Investment Governance Framework

Last Updated: February 6, 2026.

Framework Overview

Benefaction Foundation (“Benefaction” or the “Foundation”) has developed an investment governance framework, which consists of a system of structures, policies, and procedures that guide Benefaction's investment decisions. The framework provides clarity on roles and responsibilities, ensures investment strategy aligns with goals and risk tolerance, and promotes accountability and transparency. Benefaction’s investment governance framework generally consists of the following documents, as may be amended from time to time:

The Foundation’s governing documents, including its By-Law dated June 7, 2018, which provides that the Board of Directors of Benefaction (the “Board”) appoints Benefaction’s investment committee (the “Investment Committee”), and other similar rules regarding how Board policies are Developed and approved;
The terms of reference of the Investment Committee last updated in January 2026 (the “Investment Committee Terms of Reference”;
The Investment Policy Statement last updated in November 2022 (the “Investment Policy”);
The Financial Controls Policy last updated in January 2026 (the “Investment and Financial Controls Policy”) and
This “Investment Governance Framework” dated December 16, (the “Investment Governance Framework”).

The framework is informed by the federal and provincial laws, rules, and regulations that apply to Benefaction as a registered charity, as well as governance and investment best practices.

For the avoidance of doubt, all of the documents referenced herein should be read together for the complete understanding Benefaction’s obligations and processes pertaining to investments.

Best practices for an effective framework include:

Differentiate governance from management: Good governance focuses on long-term strategy and oversight, not the day-to-day execution of investments. Benefaction’s governance body, the Board, sets the strategic direction, and management or delegated parties carry it out.

Prioritize transparency: Document all decisions and provide clear, consistent communication to all stakeholders (Benefaction Investment Committee, Investment Manager and, when necessary, Donor Advisor) regarding the investment strategy and rationale.

Ensure regular reviews: Periodically review the governance structure and policies to ensure they remain appropriate for Benefaction's circumstances and market conditions.

Maintain a long-term view: Emphasize long-term goals and measuring overall success, which can help prevent emotional or rash decisions during periods of market stress.

Use specialist resources appropriately: Understand the skills and resources available internally and know when to delegate specific tasks, such as due diligence or asset manager selection, to qualified third parties.

People & Structure

Roles & Responsibilities

Board of Directors

The directors on Benefaction’s Board have a fiduciary duty regarding assets held in the Foundation’s donor advised funds (“DAFs”). In order to fulfill their fiduciary duties, the directors must ensure that the framework described herein is complete and accurate, and that it is being implemented as contemplated in the documents.

More specifically, in ensuring that the framework is complete and accurate, the Board should pay particular attention to the following:

All investments of assets must be done in accordance with applicable provincial legislation, e.g. Trustee Act (Ontario) and other similar comparable provincial statutes.
It is necessary that a high level of supervision and regular investment reviews of all portfolios managed by third parties is undertaken by the Board and/or the Investment Committee.
At the discretion of the Board, the investment of assets held in DAFs can be outsourced to one or more investment managers.
Investment managers used by Benefaction must be firms and/or individuals registered and in good standing with either an appropriate provincial securities commission or the Canadian Investment Regulatory Organization (CIRO).

Investment Committee

The Investment Committee is appointed by the Board and is responsible for the development of Benefaction’s Investment Policy. The Investment Policy must be approved by the Board.

The Investment Committee is responsible for ensuring that Benefaction’s investment goals are reflected in the Investment Policy. Generally speaking, the Foundation’s objective is to generate a total investment return that to the greatest extent possible protects the granting power of the capital component and the required disbursement level and recovers the cost of managing and administering the funds. The return objective is to exceed CPI net of management fees and expenses on average annualized. It is understood that this rate of return may not be achieved in every year. The Foundation’s return objectives are ranked as follows:

Preservation of capital
Generation of ‘income’ to meet disbursement requirements
Generation of growth in the capital value of the investments in order to protect their value in real (inflation-adjusted) terms for long term charitable purposes.

Further details on the role and responsibilities of Investment Committee members can be found in the Investment Committee Terms of Reference.

Exceptions to the Investment Policy

As provided for in Benefaction’s Investment Policy, from time to time, the circumstances surrounding a particular gift or DAF may warrant an exception be made to the Investment Policy, with approval from either: (i) the Investment Committee or (ii) the Board following a recommendation from the Investment Committee. Board approval is required for exceptions that exceed $25 million of Foundation assets. All other exceptions may be approved by the Investment Committee.

For example, asset allocations may be approved for a DAF that vary from policy parameters provided that such exceptions are consistent with permitted investments (as set out in the Investment Policy) and are aligned with an overall strategy of capital preservation. Furthermore, investments covered by CRA’s Program Related Investment rules may also be included. These rules enable a charity to make investments which directly further its charitable purposes, not to make a profit. These investments can include loans (often at below-market rates), loan guarantees, share purchases, or leases of property. A key requirement is that the investment's primary purpose must be charitable, even if a financial return is realized.

A plan to revert to the Investment Policy using a predetermined strategy and within an acceptable timeline should be in place prior to accepting the gift and allowing the exception.

In exceptional circumstances, the Board or Investment Committee may agree that the Foundation is able to accept a maximum portfolio allocation to this type of investment within a specific DAF with prior acknowledgement of all interested parties. Some prospectus-exempt investments may carry inherent risks such as liquidity.

Donor Advisors

As provided for in Benefaction’s template form of donor agreement (the “Donor Agreement”) the individual(s) establishing the DAF, or a specifically designated alternative, are identified as “Donor Advisors” for the DAF. These are the only people able to make granting recommendations to Benefaction for its consideration and final approval.

In a case where the DAF is opened by a business or partnership, the business or partnership will appoint one or more persons to undertake the role of Donor Advisor.

Donor Advisors are not permitted to direct how funds donated are invested.

Provincial Trustee Acts obligate charities to act as prudent investors and exercise fiduciary control over investments.
The Income Tax Act (Canada) has a similar condition to demonstrate that a donor is not permitted to control assets gifted to a registered charity.

However, Benefaction permits the Donor Advisor, at the time of establishing the DAF, to recommend an investment advisor or portfolio manager to manage their donated assets on behalf of the Foundation.

Donor Advisors may have a preference as to the nature of investments to be held in their DAF. The Investment Committee, at its sole discretion, may provide a range of investment options with varying degrees of risk and duration all of which comply with governing regulations. Where Donor Advisors wish to impose restrictions on investment related matters, it must be done at the outset, via the donor agreement between the Donor Advisor and Benefaction. Additionally, from time to time, Benefaction may receive investment recommendations for their consideration, including those related to impact investing or private equity for example, from the Donor Advisor.

Investment Managers

Investment Managers are responsible for executing the investment management decisions, buying/selling, raising funds, etc. Per above, Donor Advisors may recommend a person to manage the assets held in their DAF. Each Investment Manager must be a licensed professional. Specifically, a Financial Professional according to FSRA of Ontario which can indicate a Financial Planner or a Financial Advisor. While some Financial Planners can also have a license to trade mutual funds, not all do. The Investment Manager must be a registered representative. Benefaction’s New Accounts team conducts a search on the Canadian Securities Administrators National Registration Search website for all new recommended Investment Managers, to confirm their registration prior to opening an account with them.

Delegation of Authority

Trade Authorization

By resolution of the Board, Nicola Delaney Elkins, Meredith Agnew and Joely Elkins are granted trading authority (each, a “TA”) and are authorized and empowered to transfer, endorse, buy, sell, assign and set over, and deliver any and all shares, stocks, bonds, debentures, notices, evidences of indebtedness, or other securities now or hereafter standing in the name of or owned by Benefaction (collectively, “Authorizing Trades”) and to make, execute and deliver, under the corporate seal of Benefaction or otherwise, and any and all written instruments necessary or proper to effectuate the authority hereby conferred. Each may each act on their own for the purposes of Authorizing Trades.

In keeping with investment industry standards, each TA must be absent from their Authorizing Trades duties for two consecutive weeks to enhance internal control. Such a requirement enhances the viability of a sound internal control environment because it is generally accepted that fraudulent activity requires the continual presence of the wrongdoer.

Attorney Powers

By resolution of the Board, Nicola Delaney Elkins and Meredith Agnew and Joely Elkins are appointed as Attorneys. Decisions, including decisions relating to the opening of new accounts, and the signing of documents, including Investment Policy documents for discretionary managed accounts and insurance documents, must be made or signed by at least two (2) Attorneys.

Oversight Body: Canada Revenue Agency

Operating a Registered Charity

Canada Revenue Agency (CRA) defines requirements for filing a T3010 return, issuing receipts and receiving donations, charitable activities, books and records, annual spending requirements and more on the Charities Directorate website here. CRA also defines DAFs, for the purpose of completing annual T3010 filings, as “a fund segregated into donor accounts, owned and controlled by a registered charity. Each account is comprised of contributions made by individual donors. Donors may provide ongoing non-binding suggestions on payouts from DAFs, but it is the charity's sole responsibility to make such decisions”. As delegated by the Board, it is the responsibility of management to ensure that Benefaction maintains compliance with all of these requirements.

Succession Planning

Investment Committee, Trade Authorities & Attorneys

As described above, Benefaction has identified three (3) TAs and Attorneys for the Foundation. Each may each act on their own for the purposes of Authorizing Trades and certain decisions and/or documents must be made or signed by at least two (2) Attorneys, as described above under “Delegation of Authority”. If one of Nicola Delaney Elkins, Meredith Agnew and Joely Elkins was not available on a temporary basis, the two remaining individuals could continue normal operations for the Foundation. If the person is not available on a permanent basis, the Board would be consulted to identify a replacement TA and Attorney, via an external search to hire a new team member.

If an Investment Committee member is not available on a permanent basis, they would be replaced by a different Board member or Benefaction’s then current CEO or CIO. The replacement will depend on which individual is no longer available.