Legal and Proxy

PROXY

Proxy Voting Policies, Procedures and Guidelines

EHP Funds Inc. (“EHP Funds”) will vote proxies, subject to the following conditions:

(a) EHP Funds will vote proxies in the best interests of the applicable fund.

(b) EHP Funds has engaged a third party to help advise on proxy voting matters and record keeping.

(c) Where a conflict of interest arises between EHP Funds’ interests and those of a fund, the fund's interest will prevail. EHP Funds will document any instance where a conflict of interest could be construed.

(d) EHP Funds will attempt to vote all proxies. However, there may be circumstances where voting may be impractical. These situations include, but are not limited to: insufficient information available, proxy documents not being delivered by the custodian in a timely fashion, lack of English proxy materials, cost of voting outweighs potential benefit to a fund, and lack of materiality.

(e) Accordingly, EHP Funds generally votes proxies in a uniform manner for its funds and in accordance with these Policies and Procedures and the Guidelines.

(f) The Guidelines are available upon request by contacting us by email at info@ehpfunds.com or by telephone at: 1.833.360.3100