Building Trust by
Doing What Is Right

Governance

We strive to conduct our business with integrity and demonstrate accountability for our actions. Good corporate governance, ethical business conduct and compliance management are important parts of our responsible business management philosophy. We are focused on enabling a values-based culture across our company, so that people understand the importance of complying with all applicable legal and ethical standards and embedding our sustainability principles in everything we do.

Ethics and Integrity

Our values and Code of Conduct guide how we work together and do what is right. Employees receive training on ethics, privacy, anti-corruption, money laundering and safety, and confirm compliance annually. We also expect suppliers to uphold ethical, environmentally sound and socially responsible practices through clear responsible business standards on our behalf.

Corporate Governance

Our company President, supported by the executive team, has overall responsibility for managing and growing our business. This includes ensuring that strategies and goals are aligned with our changing business context and includes both financial and non-financial objectives. Various senior management committees assist the executive team:

Corporate Environmental Committee

Cross-functional team responsible for reviewing and evaluating the Environmental & Sustainability Policy and associated programs, including ensuring environmental and health and safety compliance, responsible practices that meet the standards of due diligence and prevent or mitigate losses, effective training and implementation, appropriate response to environmental issues and applicability to GWL Realty Advisors’ business model and new business initiatives.

Human Resources Committee

Investment Committee

Transformation Committee

Managing Compliance

Our robust compliance framework helps us meet legal and regulatory responsibilities. Overseen by our risk and compliance team, it combines Canada Life’s risk assessment process with real estate-specific policies and practices. Our obligations include OSFI requirements, commercial and residential tenancies, real estate brokerage licensing, privacy, anti-money laundering, health and safety, and environmental matters. Third-party audits, provincial licensing monitoring and independent verification help strengthen accountability and confirm our expectations are upheld consistently.

Real Estate Brokerage Licensing

Privacy

Bribery, Corruption and Money Laundering

Conflict of Interest

Environmental Sustainability

Health and Safety

Enterprise Risk
Management

Risk management is central to our strategy and embedded in daily decisions. Our Compliance Committee oversees a precautionary approach to identifying and managing key risks. We consult regulators, clients, tenants and other stakeholders, supported by due diligence covering financial, physical, governance, regulatory, market, environmental and social factors. Quarterly reporting to our executives and Canada Life ensures material impacts, risks and opportunities remain clearly understood, monitored and managed across our business.

Responsible Investing

As a trusted real estate investment advisor, our primary objective is to deliver strong, long-term returns for our clients. This means investing in quality assets and protecting and enhancing the value of our clients’ assets by considering both financial and non-financial value drivers, including environmental, social and governance (ESG) factors.

Our Investment Policy guides our approach to acquiring and disposing of our clients’ real estate assets, and requires rigorous ESG due diligence assessments that are reviewed by our Investment Committee and portfolio teams before a transaction is executed.

Downloads

Reducing Our Environmental Footprint 2025