure enough to address tough issues or take risks.

CI’s efforts to foster diversity and ensure that all employees are supported and encouraged to achieve their career potential are recognized and supported by a Diversity Policy. Additionally, discrimination, harassment and other inappropriate behaviour are addressed by CI’s Code of Conduct.

In October 2020, CI established a Diversity and Inclusion Committee, with a mandate to promote a culture of inclusion through communications, events and outreach. This committee expanded in 2021 to incorporate a leadership council comprised of management staff that work within the revised committee structure.

Other diversity measures at CI in 2021 included:

  • The development of an unconscious bias learning series which required mandatory completion by senior leadership. CI intends to provide this training to all employees in 2022.
  • The launch of a Diversity & Inclusion intranet hub providing access to a variety of relevant information and resources.
  • The expansion of CI’s Women in Financial Services Mentorship Program, in place since 2012, to be gender neutral and provide consideration for inclusive representation. The program prepares participants to advance to leadership roles.
  • Management considers diversity in the hiring and advancement of executives and senior managers. With regards to gender diversity, CI, including its major subsidiaries, has 14 women executive officers representing approximately 29% of the total number of executive officers.

CI is committed to equality and materially complies with applicable regulations related to pay equity. CI has had a pay equity plan in place for Canadian employees since 2004.

Employee Engagement, Talent and Wellness

  • To promote engagement and an ownership mentality among employees, CI introduced an Employee Share Purchase Plan in 2021. Under the plan, full-time employees can purchase CI stock through payroll deductions and receive an additional 15% company contribution.
  • CI provides extensive training and learning opportunities for employees, giving them access to a variety of tools, courses and other resources to support skill development. Leadership training for new managers is provided through a third-party firm.
  • To help employees succeed through CI’s digital transformation, a change management campaign included “learning paths” customized to their departments and teams. In 2021, approximately 600 staff members took part in a learning path to expand their skillsets for digital work.
  • CI also supports those who pursue relevant education and training on their own initiative through tuition reimbursement and other recognition. And despite the pandemic, in 2021 CI offered important learning opportunities and work experience to 56 students through summer and co-op placements.
  • CI promotes the wellness of its employees through enhanced benefits and health and wellness programs. To help employees manage the impacts of the COVID-19 pandemic, CI doubled its benefits coverage for psychological services.
  • CI’s Health and Wellness program provides many resources for employees to navigate difficult times as well as focus on health and wellness year-round. These include webinars on topics such as nutrition, and a health coaching program that provides resources for chronic disease management.

Commitment to Communities

CI is committed to supporting communities across Canada and to being a good corporate citizen.

In addition to donating to charitable and community causes, we provide employees with one paid day off per year, known as a Ray Day, to volunteer with a community organization or charity of their choice. This program was named in memory of the late Ray Chang, who served as CI’s Chairman and Chief Executive Officer and was well known for his philanthropy.

CI’s charitable donations in 2021 included a significant contribution to Second Harvest, Canada’s largest organization involved in rescuing surplus food and redistributing it to feed people in need. CI leadership also donated $27,500 to support the Children’s Aid Foundation of Canada and fund scholarships for youth who were in foster care.

Commitment to Environmental Sustainability

CI acknowledges the importance of addressing issues related to climate change. We are currently working to establish a more systematic approach to addressing and reporting on this issue in our corporate operations and in 2022, engaged a third-party ESG consultant to assist us in these efforts.

environmental sustainability

At the operational level, we have undertaken several initiatives to reduce our direct impact on the environment, including moving to cloud services and reducing paper use. The vast majority of our fund investor statements now being delivered electronically and we have significantly reduced stocks of pre-printed marketing materials. CI also recycled approximately 39 tonnes of paper at its Toronto locations through a secure shredding service alone in 2021.


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