Companion Policy to NI 81-102 Investment Funds
Part 2 Comments on Definitions Contained in the instrument
Section 2.9

“manager” –

The definition of “manager” under the Instrument only applies to the person or company that actually directs the business of the investment fund, and does not apply to others, such as trustees, that do not actually carry out this function. Also, a “manager” would not include a person or company whose duties are limited to acting as a service provider to the investment fund, such as a portfolio adviser.