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Jantzi Research Inc's Submission in Response to Finance Canada's Regulatory Framework for Federally Regulated Defined Benefit Pension Plans consultation:

September 15, 2005

Diane Lafleur
Financial Sector Policy Branch , Department of Finance
L'Esplanade Laurier, 20th floor East Tower
140 O'Connor Street
Ottawa, ON K1A 0G5 �

Re:

Consultation on defined benefit pension plans and the Pension Benefits Standards Act

Dear Ms. Lafleur:

Jantzi Research Inc. is an independent investment research firm that evaluates and monitors the environmental, social, and governance performance of Canadian equities. Our clients are institutional and retail investors that consider corporate social and environmental performance when managing their investments.We welcome the opportunity to comment on regulatory and legislative issues regarding defined benefit pension plans covered by the federal Pension Benefits Standards Act.

While the consultation paper addresses a number of issues important to pension plan members, it fails to address the key issue of disclosure by pension funds governed by the PBSA of the ways in which social, environmental, and ethical considerations play a role, if any, in the management of pension funds. Similarly, it fails to discuss the issue of disclosure by pension funds of their proxy voting policies and voting records.

There is a growing body of evidence that suggests that the evaluation of social and environment performance is critical to understanding the risks and opportunities faced by companies. Such evidence therefore also suggests that the consideration of social and environmental performance when making investment decisions is likely to have an impact on share value, especially in the long term. Indeed, a growing number of institutional investors, including a number of major pension funds in the United States and Europe, have come to view the examination of social and environmental performance as an essential part of the exercise of their fiduciary duty. There is also a growing recognition that pension funds have a fiduciary duty to vote their shares on behalf of their plan members.

In light of these important trends, pension plan members have a right to know if and how their plans consider social and environmental performance in the management of their pension money. Similarly, plan members have a right to know the proxy voting policies and voting records of their plans. Currently there is a lack of transparency in both of these areas, and the review of the PBSA provides an opportunity to address this problem.

Jantzi Research supports the brief submitted to you by the Social Investment Organization on August 25, 2005. That brief calls for regulatory change that would require pension funds governed by the PBSA to disclose their social and environmental policies and to make public their voting policies and voting records. Such change would increase the level of accountability and transparency among the funds covered by the PBSA - and probably among Canadian pension funds in general - and it would help to ensure that pension funds give due consideration to non-financial factors that affect risk and shareholder value in the long term.

We thank you for your attention to these matters.

Sincerely,

Michael Jantzi

President

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Rob Gross

Managing Partner

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Kevin Ranney

Managing Partner